diff --git a/vision-fixhub/ds10-01/de71ec1d3758680f5ac544a6ebcf3d2939beaec12d0bd375f78f0c2f2e73caf8.md b/vision-fixhub/ds10-01/de71ec1d3758680f5ac544a6ebcf3d2939beaec12d0bd375f78f0c2f2e73caf8.md new file mode 100644 index 0000000000000000000000000000000000000000..43d3d4fb9d8f189bea602e55723eb8f7cb937b00 --- /dev/null +++ b/vision-fixhub/ds10-01/de71ec1d3758680f5ac544a6ebcf3d2939beaec12d0bd375f78f0c2f2e73caf8.md @@ -0,0 +1,9 @@ +From: AAG Legal Request For Information +Sent: Thursday. February 13, 2020 9:04 PM +(NY) (FBI) +Subject: Fed GJ SBP 2020-01-23- Maxwell- +Please be advise that Alaska Airlines has no responsive records for the above mentioned subpoena, +for the specific time frame requested. +Be Legard Team +SDNY_GM_00000965 + diff --git a/vision-fixhub/ds10-01/de71ec1d3758680f5ac544a6ebcf3d2939beaec12d0bd375f78f0c2f2e73caf8.receipt.json b/vision-fixhub/ds10-01/de71ec1d3758680f5ac544a6ebcf3d2939beaec12d0bd375f78f0c2f2e73caf8.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..e7fd80f2c0dc1ec12053db790fc7d4c1d2d3f088 --- /dev/null +++ b/vision-fixhub/ds10-01/de71ec1d3758680f5ac544a6ebcf3d2939beaec12d0bd375f78f0c2f2e73caf8.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -25, + "dataset": "marble-joined", + "doc_id": "de71ec1d3758680f5ac544a6ebcf3d2939beaec12d0bd375f78f0c2f2e73caf8", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "fe9ba1e7361ab376a85a2cb5cfc3519c7aa86c07979e3970563543e7ae288dc5", + "output_sha256": "100fd4461012ad2d9b53e5333ffa6b6f8f989a116d6f1a746dbb26eb19b6e610", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds10-01/e763a88b6230da521c30136f308efb75ccf2a8ba7d9586bd0b77d6825aa6370e.md b/vision-fixhub/ds10-01/e763a88b6230da521c30136f308efb75ccf2a8ba7d9586bd0b77d6825aa6370e.md new file mode 100644 index 0000000000000000000000000000000000000000..6439bcf80d08ce3a693fdef8230112f262386b98 --- /dev/null +++ b/vision-fixhub/ds10-01/e763a88b6230da521c30136f308efb75ccf2a8ba7d9586bd0b77d6825aa6370e.md @@ -0,0 +1,66 @@ +RESPONSE COVER SHEET +11760 US HIGHWAY 1 +SUITE 600 +NORTH PALM BEACH, FL 33408-3029 +Phone +Facsimile| +To: +File Code: 2712626 +NEW YORK NY 10278-0004 +Phone Number: +Fax Number: T +Case Number: +Case Name: +Request Dated: 4/5/2015 +Received On: 4/9/201: +From: NMD +Number of Pages +Date: 4/25/2019 +Number(s) listed in the Legal Demand may not have been assigned to AT&T or an AT&T subscriber(s) during the +entire time frame listed. However, although the number(s) may have been assigned to another carrier during some +or all of the time requested, the number(s) may have roamed on the AT&T network or received/made calls from/to +an AT&T subscriber during the referenced date range, and, if available, AT&T has produced that responsive +information. These numbers will not be accompanied by a subscriber report. +CONFIDENTIALITY NOTICE +This cover sheet, and any document which may accompany it, contains information from the Global Legal Demand Center which is intended for use only by the +individual to whom it is addressed, and which may contain information that is privileged, confidential and or otherwise exempt from disclosure under applicable law. If +thesede of dis meson, cop in the inter use of cim of the person reape is triot friting if mostage o ched i do i. i lie sure, +us immediately by telephone to arrange for the return of this communication to us at our expense. Thank you. +EPTA_00115091 + + +2712626 NMD +11760 US HIGHWAY +SUITE 600 +NORTH PALM BEACH, FL 33408-3029 +(Fax) +CERTIFICATE OF AUTHENTICITY OF DOMESTIC RECORDS PURSUANT TO +FEDERAL RULES OF EVIDENCE 902(11) AND 902(13) +1, Nicholas DeRoy, attest, under penalties of perjury by the laws of the United States of America +pursuant to 28 U.S.C. § 1746, that the information contained in this certification is true and +correct. I am employed by AT&T, and my title is Legal Compliance Analyst. I am qualified to +authenticate the records attached hereto because I am familiar with how the records were created, +managed, stored, and retrieved. I state that the records attached hereto are true duplicates of the +original records in the custody of AT&T. I further state that: +a. All records attached to this certificate were made at or near the time of the occurrence of +the matter set forth by, or from information transmitted by, a person with knowledge of +those matters, they were kept in the ordinary course of the regularly conducted business +activity of AT&T, and they were made by AT&T as a regular practice; and +b. Such records were generated by AT&T's electronic process or system that produces an +accurate result, to wit: +1. +The records were copied from electronic device(s), storage mediums), or file(s) +in the custody of AT&T in a manner to ensure that they are true duplicates of the +original records; and +2. +The process or system is regularly verified by AT&T, and at all times pertinent to +the records certified here the process and system functioned properly and +normally. +I further state that this certification is intended to satisfy Rules 902(11) and 902(13) of the +Federal Rules of Evidence. +April 25, 2019 +Date +Nicholas DeRor +Signature +SDNY_GM_00001016 + diff --git a/vision-fixhub/ds10-01/e763a88b6230da521c30136f308efb75ccf2a8ba7d9586bd0b77d6825aa6370e.receipt.json b/vision-fixhub/ds10-01/e763a88b6230da521c30136f308efb75ccf2a8ba7d9586bd0b77d6825aa6370e.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..069617a2770728190d44d7eb37f2212f6ed4df0d --- /dev/null +++ b/vision-fixhub/ds10-01/e763a88b6230da521c30136f308efb75ccf2a8ba7d9586bd0b77d6825aa6370e.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -37, + "dataset": "marble-joined", + "doc_id": "e763a88b6230da521c30136f308efb75ccf2a8ba7d9586bd0b77d6825aa6370e", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "4c8496d52944470141263b114cad797d35e239878cb9c3270ef0594d0c24244a", + "output_sha256": "3117ed9d5c5a31be1b4f595682c850a270d01dbe7cdb30a0bb72ad0956498ed3", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds10-01/eca7fd34718c8ab52de21d2250a6f6493a2a52f244a685b52365d245961f346a.md b/vision-fixhub/ds10-01/eca7fd34718c8ab52de21d2250a6f6493a2a52f244a685b52365d245961f346a.md new file mode 100644 index 0000000000000000000000000000000000000000..eb117dca32b590f3a54e5d14ce87cf96f66b8420 --- /dev/null +++ b/vision-fixhub/ds10-01/eca7fd34718c8ab52de21d2250a6f6493a2a52f244a685b52365d245961f346a.md @@ -0,0 +1,25 @@ +BUSINESS RECORD CERTIFICATION OF APPLE INC. CUSTODIAN OF +RECORDS +1, Lesley Ahlberg, hereby declare: +1. +I am employed by Apple Inc. and that my official title is Legal Specialist. I am a +duly authorized Custodian of Records, or other qualified witness for Apple Inc. ("Apple") +located in Cupertino, California. As such I have the authority to certify these records, +APL000001_APPLE_CONFIDENTIAL produced January 8, 2019 in response to a subpoena +served on December 31, 2018. I am authorized to submit this declaration on behalf of Apple. +Each of the records produced is the original or a duplicate of the original record in +the custody of Apple Inc. +These records were made at or near the time of the occurrence of the matters set +forth in the records; +4. +These records were kept in the course of the regularly conducted activity; and, +These records were made by the regularly conducted activity as a regular practice. +I declare under penalty of perjury under the laws of California that the foregoing is true and +correct. +DATED: January 8, 2019 + APPLE INC. +By: Laly thesis +Name: Lesley Ahlberg +Title: Legal Specialist, Apple Inc. +SDNY_GM_00001013 + diff --git a/vision-fixhub/ds10-01/eca7fd34718c8ab52de21d2250a6f6493a2a52f244a685b52365d245961f346a.receipt.json b/vision-fixhub/ds10-01/eca7fd34718c8ab52de21d2250a6f6493a2a52f244a685b52365d245961f346a.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..e07312aadd649ed033852aef5b3ce8d0c5d83405 --- /dev/null +++ b/vision-fixhub/ds10-01/eca7fd34718c8ab52de21d2250a6f6493a2a52f244a685b52365d245961f346a.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -25, + "dataset": "marble-joined", + "doc_id": "eca7fd34718c8ab52de21d2250a6f6493a2a52f244a685b52365d245961f346a", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "4c02ce4d0daa47cf41aebaac545a1eb4b153ff791ecf74b228e75fc29bc5fd21", + "output_sha256": "ef5f06d034fb897fa7fd57b764153c8b571a032b2566f6c21dd0d1a9f3b80cf6", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds10-01/ef4514cb04293f3036b3ef75d1c7749d40c8abd0d5bd751acbd85a9831b42a90.md b/vision-fixhub/ds10-01/ef4514cb04293f3036b3ef75d1c7749d40c8abd0d5bd751acbd85a9831b42a90.md new file mode 100644 index 0000000000000000000000000000000000000000..853cac50c2e43da7c902851af128c3d61f64af24 --- /dev/null +++ b/vision-fixhub/ds10-01/ef4514cb04293f3036b3ef75d1c7749d40c8abd0d5bd751acbd85a9831b42a90.md @@ -0,0 +1,705 @@ +ORIGINAL +AO 106 (SDNY Rev. 01/17) Application for a Search Warrant +for the +Southern District of New York +In the Matter of the Search of +briefly describe the property to be searche +r identify the person by name and address +See Attached Affidavit and its Attachment A +1OMAG 6573 +APPLICATION FOR A SEARCH AND SEIZURE WARRANT +, a federal law enforcement officer or an attorney for the government, request a search warrant and state unde +enalty of perjury that I have reason to believe that on the following person or property (identify the person or describe th +property to be searched and give its location): +located in the +Southern +person or describe the property to be seized): +See Attached Affidavit and its Attachment A +District of +New York +, there is now concealed (identify the +The basis for the search under Fed. R. Crim. P. 41(c) is (check one or more): +V evidence of a crime; +• contraband, fruits of crime, or other items illegally possessed; +• property designed for use, intended for use, or used in committing a crime; +• a person to be arrested or a person who is unlawfully restrained. +The search is related to a violation of: +Code Section(s) +18 U.S.C. §S 1591 and +371 +Offense Description(s) +Sex trafficking of minors; sex trafficking conspiracy +The application is based on these facts: +See Attached Affidavit and its Attachment A +• Continued on the attached sheet. +• Delayed notice of _ +_ days (give exact ending date if more than 30 days: +under 18 U.S.C. § 3103a, the basis of which is set forth on the attached sheet. +) is requested +Sworn to before me and signed in my presence. +Date: +7•6-19 +City and state: New York, NY +FBI +Robertens +age's signatume +Hon. Barbara Moses, U.S. Magistrate Judge +Printed name and title + +SDNY_GM_00000045 +EPTA_00114129 + + +In the Matter of the Application of the United +states Of America for a Search and Seizur +Varrant for the Premises Known and Describer +as 9 East 71st Street, New York, New York and +Any Closed Containers/Items Contained Therein +19MAG 6573 +TO BE FILED UNDER SEAL +Agent Affidavit in Support of +Application for Search and Seizure +Warrant +SOUTHERN DISTRICT OF NEW YORK) ss.: +being duly sworn, deposes and says: +I. Introduction +A. Affiant +I have been a Special Agent with the Federal Bureau of Investigation (*FBI") since +2017. During that time, I have participated in numerous investigations and prosecutions of crimes +against children, including the sex trafficking of minors. I have also participated in the execution +of multiple search warrants. +2. +I make this Affidavit in support of an application pursuant to Rule 41 of the Federal +Rules of Criminal Procedure for a warrant to search the premises specified below (the "Subject +Premises") for the purpose of photographing, video-recording or otherwise documenting the +appearance of its interior, and to seize the items and information described in Attachment A. This +affidavit is based upon my personal knowledge; my review of documents and other evidence; and +my conversations with other law enforcement personnel. Because this affidavit is being submitted +for the limited purpose of establishing probable cause, it does not include all the facts that I have +learned during the course of my investigation. Where the contents of documents and the actions, +statements, and conversations of others are reported herein, they are reported in substance and in +part, except where otherwise indicated. +1 + +SDNY_GM_00000046 + + + +B. The Subject Premises +The Subject Premises are particularly described as a nearly 19,000 square foot +multi-story, single-family residence located at 9 East 71st Street, New York, New York, and +include all locked and closed containers found therein. As detailed further herein, the Subject +Premises is believed to be owned, possessed and controlled by JEFFREY EPSTEIN, a target +subject of this investigation. A photograph of the front entrance to the Subject Premises is included +below: +Google +C. The Target Subject and the Subject Offenses +4. +The Target Subject of this investigation is JEFFREY EPSTEIN. +For the reasons detailed below, I believe that there is probable cause to believe that +the Subject Premises contain evidence, fruits, and instrumentalities of violations of Title 18, United +States Code, Section 1591 (sex trafficking of minors) and Title 18, United States Code, Section +371 (sex trafficking conspiracy) (the "Subject Offenses") by the Target Subject. +2 + +SDNY_GM_00000047 + + + +I. Probable Cause +A. Probable Cause Regarding the Target Subject's Commission of the +Subjeet Offenses +6. +On or about July 2, 2019, a grand jury in this District returned an Indictment +charging JEFFREY EPSTEIN with the Subject Offenses. A copy of the Indictment is attached +hereto as Exhibit A and is incorporated by reference. +B. Probable Cause Justifying Search of the Subject Premises +7. +As set forth in Exhibit A, from at least in or about 2002, up to and including at least +in or about 2005, JEFFREY EPSTEIN sexually abused multiple minor girls in the Southern +District of New York and elsewhere. During that time and continuing to the present, EPSTEIN +possessed and controlled the Subject Premises, which is described in Exhibit A as "the New York +Residence." +8. +As further set forth in paragraphs 8 through 10 of Exhibit A, from at least in or +about 2002, up to and including at least in or about 2005, EPSTEIN sexually abused numerous +minor victims at the Subject Premises. In particular, and as alleged in the Indictment, when a +victim arrived at the Subject Premises, she would be escorted to a room inside the Subject Premises +with a massage table, where she would perform a massage on EPSTEIN. The victims, who were +as young as 14 years of age, were told by EPSTEIN or other individuals to partially or fully undress +before beginning the "massage." During the encounter, EPSTEIN would escalate the nature and +scope of physical contact with his victim to include, among other things, sex acts such as groping +and direct and indirect contact with the victims' genitals. EPSTEIN typically would also +masturbate during these sexualized encounters, ask victims to touch him while he masturbated, +and touch victims' genitals with his hands or with sex toys. Following each encounter, EPSTEIN +or one of his employees or associates paid the victim in cash. +3 + +SDNY_GM_00000048 + + + +9. +As set forth in paragraphs 12 through 13 of Exhibit A, to further facilitate his ability +to abuse minor girls in New York, JEFFREY EPSTEIN, the defendant, asked and enticed certain +of his victims to recruit additional minor girls to perform "massages" and similarly engage in sex +acts with EPSTEIN. When a victim would recruit another minor girl for EPSTEIN, he paid both +the victim-recruiter and the new victim hundreds of dollars in cash. EPSTEIN knew that his +vietims were underage, including because certain victims told him their age. +10. +One of the victims identified in paragraph 22 of Exhibit A is Victim-1. As part of +the FBI's investigation of EPSTEIN, other law enforcement officers and I have interviewed +Victim-1.' I know from my personal participation of interviews with Victim-1, my conversations +with other law enforcement officers who have interviewed Victim-1, and my review of notes and +reports of other interviews with Victim-1 that Victim-1 has provided the following information, in +substance and in part: +a. Between approximately 2002 and 2005, EPSTEIN sexually abused Victim-1 on +multiple occasions in the Subject Premises. This sexual abuse all occurred when Victim-1 was +under the age of 18. +b. During that same period, Victim-1 observed multiple floors of the Subject Premises +and numerous individual rooms within the Subject Premises. Victim-1 has provided detailed +descriptions of certain aspects of the interior of the Subject Premises, including Victim-1's +' In meetings with the Government, Victim-1 has disclosed that, approximately a decade ago, she +committed marriage fraud in order to obtain a green card and, subsequently, U.S. citizenship. She +has also disclosed personal substance abuse, primarily involving the abuse of prescription drugs, +during various periods between the early 2000s and 2019. Victim-1 has also disclosed having +worked for approximately a year at a "happy-ending" massage parlor, performing paid sex acts. +Victim-1 is currently pursuing a civil damages claim against EPSTEIN for his sexual abuse of her. +Information provided by Victim-1 has proven reliable and has been corroborated by independent +evidence, including documents and records obtained during the investigation and the accounts of +other victims whom Victim-1 has never met. +4 + +SDNY_GM_00000049 + + + +memory of specific details regarding the layout, furnishings, decorations, and floor pattern of +various areas within the Subject Premises. +11. +I know from my review of publicly available corporate and property records that at +all times relevant to the Subject Offenses as alleged in the Indictment, the Subject Premises was +owned by Nine East 71st Street Corporation (the "Corporation"). The President of the Corporation +is listed as JEFFREY EPSTEIN, and no other officers or occupants are identified on the +Corporation paperwork. In or around December 2011, the Subject Premises was transferred from +the Corporation to another corporate entity, Maple, Inc., which is registered in the U.S. Virgin +Islands, where EPSTEIN was then known to and continues to reside. Though no officer of Maple, +Inc., is identified in the transfer paperwork, the signature of both the buyer and seller in the +transaction appear to be the same. Moreover, the deed lists the consideration for the transfer of +the Subject Premises as $10, an amount facially inconsistent with a fair market transfer to a third +party. +12. +I know from my participation in this investigation that EPSTEIN has continued to +possess and control the Subject Premises from at least in or about 2002 to the present. In particular, +I know from my review of Sex Offender Registration records that EPSTEIN presently lists the +Subject Premises as one of his residences. +Moreover, as described in paragraph 11, above, +although ownership of Subject Premises was transferred from one corporate entity to another in +December 2011, both corporations appear to be under EPSTEIN's control, and EPSTEIN appears +to remain the sole owner and occupant of the Subject Premises. +13. +Additionally, although Victim-1 has not been in the Subject Premises since in or +around 2005, based on my review of publicly available records maintained by the New York City +Department of Buildings ("DOB"), it does not appear that there have been any significant or +5 + +SDNY_GM_00000050 + + + +structural renovations to the interior of the Subject Premises since that time. In particular, the +DOB reflects only three approved alteration permits for the Subject Premises, one in or around +2011 which authorized façade restoration but expressly noted that there would be "no change to +occupancy, use egress or bulk," and two permitting the "installation of heavy duty sidewalk shed" +outside of the Subject Premises at various points, but similarly noting that there would be "no +changes in use, egress or occupancy." As such, while it is possible that certain interior decorations +have changed since 2005, it is probable that structural components of the interior, such as +•Victim-I's description of the layout of rooms and floors, among other details, would remain the +same. +6 + +SDNY_GM_00000051 + + + +II. Conclusion and Ancillary Provisions +14. +Based on the foregoing, I respectfully submit that there is probable cause to believe +that photographing, video-recording, and otherwise documenting the appearance of the interior of +the Subject Premises, and seizing the items described in Attachment A, will yield evidence of the +Subject Offenses. +In particular, evidence depicting the interior of the Subject Premises and +reflecting the occupancy, ownership, layout, furnishings, decorations, and floor pattern of the +Subject Premises will corroborate Victim-1's account of EPSTEIN's commission of the Subject +Offenses. I further submit that there is probable cause to believe that such evidence will be located +within the Subject Premises and therefore request the court to issue a warrant to seize the items +and information specified in Attachment A to this affidavit and to the Search and Seizure Warrant. +Special Agent +Federal Bureau of Investigation +Sworn to before me on +July 6, 2019 +Bobarths +THE HONORABLE BARBARA MOSES +UNITED STATES MAGISTRATE JUDGE +7 + +SDNY_GM_00000052 + + + +ATTACHMENT A +I. Premises to be Searched—Subject Premises +1. +The premises to be searched (the "Subject Premises") are described as a nearly +19,000 square foot multi-story single-family residence located at 9 East 71st Street, New York, +New York, and include all locked and closed containers found therein. A photograph of the front +entrance to the Subject Premises is included below: +Google +II. Items to Be Seized +1. This warrant authorizes executing agents to photograph, video record and otherwise +document the full interior of the Subject Premises, including any items, furnishings, or possessions +therein. +2. In addition, this warrant authorizes the seizure of certain evidence, fruits, and +instrumentalities of violations of Title 18, United States Code, Sections 1591 (sex trafficking of +minors) and 371 (sex trafficking conspiracy) (the "Subject Offenses") described as follows: +a. Evidence concerning occupancy or ownership of the Subject Premises, +including utility and telephone bills, mail envelopes, addressed correspondence, +diaries, statements, identification documents, address books, telephone +directories, and photographs of its occupant(s). +b. Evidence concerning the layout, furnishings, decorations, and floor pattern of +the Subject Premises, including photographs and blueprints of the Subject +Premises. + +SDNY_GM_00000053 + + + + +8 + +SDNY_GM_00000054 + + + +- - +UNITED STATES OF AMERICA +- V. +JEFFREY EPSTEIN, +Defendant. +SEALED +INDICTMENT +19 Cr. +19 CRIM +490 +X +COUNT ONE +(Sex Trafficking Conspiracy) +The Grand Jury charges: +1. +OVERVIEW +As set forth herein, over the course of many +years, JEFFREY EPSTEIN, the defendant, sexually exploited and• +abused dozens of minor girls at his homes in Manhattan, New +York, and Palm Beach, Florida, among other locations. +2. +In particular, from at least in or about 2002, up +to and including at least in or about 2005, JEFFREY EPSTEIN, the +defendant, enticed and recruited, and caused to be enticed and +recruited, minor girls to visit his mansion in Manhattan, New +York (the "New York Residence") and his estate in Palm Beach, +Florida (the "Palm Beach Residence") to engage in sex acts with +him, after which he would give the victims hundreds of dollars +in cash. Moreover, and in order to maintain and increase his +supply of victims, EPSTEIN also paid certain of his victims to +recruit additional girls to be similarly abused by EPSTEIN. In +SDNY_GM_00000055 + + + + +this way, EPSTEIN created a vast network of underage victims for +him to sexually exploit in locations including New York and +Palm Beach. +3. +The victims described herein were as young as 14 +years old at the time they were abused by JEFFREY EPSTEIN, the +defendant, and were, for various reasons, often particularly +vulnerable to exploitation. EPSTEIN intentionally sought out +minors and knew that many of his victims were in fact under the +'age of 18, including because, in some instances, minor victims +expressly told him their age. +4. In creating and maintaining this network of minor +victims in multiple states to sexually abuse and exploit, +JEFFREY EPSTEIN, the defendant, worked and conspired with +others, including employees and associates who facilitated his +conduct by, among other things, contacting victims and +scheduling their sexual encounters with EPSTEIN at the New York +Residence and at the Palm Beach Residence. +FACTUAL BACKGROUND +5. +During all time periods charged in this +Indictment, JEFFREY EPSTEIN, the defendant, was a financier with +multiple residences in the continental United States, including +the New York Residence and the Palm Beach Residence. +6. +Beginning in at least 2002, JEFFREY EPSTEIN, the +defendant, enticed and recruited, and +caused to be enticed and + +SDNY_GM_00000056 + + + +recruited, dozens of minor girls to engage in sex acts with him, +after which EPSTEIN paid the victims hundreds of dollars in +cash, at the New York Residence and the Palm Beach Residence. +In both New York and Florida, JEFFREY EPSTEIN, +the defendant, perpetuated this abuse in similar ways. Victims +were initially recruited to provide "massages" to EPSTEIN, which +would be performed nude or partially nude, would become +increasingly sexual in nature, and would typically include one +or more sex acts. EPSTEIN paid his victims hundreds of dollars +in cash for each encounter. Moreover, +EPSTEIN actively +encouraged certain of his victims to recruit additional girls to +be similarly sexually abused. +EPSTEIN incentivized his victims +to become recruiters by paying these victim-recruiters hundreds +of dollars for each girl that they brought to EPSTEIN. In so +doing, EPSTEIN maintained a steady supply of new victims to +exploit. +8. +The New York Residence +At all times relevant to this Indictment, JEFFREY +EPSTEIN, the defendant, possessed and controlled a multi-story +private residence on the Upper East Side of Manhattan, New York, +i.e., the New York Residence. +Between at least in or about 2002 +and in or about 2005, EPSTEIN abused numerous minor victims at +the New York Residence by causing these victims to be recruited +to engage in paid sex +acts with him. + +SDNY_GM_00000057 + + + +9. +When a victim arrived at the New York Residence, +she typically would be escorted to a room with a massage table, +where she would perform +a massage on JEFFREY EPSTEIN, the +defendant. The victims, who were as young as 14 years of age, +were told by EPSTEIN or other individuals to partially or fully +undress before beginning the "massage." During the encounter, +EPSTEIN would escalate the nature and scope of physical contact +with his victim to include, among other things, sex acts such as +groping and direct and indirect contact with the victim's +genitals. +EPSTEIN typically would also masturbate during these +sexualized encounters, ask victims to touch him while he +masturbated, +and touch victims' genitals with his hands or with +sex toys. +10. In connection with each sexual encounter, JEFFREY +EPSTEIN, the defendant, or one of his employees or associates, +paid the victim in cash. +Victims typically were paid hundreds +of dollars in +, cash for each encounter. +11. JEFFREY EPSTEIN, the defendant, knew that many of +his New +York victims were +underage, including because certain +victims told him their age. Further, once these minor victims +were recruited, many were abused by EPSTEIN on multiple +subsequent occasions' at the New York Residence. EPSTEIN +sometimes personally contacted victims to schedule appointments +at the New York Residence. In other instances, EPSTEIN directed + +SDNY_GM_00000058 + + + +employees and associates, including a New York-based employee. +("Employee-1"), to communicate with victims via phone to arrange +for these victims to return to the New York Residence for +additional sexual encounters with EPSTEIN. +12. Additionally, and to further +facilitate his +ability to abuse minor girls in New York, JEFFREY EPSTEIN, the +defendant, asked and enticed certain of his victims to recruit +additional girls to perform "massages" and similarly engage in +sex acts with EPSTEIN. When a victim would recruit another girl +for EPSTEIN, he paid both the victim-recruiter and the new +victim hundreds of dollars in cash. Through these victimrecruiters, EPSTEIN gained access to and was able to abuse +dozens of additional minor' +girls. +13. In particular, certain recruiters brought dozens +of additional minor girls to the New York Residence to give +massages to and engage in sex acts with JEFFREY EPSTEIN, the +defendant. EPSTEIN encouraged victims to recruit additional +girls by offering to pay these victim-recruiters for every +additional girl they brought to EPSTEIN. +When a victimrecruiter accompanied a new minor victim to the New York +Residence, both the victim-recruiter and the new minor victim +were paid hundreds of dollars by EPSTEIN for each encounter: In +addition, certain victim-recruiters routinely scheduled these + +SDNY_GM_00000059 + + + +encounters through Employee-1, who sometimes asked. the +recruiters to bring a specific minor girl for EPSTEIN. +The Palm Beach Residence +14. In addition to recruiting and abusing minor girls +in New York, JEFFREY EPSTEIN, the defendant, created a similar +network of minor girls to victimize in Palm Beach, Florida, +where EPSTEIN owned, possessed and controlled another large +residence, i.e., the Palm Beach Residence. EPSTEIN frequently +traveled from New York to Palm Beach by private jet, before +which an employee or associate would ensure that minor victims +were available for encounters upon his arrival in Florida. +15. At the Palm Beach Residence, JEFFREY EPSTEIN, the +defendant, engaged in a similar course of abusive conduct. +When a +victim initially arrived at the Palm Beach Residence, she +would be escorted to a room, sometimes by an employee of +EPSTEIN' s, including, at times, two assistants ("Employee-2" and " +"Employee-3") who, as described herein, were also résponsible +for scheduling sexual encounters with minor victims. Once +inside, the victim would provide à nude or semi-nude massage for +EPSTEIN, who would himself typically be naked. During these +encounters, EPSTEIN would escalate the nature and scope of the +physical contact to include sex acts such as groping and direct +and indirect contact with the victim's genitals. EPSTEIN would +also typically masturbate during +these encounters, ask victims + +SDNY_GM_00000060 + + + +to touch him while he masturbated, and touch victims' genitals +with his hands or with sex toys. +16. In connection with each sexual encounter, JEFFREY +EPSTEIN, the defendant, or one of his employees or associates, +paid the victim in cash. Victims typically were paid hundreds +of dollars for each encounter. +17. JEFFREY EPSTEIN, the defendant, knew that certain +of his victims were underage, including because certain victims +told him their age. In addition, as with New York-based +victims, many Florida victims, once recruited, were abused by +JEFFREY EPSTEIN, the defendant, on multiple additional +occasions. +18. JEFFREY EPSTEIN, the defendant, who during the +relevant time period was frequently in New York, would arrange +for Employee-2 or other employees to contact victims by phone in +advance of EPSTEIN's travel to Florida to ensure appointments +were scheduled for when he arrived. In particular, in certain +instances, Employee-2 placed phone calls to minor victims in +Florida to schedule encounters at the Palm Beach Residence. At +the time of certain of those phone calls. +EPSTEIN and Employee-2 +were in New York, New York. Additionally, certain of the +individuals victimized at the Palm Beach Residence were +contacted by phone by Employee-3 to schedule these encounters. + +SDNY_GM_00000061 + + + +19. Moreover, as in New York, to ensure a steady +stream of minor victims, JEFFREY EPSTEIN, the defendant, asked +and enticed certain victims in Florida to recruit other girls to +engage in sex acts. +EPSTEIN paid hundreds of dollars to victimrecruiters for each additional girl they brought to the Palm +Beach Residence. +STATUTORY ALLEGATIONS +20. From at least in or about 2002, up to and +including in or about 2005, in the Southern District of New York +and elsewhere, JEFFREY EPSTEIN, the defendant, and others known +and unknown, willfully and knowingly did combine, conspire, +confederate, +and agree together and with each other to comnit an +offense against the United States, to wit, sex trafficking of +minors, in violation of Title 18, United States Code, Section, +1591 (a) and (b). +21. It was a part and object of the conspiracy that +JEFFREY EPSTEIN, the defendant, and others known and unknown, +would and did, in and affecting interstate and foreign commerce, +recruit, entice, harbor, transport, provide, and obtain, by any +means a person, and to benefit, +financially and by receiving +anything of value, from participation in a venture which has +engaged in any such act, knowing that the person had not +attained the age of 18 years and would be caused to engage in a + +SDNY_GM_00000062 + + + +commercial sex act, in violation of Title 18, United States +Code, Sections 1591(a) +and (b) (2). +Overt Acts +22. In furtherance of the conspiracy and to effect +the illegal object thereof, the following overt acts, +among +others, were committed in the Southern District of New York and +elsewhere: +a. In or about 2004, JEFFREY EPSTEIN, the +defendant, enticed and recruited multiple minor victims, +including minor victims identified herein as Minor Victim-1, +Minor Victim-2, and Minor Victim-3, to engage in sex acts with +EPSTEIN at his residences in Manhattan, New York, and Palm +Beach, +Florida, after which he provided them with hundreds of +dollars in cash for each encounter. +b. +In or about 2002, Minor Victim-1 was +recruited to engage in sex acts with EPSTEIN and was repeatedly +sexually abused by EPSTEIN at the New York Residence over a +period of years and was paid hundreds of dollars for each +encounter. EPSTEIN also encouraged and enticed Minor Victim-1 +to recruit other girls to engage in paid sex acts, which she +did. EPSTEIN asked Minor Victim-1 how old she was, and Minor +Victim-1 answered truthfully. +c. In or about 2004, Employee-1, located in the +Southern District of New York, and on behalf of EPSTEIN, placed + +SDNY_GM_00000063 + + + +a telephone call to Minor Victim-1, in order to schedule an +appointment for Minor Victim-1 to engage in paid sex acts with +EPSTEIN. +d. +In or about 2004, Minor Victim-z was +recruited to engage in sex acts with EPSTEIN and was repeatedly +sexually abused by EPSTEIN at the Palm Beach Residence over a +period of years and was paid hundreds of dollars after each +encounter. EPSTEIN also encouraged and enticed Minor Victim-2 +to recruit other girls to engage in paid sex acts, which she +did. +e. In or about 2005, Employee-2, located in the +Southern District of New York, and on behalf of EPSTEIN, placed +a telephone call to Minor Victim-2 in order to schedule an +appointment for Minor Victim-2 to engage in paid sex acts with +EPSTEIN. +I. In or about 2005, Minor Victim-3 was +recruited to engage in sex acts with EPSTEIN and was repeatedly +sexually abused by EPSTEIN at the Palm Beach Residence over a +period of years and was paid hundreds of dollars for each +encounter. EPSTEIN also encouraged and enticed Minor Victim-3 +to recruit other girls to engage in paid sex acts, which she +did. EPSTEIN asked Minor Victim-3 how old she was, and Minor +Victim-3 answered truthfully. + +SDNY_GM_00000064 + + + +In or about 2005, Employee-2, located in the +Southern District of New York, +and on behalf of EPSTEIN, placed +a telephone call to Minor Victim-3 in Florida in order to +schedule an appointment for Minor Victim-3 to engage in paid sex +acts with EPSTEIN. +h. In or about 2004, Employee-3 placed a +telephone call to Minor Victim-3 in order to schedule an +appointment for Minor Victim-3 to engage in paid sex acts with' +EPSTEIN. +(Title 18, United States Code, Section 371.) +COUNT IWO +(Sex Trafficking) +The Grand Jury further charges: +23. +The allegations contained in paragraphs 1: +through 19 and 22 of this Indictment are repeated and realleged +as if fully set forth within. +24. From at least in or about 2002, up to. and +including in or about 2005, in the Southern District of New +York, JEFFREY EPSTEIN, the defendant, willfully and knowingly, +in and affecting interstate and foreign conmerce, did recruit, +entice, harbor, transport, provide, and obtain by any means a +person, knowing that the person had not attained the age of 18 +years +and would be caused to engage in a commercial sex act, and +did aid and abet the same, to wit, EPSTEIN recruited, enticed, +harbored, transported, provided, and obtained numerous + +SDNY_GM_00000065 +EPTA_00114149 + + +individuals who were less than 18 years old, including but not +limited to Minor Victim-1, as described above, and who were then +caused to engage in at least one commercial sex act in +Manhattan, New York. +. (Title 18, United States Code, Sections 1591(a), +(b) (2), and 2.) +FORFEITURE ALLEGATIONS +25. As a result of committing the offense alleged in +Count Iwo of this Indictment, JEFFREY EPSTEIN, the defendant, +shall forfeit to the United States, pursuant to Title 18, United +States Code, Section 1594 (c) (1), any property, real and +personal, that was used or intended to be used to commit or to +facilitate the connission of the offense alleged in Count Iwo, +and any property, real or personal, constituting or derived from +any proceeds obtained, directly or indirectly, as a result of +the offense alleged in Count Iwo, or any property traceable to +such property, and the following specific property: +The lot or parcel of land, together with its +buildings, appurtenances, improvements, fixtures, attachments +and easements, located at 9 East 71st Street, New York, New +York, with block number 1386 and lot number 10, owned by +Maple, Inc. + +SDNY_GM_00000066 + + + +Substitute Asset Provision +26. +If any of the above-described forfeitable +property, as a result of any act or omission of the defendant: +(a) cannot be located upon the exercise of due diligence; +(b) has been transferred or sold to, or deposited with, a +third person; +(c) has been placed beyond the jurisdiction of the Court; +(d), has been substantially diminished in value; oI +(e) has been commingled with other property which cannot +be subdivided without difficulty; +it is the intent of the United States, pursuant to 21 U.s.C. +$ 853 (p) and 28 Ü.S.C. S 2461 (c), to seek forfeiture of any +other property of the defendant up to the value of the above +forfeitable property. +(Title 18, United States Code, Section 1594; Title 21, +United States Code, Section 853(p); and +Title 28, United States Code, Section 2461.) +Gramzas +FOREPERSON +Beer As Born +BERMAN +United States Attorney + +SDNY_GM_00000067 +EPTA_00114151 + + +Form No. USA-338-274 (Ed. 9-25-58) +UNITED STATES OF AMERICA +V. +JEFFREY EPSTEIN, +Defendant. +INDICTMENT +(18 U.S.C. SS 371, 1591 (a), (b) (2), +and 2) +GEOFFREY S. BERMAN +United States Attorney +Foreperson + +SDNY_GM_00000068 diff --git a/vision-fixhub/ds10-01/ef4514cb04293f3036b3ef75d1c7749d40c8abd0d5bd751acbd85a9831b42a90.receipt.json b/vision-fixhub/ds10-01/ef4514cb04293f3036b3ef75d1c7749d40c8abd0d5bd751acbd85a9831b42a90.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..c57ddd1ca4abae8f34ebb76eb9870607890cdb02 --- /dev/null +++ b/vision-fixhub/ds10-01/ef4514cb04293f3036b3ef75d1c7749d40c8abd0d5bd751acbd85a9831b42a90.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -1170, + "dataset": "marble-joined", + "doc_id": "ef4514cb04293f3036b3ef75d1c7749d40c8abd0d5bd751acbd85a9831b42a90", + "engine": "marble-apple-vision", + "event_count": 74, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "f8fd7bd0401cccf03e4b33f4049ce730213ab32bc57a0611b1f34706e64562a2", + "output_sha256": "b47e96aa04a3e659f21132d38b30bfcaaa75d1bb4ac9f02c8bb22d97fa6d9b28", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds10-01/f760e28c26804218c592f50d00ce234db5a129d6c5d1303af5245f08ac3a207d.md b/vision-fixhub/ds10-01/f760e28c26804218c592f50d00ce234db5a129d6c5d1303af5245f08ac3a207d.md new file mode 100644 index 0000000000000000000000000000000000000000..8ee3e0bc1a831c7778f65c72ec5b4733ae4e00c8 --- /dev/null +++ b/vision-fixhub/ds10-01/f760e28c26804218c592f50d00ce234db5a129d6c5d1303af5245f08ac3a207d.md @@ -0,0 +1,1570 @@ +AO 106 (SDNY Rev. 01/17) Application for a Search Warrant +In the Matter of the Search of +(Briefly describe the property to be searched +or identify the person by name and adare +Ablack iPhone with IMEI No. 357201093322785 +19MAG 6581 +Case No. +Seein Agent hailines sid fim a bine sitate; +I, a federal law enforcement officer or an attorney for the government, request a search warrant and state under +penalty of perjury that I have reason to believe that on the following person or property (identify the person or describe the +property to be searched and give its location): +located in the Southun +person or describe the property to be seized): +See Attached Affidavit and its Attachment A +District of New York +, there is now concealed (identify the +The basis for the search under Fed. R. Crim, P. 41(c) is (check one or more): +• evidence of a crime; +• contraband, fruits of crime, or other items illegally possessed; +O property designed for use, intended for use, or used in committing a crime; +• a person to be arrested or a person who is unlawfully restrained. +The search is related to a violation of: +Code Section(s) +18. USC 51591+371 +Offense Description(s) +Sex Trafficking of Minors +sex Trafficking Conspiracy +The application is based on these facts: +See Attached Affidavit and its Attachment A +• Continued on the attached sheet. +• Delayed notice of _30 days (give exact ending date if more than 30 days: +under 18 U.S.C. § 3103a, the basis of which is set fouth on the attached sheet +) is requested +'Sworn to before me and signed in my presence. +JUL 1 5 2019 +City and state: New York, NY +Judge's signature +HON. KEVIN NATHANIEL FOX +United StabeetMagistatoreudge +CONFIDENT or i on ones +EPTA_00114267 + + +19MAG 6581 +In the Matter of the Application of the United +TO BE FILED UNDER SEAL +CDs +SOUTHERN DISTRICT OF NEW YORK) ss.: +being duly sworn, deposes and says: +I. Introduction +A. Affiant +1. +I have been a Special Agent with the Federal Bureau of Investigation ("FBI") since +As such, I am a "federal law enforcement officer" within the meaning of Federal Rule of +Criminal Procedure 41(a)(2)(C), that is, a government agent engaged in enforcing the criminal +laws and duly authorized by the Attorney General to request a search warrant. I am currently +assigned to investigate violations of criminal law relating to the sexual exploitation of children. +As part of my responsibilities, I have participated in numerous investigations and prosecutions of +crimes against children, including the sex trafficking of minors, and have participated in the +execution of search warrants involving electronic evidence. +2. +I make this Affidavit in support of an application pursuant to Rule 41 of the Federal +Rules of Criminal Procedure for a warrant to search certain electronic devices, compact disks and +related electronic media specified below (the "Subject Items") for the items and information +described in Attachment A. This affidavit is based upon my personal knowledge; my review of +documents and other evidence; my conversations with other law enforcement personnel; and my + +SDNY_GM_00000184 + + + +training, experience and advice received concerning the use of computers in criminal activity and +the forensic analysis of electronically stored information ("ES!"). Because this affidavit is being +submitted for the limited purpose of establishing probable cause, it does not include all the facts +that I have learned during the course of my investigation. Where the contents of documents and +the actions, statements, and conversations of others are reported herein, they are reported in +substance and in part, except where otherwise indicated. +B. The Subject Items +3. +The Subject Items are particularly described as follows!: +a. +A black iPhone with IMEI number 357201093322785, which was seized +from JEFFREY EPSTEIN on or about July 6, 2019 ("Subject Item-1"). +bA silver iPad with serial number DLXQGM3KGMW3, which was seized +from JEFFREY EPSTEIN on or about July 6, 2019 ("Subject Item-2"). +c. +about July 11, 2019 ("Subject Item-3"). +Two black binders with CDs, which were seized trom a blue suitcase on or +by Special Agent +July 11, 2019 ("Subject Item-4"). +2019 ("Subject Item-5"). +f. +or about July 11, 2019 ("Subject Item-6"). +Two black hard drives, which were seized, from a blue suitcase on or about +by Special Agent +A box of CDs, which was seized from a blue suitcase on or about July I!, +by Special Agent +Two binders with various CDs, which were seized, from a black suitcase on +ly Special Agent +1 To the extent that the Subject Items contain any SD cards or other removable storage media, the +description of each such item encompasses those SD cards and other media. + +SDNY_GM_00000185 + + + +4. +Based on my training, experience, and research, I know that Subject Item-1 and +Subject Item-2 both have capabilities that allow them to serve as a wireless telephone, digital +camera, portable media player, GPS navigation device, and PDA. +5. +The Subject Items are all presently located in the Southern District of New York. +C. The Target Subjeet and the Subject Offenses +6. +The Target Subject of this investigation is JEFFREY EPSTEIN. +7. +For the reasons detailed below, I respectfully submit that there is probable cause to +believe that the Subject Items contain evidence, fruits, and instrumentalities of violations of Title +18, United States Code, Section 1591 (sex trafficking of minors); and Title 18, United States Code, +Section 371 (sex trafficking conspiracy) (the "Subject Offenses") by the Target Subject. +I. Probable Cause +A. Probable Cause Regarding the Target Subject's Commission of the Subject Offenses +On of about July 2, 2019, a grand jury in this District returned an Indictment +charging JEFFREY EPSTEIN with the Subject Offenses. A copy of the Indictment is attached +hereto as Exhibit A and is incorporated by reference. +That same day, the Honorable Barbara Moses, United States Magistrate Judge, +signed an arrest warrant for JEFFREY EPSTEIN. A copy of the Arrest Warrant is attached hereto +as Exhibit B and is incorporated by reference. +B. Probable Cause Justifying Search of the Subject Items +The Indictment and Victim-1 +10. +As set forth in Exhibit A, from at least in or about 2002, up to and including at least +in or about 2005, JEFFREY EPSTEIN sexually abused multiple minor girls in the Southern +District of New York and elsewhere. During that time and continuing to the present, EPSTEIN + +SDNY_GM_00000186 + + + +possessed and controlled a multi-story, single-family residence located at 9 East 71st Street, New +York, New York, which is described in Exhibit A as "the New York Residence." +11. +As further set forth in paragraphs 8 through 10 of Exhibit A, from at least in or +about 2002, up to and including at least in or about 2005, EPSTEIN sexually abused numerous +minor victims at the New York Residence. In particular, and as alleged in the Indictment, when a +victim arrived at the New York Residence, she would be escorted to a room inside the Subject +Premises with a massage table, where she would perform a massage on EPSTEIN. The victims, +who were as young as 14 years of age, were told by EPSTEIN or other individuals to partially or +fully undress before beginning the "massage." During the encounter, EPSTEIN would escalate +the nature and scope of physical contact with his victim to include, among other things, sex acts +such as groping and direct and indirect contact with the victims' genitals. EPSTEIN typically +would also masturbate during these sexualized encounters, ask victims to touch him while he +masturbated, and touch victims' genitals with his hands or with sex toys. Following each +encounter, EPSTEIN or one of his employees or associates paid the victim in cash. +12. +As set forth in paragraphs 12 through 13 of Exhibit A, to further facilitate his ability +to abuse minor girls in New York, JEFFREY EPSTEIN asked and enticed certain of his victims to +recruit additional minor girls to perform "massages" and similarly engage in sex acts with +EPSTEIN. When a victim would recruit another minor girl for EPSTEIN, he paid both the victimrecruiter and the new victim hundreds of dollars in cash. EPSTEIN knew that his victims were +underage, including because certain victims told him their age. +13. +One of the victims identified in paragraph 22 of Exhibit A is Victim-1. As part of +the FBI's investigation of EPSTEIN, other law enforcement officers and I have interviewed + +SDNY_GM_00000187 + + + +Victim-1.2 During those interviews, Victim-1 has provided the following information, in +substance and in part: +a. Between approximately 2002 and 2005, EPSTEIN sexually abused Victim-1 on +multiple occasions in the New York Residence. This sexual abuse all occurred when Victim-1 +was under the age of 18. +The July 6, 2019 Seizure of Subject Item-1 and Subject Item-2 +14. +I know from my personal participation in this investigation and my conversations +with other law enforcement agents that on July 6, 2019, JEFFREY EPSTEIN was aboard a private +jet that flew from France and landed at approximately 5:30 p.m. in Teterboro Airport in Bergenal Ourty +New Jersey. Upon his arrival at Teterboro Airport, and as part of his re-entry into the United +States, EPSTEIN was searched by agents of U.S. Customs and Border Protection ("CBP"*), who +found both Subject Item-1 and Subject Item-2 in EPSTEIN's possession. The CBP agents then +provided Subject Item-1 and Subject Item-2 to Special Agents of the FBI who also placed +EPSTEIN under arrest. The FBI subsequently transported Subject Item-1 and Subject Item-2 to +FBI offices located in the Southern District of New York, where they are currently located. +2 In meetings with the Government, Victim-l has disclosed that, anproximately a decade ago, she +Information provided by Victim-1 has proven reliable and has been corroborated by independent +evidence, including documents and records obtained during the investigation and the accounts of +other victims whom Victim-1 has never met. + +SDNY_GM_00000188 + + + +The July 6, 2019 and July 7, 2019 Search Warrants for the New York Residence +15. +On or about July 6, 2019, the Honorable Barbara Moses, United States Magistrate +Judge, signed a search warrant authorizing a search of the New York Residence. The search +warrant is attached as Exhibit C and incorporated by reference herein. +16. +At approximately 6 p.m. on or about July 6, 2019, law enforcement officers (the +"Search Team") commenced executing the search warrant at the New York Residence. +17. +Based on the Search Team's observations during an initial search of the New York +Residence, at approximately 7 p.m., the Search Team stopped the search and froze the scene in +order to seek a new search warrant. +18. +On or about July 7, 2019, the Honorable Barbara Moses, United States Magistrate +Judge, signed a second search warrant authorizing a search of the New York Residence (the +"Second Warrant"). The Second Warrant is attached as Exhibit D, and incorporated by reference +herein. At approximately 2:30 a.m., the Search Team resumed the search, and commenced +searching pursuant to the Second Warrant. +19. Based on my conversations with members of the Search Team, I have learned the +following: +a. The Search Team observed a number of computing devices, including computers +and tablet devices, throughout the New York Residence. +b. Inside a safe in a closet on the third floor (the "Saffe"), the Search Team discovered +and seized, among other items, several binders containing sleeves of compact discs, most of which +are labeled with handwriting. In total, the binders contain dozens of compact discs. One disc is +labeled "Young +" Another disc is labeled "Nudes 00-24." Another is +labeled "Misc. Nudes." Yet another is labeled "Girl Pics Nude." Some discs contain the word + +SDNY_GM_00000189 + + + +"Zorro" or "LSJ." For example, one disc is marked "Dana Zorro Pics." Based on my +conversations with law enforcement agents who have participated in this investigation, I believe +the name "Zorro" refers to Zorro Ranch, EPSTEIN's property in New Mexico, and the name LSJ +refers to Little Saint James, EPSTEIN's property in the U.S. Virgin Islands. The majority of the +dises contain titles that include female names. Some of the discs in the binders seized by the +Search Team have titles that appear to refer to trips or vacations. +c. During the search, the Search Team did not seize at that time certain binders of +discs located in the Safe, where the majority of the dises in the binder were labeled in a manner +that did not appear to refer to girls or nudes. The Search Team also did not seize at that time +several unlabeled hard drives, which were also located in the Safe. As detailed below, those +additional binders of dises are among the subjects of this application. +d. In addition to the Safe, in the drawer of a dresser in a room on the Fifth floor of the +New York Residence, the Search team discovered and seized, among other items, a shoebox (the +"Shoebox") which contained numerous compact discs. The majority of the discs are labeled, in +handwriting, with female names. One disc is labeled "Thai Massage." Another dise is labeled +"Blonde Girl Photo Shoot." Yet another disc is labeled "Misc. Girls Nude/Dinner--Scientists." +The dises in the Shoebox were seized by the Search Team. In another drawer of that same dresser, +the Search Team discovered loose polaroid photographs depicting young, nude females who, based +on the training and experience of law enforcement officers who observed them, appear to be +teenagers. In that same drawer, the Search Team discovered a folder marked, in handwriting, +which contained photographs, including nude and sexually suggestive photographs of a +young girl who, based on the training and experience of law enforcement officers who observed +them, appears to be younger than 18. The folder also contained other nude photographs of young + +SDNY_GM_00000190 + + + +girls who appear to be teenagers, based on my training and experience. Inside the folder is a +which was seized by the Search Team. +compact disc marked +e. In a closet on the Fifth Floor of the New York Residence, the Search Team +discovered, among other items, a box marked "women/old photos." The box contained, among +other items, approximately seven compact discs, which are labeled with hand-written titles. One +disc is labeled "nudes 00-24." Another is labeled "Photographer--Mackla '03" The remaining +dises contain titles that include female names. All of the foregoing discs were seized by the Search +Team. +f. In that same closet, the Search Team discovered numerous black binders containing +what appear to be print outs of digital photographs (with file names underneath) and compact dises. +The Search Team seized approximately ten binders (the "Seized Binders") 3 which appeared to +contain, among other photographs, photographs of nude or partially nude young girls, some of +which are in sexually suggestive poses. Based on the training and experience of law enforcement +officers who observed them, at least some of the young girls depicted in the photographs appear +to be teenagers, including some who appear to be under the age of 18. The Seized Binders also +include photographs of what appear to be personal functions, events, and travel. +g. The compact discs seized by the Search Team and described in paragraphs 19(a)-(d) +are currently stored within the Southern District of New York in containers marked for +identification with FBI evidence numbers 15, 16, 17, 18, and 22 (the "Seized Discs"). +The July 7, 2019 Search Warrant for the Seized Discs +20. +On or about July 7, 2019, the Honorable Barbara Moses, United States Magistrate +Judge, signed a third search warrant to search and seize electronic media stored on the Seized Dises +3 The Search Team did not seize the remaining binders. + +SDNY_GM_00000191 + + + +(the "Third Search Warrant"). The Third Warrant is attached as Exhibit E, and incorporated by +reference herein. +21. +following: +Based on my conversations with law enforcement agents who have reviewed the +Seized Discs pursuant to the Third Search Warrant (the "Reviewing Agents"), I have learned the +a. The dises contain approximately thousands of nude or partially nude photographs +of girls or young women, many of which are in sexually suggestive poses. Based on my +conversations with the Reviewing Agents, who have particular training and experience relating to +child erotica and visual depictions of children in child exploitation cases, I have learned that the +Reviewing Agents believe that many of the nude or partially nude images they have reviewed +appear to depict girls under the age of 18. Moreover, many of the photographs appear to be labeled +with file names that suggest the photographs depict these girls at properties associated with +JEFFREY EPSTEIN. For example, some file names are labeled "Zorro" or "LSJ." +b. Among the photographs on the Seized Discs, the Reviewing Agents identified +partially-nude photographs of a young girl, labeled with an associated name that matched a +particular individual ("Individual-1"). After identifying those photographs, the Government was +advised by Individual-1's counsel that Individual-1 recalls the month and year during which she +believes those partially-nude photographs were taken, and also the location where they were taken, +and that she was 17 years old at the time. +The July 11, 2019 Search Warrant for All Electronic Devices and Storage Media in the +New York Residence +22. +Following the initiation of the FBI's review of the Seized Discs, on or about July +11, 2019, the Honorable Henry B. Pitman, United States Magistrate Judge, signed another search +warrant authorizing another search of the New York Residence and specifically authorizing the + +SDNY_GM_00000192 + + + +:... +.. +seizure and search of electronic devices and storage media inside the New York Residence (the +"Fourth Warrant"). The Fourth Warrant is attached as Exhibit F and incorporated by reference +herein. +23. +Later on July 11, 2019, the Search Team executed the Fourth Warrant at the New +York Residence. +24. Based on my conversations with members of the Search Team, I have learned the +following, among other things, regarding the execution of the Fourth Warrant: +a. +During the July 11, 2019 execution of the Fourth Warrant inside the New +York Residence, the Search Team found that the Safe described above was empty and, in +particular, that the collection of discs and hard drives described in paragraph 19b, above, that the +Search Team had not seized during its prior search of the New York Residence on July 7, 2019, +had been removed. +b. +After discovering that the Safe was empty, the Search Team spoke with an +employee who worked at the New York Residence (the "Employee"). During that conversation, +the Employee told the Search Team that after the completion of the prior search on July 7, 2019, +the Employee had been instructed by a third party ("the Third Party") to take the contents of the +Safe out of the New York Residence and deliver those items to the Third Party. The Employee +further told the Search Team that after receiving that instruction, the Employee packed the contents +of the Safe into two suitcases and delivered those suitcases to the Third Party. The Employee +provided the Search Team with the Third Party's contact information. +The Search Team then contacted the Third Party. During the ensuing +conversation, the Third Party confirmed receipt of two suitcases from the Employee but also told + +SDNY_GM_00000193 + + + +the Search Team that the Third Party had not opened the suitcases or touched or tampered with +their contents. The Third Party also agreed to deliver the two suitcases to the Search Team. +d. +Later on July 11, 2019, and consistent with the conversation described +above, the Third Party met the Search Team outside of the New York Residence and provided +Special +"them with the two suitcases described above, one of which was blue and one of which was black. +Agent +Consistent with standard law enforcement protocol, the Search. Team conducted an inventory of +both suitcases before taking custody of them. While taking an inventory of the blue suitcase, the +Search Team discovered, among other items, Subject Item-3, Subject Item-4, and Subject Item-5. +While taking an inventory of the black suitcase, the Search Team discovered, among other items, +Subject Item-6. These items, i.e., Subject Items -3, -4, -5, and -6, appeared to be the same items +observed in the Safe by the Search Team during the July 7, 2019 search of the New York +Residence. +The 2018 Payments +25. Based on my participation in this investigation, my review of open source materials, +and my review of financial records, I have further learned the following: +a. +On or about November 28, 2018, the Miami Herald began publishing a +series of articles related to JEFFREY EPSTEIN, his sex trafficking of minor girls, and the +circumstances of a non-prosecution agreement ("NPA") he previously negotiated with the +Southern District of Florida. Among other things, the NPA identified several individuals as +EPSTEIN's co-conspirators in the sex trafficking of minor girls. +Records obtained by the Government from a financial institution +('Institution-1") appear to show that just two days after the Miami Herald began publishing its +series, on or about November 30, 2018, the defendant wired $100,000 from a trust account he + +SDNY_GM_00000194 + + + +controlled to an individual named as a possible co-conspirator in the NPA. The same records from +Institution-1 appear to show that just three days after that, on or about December 3, 2018, the +defendant wired $250,000 from the same trust account to another individual named as a possible +co-conspirator in the NPA and also identified as one of the defendant's employees in the +Indictment. +Neither of these payments appears to be recurring or repeating during the +approximately five years of bank records presently available. +C. +This course of action, and in particular its timing, suggests the defendant +was still in communication with and attempting to further influence co-conspirators who might +provide information against him in light of the recently re-emerging allegations. +Request to Search the Subject Items +26. +Based on my training and experience and participation in this investigation, I +respectfully submit that there is probable cause to believe that the Subject Items will contain and/or +constitute additional fruits, evidence and instrumentalities of the Subject Offenses. As an initial +matter, all of the Subject Items were initially found in the same Safe in which EPSTEIN was +storing discs and other media already reviewed and which contain hundreds of not thousands of +nude and suggestive images of young females, some of whom appear to be under 18. Given as +much, and because there is probable cause to believe that Epstein engaged in sex trafficking of +underage girls, there is probable cause to believe that the additional storage media in EPSTEIN's +possession and control—i.e., the Subject Items—-will contain evidence of the Subject Offenses. +Moreover, that efforts were made to remove Subject Items - 3, -4, -5, and -6 from the New York +Residence after the initial search only further reinforces the probable cause to believe that those +Subject Items contain and constitute fruits, evidence and instrumentalities of the Subject Offenses. + +SDNY_GM_00000195 + + + +: +27. +With respect to Subject Item-1 and Subject Item-2, both are electronic devices +capable of sending, receiving, and containing thousands of messages and images. Based on my +training and experience, I am aware that individuals who store nude and/or sexually suggestive +photographs of minors on compact discs or other external storage devices typically access those +images from computers and other electronic devices in order to view those images, and individuals +who store such materials on compact discs typically store similar files on other computing devices +and storage devices like Subject Item-1 and Subject Item-2. Further, in light of the payments to +potential co-conspirators described in paragraph 25, above, I respectfully submit there is probable +cause to believe that EPSTEIN still communicates with at least some of his co-conspirators about +the Subject Offenses and that such communications may occur using Subject Item-1 and Subject +Item-2. +28. +I further know from my training and experience that computer files or remnants of +such files can be recovered months or even years after they have been created of saved on an +electronic device such as the Subject Items. Even when such files have been deleted, they can +often be recovered, depending on how the device has subsequently been used, months or years +later with forensics tools. Thus, the ability to retrieve from information from the Subject Items +depends less on when the information was first created of saved than on a particular user's device +configuration, storage capacity, and computer habits. +29. +Based on the foregoing, I respectfully submit there is probable cause to believe that +evidence of JEFFREY EPSTEIN's commission of the Subject Offences is likely to be found on +the Subject Items.. + +SDNY_GM_00000196 + + + +I. Procedures for Searching ESI +A. Review of ESI +30. +Law enforcement personnel (who may include, in addition to law enforcement +officers and agents, attorneys for the government, attorney support staff, agency personnel +assisting the government in this investigation, and outside technical experts under government +control) will review the ESI contained on the Subject Items for information responsive to the +warrant. +31. In conducting this review, law enforcement may use various techniques to +determine which files or other ESI contain evidence or fruits of the Subject Offenses. Such +techniques may include, for example: +• surveying directories or folders and the individual files they contain (analogous to +looking at the outside of a file cabinet for the markings it contains and opening a drawer +believed to contain pertinent files); +• conducting a file-by-file review by "opening" or reading the first few "pages" of such +files in order to determine their precise contents (analogous to performing a cursory +examination of each document in a file cabinet to determine its relevance); +• "scanning" storage areas to discover and possibly recover recently deleted data or +deliberately hidden files; and +• performing electronic keyword searches through all electronic storage areas to +determine the existence and location of data potentially related to the subject matter of +the investigation; and +• reviewing metadata, system information, configuration files, registry data, and any +other information reflecting how, when, and by whom the computer was used. +4 Keyword searches alone are typically inadequate to detect all relevant data. For one thing, +keyword searches work only for text data, yet many types of files, such as images and videos, do +not store data as searchable text. Moreover, even as to text data, there may be information properly +subject to seizure but that is not captured by a keyword search because the information does not + +SDNY_GM_00000197 + + + +32. +Law enforcement personnel will make reasonable efforts to restrict their search to +data falling within the categories of evidence specified in the warrant. Depending on the +circumstances, however, law enforcement may need to conduct a complete review of all the ESI +from the Subject Items to evaluate its contents and to locate all data responsive to the warrant. +B. Return of the Subject Items +33. +If the Government determines that the Subject Items are no longer necessary to +retrieve and preserve the data on the Subject Items, and that the Subject Items are not subject to +seizure pursuant to Federal Rule of Criminal Procedure 41(c), the Government will return the +Subject Items. E +Computer data that is encrypted or unreadable will not be returned +unless law enforcement personnel have determined that the data is not (i) an instrumentality of the +offense, (ii) a fruit of the criminal activity, (iii) contraband, (iv) otherwise unlawfully possessed, +or (v) evidence of the Subject Offenses. + +SDNY_GM_00000198 +EPTA_00114282 + + +IV. Conclusion and Ancillary Provisions +34. +Based on the foregoing, I respectfully request the court to issue a warrant to seize +the items and information specified in Attachment A to this affidavit and to the Search and Seizure +Warrant. +35. +In light of the confidential nature of the continuing investigation, I respectfully +request that this affidavit and all papers submitted herewith be maintained under seal until the +Court orders otherwise. +Special Agent +, Federal Bureau of Investigation +Sworn to before me on JuL 1 5 2019' +July 15, 2019 +Kevin rathaniel 7t +HON, KEVIN NATHANIEL FOX +UNITED STATES MAGISTRATE JUDGE + +SDNY_GM_00000199 +EPTA_00114283 + + +Attachment A +1. Items Subject to Search and Seizure +The Subject Items are particularly described as follows!: +• A black iPhone with IMEI number 357201093322785, which was seized from +JEFFREY EPSTEIN on or about July 6, 2019 ("Subject Item-1"). +• A silver iPad with serial number DIXQGM3KGMW3, which was seized from +JEFFREY EPSTEIN on or about July 6, 2019 ("Subject Item-2"). +• Two black binders with CDs, which were seized from a blue suitcase on or about Al +July 11, 2019 ("Subject Item-3"). +by pecial Agent +• Two black hard drives, which were seized from a blue suitcase on or about my 112Ag +2019 ("Subject Item-4"). +by бреса Agent +• A box of CDs, which was seized from a Blue suitcase on or about July 11, 2019 +("Subject Item-5"). +by special Agent +• Two binders with various CDs, which were seized, from a black suitcase on or about +July 11, 2019 ("Subject Item-6"): +ly Special Agent +II. Review of ESI on the Subject Items +Law enforcement personnel (who may include, in addition to law enforcement officers and +agents, attorneys for the government, attorney support staff, agency personnel assisting the +government in this investigation, and outside technical experts under government control) are +authorized to review the ESI contained on the Subject Items for evidence, fruits, and +instrumentalities of violations of Title 18, United States Code, Sections 1591 (sex trafficking of +minors), and 371 (sex trafficking conspiracy) (the "Subject Offenses") described as follows: +1. +Any documents or communications with or regarding victims or potential victims +of the Subject Offenses; +2. Any photographs of victims or potential victims of the Subject Offenses; +3. +Any nude, partially nude, or sexually suggestive photographs of individuals who +appear to be teenage girls, or younger; +4. +Records, data, or other items that evidence ownership, control, or use of, or access +to the Subject Items, including, but not limited to access history data, historical location data, +' To the extent that the Subject Items contain any SD cards or other removable storage media, the +description of each such item encompasses those SD cards and other media. + +SDNY_GM_00000200 + + + +configuration files, saved usernames and passwords, user profiles, e-mail contacts, and +photographs; +5. +Any child erotica, defined as suggestive visual depictions of nude minors that do +not constitute child pornography as defined by 18 U.S.C. § 2256(8). +As to Subject Item-1 and Subject Item-2, Law enforcement personnel (who may include, +in addition to law enforcement officers and agents, attorneys for the government, attorney support +staff, agency personnel assisting the government in this investigation, and outside technical experts +under government control) are further authorized to review the ESI contained on Subject Item-1 +and Subject Item-2 for evidence, fruits, and instrumentalities of violations of Title 18, United +States Code, Sections 1591 (sex trafficking of minors), and 371 (sex trafficking conspiracy) (the +"Subject Offenses") described as follows: +1. +Offenses. +Any documents or communications with or regarding co-conspirators in the Subject +In conducting this review, law enforcement personnel may use various techniques to +determine which files or other ESI contain evidence or fruits of the Subject Offenses. Such +techniques may include, for example: +• surveying directories or folders and the individual files they contain (analogous to +looking at the outside of a file cabinet for the markings it contains and opening a drawer +believed to contain pertinent files); +• +conducting a file-by-file review by "opening" or reading the first few "pages" of such +files in order to determine their precise contents (analogous to performing a cursory +examination of each document in a file cabinet to determine its relevance); +• eiberacy tote tea a discover and posily recoverely deleted data or +• performing electronic keyword searches through all electronic storage areas to +determine the existence and location of data potentially related to the subject matter of +the investigation; and +• reviewing metadata, system information, configuration files, registry data, and any +other information reflecting how, when, and by whom the computer was used. +Law enforcement personnel will make reasonable efforts to search only for files, +documents, or other electronically stored information within the categories identified in Section II +of this Attachment. However, law enforcement personnel are authorized to conduct a complete +review of all the ESI from seized devices or storage media if necessary to evaluate its contents and +to locate all data responsive to the warrant. + +SDNY_GM_00000201 + + + + + +SDNY_GM_00000202 + + + +i" +UNITED STATES OF AMERICA +- V. - +JEFFREY EPSTEN, +Defendant. +SEALED +INDICTMENT +19 Ct. +19 CRIM +490 +- - +- - X +COUNT ONE +(Sex Irafficking Conspiracy) +The Grand Jury charges: +OVERVIEW +1. . +As set forth herein, over the course of many +years, JEFFREY EPSTEIN, the defendant, sexually exploited and +abused dozens of minor girls at his homes in Manhattan, New +York, +and Palm Beach, Florida, among other locations. +2. In particular, from at least in or about 2002, up +to and including at least in or about 2005, JEFFREY EPSTEIN, the +defendant, enticed and recruited, and caused to be enticed and +recruited, minor girls to visit bis mansion in Manhattan, New +York (the "New York Residence") and his estate in Palm Beach, +• Florida (the "Palm Beach Residence") to engage in sex acts with +him, after which he would give the victims hundreds of dollars +in cash. +Moreover, and in order to maintain and increase his +supply of victims, EPSTEIN also paid certain of his victims to +recruit additional girls to be similarly abused by EPSTEIN. In + +SDNY_GM_00000203 + + + +this way, EPSTEIN created a vast network of underage victims for +him to sexually exploit in locations including +New York and +Palm Beach. +3. The victims described herein were as young as 14 +years old at the time they were abused by JEFFREY EPSTEIN, the +defendant, and were, for various reasons, often particularly +vulnerable to exploitation. EPSTEIN intentionally sought out +minors and knew that many of his victims were in fact under the +age of 18, including because, in some instances, minor victims +expressly told him their age. +4. In creating and maintaining this network of minor +victims in multiple states to sexually abuse and exploit, +JEFFREY EPSTEIN, the defendant, worked and conspired with, +others, including employees and associates who facilitated his +conduct by, among other things, contacting victims and +scheduling their sexual encounters with EPSTEIN at the New York +Residence and at the Palm Beach Residence. +FACTUAL BACKGROUND +5. During all time periods charged in this +Indictment, JEFFREY EPSTEIN, the defendant, was a financier with +multiple residences in the continental United States, including +the New York Residence and the Palm Beach Residence. +6. +Beginning in at least 2002, JEFFREY EPSTEIN, the +defendant, enticed and recruited, and +caused to be enticed and + +SDNY_GM_00000204 +EPTA_00114288 + + +:. +: +recruited, dozens of minor girls to engage in sex acts with him, +after which EPSTEIN paid the victims hundreds of dollars in +cash, at the New York Residence and the Palm Beach Residence. +7: In both New York and Florida, JEFFREY EPSTEIN, +the defendant, perpetuated this abuse in similar ways. Victims +were initially recruited to provide "massages" to EPSTEIN, which +would be performed nude or partially nude, would become +increasingly sexual in nature, and would typically include one +or more sex +acts. +EPSTEIN paid his victims hundreds of dollars +in cash for each encounter. Moreover, EPSTEIN actively +encouraged certain of his victims to recruit additional girls to +be similarly sexually abused. EPSTEIN incentivized his victims +to become recruiters by paying these victim-recruiters hundreds +of dollars for each girl that they brought to EPSTEIN. In so +doing, EPSTEIN maintained a steady supply of new victims to +exploit. +The New York Residence +8. At all times relevant to this Indictment, JEFFREY +EPSTEIN, the defendant, possessed and controlled a multi-story +private residence on the Upper East Side of Manhattan, New York, +i.e., the New York Residence. Between at least in or about 2002 +andin or about +2005, EPSTEIN abused numerous minor victims at +the New York Residence by causing these victims to be recruited +to engage in paid sex acts with him. + +SDNY_GM_00000205 + + + +9. +When a victim arrived at the New York Residence, +she typically would be +escorted to a room with a massage table, +where +she would perform a massage on JEFFREY EPSTEIN, the +defendant. The victims, who were as young as 14 years of age, +were told by EPSTEIN or other individuals to partially or fully +undress before beginning the "massage." During the encounter, +EPSTEIN would escalate the nature and scope of physical contact +with his victim to include, among other things, sex acts such as +groping and direct and indirect contact with the victim's +genitals. +EPSTEIN typically would also masturbate during these +sexualized encounters, +ask victims to touch him while he +masturbated, and touch victims' genitals with his hands or with +sex toys. +10. In connection with each sexual encounter, JEFFREY +EPSTEIN, the defendant, or one of his employees or associates, +paid the victim in cash. Victims typically were paid hundreds +of dollars in +cash for each encounter. +11. JEFFREY EPSTEIN, the defendant, knew that many of +his New York victims were underage, including because certain +victims told him their age. +Further, once these minor victims +were recruited, many were abused by EPSTEIN on multiple +subsequent occasions' at the New York Residence. EPSTEIN +sometimes personally contacted victims to schedule appointments +at the New York Residence. In other instances, EPSTEIN directed + +SDNY_GM_00000206 + + + +... +employees and associates, including a New York-based employee +("Employee-1"), to conmunicate with victims via phone to arrange +for these victims to return to the New York Residence for +additional sexual encounters with EPSTEIN. +12. Additionally, and to further facilitate his +ability to abuse minor girls in New York, JEFFREY EPSTEIN, the +defendant, asked and enticed certain of his victims to recruit +additional girls to perform "massages" and similarly engage in +sex acts with EPSTEIN. When a victim would recruit another girl +for EPSTEIN, he paid both the victim-recruiter and the new +victim hundreds of dollars in cash. Through these victimrecruiters, EPSTEIN gained access +to and was able to abuse +dozens of additional minor girls. +13. In particular, certain recruiters brought dozens +of additional minor girls to the New York Residence to give +massages to and engage in sex acts with JEFFREY EPSTEIN, the +defendant. EPSTEIN encouraged victims to recruit additional +girls by offering to pay these victim-recruiters for every +additional girl they brought to EPSTEIN. +When a victimrecruiter accompanied a new minor victim to the New York +Residence, both the victim-recruiter and the new minor victim +were paid hundreds of dollars by EPSTEIN for each encounter: In +addition; certain victim-recruiters routinely scheduled these + +SDNY_GM_00000207 + + + +encounters through Employee-1, who sometimes asked the +recruiters +to bring a specific minor girl for EPSTEIN. +The Palm Beach Residence +14. In addition to recruiting and abusing minor girls +in New York, JEFFREY EPSTEIN, the defendant, created a similar +network of minor girls to victimize in Palm Beach, Florida, +where EPSTEIN owned, possessed and controlled another large +residence, i.e., the Palm Beach Residence. EPSTEIN frequently +traveled from New York to Palm Beach by private jet, before +which an employee or associate +would ensure that minor victims +were available for encounters upon his arrival in Florida. +15. At the Palm Beach Residence, JEFFREY EPSTEIN, the +defendant, engaged in a similar course of abusive conduct. +When a +victim initially arrived at the Palm Beach Residence, she +would be escorted to a room, sometimes by an employee of +EPSIEIN' s, including, at times, two assistants ("Employee-2" and ' +"Employee-3") who, as described herein, were also responsible +for scheduling sexual encounters with minor victims. +Once +inside, the victim would provide á nude or semi-nude massage for +EPSTEIN, who would himself typically be naked. During these +encounters, EPSTEIN would escalate the nature and scope of the +physical contact to include sex acts such as groping and direct +and indirect contact with the victim's genitals. +EPSTEIN would• +also typically masturbate during these encounters, ask victims + +SDNY_GM_00000208 + + + +to touch him while he masturbated, and touch victims' genitals +with his hands or with sex toys. +16. In connection with each sexual encounter, JEFFREY +EPSTEIN, the defendant, or one of his employees or associates, +paid the victim in cash. Victims typically were paid hundreds +of dollars for each encounter. +17. +JEFFREY EPSTEIN, the defendant, knew that certain +of his victims were underage, including because certain victims +told him their age. In addition, as +with New York-based +victims, many Florida victims, once recruited, were abused by +JEFFREY EPSTEIN, the defendant, on multiple additional +'occasions. +18. JEFFREY EPSTEIN, the defendant, who during the +relevant time period was frequently in New York, would arrange +for Employee-2 or other employees to contact victims by phone in +advance of EPSTEIN's travel to Florida to ensure appointments +were scheduled for when he arrived. In particular, in certain +instances, Employee-2 placed phone calls to minor victims in +Florida to schedule encounters at the Palm Beach Residence. At +the time of certain of those phone calls, EPSTEIN and Employee-2 +were in New York, New York. Additionally, certain of the +individuals victimized at the Palm Beach Residence were +contacted by phone by Employee-3 to schedule these encounters. + +SDNY_GM_00000209 + + + +19. Moreover, as in New York, to ensure a steady +stream of minor victims, JEFFREY EPSTEIN, the defendant, asked +and enticed certain victims in Florida to recruit other girls to +engage in sex acts. +EPSTEIN paid hundreds of dollars to victimrecruiters for each additional girl they brought to the Palm +Beach Residence. +STATUTORY ALLEGATIONS +20. From at least in or about 2002, up to and +including in or about 2005, in the Southern District of New York +and elsewhere, JEFFREY EPSTEIN, the defendant, and others known +and unknown, willfully and knowingly did combine, conspire, +confederate, and agree together and with each other to commit an +offense against the United States, to wit, sex trafficking of +minors, in violation of Title 18, United States Code, Section. +1591(a) and (b) . +21. It was a part and object of the conspiracy that +JEFFREY EPSTEIN, the defendant, and others known and unknown, +would and did, in and affecting interstate and foreign commerce, +recruit, entice, harbor, transport, provide, and obtain, by any +means a person, and to benefit, financially and by receiving +anything of value, from participation in a venture which has +engaged in any such act, knowing that the person had not +attained the age of 18 years and would be caused to engage in a + +SDNY_GM_00000210 + + + +commercial sex act, in violation of Title 18, United States +Code, Sections 1591 (a) and (b) (2). +Overt Acts +22. In furtherance of the conspiracy and to effect +the illegal object thereof, the following overt acts, among +others, were committed in the Southern District of New York and +elsewhere: +a. +In or about 2004, JEFFREY EPSTEIN, the +defendant, enticed and recruited multiple minor victims, +including +minor victims identified herein as Minor Victim-1, +Minor Victim-2, and Minor Victim-3, to engage in sex acts with +EPSTEIN at his residences in Manhattan, New York, and Palm +Beach, Florida, after which he provided them with hundreds of +dollars in cash for each encounter. +i +b. In or about 2002, Minor Victim-1 was +recruited to engage in sex acts with EPSTEIN and was repeatedly +sexually abused by EPSTEIN at the New York Residence over a +period of years and was paid hundreds of dollars for each +encounter. +EPSTEIN also encouraged and enticed Minor Victim-1 +to recruit other girls to engage +‚in paid sex acts, which she +did. EPSTEIN asked Minor Victim-1 how old she was, and Minor +Victim-1 answered truthfully. +c. In oi about 2004, Employee-1, located in the +Southern District of New York, and on behalf of EPSTEIN, placed + +SDNY_GM_00000211 + + + +a telephone call to Minor Victim-1, in order to schedule an +appointment for Minor Victim-1 to engage in paid sex acts with +EPSTEIN. +d. In or about 2004, Minor Victim-2 was +recruited to engage in sex acts with EPSTEIN and was repeatedly +sexually abused by EPSTEIN at the Palm Beach Residerice over a +period of years and was paid hundreds of dollars after each +encounter. EPSTEIN also encouraged and enticed Minor Victim-2 +to recruit other girls to engage in paid sex acts, which she +did. +e. In or about 2005, Employee-2, located in the +Southern District of New York, and on behalf of EPSTEIN, placed +a telephone call to Minor Vietim-2 in order to schedule an +appointment for Minor Victim-2 to engage in paid sex acts with +EPSTEIN. +I. In or about 2005, Minor Victim-3 was +recruited to engage in sex acts with EPSTEIN and was repeatedly +sexually abused by EPSTEIN at the Palm Beach Residence over a +period of years and was paid hundreds of dollars for each +encounter. EPSTEIN also encouraged and enticed Minor Victim-3 +to recruit other girls to engage in paid sex acts, which she +did. EPSTEIN asked Minor Victim-3 how old she was, and Minor +Victim-3 answered truthfully. + +SDNY_GM_00000212 + + + +g. In or about 2005, Employee-2, located in the +Southern District of New York, and on behalf of EPSTEIN, placed +a telephone call to Minor Victim-3 in Florida in order to +schedule an appointment for Minor Victim-3 to éngage in paid sex +acts with EPSTEIN. +h. In or about 2004, Employee-3 placed a +telephone call to Minor Victim-3 in order to schedule an +appointment for Minor Victim-3 to engage in paid sex acts with +EPSTEIN. +(Title 18, United States Code, Section 371.) +COUNT TWO +(Sex Trafficking) +The Grand Jury further charges: +23. The allegations contained in paragraphs 1 +• through 19 and 22 of this Indictment are repeated and realleged +as if fully set forth within. +24. From at least in or about 2002, up to. and +including in or about 2005, in the Southern District of New +York, +JEFFREY EPSTEIN, the defendant, willfully and knowingly, +in and affecting interstate and foreign commerce, did recruit, +entice, harbor, transport, provide, and obtain by any means a +person, knowing that the person had not attained the age of 18 +years and would be caused to engage in a commercial sex +act, and +did aid and abet the same, to wit, EPSTEIN recruited, enticed, +harbored, transported, provided, and obtained numerous + +SDNY_GM_00000213 + + + +individuals who were less than 18 years old, including but not +limited to Minor Victim-1, as described above, and who were then +caused to engage in at least one commercial sex act in +Manhattan, New York. +(Title 18, United States Code, Sections 1591(a), +(b) (2), and 2.) +FORFEITURE ALLEGATIONS +25. As a result of committing the offense alleged in +Count Iwo of this Indictment, JEFFREY EPSTEIN, the defendant, +shall forfeit to the United States, pursuant to Title 18, United +States Code, Section 1594(c) (1), any property, real and +personal, that was used or intended to be used to commit or to +facilitate the commission of the offense alleged in +Count Iwo, +and any property, real or personal, constituting or derived from +any proceeds obtained, directly or indirectly, as a result of +the offense alleged in Count Iwo, or any property traceable to +such property, and the following specific property: +a. +The lot or parcel of land, together with its +buildings, appurtenances, improvements, fixtures, attachments +and easements, located at 9 East İlst Street, New York, New +York, with block number 1386 and lot number 10, owned by +Maple, Inc. + +SDNY_GM_00000214 + + + +Substitute Asset Provision +26. If any of the above-described forfeitable +property, as a result of any act or omission of the defendant: +(a) cannot be located upon the exercise of due diligence; +(b) has been transferred or sold to, or deposited with, a +third person; +(c) has been placed beyond the jurisdiction of the Court; +(d), has been substantially diminished in value; or +(e) has been conmingled with other property which cannot +be subdivided without difficulty; +it is the intent of the United States, pursuant to 21 U.S.C. +$ 853 (p) +and 28 U.S.C. S 2461(c), to seek forfeiture of any +other property of the defendant up to the value of the above +forfeitable property. +(Title 18, United States Code, Section 1594; Title 21, +United States Code, Section 853 (p); and +Title 28, United States Code, Section 2461.) +1. Blume +GEOFFREY +BERMAN +United States Attorney + +SDNY_GM_00000215 +EPTA_00114299 + + +Form No. USA-33s-274 (Ed. 9-25-58) +UNITED STATES OF AMERICA +v. +JEFFREY EPSTEIN, +Defendant. +INDICTMENT +(18 U.S.C. SS 371, 1591 (a), (b) (2), +and 2) +GEOFFREY S. BERMAN +United States Attorney + +SDNY_GM_00000216 + + + + + +SDNY_GM_00000217 + + + +Mod AO 442 (09/15), Arrest Warrant AUSA Nemo & Telno: Alison Moe, 212-637-2225 +Southern District of New York +United States of America +V. +Jeffrey Epstein +Defendant +Case No. +19 CRIM +ARREST WARRANT +490 +To: +Any authorized law enforcement officer +• YOU ARE COMMANDED to arrest and bring before a United States magistrate judge without unnecessary delay +(name of person to be arrested) Jeffrey Epstein +who is accused of an offense or violation based on the following document filed with the court: +• Indictment +• Probation Violation Petition +• Superseding Indictment • Information +• Supervised Release Violation Petition +This offense is briefly described as follows: +. Title 18, United States Code, Section 371 (sex trafficking conspiracy) +Title 18, United States Code, Sections 1591(a), (b)(2), and (2) (sex trafficking of minors) +• Superseding Information O Complaint +• Violation Notice • Order of the Court +City and state: +07/02/2019 +New York, NY +The Honorable Barbara Moses, U,S, Magistrate Judge +Printed name and fille +This warrant was received on (date) +, and the person was arrested on (date) +at (city and state) +Arresting officer's signature + +SDNY_GM_00000218 + + + + + +SDNY_GM_00000219 + + + +AO 93 (SDNY Rev. 01/17) Search and Seizure Warrent +Southern District of New York +In the Matter of the Search of +are deter proper on setried. +See Attachment A +Case No. +SEARCH AND SEIZURE WARRANT +• To: +Any authorized law enforcement officer +An application by a federal law enforcement officer or an attorney for the government requests the search +of the following person or property located in the +Southern +District of +Now York. +(identify the person or describe the property to be searched and give its location): +See Attachment A +The person or property to be searched, described above, is believed to conceal (identify the person or describe the property +to be seized): . +See Attachment A +The search and seizure are related to violation(s) of (insert statulory cifations): +Title 18, United States Code, Sections 371 and 1591 +I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or +property. +YOU ARE COMMANDED to execute this warrant on or before +7.20-19 +I in the daytime 6:00 a.m. to 10 p.m. +• at any time in the day or night as I find rots oned cause has been +established. +Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property +taken to the person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the +place where the property was taken. +The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an +inventory as required by law and promptly return this warrant and inventory to the Clerk of the Court +] Upon its return, this warrant and inventory should be filed under seal by the Clerk of the Court. +• I find that immediate notification may have an adverse result listed in 18 U.S.C. § 2705 (except for delay +of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose property, will be +searched or seized (check the appropriate box) Ofor +days (not to exceed 30). +Ountil, the facts justifying, the later specific date of +Date and time issued: +7-6.19 10:14a.M. +obertons +Judge's signature +City and state: New York, NY +Hon. Barbara Moses, U.S. Magistrate Judge +CONFIDENTIA manite SON OM 00220 +EPTA_00114304 + + +• * +Date and time warrant executed: +[ Copy of warrant and inventory left with: +Case No.: +Inventory made in the presence of: +Inventory of the property taken and name of any person(s) seized: +Certification +I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant +to the Court. +Executing officer's signature + +SDNY_GM_00000221 + + + +I. Premises to be Searched— Subjeet Premises +The premises to be searched (the "Subject Premises") are described as a nearly +19,000 square foot multi-story single-family residence located at 9 East 71st Street, New York, +New York, and include all locked and closed containers found therein. A photograph of the front +entratice to the Subject Premises is included below: +Google +II. Items to Be Seized +1. This warrant authorizes executing agents to photograph, video record and otherwise +document the fill interior of the Subject Premises, including any items, furnishings, or possessions +therein. +2. In addition, this warrant authorizes the seizure of certain evidenco, fruits, and +instrumentalities of violations of Title 18, United States Code, Sections 1591 (sex trafficking of +minors) and 371 (sex trafficking conspiracy) (the "Subject Offenses") described as follows: +a. Evidence concerning occupancy or ownership of the Subject Premises, +including utility and telephone bills, mail envelopes, addressed correspondence, +diaries, statements, identification documents, address books, telephone +directories, and photographs of its occupant(s). +b. Evidence concerning the layout, furnishings, decorations, and floor pattern of +the Subject Premises, including photographs and blueprints of the Subject +Premises. + +SDNY_GM_00000222 + + + + + +SDNY_GM_00000223 + + + +AO 93 (SDNY Rev. 01/17) Search and Seizure Warrant +Southern District of New York +In the Matter of the Search of +Briefly describe she property to be searcher +ar identify the person by name and odaress +See Attachment A +Case No. +SEARCH AND SEIZURE WARRANT +To: Any authorized law enforcement officer +An application by a federal law enforcement officer or an attorney for the government requests the search +of the following person or property located in the +Southern +District of +New York +(identify the person or describe the property so be searched and give irs location); +See Attachment A +The person or property to be searched, described above, is believed to conceal (identify the person or describe she property +to be seized): +See Attachment A +The search and seizure are related to violation(s) of (insert starvory citations): +Title 18, United States Code, Sections 371 and 1591 +I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or +property. +YOU ARE COMMANDED to execute this warrant on or before +July 7, 2019 +(not to exceed 14 days) +• in the daytime 6:00 a.m. to 10 p.m. • at any time in the day or night as I find reasonable cause has been +established. +Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property +taken to the person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the +place where the property was taken. +The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an +inventory as required by law and promptly return this warrant and inventory to the Clerk of the Court. +• Upon its return, this warrant and inventory should be filed under seal by the Clerk of the Court. +• 1 find that immediate notification may have an adverse result listed in 18 U.S.C. § 2705 (except for delay +of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose property, will be +searched or seized (check the appropriate box) +days (not to exceed 30). +Cuntil, the facts justifying, the later specific date of +Date and time issued: +77-19 7:03a.M. +obertles +Judge's signature +City and state: +New York, NY +Hon. Barbara Moses, U.S. Magistrate Judge + +SDNY_GM_00000224 + + + +Date and time warrant executed: +Case No.: +Inventory made in the presence of : +Inventory of the property taken and name of any person(s) seized +[Copy of warrant and inventory left with: +Certification +I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant +to the Court. +Erecuting officer's signature + +SDNY_GM_00000225 + + + +I. Premises to be Searched—Subject Premises +1. +The premises to be searched (the "Subject Premises") are described as a multi-story +single-family residence located at 9 East 71st Street, New York, New York, and include all locked +and closed containers found therein. A photograph of the front entrance to the Subject Premises +is included below: +Google +I. Items to Be Seized +A. Evidence, Fruits, and Instrumentalities of the Subject Offenses +This warrant authorizes the seizure of certain evidence, fruits, and instrumentalities of +violations of Title 18, United States Code, Sections 1591 (sex trafficking of minors) and 371 +(sex trafficking conspiracy) (the "Subject Offenses") described as follows: +i. Any and all taxidermied dogs. +ii. Any and all massage tables and massage paraphernalia. +ili. Any and all busts or three-dimensional representations of female human +torsos. +iv. Any and all photos or representations depicting nude or partially nude +women located in the Massage Room, as defined herein. +v. Any and all sex toys and sex paraphernalia located in the Massage +Room, as defined herein. + +SDNY_GM_00000226 + + + +vi. A binder labeled "PB Girls" and any other documents or +communications with or regarding victims or potential victims of the +Subject Offenses. +2 + +SDNY_GM_00000227 +EPTA_00114311 + + + + +SDNY_GM_00000228 + + + +A093 (SDNY Rev. 01/17) Search and Seizure Warrant +Southern District of New York +In the Matter of the Search of +Case No. +See Attachment A +SEARCH AND SEIZURE WARRANT +To: +Any authorized law enforcement officer +An application by a federal law enforcement officer or an attorney for the government requests the search +of the following person or property located in the +Southern +District of +New York. +(identify the person or describe the property to be searched and give its location): +See Attachment A +The person or property to be searched, described above, is believed to conceal (identify the person or describe the property +lo be seized): +See Attachment A +The search and seizure are related to violation(S) of (insert statutory citations): +Title 18, United States Code, Sections 371 and 1591 +1 find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or +property. +YOU ARE COMMANDED to execute this warrant on or before +July 21, 2019 +(not ro exceed 14 days) +• in the daytime 6:00 a.m. to 10 p.m. +• at any time in the day or night as I find reasonable cause has been +established. +Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property +taken to the person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the +place where the property was taken. +The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an +inventory as required by law and promptly return this warrant and inventory to the Clerk of the Court. +• Upon its return, this warrant and inventory should be filed under seal by the Clerk of the Court. +• I find that immediate notification may have an adverse result listed in 18 U.S.C. § 2705 (except for delay +of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose property, will be +searched or seized (check the appropriate box) Ofor +days (not to exceed 30). +Duntil, the facts justifying, the later specific date of +Date and time issued: 77-19 11:33P.M. +signature +City and state: New York, NY +CONFIDEN Ages. Mason e:3022 + + + +Date and time warrant executed: +Case No.: +Inventory made in the presence of : +Inventory of the property taken and name of any person(s) seized: +Copy of warrant and inventory left with: +Certification +1 declare under penalty of perjury that this inventory is correct and was returned along with the original warrant +to the Court. +Erecuting officer's signature +Printed name and tille + +SDNY_GM_00000230 + + + +I. The Subject Devices to Be Searched +The Subject Devices are particularly described as compact discs stored in containers +marked with FBI evidence numbers 15, 16, 17, 18, and 22, seized from the residence located at 9 +East 71st Street, New York, New York, on or about July 7, 2019. +II. Items to Be Seized +A. Evidence, Fruits, and Instrumentalities of the Subject Offenses +This warrant authorizes the seizure of certain evidence, fruits, and instrumentalities of +violations of Title 18, United States Code, Sections 1591 (sex trafficking of minors), and 371 (sex +trafficking conspiracy) (the "Subject Offenses") described as follows: +1. +Any documents or communications with or regarding victims or potential victims +of the Subject Offenses; +2. Any photographs of victims or potential victims of the Subject Offenses; +3. +Any nude, partially nude, or sexually suggestive photographs of individuals who +appear to be teenage girls, or younger; +4. +Motion pictures, films, videos, and other recordings of visual or written depictions +of minors engaged in sexually explicit conduct, as defined in 18 U.S.C. § 2256(2); +5. +Records or other items that evidence ownership, control, or use of, or access to +devices, storage media, and related electronic equipment used to access, transmit, or store +information relating to the Subject Offenses, including, but not limited to, sales receipts, +warranties, bills for Internet access, handwritten notes, registry entries, configuration files, saved +usernames and passwords, user profiles, e-mail contacts, and photographs; +6. +Any child erotica, defined as suggestive visual depictions of nude minors that do +not constitute child pornography as defined by 18 U.S.C. § 2256(8). +B. Review of ESI +Law enforcement personnel (including, in addition to law enforcement officers and agents, +and depending on the nature of the ESI and the status of the investigation and related proceedings, +attorneys for the government, attorney support staff, agency personnel assisting the government in +this investigation, and outside technical experts under government control) will create a forensic +image of the Subject Devices (if practicable) and review the ESI contained therein for information +responsive to the warrant. +In conducting this review, law enforcement personnel may use various techniques to +determine which files or other ESI contain evidence or fruits of the Subject Offenses. Such +techniques may include, for example: + +SDNY_GM_00000231 + + + +• surveying directories or folders and the individual files they contain (analogous to +looking at the outside of a file cabinet for the markings it contains and opening a drawer +believed to contain pertinent files); +• conducting a file-by-file review by "opening" or reading the first few "pages" of such +files in order to determine their precise contents (analogous to performing a cursory +examination of each document in a file cabinet to determine its relevance); +• "scanning" storage areas to discover and possibly recover recently deleted data or +deliberately hidden files; and +• performing electronic keyword searches through all electronic storage areas to +determine the existence and location of data potentially related to the subject matter of +the investigation; and +reviewing metadata, system information, configuration files, registry data, and any +other information reflecting how, when, and by whom the computer was used. +Law enforcement personnel Will make reasonable efforts to search only for files, +• contents and to locate all data responsive to the warrant. +• Keyword searches alone are typically inadequate to detect all relevant data. For one thing, +keyword searches work only for text data, yet many types of files, such as images and videos, do +not store data as searchable text. Moreover, even as to text data, there may be information properly +subject to seizure but that is not captured by a keyword search because the information does not +2 + +SDNY_GM_00000232 + + + + + +SDNY_GM_00000233 + + + +AO 93(8DNY Rev, 01/17) Search and Seizure Warrant +Suda SHE NO *9 MAG 6439 +In the Matter of the Search of +Briefly describe the property to be searchs +ur identify the person by name and address +See Attachment A +Case No. 19 Cr. 490 (RMB) +SEARCH AND SEIZURE WARRANT +To: Any authorized law enforcement officer +An application by a federal law enforcement officer or an attorney for the government requests the search +of the following person or property located in the +Southern +District of +New York +(idenitfy the person or describe the property to be searched and give its location): +See Attachment A +The person or property to be searched, described above, is believed to conceal (identify the person or describe the property +to be seized): +See Attachment A +The search and seizure are related to violation(s) of (insert statutory citations): +Title 18, United States Code, Sections 371 and 1591 +I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or +property. +YOU ARE COMMANDED to execute this warrant on or before +July 12, 2019 +(not to exceed 14 days) +29 in the daytime 6:00 a.m. to 10 p.m. +at any time in the day or night as I find reasonable cause has been +Unless delayed notice is authorized below, you must give a copy. of the warrant and a receipt for the property +taken to the person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the +place where the property was taken. +The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an +inventory as required by law and promptly return this warrant and inventory to the Clerk of the Court. +• Upon its return, this warrant and inventory should be filed under seal by the Clerk of the Court. +USM Initials +• I find that immediate notification may have an adverse result listed in 18 Y,S C, $ 2705 (except for delay +of trial), and authorize the officer execuțing this warrant to delay notice to the person! who, of Whose property, will be +searched or seized (check the appropriate box) Ofor +days (not to exceed 30). +Cuntil, the facts justifying, the latel specific date of +Date and time issued: +•IS/Henry Pitman +Judge sistinature +City and state: New York, NY +CONFIDENTA +LS: MagistraBY@M_00000234 + + + +AO93 (SDNY Rev. 01/17) Search and Scizure Warrant (Page 2) +| Date and time warrant executed: +Case No.: +Inventory made in the presence of : +Inventory of the property taken and name of any person(s) seized: +Copy of warrant and inventory left with: +Certification +I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant +to the Court. +Executing officer's signature + +SDNY_GM_00000235 + + + +I. Premises to be Searched Subject Premises +The premises to be searched (the "Subject Premises) are described as a multi-story +single-family residence located at 9 East 71st Street, New York, New York, and include all locked +and closed containers found therein. A photograph of the front entrance to the Subject Premises +is included below: +Google_ +II. Items to Be Seized +A. Evidence, Fruits, and Instrumentalities of the Subject Offenses +This warrant authorizes the seizure of certain evidence, fruits, and instrumentalities of +violations of Title 18, United States Code, Sections 1591 (sex trafficking of minors), and 371 (sex +trafficking conspiracy) (the "Subject Offenses") described as follows: +The items to be seized from the Subject Premises are any computer devices and storage +media that may contain any electronically stored information falling within the categories set forth +in Section B of this Attachment, including, but not limited to, desktop and laptop computers, disk +drives, modems, thumb drives, personal digital assistants, smart phones, digital cameras, scanners, +routers, modems, and network equipment used to connect to the Internet. In lieu of seizing any +such computer devices or storage media, this warrant also authorizes, in the alternative, the +copying of such devices or media for later review. +The items to be seized from the Subject Premises also include: + +SDNY_GM_00000236 + + + +1. +Any items or records needed to access the data stored on any seized or copied +computer devices or storage media, including but not limited to any physical keys, encryption +devices, or records of login credentials, passwords, private encryption keys, or similar information. +2. +Any items or records that may facilitate a forensic examination of the computer +devices or storage media, including any hardware or soflware manuals or other information +concerning the configuration of the seized or copied computer devices or storage media. +3. +Any evidence concerning the identities or locations of those persons with access to, +control over, or ownership of the seized or copied computer devices or storage media. +B. Search and Seizure of Electronically Stored Information +As set forth in Section A to this attachment, this warrant authorizes the search of the Subject +Premises for any computer devices and storage media that may contain any electronically stored +information falling within the categories set forth below: +Any documents or communications with or regarding victims or potential victims +of the Subject Offenses; +5. +Any photographs of victims or potential victims of the Subject Offenses; +Any nude, partially nude, or sexually suggestive photographs of individuals who +appear to be teenage girls, or younger; +7. +Records or other items that evidence ownership, control, or use of, or access to +devices, storage media, and related electronic equipment used to access, transmit, or store +information relating to the Subject Offenses, including, but not limited to, sales receipts, +warranties, bills for Internet access, handwritten notes, registry entries, configuration files, saved +usernames and passwords, user profiles, e-mail contacts, and photographs; +Any child erotica, defined as suggestive visual depictions of nude minors that do +not constitute child pornography as defined by 18 U.S.C. § 2256(8). +C. Review of EST +Law enforcement personnel (including, in addition to law enforcement officers and agents, +and depending on the nature of the EST and the status of the investigation and related proceedings, +attorneys for the government, attorney support staff, agency personnel assisting the government in +this investigation, and outside technical experts under government control) will create a forensic +image of the Subject Devices (if practicable) and review the ESI contained therein for information +responsive to the warrant, that is, for the materials specified in Section B of this Attachment. +In conducting this review, law enforcement personnel may use various techniques to +determine which files or other ESI contain evidence or fruits of the Subject Offenses. Such +techniques may include, for example: + +SDNY_GM_00000237 +EPTA_00114321 + + +• surveying directories or folders and the individual files they contain (analogous to +looking at the outside of a file cabinet for the markings it contains and opening a drawer +believed to contain pertinent files); +conducting a file-by-file review by "opening" or reading the first few "pages" of such +files in order to determine their precise contents (analogous to performing a cursory +examination of each document in a file cabinet to determine its relevance); +• "scanning" storage areas to discover and possibly recover recently deleted data or +deliberately hidden files; and +• performing electronic keyword searches through all electronic storage areas to +determine the existence and location of data potentially related to the subject matter of +the investigation; and +• reviewing metadata, system information, configuration files, registry data, and any +other information reflecting how, when, and by whom the computer was used. +Law enforcement personnel will make reasonable efforts to search only for files, +documents, or other electronically stored information within the categories identified in Section +IIA of this Attachment. However, law enforcement personnel are authorized to conduct a +complete review of all the ESI from seized devices or storage media if necessary to evaluate its +contents and to locate all data responsive to the warrant. +• Keyword searches alone are typically inadequate to detect all relevant data. For one thing, +keyword searches work only for text data, yet many typcs: of files, such as images and videos, do +not store data as searchable text. Moreover, even as to text data, there may be information properly +subject to seizure but that is not captured by a keyword search because the information does not + +SDNY_GM_00000238 diff --git a/vision-fixhub/ds10-01/f760e28c26804218c592f50d00ce234db5a129d6c5d1303af5245f08ac3a207d.receipt.json b/vision-fixhub/ds10-01/f760e28c26804218c592f50d00ce234db5a129d6c5d1303af5245f08ac3a207d.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..f4254dde76d197a60364d0675afb9ea770a4ef21 --- /dev/null +++ b/vision-fixhub/ds10-01/f760e28c26804218c592f50d00ce234db5a129d6c5d1303af5245f08ac3a207d.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -3269, + "dataset": "marble-joined", + "doc_id": "f760e28c26804218c592f50d00ce234db5a129d6c5d1303af5245f08ac3a207d", + "engine": "marble-apple-vision", + "event_count": 167, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "a347cc8f351cc9f1cbd5338fa774a7ede99daa8e3e25c7271a7b84c68c99a8fd", + "output_sha256": "157132f55d76d7c087df8fb710d4994a07f64f8d6740a0a6911ed425dc3f25bb", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds10-01/fcc00534b7b5fb2a5d684217fb519bdfc1a0cfa020cea4e7267ec43367b87541.md b/vision-fixhub/ds10-01/fcc00534b7b5fb2a5d684217fb519bdfc1a0cfa020cea4e7267ec43367b87541.md new file mode 100644 index 0000000000000000000000000000000000000000..b550ea8937c31059c0c60a99071b9c842b76b0ec --- /dev/null +++ b/vision-fixhub/ds10-01/fcc00534b7b5fb2a5d684217fb519bdfc1a0cfa020cea4e7267ec43367b87541.md @@ -0,0 +1,29 @@ +From: subpoena-criminal@amazon.com [mailto:subpoena-criminal@amazon.com] +Sent: Friday, January 31, 2020 7:22 PM +To: +(NY) (FBI) +Subject: Amazon Ref. No. CRIM1048721 2020 DS: Ghislaine Maxwell (External Case No. +2018R01618) +Certificate of Authenticity +1, Maureen Townsel, declare as follows: +1. Iam an employee of Amazon, Inc. ("Amazon"). I make this declaration based on +personal, firsthand knowledge and, if called and sworn as a witness, I could and would +testify as set forth below. +2. Amazon produced documents responsive to the above-referenced law enforcement +request. +3. All documents produced by Amazon are authentic, are what they purport to be, and +accurately describe the transactions, communications, and events set forth therein. +4. All documents produced by Amazon are business records in that they are (i) records +kept in the ordinary course of business; (i) created at or near the time of the transactions +or events reflected therein, or based on information from a person with knowledge of +the transaction or events; and (ili) kept as a part of a regular business activity. +I declare under penalty of perjury under the laws of the United States of America that the +foregoing is true and correct. +Executed on 1/31/2020, at Seattle, Washington. +Maureen Townsel +Law Enforcement Response Specialist +Amazon.com, Inc. +NOTICE: This communication might contain privileged and/or confidential information. If +communication in error and that you have deleted it. +SDNY_GM_00000972 + diff --git a/vision-fixhub/ds10-01/fcc00534b7b5fb2a5d684217fb519bdfc1a0cfa020cea4e7267ec43367b87541.receipt.json b/vision-fixhub/ds10-01/fcc00534b7b5fb2a5d684217fb519bdfc1a0cfa020cea4e7267ec43367b87541.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..d72d90df0481245b8333f4f6de18eef821873c79 --- /dev/null +++ b/vision-fixhub/ds10-01/fcc00534b7b5fb2a5d684217fb519bdfc1a0cfa020cea4e7267ec43367b87541.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -25, + "dataset": "marble-joined", + "doc_id": "fcc00534b7b5fb2a5d684217fb519bdfc1a0cfa020cea4e7267ec43367b87541", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "6a8a3943a09e4fc172e5500041680f47ab8a48d0096d398ef1d44d3a58855195", + "output_sha256": "05ec25d99bf846210a8cf21f9f13af200c6447216ca6a5e401d1e60193496602", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/02cec58b0a7452f6685978cd9ac2efcb1975130ab1f35601426b6f73c99cac38.md b/vision-fixhub/ds11-01/02cec58b0a7452f6685978cd9ac2efcb1975130ab1f35601426b6f73c99cac38.md new file mode 100644 index 0000000000000000000000000000000000000000..86c6586486b13ab15e12a1cc547235b605333b2e --- /dev/null +++ b/vision-fixhub/ds11-01/02cec58b0a7452f6685978cd9ac2efcb1975130ab1f35601426b6f73c99cac38.md @@ -0,0 +1,21 @@ +To: +Larry Visoski +From: +Sent: +Tue 5/9/2017 4:37:28 PM +Subject: Re: 301 +Checking! I think so +Sent from my iPhone +> On May 9, +2017, at 11:42 AM, Larry Visoski < +wrote: +> +> Hil +> Any chance for two apartments at Apt 301 for tonight and tomorrow? +> Me and my new pilot Chip,. +> IMK| +> Thx +> Larry +> +> Sent from my iPhone +EFTA_R1_00936308 diff --git a/vision-fixhub/ds11-01/02cec58b0a7452f6685978cd9ac2efcb1975130ab1f35601426b6f73c99cac38.receipt.json b/vision-fixhub/ds11-01/02cec58b0a7452f6685978cd9ac2efcb1975130ab1f35601426b6f73c99cac38.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..67ae7e760c704803a6781f4ad694ed6aec063c49 --- /dev/null +++ b/vision-fixhub/ds11-01/02cec58b0a7452f6685978cd9ac2efcb1975130ab1f35601426b6f73c99cac38.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "02cec58b0a7452f6685978cd9ac2efcb1975130ab1f35601426b6f73c99cac38", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "6676d7f5e8da7194407f495e496a9fdfc9af90285a32a57118a5987f97798004", + "output_sha256": "fa4d6085ad889f2f3cfaf78b791a7bf0a2119e8b01c4edb5635aab3e5e81e41b", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/06545d29c809fbc43b642949c69392b56e55122a216a8ae57ec545a6ceef90a0.md b/vision-fixhub/ds11-01/06545d29c809fbc43b642949c69392b56e55122a216a8ae57ec545a6ceef90a0.md new file mode 100644 index 0000000000000000000000000000000000000000..323cf4f6583c8c550b0c089f9b8136ee5ed9c001 --- /dev/null +++ b/vision-fixhub/ds11-01/06545d29c809fbc43b642949c69392b56e55122a216a8ae57ec545a6ceef90a0.md @@ -0,0 +1,29 @@ +To: +Jeffrey Epsteinjjeevacation@gmail.com] +From: +Lesley Groff +Sent: +Mon 5/8/2017 1:20:57 PM +Subject: Fwd: Two Additional Tickets for Peggy Siegal +FYI! +Sent from my iPhone +Begin forwarded message: +From: Gary Jaworski 4 +Date: May 8, 2017 at 9:18:37 AM EDT +To: Lila Walker < +Cc: +Subject: Re: Two Additional Tickets for Peggy Siegal +Hi. Yes. We'll have 2 tickets for them at the show. Starts at 7 pm at the DAVID +H. Koch Theater at Lincoln Center. Ends about 9 pm. Details about where to pick +up tickets will come later today. +Sent from my iPhone +On May 8, 2017, at 9:05 AM, Lila Walker 4 +wrote: +Dear Gary, +Could you please confirm that you were able to secure tickets for +If so, please let us know pick-up details and any other important info. +Lesley (CC'd) will relay this info to +Many thanks, +Lila +Sent from my iPhone +EFTA_R1_00936378 diff --git a/vision-fixhub/ds11-01/06545d29c809fbc43b642949c69392b56e55122a216a8ae57ec545a6ceef90a0.receipt.json b/vision-fixhub/ds11-01/06545d29c809fbc43b642949c69392b56e55122a216a8ae57ec545a6ceef90a0.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..5bc4ffc26c48192b4aadd55daefcd26539968b62 --- /dev/null +++ b/vision-fixhub/ds11-01/06545d29c809fbc43b642949c69392b56e55122a216a8ae57ec545a6ceef90a0.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "06545d29c809fbc43b642949c69392b56e55122a216a8ae57ec545a6ceef90a0", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "2b283a32ac5ee8ec7aa6e9b53c51685e627360c261732f87cab14ee4f6c30962", + "output_sha256": "343b052c7a2f52c5b5fede2705e9b5098eb6b5c172f2cca693885cd27ea2b5c1", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/0d60c2615aafbb22946b54731c03b304e99dafd7a1a8cee16095abd2654597f5.md b/vision-fixhub/ds11-01/0d60c2615aafbb22946b54731c03b304e99dafd7a1a8cee16095abd2654597f5.md new file mode 100644 index 0000000000000000000000000000000000000000..c34cc36967e10bc7ae2839a69004e2e9330aa91b --- /dev/null +++ b/vision-fixhub/ds11-01/0d60c2615aafbb22946b54731c03b304e99dafd7a1a8cee16095abd2654597f5.md @@ -0,0 +1,5 @@ +From: +Subject: +Alert - 1:00pm Appt w/Masha Drokova (Yury is her assistant +May 18, 2017 1:00 PM : 1:00pm Appt w/Masha Drokova (Yury is her assistant +EFTA_R1_00936415 diff --git a/vision-fixhub/ds11-01/0d60c2615aafbb22946b54731c03b304e99dafd7a1a8cee16095abd2654597f5.receipt.json b/vision-fixhub/ds11-01/0d60c2615aafbb22946b54731c03b304e99dafd7a1a8cee16095abd2654597f5.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..000118d6e8188c87c01d5c6bde30ebe06734076f --- /dev/null +++ b/vision-fixhub/ds11-01/0d60c2615aafbb22946b54731c03b304e99dafd7a1a8cee16095abd2654597f5.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "0d60c2615aafbb22946b54731c03b304e99dafd7a1a8cee16095abd2654597f5", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "b42e9d772f8a3ed3274274385c5a91abd7d77159fb7c04050ab0603810929ba5", + "output_sha256": "33185c788a71769ad514ae59627967d19a0c5985cdb573d90f90eee5e0a30531", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/12d39864e20d0af05a0e610f9fe40ca7858d94bc53d98f8a9669275e14843eb5.md b/vision-fixhub/ds11-01/12d39864e20d0af05a0e610f9fe40ca7858d94bc53d98f8a9669275e14843eb5.md new file mode 100644 index 0000000000000000000000000000000000000000..4c5f3de719efaba64cda1eab974c149db8e2eea9 --- /dev/null +++ b/vision-fixhub/ds11-01/12d39864e20d0af05a0e610f9fe40ca7858d94bc53d98f8a9669275e14843eb5.md @@ -0,0 +1,73 @@ +Amex Centurian Travell +From: +Lesley Groff +Sent: +Fri 5/19/2017 6:23:13 PM +Subject: Re: 3d party credit card authorization form +thanks +On May 19, 2017, at 2:18 PM, Natalia Molotkova +> wrote: +Regards, +Natalia (Natasha) Molotkova +Centurion Relationship Manager +Hours: Mon, Wed 9a-4p, 530p-7p +Tue, Thur, Fri 9a - 530p EST +For to pay reservation, you completing and emailing: +1- The letter form enclosed in this mail (5092,00 Moroccan Dirhams) +2- Hight resolution scanned copy of your credit card from both side. +3- Copy of the passeport of the credit card holder's +4- We accept Visa & Master Card +Cordially +FIKRI Youness +Service Réservation +EFTA_R1_00936398 + + +Hötel Kenzi Farah +Avenue du President KENNEDY|40 000 Marrakech +,% please consider the environment before printing this e-mail +De : Natalia X Molotova [L +Envoyé : vendredi 19 mai 2017 16:38 +Objet : 3d party credit card authorization form +Dear Yniss, +Will you be so kind to email me the 3d party credit card authorization form for confir +guest name is +I guaranteed her reservation with her boss's card, and he wants to pay for her stay. +Thank you, +Natalia (Natasha) Molotkova|Relationship Manager +American Express Centurion Servicing +Working hours: 9:00am-5:30pm Monday-Friday +Behind every great travel moment is a Journeymaker +EFTA_R1_00936399 + + +who helped make it happen. Journeymakers.com +American Express made the following annotations +"This message and any attachments are solely for the intended recipient and may contain confidential or p +the intended recipient, any disclosure, copying, use, or distribution of the information included in this mes +prohibited. If you have received this communication in error, please notify us by reply e-mail and immedia +message and any attachments. Thank you." +American Express a ajouté le commentaire suivant le +Ce courrier et toute pièce jointe qu'il contient sont réservés au seul destinataire indiqué et peuvent renferr +et privilégiés. Si vous n'êtes pas le destinataire prévu, toute divulgation, duplication, utilisation ou distrib +jointe est interdite. Si vous avez reçu cette communication par erreur, veuillez nous en aviser par courrier +courier et les pièces jointes. Merci. +American Express made the following annotations +"This message and any attachments are solely for the intended recipient and may contain confidential or priv +intended recipient, any disclosure, copying, use, or distribution of the information included in this message a +you have received this communication in error, please notify us by reply e-mail and immediately and permar +attachments. Thank you." +American Express a ajouté le commentaire suivant le +Ce courrier et toute pièce jointe qu'il contient sont réservés au seul destinataire indiqué et peuvent renfermel +privilégiés. Si vous n'êtes pas le destinataire prévu, toute divulgation, duplication, utilisation ou distribution d +interdite. Si vous avez reçu cette communication par erreur, veuillez nous en aviser par courrier et détruire ir +pièces jointes. Merci. +Privacy Statement | Visit the Centurion Card website +To learn more about e-mail security or report a suspicious e-mail, please visit us at americanexpress.com/phishing. +© 2015 American Express. All rights reserved +American Express uses 3rd party concierge service providers who are not authorized to act on behalf of American Express and you acknowledge that Amer +Express is in no way responsible or liable for the actions of the service provider and the only remedy for any claims relating to services or products provided +service provider is against the service provider and not against American Express. You are responsible for any purchases, shipping charges and/or fees you +authorize. We reserve the right to note profile and preference data for servicing purposes. + +EFTA_R1_00936400 diff --git a/vision-fixhub/ds11-01/12d39864e20d0af05a0e610f9fe40ca7858d94bc53d98f8a9669275e14843eb5.receipt.json b/vision-fixhub/ds11-01/12d39864e20d0af05a0e610f9fe40ca7858d94bc53d98f8a9669275e14843eb5.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..2cd0aecc2d4a6b8cd7c36af67f6c92133eed1e83 --- /dev/null +++ b/vision-fixhub/ds11-01/12d39864e20d0af05a0e610f9fe40ca7858d94bc53d98f8a9669275e14843eb5.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -36, + "dataset": "marble-joined", + "doc_id": "12d39864e20d0af05a0e610f9fe40ca7858d94bc53d98f8a9669275e14843eb5", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "d21fb5f27ba453afda0d2b9b7ca021fcd389ec9d25cc20903c44f545fb393e49", + "output_sha256": "3843ac9a55fbef7ec2659b82a32fd98da7aa7c10fe5112fd8be041dc151a8688", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/1aa6ea333d4c6fea16675556abcdf1501bce29c5454f3932fce9c5016120582e.md b/vision-fixhub/ds11-01/1aa6ea333d4c6fea16675556abcdf1501bce29c5454f3932fce9c5016120582e.md new file mode 100644 index 0000000000000000000000000000000000000000..004bf4aa04f25579771ef086e6ebbf6464dcc690 --- /dev/null +++ b/vision-fixhub/ds11-01/1aa6ea333d4c6fea16675556abcdf1501bce29c5454f3932fce9c5016120582e.md @@ -0,0 +1,15 @@ +To: +Jeffrey Epstein| +Cc: +merwin dela cruz +McCorquodal +¡ Marites (Tess) +I: Jojo Fontanillal +From: +Lesley Groff +Sent: +Tue 5/30/2017 12:06:52 PM +Subject: Matthew Hiltzik +Matthew Hiltzik will come see you Thursday at 4:15. +Sent from my iphone +EFTA_R1_00936336 diff --git a/vision-fixhub/ds11-01/1aa6ea333d4c6fea16675556abcdf1501bce29c5454f3932fce9c5016120582e.receipt.json b/vision-fixhub/ds11-01/1aa6ea333d4c6fea16675556abcdf1501bce29c5454f3932fce9c5016120582e.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..2e7b1d02ae1dc14c6398d744a4350e0585d448f4 --- /dev/null +++ b/vision-fixhub/ds11-01/1aa6ea333d4c6fea16675556abcdf1501bce29c5454f3932fce9c5016120582e.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "1aa6ea333d4c6fea16675556abcdf1501bce29c5454f3932fce9c5016120582e", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "7ade7c84edba8766141898b429949ee7c74229b7b6059c6f615f2309b85e826d", + "output_sha256": "4a37d526764abdf688b8eda93ee03676d56696bbb2f5076ac185bd630fa796d9", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/1b1eceb0d4726d659dc2c77fb81d140fc15a9b359145d3b06f1694c4bed68ade.md b/vision-fixhub/ds11-01/1b1eceb0d4726d659dc2c77fb81d140fc15a9b359145d3b06f1694c4bed68ade.md new file mode 100644 index 0000000000000000000000000000000000000000..90982deb77f63584ee2d877de92059dbc3f0e22d --- /dev/null +++ b/vision-fixhub/ds11-01/1b1eceb0d4726d659dc2c77fb81d140fc15a9b359145d3b06f1694c4bed68ade.md @@ -0,0 +1,11 @@ +To: +From: +Sent: +Thur 5/18/2017 11:54:52 AM +Subject: Jeffrey Epstein +MorningFaith!! Jeffrey is in N Y and asking if you can +after work hours? What is good for you? +see him!? +Maybe +Sent from my iPhone +EFTA_R1_00936343 diff --git a/vision-fixhub/ds11-01/1b1eceb0d4726d659dc2c77fb81d140fc15a9b359145d3b06f1694c4bed68ade.receipt.json b/vision-fixhub/ds11-01/1b1eceb0d4726d659dc2c77fb81d140fc15a9b359145d3b06f1694c4bed68ade.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..622e2a74b1c974652ddd6f461811eea7de98f609 --- /dev/null +++ b/vision-fixhub/ds11-01/1b1eceb0d4726d659dc2c77fb81d140fc15a9b359145d3b06f1694c4bed68ade.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "1b1eceb0d4726d659dc2c77fb81d140fc15a9b359145d3b06f1694c4bed68ade", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "8a00f48ba88a8a48df28a065f4e7fab745fced4a35c47043534cd7371f455cbd", + "output_sha256": "9c251f4491575c12a1eee37ad2fdb0c7ec955e0432c496445cefef9f80fb7291", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/2cf97cebcf2ef6d117aa704e338440a7d026ba3af240904ca027b621ce1eb550.md b/vision-fixhub/ds11-01/2cf97cebcf2ef6d117aa704e338440a7d026ba3af240904ca027b621ce1eb550.md new file mode 100644 index 0000000000000000000000000000000000000000..180eb4cc293ad32b6026af9894d05e1d3f3130db --- /dev/null +++ b/vision-fixhub/ds11-01/2cf97cebcf2ef6d117aa704e338440a7d026ba3af240904ca027b621ce1eb550.md @@ -0,0 +1,34 @@ +To: +Peggy Siegall +Cc: +Peggy Siegall +From: +Sent: +Sat 5/6/2017 9:09:08 PM +Subject: +Re: Jeffrey Epstein +ok Peggy. Totally understand. Do keep me posted if you are able to get tix for +show. +Sent from my iPhone +> On May 6, 2017, at 5:02 PM, Peggy Siegal +> +wrote: +> I have two tables. Both are filled with 12 at each. I mixed the 12 tickets I +12 tickets Jeffrey underwrote. I can not take those tables apart at +tees ate date To Yearer the tone seated to the pose stone st +> I will call Lincoln Center and see if I can get two more tickets. The show will +probably be doable. I don't know about the seated dinner...I will try. +> Back to you asap. +> XOXO Peggy +Original Message +> From: +Sent: Saturday, May 6, 2017 4:09 PM +To: Peggy Siegal +Cc: Peggy Siegal +Subject: Jeffrey Epstein +> Hi Peggy. Jeffrey is asking if you might have 2 extra tickets to your event +tomorrow night...and if so, could we please give them to his 2 assistants. +> Please let me know! +> Thanks, +> Sent from my iPhone +EFTA_R1_00936351 diff --git a/vision-fixhub/ds11-01/2cf97cebcf2ef6d117aa704e338440a7d026ba3af240904ca027b621ce1eb550.receipt.json b/vision-fixhub/ds11-01/2cf97cebcf2ef6d117aa704e338440a7d026ba3af240904ca027b621ce1eb550.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..f2351a3771087b0956dca0fc0db293521e6d8c3e --- /dev/null +++ b/vision-fixhub/ds11-01/2cf97cebcf2ef6d117aa704e338440a7d026ba3af240904ca027b621ce1eb550.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "2cf97cebcf2ef6d117aa704e338440a7d026ba3af240904ca027b621ce1eb550", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "63dc777b7c4e89a3119a47889845e6e96ec6bc9d8734fa2a0a4dfd8f6a6187fd", + "output_sha256": "f8ba03950d58fb9204411b0c761ef1842e8b49d47b4347d23bce5170196eca76", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/32a8c2f1ffc864059b6348bccfb2319ffef21e178fe66b6465802e15c198d1b4.md b/vision-fixhub/ds11-01/32a8c2f1ffc864059b6348bccfb2319ffef21e178fe66b6465802e15c198d1b4.md new file mode 100644 index 0000000000000000000000000000000000000000..e4ec0651a3f475ece2e04e6e99c3056f1a95ae39 --- /dev/null +++ b/vision-fixhub/ds11-01/32a8c2f1ffc864059b6348bccfb2319ffef21e178fe66b6465802e15c198d1b4.md @@ -0,0 +1,50 @@ +To: +Larry Visoski Larryl +From: +Sent: +Thur 4/6/2017 1:14:59 PM +Subject: Re: Airline +welcome... +> On Apr 6, 2017, at 9:13 AM, Larry Visoski +wrote: +> +> Many many thx !!!! +> +> Sent from my iPhone +> +>> On Apr 6, 2017, at 2:11 PM, +wrote: +>> +>> done..canceled other flight I booked last night +>> +>>> On Apr 6, 2017, at 8:48 AM, Larry Visoski +wrote: +>>> +>>> I heard Easyjet has a 7:30pm departure to Marrakesh- CDG,, +>>> +>>> 4:10pm +>>> Transavia, Airlines +›>> Also to Marrakesh- Orly +>>> +>>> Sent from my iPhone +>>> +>>>> On Apr 6, 2017, at 1:45 PM, +wrote: +>>>> +>>>> Ha. Too funny, This is latest flight in. A real airline. I don't know if +chey have little airlines there? +»>>> +>>>> +Sent from my iPhone +>>>> +>>>>> On Apr 6, 2017, +at 8:43 AM, Larry Visoski +wrote: +>>>>>1 +>>>>> Can you book a ticket for Daddi to Paris from Marrakesh?? Tonight? +>>>>> Can you help22? +>>>>> +>>>>> Sent from my iPhone +>>> +> +EFTA_R1_00928880 \ No newline at end of file diff --git a/vision-fixhub/ds11-01/32a8c2f1ffc864059b6348bccfb2319ffef21e178fe66b6465802e15c198d1b4.receipt.json b/vision-fixhub/ds11-01/32a8c2f1ffc864059b6348bccfb2319ffef21e178fe66b6465802e15c198d1b4.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..170581b593ee29df98682eb89d5b15ef3adaafad --- /dev/null +++ b/vision-fixhub/ds11-01/32a8c2f1ffc864059b6348bccfb2319ffef21e178fe66b6465802e15c198d1b4.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": 0, + "dataset": "marble-joined", + "doc_id": "32a8c2f1ffc864059b6348bccfb2319ffef21e178fe66b6465802e15c198d1b4", + "engine": "marble-apple-vision", + "event_count": 0, + "fix_ids": "[]", + "idempotent": true, + "input_sha256": "dace356e8e6749247a6ec72b0636eedcd9c1c1ddecad32649c6182fd9b3180e4", + "output_sha256": "dace356e8e6749247a6ec72b0636eedcd9c1c1ddecad32649c6182fd9b3180e4", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/32c1828acc69bd4d24041620d7fe9d29f853d06b8fceea633dc279e46e9e9b87.md b/vision-fixhub/ds11-01/32c1828acc69bd4d24041620d7fe9d29f853d06b8fceea633dc279e46e9e9b87.md new file mode 100644 index 0000000000000000000000000000000000000000..ade0f5366605abca5b6cc75ed697785050ef36fd --- /dev/null +++ b/vision-fixhub/ds11-01/32c1828acc69bd4d24041620d7fe9d29f853d06b8fceea633dc279e46e9e9b87.md @@ -0,0 +1,7 @@ +From: +Subject: +Alert - car for +April 27, 2017 6:30 AM : car for l +to go to airport tomorrow or Jojo? rec loc#BJCFSS +Ito go to airport tomorrow or Jojo? rec loc#BJCFSS +EFTA_R1_00936304 diff --git a/vision-fixhub/ds11-01/32c1828acc69bd4d24041620d7fe9d29f853d06b8fceea633dc279e46e9e9b87.receipt.json b/vision-fixhub/ds11-01/32c1828acc69bd4d24041620d7fe9d29f853d06b8fceea633dc279e46e9e9b87.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..b6bc2b5073ba35aff23f5e362216bb3c2c3f00f9 --- /dev/null +++ b/vision-fixhub/ds11-01/32c1828acc69bd4d24041620d7fe9d29f853d06b8fceea633dc279e46e9e9b87.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "32c1828acc69bd4d24041620d7fe9d29f853d06b8fceea633dc279e46e9e9b87", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "91fb5f100751922de66bb5534e27c9078b46b1dd0cec14ac664b2acd633d0e82", + "output_sha256": "997c8c221f41939d55f71e4185761a320557b44372bdc6653dd311869309a97e", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/3423efede5561fddb4276fa3ef1b79adc25767df579c5e1cf12553d858c47453.md b/vision-fixhub/ds11-01/3423efede5561fddb4276fa3ef1b79adc25767df579c5e1cf12553d858c47453.md new file mode 100644 index 0000000000000000000000000000000000000000..1cd2379219f2e102301b210a937cac80db536058 --- /dev/null +++ b/vision-fixhub/ds11-01/3423efede5561fddb4276fa3ef1b79adc25767df579c5e1cf12553d858c47453.md @@ -0,0 +1,75 @@ +To: +From: +Natalia Molotkova +Sent: +Wed 5/24/2017 2:25:35 PM +Subject: Karyna's flights to France +Title: American Express ® +OK, please let me know. +Regards, +Natalia (Natasha) Molotkova +Centurion Relationship Manager +(877) 877-0987 +Hours: Mon, Wed ga-4p, 530p-7p +Tue, Thur, Fri 9a - 530p EST +Not yet. I emailed her this morning to let me know once she is done. Th however! Later today or +latest tomorrow to cancel +Sent from my iPhone +On May 24, 2017, at 10:17 AM, Natalia Molotkova +wrote: +Ok to cancel her flights to France and hotel? Did she have her visa appointments already? +Regards, +Natalia (Natasha) Molotkova +Centurion Relationship Manager +(877) 877-0987 +Hours: Mon, Wed 9a-4p, 530p-7p +Tue, Thur, Fri 9a - 530p EST +Good. +Regards, +Natalia (Natasha) Molotkova +Centurion Relationship Manager +EFTA_R1_00936449 + +(877) 877-0987 +Hours: Mon, Wed 9a-4p, 530p-7p +Tue, Thur, Fri 9a - 530p EST +That's it. You have Correct flight is the sat May 27 departing 9am arriving 1:02! Th +Sent from my iPhone +On May 24, 2017, at 10:04 AM, Natalia Molotkova < +wrote: +Thanks +Sent from my iPhone +On May 24, 2017, at 10:00 AM, Natalia Molotkova +• wrote: +Record locator LGPRDG flights is +DL 465 27MAY JFK STT 900A 102P +Record locator AEPGSL +B62903 26MAY JFK SJU 800A 1158A +B65762 26MAY SJU STT 200P 235P +Was voided. +Any other records out there? +Regards, +Natalia (Natasha) Molotkova +Centurion Relationship Manager +(877) 877-0987 +Hours: Mon, Wed 9a-4p, 530p-7p +Tue, Thur, Fri 9a - 530p EST +Will do today. +Regards, +EFTA_R1_00936450 + +Natalia (Natasha) Molotkova +Centurion Relationship Manager +(877) 877-0987 +Hours: Mon, Wed 9a-4p, 530p-7p +Tue, Thur, Fri 9a - 530p EST +Hi Natasha...! just want to make sure we have cancelled the flights we had booked for Karyna to +go from NY to STT on Thurs. and on Fri. She will for sure take the Sat. flight at 1:02 pm on Delta +#465 (Rec. Loc. LGPRDG) | believe we DID cancel the other 2 but just want to make double +sure...thanks! +Privacy Statement | Visit the Centurion Card website +To learn more about e-mail security or report a suspicious e-mail, please visit us at americanexpress.com/phishing- +© 2015 American Express. All rights reserved +American Express uses 3rd party concierge service providers who are not authorized to act on behalf of American Express +reserve the right to note profile and preference data for servicing purposes. +EFTA_R1_00936451 diff --git a/vision-fixhub/ds11-01/3423efede5561fddb4276fa3ef1b79adc25767df579c5e1cf12553d858c47453.receipt.json b/vision-fixhub/ds11-01/3423efede5561fddb4276fa3ef1b79adc25767df579c5e1cf12553d858c47453.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..55348b2dcc6dbf62f03fc5f37157d624dbb4110c --- /dev/null +++ b/vision-fixhub/ds11-01/3423efede5561fddb4276fa3ef1b79adc25767df579c5e1cf12553d858c47453.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "3423efede5561fddb4276fa3ef1b79adc25767df579c5e1cf12553d858c47453", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "6d4f7bf9c2c3f9d41e6f346a228aa29591478742af44ca6591c70a0f109a55ae", + "output_sha256": "3ab3ad3d5ad48088db5bbaab22cb2a81e8a53c49a01c6494a478390f8dd73c52", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/36cf352734b5ecd4a43b2ac5d7717f279bc1c3d36f840f4029133ec1039f2fae.md b/vision-fixhub/ds11-01/36cf352734b5ecd4a43b2ac5d7717f279bc1c3d36f840f4029133ec1039f2fae.md new file mode 100644 index 0000000000000000000000000000000000000000..e596a3223a4771b0c8f94c8dff712c5c177c3933 --- /dev/null +++ b/vision-fixhub/ds11-01/36cf352734b5ecd4a43b2ac5d7717f279bc1c3d36f840f4029133ec1039f2fae.md @@ -0,0 +1,14 @@ +To: +From: +Sent: +Tue 5/16/2017 2:13:52 PM +Subject: +Re: +thanks. +May 16th: departing VKO 11:55pm arriving St.. Petersburg at 1:25am( Layover is 4 H 40 M) +Depart St. Petersburg 8:35am arrive CDG 3:30pm +May 17th: Depart CDG 6:10pm arrive SVO (not +On May 16, 2017, at 10:05 AM, +Dubovskaia Svetlana +> wrote: +EFTA_R1_00936463 diff --git a/vision-fixhub/ds11-01/36cf352734b5ecd4a43b2ac5d7717f279bc1c3d36f840f4029133ec1039f2fae.receipt.json b/vision-fixhub/ds11-01/36cf352734b5ecd4a43b2ac5d7717f279bc1c3d36f840f4029133ec1039f2fae.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..23d541c7bd3dbe75c32d1fe026bfd96194edd1a5 --- /dev/null +++ b/vision-fixhub/ds11-01/36cf352734b5ecd4a43b2ac5d7717f279bc1c3d36f840f4029133ec1039f2fae.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "36cf352734b5ecd4a43b2ac5d7717f279bc1c3d36f840f4029133ec1039f2fae", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "79cf0dbcd7749206c111270156ed19af3b888a82364ff9b66a6ce98ca8f089db", + "output_sha256": "bac3e99b12decc2503fb27a578fd1763898f5f555df7c339a872fae5360e870e", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/3985581f049cb6d0326205eec46d056ce9aa2ab517430b420417e3606d4e6771.md b/vision-fixhub/ds11-01/3985581f049cb6d0326205eec46d056ce9aa2ab517430b420417e3606d4e6771.md new file mode 100644 index 0000000000000000000000000000000000000000..2e2d9be72bb66cf986bc11b7d20ef6ba9b7ec606 --- /dev/null +++ b/vision-fixhub/ds11-01/3985581f049cb6d0326205eec46d056ce9aa2ab517430b420417e3606d4e6771.md @@ -0,0 +1,50 @@ +To: +Lesley Grof +From: +Sent: +Mon 5/15/2017 6:54:12 PM +Subject: RE: Jeffrey Epstein +Dear Lesley, +We have 1 ticket for hopefully seated. It will be under her name so when she arrives at the Front +Counter she needs to get her ticket there. +Best wishes, +From: Lesley Groff [ +Sent: Monday, May 15, 2017 2:36 PM +To: +Subject: Re: Jeffrey Epstein +ok super! +On May 15, 2017, at 2:35 PM, +wrote: +Let me look into this now...I don't think we have any seats left but at least I can +try for a standing ticket +----Original Message- +From: Lesley Groff +Sent: Monday, May 15, 2017 2:31 PN +To: | +Subject: Jeffrey Epstein +Hello +...Jeffrey would like +you please rey we ul the is ...o make sure sto the tend (rion to ire hoar +put it! +Please let me know if she needs to bring ID or how this works... +EFTA_R1_00936486 + + +Thank you! +Lesley +Visit www.christies.com to explore special multi-media sale promotions, browse our +illustrated catalogues and leave absentee bids through LotFinder(R), Christie's +online search engine, and register for Internet bidding with Christie's Live(TM). +This message and any attachment are confidential. If you are not the intended recipient, +please telephone or email the sender and delete the message and any attachment +from your system. If you are not the intended recipient you must not copy this +message or attachment or disclose the contents to any other person. +---------- +Visit www.christies.com to explore special multi-media sale promotions, browse our illustrated +catalogues and leave absentee bids through LotFinder(R), Christie's online search engine, and +register for Internet bidding with Christie's Live(TM). +This message and any attachment are confidential. If you are not the intended recipient, please +elephone or email the sender and delete the message and any attachment from your system. It +rou are not the intended recipient you must not copy this message or attachment or disclose th +contents to any other person. +EFTA_R1_00936487 diff --git a/vision-fixhub/ds11-01/3985581f049cb6d0326205eec46d056ce9aa2ab517430b420417e3606d4e6771.receipt.json b/vision-fixhub/ds11-01/3985581f049cb6d0326205eec46d056ce9aa2ab517430b420417e3606d4e6771.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..8601c26f4cedec50a6d78837fedbff3d718fcafe --- /dev/null +++ b/vision-fixhub/ds11-01/3985581f049cb6d0326205eec46d056ce9aa2ab517430b420417e3606d4e6771.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "3985581f049cb6d0326205eec46d056ce9aa2ab517430b420417e3606d4e6771", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "8879b42e41e1bb6afc30e99c612924b952291d9ca66dad382f4080e2ff4ef021", + "output_sha256": "a536a48850020c68e576a3a04b84d962a73e5a5cb24c3391deca510307eede91", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/3b56405b339e7da30891df3c29648e9877e92aa71cbdc7002559449a0af0790f.md b/vision-fixhub/ds11-01/3b56405b339e7da30891df3c29648e9877e92aa71cbdc7002559449a0af0790f.md new file mode 100644 index 0000000000000000000000000000000000000000..952e46625f7b7a6e9e4e17ae2f235cafec523e00 --- /dev/null +++ b/vision-fixhub/ds11-01/3b56405b339e7da30891df3c29648e9877e92aa71cbdc7002559449a0af0790f.md @@ -0,0 +1,10 @@ +To: +From: +Sent: +Thur 5/18/2017 11:57:36 AM +Subject: Jeffrey Epstein +Morning Paul. Might you be available tomorrow, Friday, to come see Jeffrey? Is +after the close best? Like 5:30? +Lesley +Sent from my iPhone +EFTA_R1_00936488 diff --git a/vision-fixhub/ds11-01/3b56405b339e7da30891df3c29648e9877e92aa71cbdc7002559449a0af0790f.receipt.json b/vision-fixhub/ds11-01/3b56405b339e7da30891df3c29648e9877e92aa71cbdc7002559449a0af0790f.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..5d9d5eae3b68de5f2327277896b788d9cc9e9e50 --- /dev/null +++ b/vision-fixhub/ds11-01/3b56405b339e7da30891df3c29648e9877e92aa71cbdc7002559449a0af0790f.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "3b56405b339e7da30891df3c29648e9877e92aa71cbdc7002559449a0af0790f", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "be7f3960012d7d4887643b57089ff2570761a001a683655c14d5b53fb245e680", + "output_sha256": "9eb5b18de990f8c3de452c252cde118cf3e2d13b1e3b81a710afe4bd3726d47e", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/3cb8ba0d0ca4a2d4bf7ec7b01f300488f5d64cf08373c5633a6832b85b87c441.md b/vision-fixhub/ds11-01/3cb8ba0d0ca4a2d4bf7ec7b01f300488f5d64cf08373c5633a6832b85b87c441.md new file mode 100644 index 0000000000000000000000000000000000000000..49c5f4275f3ce7fade4f9445fe67dc51e4c2edad --- /dev/null +++ b/vision-fixhub/ds11-01/3cb8ba0d0ca4a2d4bf7ec7b01f300488f5d64cf08373c5633a6832b85b87c441.md @@ -0,0 +1,65 @@ +To: +Lesley Groff +From: +Oliver Lloyd +Sent: +Wed 5/3/2017 12:42:47 PM +Subject: Re: Jeffrey Epstein/Michael Wolff +Dear +We look for ward to speaking with Jeffery shortly. +Please be advised that in addition to myself, Sir Nicholas Lloyd (Chairman) and John Watts +BLJDirector and former senior adviser to Prime Minister Blair) will be on the cal +Ve are here to help and all matters will be handled with strictest confidenc +Kind regards, +Oliver +On 2 May 2017, at 16:15, Lesley Groff +wrote: +Great! I will have Jeffrey give you a call tomorrow ... appreciate it... +On May 2, 2017, at 10:58 AM, Oliver Lloyd wrote: +Fantastic! I am not positive what time zone you are +in.. we are EST... does tomorrow at 9am EST work for +you? Please advise a number Jeffrey should call you on +as well... +Thank you! +On May 2, 2017, at 10:23 AM, Oliver Lloyd +> wrote: +Dear +Thank you for your emails. Apologies for the slight delay, I was in the +air for much of the interim. +EFTA_R1_00936431 + + +I would be delighted to chat with Jeffrey at his convenience. Please let +me know what times suit him best +either tomorrow or Thursday and I will make +one of them work. +Kind regards, +Oliver +Sent from my iPhone +On 2 May 2017, at 14:54 +wrote: +Hello Ollie... just following up +Begin forwarded +message: +subject. Jenrey +Epstein +Date: May 1, +2017 at 11:49:36 +AM EDT +To: Oliver Lloyd +what day/time +would be +convenient for you. +EFTA_R1_00936432 + + +Thanks so much, +EFTA_R1_00936433 diff --git a/vision-fixhub/ds11-01/3cb8ba0d0ca4a2d4bf7ec7b01f300488f5d64cf08373c5633a6832b85b87c441.receipt.json b/vision-fixhub/ds11-01/3cb8ba0d0ca4a2d4bf7ec7b01f300488f5d64cf08373c5633a6832b85b87c441.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..08a08f2816b88ffff55297292de8e4a47c44a5c6 --- /dev/null +++ b/vision-fixhub/ds11-01/3cb8ba0d0ca4a2d4bf7ec7b01f300488f5d64cf08373c5633a6832b85b87c441.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -36, + "dataset": "marble-joined", + "doc_id": "3cb8ba0d0ca4a2d4bf7ec7b01f300488f5d64cf08373c5633a6832b85b87c441", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "454f5ce53320ccaf81ae8ba905e8862227bd49d03b94a440b799047d348f5103", + "output_sha256": "6c6144cd09399151861a4d93f8a7f631f95cd39211aa7a458a347077bce8df56", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/42426d49c196ac089ee3aea5a45c8a5a0898e6427a5b800d8d7e3247eea6e451.md b/vision-fixhub/ds11-01/42426d49c196ac089ee3aea5a45c8a5a0898e6427a5b800d8d7e3247eea6e451.md new file mode 100644 index 0000000000000000000000000000000000000000..44137525737f4d77ea1195e72e3b287cde9aaa3c --- /dev/null +++ b/vision-fixhub/ds11-01/42426d49c196ac089ee3aea5a45c8a5a0898e6427a5b800d8d7e3247eea6e451.md @@ -0,0 +1,290 @@ +To: +From: +Blair Hildebrand +Sent: +Thur 5/18/2017 6:42:52 PM +Subject: RE: G550 +Ok, take a look at the panel in the natural sun light if possible, it's a very nice colour. +Blair Hildebrand +Sales Manager +New United Goderich Inc. +From:_ +Sent: May-18-17 2:05 PM +To: Larry Visoski Larry +Cc: Blair Hildebrand +Subject: Re: G550 +ha! I figured! I checked on the Fed Ex...it is promised tomorrow, Friday, by 10:30am! +On May 18, 2017, at 2:01 PM, Larry Visoski < +Prote: +Blair +Will it delivered FedEx P1 Saturday tomorrow morning? Thanks Larry +Sent from my iPhone +On May 18, 2017, at 12:58 PM, Blair Hildebrand 4 +• wrote: +Here is the new tracking # for the test panel for part # ( PPG code LR5W +EFTA_R1_00936357 + + +) 2008 to current Bentley dark Sapphire. Also showed a code + +Your tracking number: 779172758591 +Your pickup confirmation number: YXUA133 +regards +Blair Hildebrand +Sales Manager +New United Goderich Inc. +From: +Sent: May-08-17 1:21 PM +To: Blair Hildebrand +Cc: Larry Visoski Larry +Subject: Re: G550 +Super! Thank you! +Sent from my iPhone +On May 8, 2017, at 1:16 PM, Blair Hildebrand +wrote: +EFTA_R1_00936358 + + +Yes it was sent out FED X this morning, here is the info. +:Tracking number 779083381560 +Your pickup confirmation number: YXUA132 +Blair Hildebrand +Sales Manager +New United Goderich Inc. +www.newunitedgoderich.com +Sent: May-08-17 12:37PM +To: Blair Hildebrand +Cc: Larry Visoski Larry +Subject: Re: G550 +paint sample has arrived! Any chance the other paint samples could be sent +out today? Jeffrey will be in NY tomorrow but leaves +again on Wed... just thought I would ask! +On May 5, 2017, at 4:46 PM, Blair +Hildebrand +wrote: +I will also be sending more paint samples on +Tuesday as I found some more colours that +maybe a better solution +EFTA_R1_00936359 + + +Blair Hildebrand +Sales Manager +New United Goderich Inc. +www.newunitedgoderich.com +Sent: May-05-17 2:45 PM +To: Blair Hildebrand +Cc: Larry Visoski Larry +Subject: Re: G550 +HI Blair...just checking in ....was the Fed Ex sent out as of yet? +On May 4, 2017, at 9:40 AM, +Blair Hildebrand +wrote! +OK I will forward to you once I +receive +Thank you +Sent from my BlackBerry 10 sm +artphone on the TELUS network +EFTA_R1_00936360 + + +Fr +Sent: Thursday, May 4, 2017 9:36 AM +To: Larry Visoski Larry; Blair Hildebrand +Subject: Re: G550 +Hi Blair, 1 am Jeffrey Epstein's assistant, +..once you have the tracking number for this +package can you please forward it to me? I want to make sure the houseman keeps his eye out for +it! thank you! +On May 3, 2017, at +10:44 PM, Larry +wrote: +Great,. Blair,. I'll have +you fwd the paint +sample to my boss's +office,. See address +below,. Could you mark +for Saturday delivery? +Thx +Larry +Can you Fedex to +Jeffrey Epstein +C/o Paint sample +9 East 71st +NY NY 10021 +Fedex # 114420816 +EFTA_R1_00936361 + + +Sent from my iPad +On May 3, 2017, at 9:34 PM, Blair Hildebrand +Larry, +Can you +confirm +your +mailing +address +for the +paint +sample +that +you +have +request +ed, we +will +ship out +to you +ОП +Friday. +Thank +you +Blair +Hildebr +and +Sales +Manag +er +New +United +Goderic +h Inc +EFTA_R1_00936362 + + +www.ne +wunited +goderich +.com +From: +Larry +Sent: April-25-17 4:35 PM +To: Blair Hildebrand +Subject: Re: G550 +Blair,,. +Can you provide a paint sample for me,. 8x11 would +fine? +I'll pay for it, "Midnight BLUE PEARL from PPG +color +chart: +Color code is: PPG Aerospace Color Chart. +Code: AL6013 or it's A16013 +(after the A it's either a 1 or an L). +called "Midnight Blue Pearl" +If you +don't +spray +PPG +paint,. +If you +EFTA_R1_00936363 + + +t +be +is +Plan D, +LLC +Sent +from +my +iPad +On Apr +25, +2017, +at 3:50 +PM, +Blair +Hildebr +and +wrote: +EFTA_R1_00936364 + + +I have requested a quote from our avionics +department and will forward to you once ! +receive from them +Thank you +Blair Hildebrand +Sales Manager +New United Goderich Inc. +www.newunitedgoderich.com +From: Larry Visoski [I +Sent: April-25-17 11:10 AN +To: Blair Hildebrand +c: Andrew Hamblir +ubject: Re: G55 +Very attractive price Blair,. +1-Can you confirm you follow the +GAMPS4000 criteria +2-can your avionics shop provide a quick +quote, I currently have Airshow4000 installed, +I understand there is a software upgrade to +revision II,, can you provide a price for this +also? +Thx +Larry +EFTA_R1_00936365 + + +Sent from my iPhone +On Apr 25, 2017, at 10:39 AM, Blair +Hildebrand +wrote: +Good morning Larry, here are the quotes +that you requested for the G550 Exterior +paint. There is a difference of 10k due to +the metallic colour. I hope you find the +prices to be competitive as I know +Gulfstream is very expensive and would be +extremely higher. We produce the same +quality with much lower prices. +We are also a one stop shop and do +Interior, Avionics and major Mod's, in the +future if vour require any of these services +please consider us for future work. If you +have any question please feel free to +contact me +Thank you +Blair Hildebrand +Sales Manager +New United Goderich Inc. +www.newunitedgoderich.com +From: Larry Visoski +Sent: April-24-17 5:13 PM +To: Blair Hildebrand +Subject: G550 +EFTA_R1_00936366 + + +Hello Blair,. +Nice speaking with you, attached is a +rendering portrayed in gray, however +my boss has decided to go with a dark +blue solid or a Dark blue metal flake,. +The engines may be a slightly lighter +shade of blue,. +No Gear or wheel well paint needed,, +Can you quote two prices? +1-Dark Metallic Blue +2-Solid Dark Blue,, +Input Date May 24th area., +ompany Name +lan D. LLO +6100 Red Hook quarters B3 +St Thomas USVI 00802 +Larry Visoski +Manager, +Airport office / mailing address; +Plan D, LLC +800 Southern Blvd., suite 20 +Vest Palm Beach, FL 3340 +c/o Larry Visoski + +Sent from my iPhone +Sent from my iPhone +<2017-0052 Strip & Paint Quotation +May 2017BH.pdf> +<2017-0053 Strip & Paint Quotation +May 2017BH.pdf> +EFTA_R1_00936367 diff --git a/vision-fixhub/ds11-01/42426d49c196ac089ee3aea5a45c8a5a0898e6427a5b800d8d7e3247eea6e451.receipt.json b/vision-fixhub/ds11-01/42426d49c196ac089ee3aea5a45c8a5a0898e6427a5b800d8d7e3247eea6e451.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..036099975aa94dc1321ce90b811cb96f3b55a553 --- /dev/null +++ b/vision-fixhub/ds11-01/42426d49c196ac089ee3aea5a45c8a5a0898e6427a5b800d8d7e3247eea6e451.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -139, + "dataset": "marble-joined", + "doc_id": "42426d49c196ac089ee3aea5a45c8a5a0898e6427a5b800d8d7e3247eea6e451", + "engine": "marble-apple-vision", + "event_count": 12, + "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "a574a87f8a7635343451d75dd42dea30c172fa7e5c495ffb9c038413a84334ee", + "output_sha256": "c097e8225ab5d4cd59a7c1bafa32e91348631183732582b8529451886ab7e612", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/4d8a4d5e3a88e3c60ac4508492a4d57c82a7b11bbd9f1d48a7514fa9bf212723.md b/vision-fixhub/ds11-01/4d8a4d5e3a88e3c60ac4508492a4d57c82a7b11bbd9f1d48a7514fa9bf212723.md new file mode 100644 index 0000000000000000000000000000000000000000..23f1bb7e56f74eaf30f3f45868e3f35c2e092d2d --- /dev/null +++ b/vision-fixhub/ds11-01/4d8a4d5e3a88e3c60ac4508492a4d57c82a7b11bbd9f1d48a7514fa9bf212723.md @@ -0,0 +1,12 @@ +To: +Larry Visosk +From: +Sent: +Fri 5/5/2017 7:27:06 PM +Subject: Weather reports PB & Paris +Hi Larry. Jeffrey would like a weather report for Paris +Sent from my iphone +and +PB +please! +EFTA_R1_00936477 diff --git a/vision-fixhub/ds11-01/4d8a4d5e3a88e3c60ac4508492a4d57c82a7b11bbd9f1d48a7514fa9bf212723.receipt.json b/vision-fixhub/ds11-01/4d8a4d5e3a88e3c60ac4508492a4d57c82a7b11bbd9f1d48a7514fa9bf212723.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..328f363823498774939b36b8f1a97870f5388d08 --- /dev/null +++ b/vision-fixhub/ds11-01/4d8a4d5e3a88e3c60ac4508492a4d57c82a7b11bbd9f1d48a7514fa9bf212723.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "4d8a4d5e3a88e3c60ac4508492a4d57c82a7b11bbd9f1d48a7514fa9bf212723", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "ed0bfedbd310c275bb2872177dfee705c39c668d12c6c3c01cb0f592787468a3", + "output_sha256": "5cd1dda1ea49394951a4068497847f706bb61af500fe96fc181308c0f70c3b5a", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/5058ffec77dd5661467e9c049fd9c6fade432c9a0b53922177e7d8d98252a052.md b/vision-fixhub/ds11-01/5058ffec77dd5661467e9c049fd9c6fade432c9a0b53922177e7d8d98252a052.md new file mode 100644 index 0000000000000000000000000000000000000000..670581267a567e0020d2c0c2548fe095bb387f39 --- /dev/null +++ b/vision-fixhub/ds11-01/5058ffec77dd5661467e9c049fd9c6fade432c9a0b53922177e7d8d98252a052.md @@ -0,0 +1,58 @@ +To: +From: +Richard Kahn +Sent: +Mon 5/1/2017 6:41:05 PM +Subject: christopher +received from jee +thanks +FYR +Richard Kahn +HBRK Associates Inc. +575 Lexington Avenue 4th Floor +New York, NY 10022 +Begin forwarded message: +From: Karyna Shuliak +Subject: Re: +Date: May 1, 2017 at 2:27:36 PM EDT +To: Jeffrey , Richard Kahn +Hi Rich, +Here is their store contact info. Thank you. +On May 1, 2017, at 2:15 PM, jeffrey E. +EFTA_R1_00936417 + + +wrote: +- Forwarded message -...... +From: Richard Kahn 1 +Date: Mon, May 1, 2017 at 2:14 PM +Subject: Re: +To: "¡effrev E." +can you please send his contact info as +thank you +Richard Kahn +HBRK Associates Inc. +575 Lexington Avenue 4th Floor +New York, NY 10022 +does not have it +On May 1, 2017, at 1:57 PM, jeffrey E. + wrote: +call christtpher hyland. ask for christoper get the exact name of the met +opera charity and send 50k from gratitude TODAY if +please note +The information contained in this communication is +confidential, may be attorney-client privileged, may +constitute inside information, and is intended only for +the use of the addressee. It is the property of +JEE +Unauthorized use, disclosure or copying of this +communication or any part thereof is strictly prohibited +and may be unlawful. If you have received this +communication in error, please notify us immediately by +return e-mail or by e-mail to jeevacation@gmail.com, and +destroy this communication and all copies thereof, +including all attachments. copyright -all rights reserved +EFTA_R1_00936418 + + +-- diff --git a/vision-fixhub/ds11-01/5058ffec77dd5661467e9c049fd9c6fade432c9a0b53922177e7d8d98252a052.receipt.json b/vision-fixhub/ds11-01/5058ffec77dd5661467e9c049fd9c6fade432c9a0b53922177e7d8d98252a052.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..928b3caa6133d8fa9dfe3240cd09e5d02947ee41 --- /dev/null +++ b/vision-fixhub/ds11-01/5058ffec77dd5661467e9c049fd9c6fade432c9a0b53922177e7d8d98252a052.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -651, + "dataset": "marble-joined", + "doc_id": "5058ffec77dd5661467e9c049fd9c6fade432c9a0b53922177e7d8d98252a052", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.disclaimer-removal.please-note-florida\"]", + "idempotent": false, + "input_sha256": "01c151370d1afc3232b2299f63082a073785e50e2084bb3078faae209c93a6a8", + "output_sha256": "77e819baf2802045a2c22726ae717f3bdbb89356ee13e398790da3bba422d148", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/50a798cc39fe6404de12d32e1310ab34ecb543a34077bcea4b1fd34302787f67.md b/vision-fixhub/ds11-01/50a798cc39fe6404de12d32e1310ab34ecb543a34077bcea4b1fd34302787f67.md new file mode 100644 index 0000000000000000000000000000000000000000..66ad876bd3f78b07240cc44c016e8f0d62f11570 --- /dev/null +++ b/vision-fixhub/ds11-01/50a798cc39fe6404de12d32e1310ab34ecb543a34077bcea4b1fd34302787f67.md @@ -0,0 +1,6 @@ +To: +From: +Subject: +Alert - check on flights today for +April 27, 2017 7:00 AM : check on flights today for +EFTA_R1_00936346 diff --git a/vision-fixhub/ds11-01/50a798cc39fe6404de12d32e1310ab34ecb543a34077bcea4b1fd34302787f67.receipt.json b/vision-fixhub/ds11-01/50a798cc39fe6404de12d32e1310ab34ecb543a34077bcea4b1fd34302787f67.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..13b1f4d966b24475f051be72e1306eb6379ef8de --- /dev/null +++ b/vision-fixhub/ds11-01/50a798cc39fe6404de12d32e1310ab34ecb543a34077bcea4b1fd34302787f67.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "50a798cc39fe6404de12d32e1310ab34ecb543a34077bcea4b1fd34302787f67", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "d2a848bf96fffb4f74843b6a0bb48e7ae735ee8287396da695e150539c97e2cb", + "output_sha256": "5882e8090114ac1f5d8dad1b5d079fe1fcd0468a941095e8cd74588f04c2cefd", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/633f116cf4aecfc95f20a0641b2d0a92d7710a14fb26f7827a7d6d0312cc6ac7.md b/vision-fixhub/ds11-01/633f116cf4aecfc95f20a0641b2d0a92d7710a14fb26f7827a7d6d0312cc6ac7.md new file mode 100644 index 0000000000000000000000000000000000000000..92fb8372c708607c6c8a956956a4fa7edace899f --- /dev/null +++ b/vision-fixhub/ds11-01/633f116cf4aecfc95f20a0641b2d0a92d7710a14fb26f7827a7d6d0312cc6ac7.md @@ -0,0 +1,48 @@ +To: +merwin dela cruz[ +From: +Sent: +Mon 5/15/2017 9:25:45 PM +Subject: +Re: Prescription for JE from Vitahealth +ok great. You can have her put it +on the dining room table for him +> On May 15, 2017, +at 5:24 PM, +Merwin Dela cruz +> +> Les, +> It did come. Marilyn is still there I will let her know. +> +> Thanks +> Merwin Dela Cruz +wrote: +» on May 15, 2017, at 3:44 PM, +>> +>> should be there within the hour for sure before 5pm. +(but if not, let me know!) +> wrote: +>> +>>> on May 15, 2017, at 3:28 PM, Merwin Dela cruz +»>> +>>> Hi +»>> Any idea what time they are going to deliver this? +>>> +>>> +>>> +>>> Merwin Dela Cruz +>>> +>>> +>>> +>>> +>>>> On May 12, 2017, +at 2:20 PM, Lesley Groff +wrote: +>>>> +>>>> prescription for +Pharmecy. +• pease for Jem wey me are reconvey May 15th from Vitalhealth +>>> +> +wrote: +EFTA_R1_00936452 diff --git a/vision-fixhub/ds11-01/633f116cf4aecfc95f20a0641b2d0a92d7710a14fb26f7827a7d6d0312cc6ac7.receipt.json b/vision-fixhub/ds11-01/633f116cf4aecfc95f20a0641b2d0a92d7710a14fb26f7827a7d6d0312cc6ac7.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..b6e4913011e9d0d5e36320de8476cb4a5762e8fa --- /dev/null +++ b/vision-fixhub/ds11-01/633f116cf4aecfc95f20a0641b2d0a92d7710a14fb26f7827a7d6d0312cc6ac7.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "633f116cf4aecfc95f20a0641b2d0a92d7710a14fb26f7827a7d6d0312cc6ac7", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "8e665487cec9b009b1a33e003293034fa5f6f025cc9652870394936b4ea65dfe", + "output_sha256": "f4cd14c68bf037935b3d5bb1731bbe60530b285fab294992ff5ae14261654441", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/63e86b797f951255bee627e914df47068220a4dd16180d897d70bb1c47b532ca.md b/vision-fixhub/ds11-01/63e86b797f951255bee627e914df47068220a4dd16180d897d70bb1c47b532ca.md new file mode 100644 index 0000000000000000000000000000000000000000..9d4315a8cebb330f750257e46cc6eb246ceed20d --- /dev/null +++ b/vision-fixhub/ds11-01/63e86b797f951255bee627e914df47068220a4dd16180d897d70bb1c47b532ca.md @@ -0,0 +1,109 @@ +To: +Natalia Molotkova +Thur 5/18/2017 3:13:56 PM +Subject: Tickets to STT +Title: American Express ® +I apologize, used bargain finder and it did offer me this option as lowest. +We can do round trip at $701.36 per person for the following itinerary, direct non stop: +DL 465 23MAY JFK STT 900A 108P +AA 936 27MAY STT JFK 210P 627P +OK to issue? +Regards, +Natalia (Natasha) Molotkova +Centurion Relationship Manager +Hours: Mon, Wed 9a-4p, 530p-7p +Tue, Thur, Fri 9a - 530p EST +Ah got it. Thanks please do check delta! +Sent from my iPhone +On May 18, 2017, at 10:39 AM, Natalia Molotkova 4 +- wrote: +I apologize, used bargain finder and it did offer me this option as lowest. +We can do round trip at $701.36 per person for the following itinerary, direct non stop: +DL 465 23MAY JFK STT +900A 108P +AA 936 27MAY STT JFK 210P 627P +OK to issue? +Regards, +Natalia (Natasha) Molotkova +Centurion Relationship Manager +EFTA_R1_00936436 + + +Hours: Mon, Wed 9a-4p, 530p-7p +Tue, Thur, Fri 9a - 530p EST +Thx +Sent from my iPhone +On May 18, 2017, at 10:37 AM, Natalia Molotova < +> wrote: +Sorry, it is direct one stop like they call it. I was not aware that AA has such flight to STT. On my +end it sows as direct. Pricing Delta on outbound +Regards, +Natalia (Natasha) Molotkova +Centurion Relationship Manager +Hours: Mon, Wed 9a-4p, 530p-7p +Tue, Thur, Fri 9a - 530p EST +Let me go inside the flight.. +Regards, +Natalia (Natasha) Molotkova +Centurion Relationship Manager +Hours: Mon, Wed ga-4p, 530p-7p +Tue, Thur, Fri 9a - 530p EST +wait! this doesn't look direct on the outbound.. Are their no direct flights available? +On May 18. 2017, at 9:56 AM. Natalia Molotkova +> wrote: +EFTA_R1_00936437 + + +On May 18, 2017. at 10:20 AM, Natalia Molotkova +> wrote: +On May 18, 2017. at 10:22 AM, Natalia Molotkova +> wrote: +Can't pre-assign any seats without fee, will be able to tell you what seats can be assigned and +how much after ticketing. +Regards, +Natalia (Natasha) Molotkova +Centurion Relationship Manager +Hours: Mon, Wed 9a-4p, 530p-7p +Tue, Thur, Fri 9a - 530p EST +OK, fare per person $579.46, non refundable coach with $200 penalty. +Regards, +Natalia (Natasha) Molotkova +Centurion Relationship Manager +Hours: Mon, Wed 9a-4p, 530p-7p +Tue, Thur, Fri 9a - 530p EST +Please Issue their tickets! thanks +On May 18, 2017. at 9:56 AM. Natalia Molotkova +• wrote: +EFTA_R1_00936438 + + +1 AA +1592 23MAY JFK STT 0805A 0330P +2 AA +936 27MAY STT JFK 0210P 0627P +1 ADT 579.46 +TOTAL FARE - USD 1738.38 +Regards, +Natalia (Natasha) Molotkova +Centurion Relationship Manager +lours: Mon, Wed 9a-4p, 530p-7 +ue, Thur, Fri 9a - 530p ES +On it. +Regards, +Natalia (Natasha) Molotkova +Centurion Relationship Manager +Hours: Mon, Wed 9a-4p, 530p-7p +Tue, Thur, Fri 9a - 530p EST +Morning. I need round trip coach tickets for +Tuesday May 23 direct flight return on Sat May 27 direct flight. Best price is?... +from NY to STT on +Sent from my iPhone +Privacy Statement | Visit the Centurion Card website +To learn more about e-mail security or report a suspicious e-mail, please visit us at americanexpress.com/phishing. +© 2015 American Express. All rights reserved +American Express uses 3rd party concierge service providers who are not authorized to act on behalf of American Express +and you acknowledge that American Express is in no way responsible or liable for the actions of the service provider and the +only remedy for any claims relating to services or products provided by the service provider is against the service provider and +not against American Express. You are responsible for any purchases, shipping charges and/or fees you authorize. We +reserve the right to note profile and preference data for servicing purposes. +EFTA_R1_00936439 diff --git a/vision-fixhub/ds11-01/63e86b797f951255bee627e914df47068220a4dd16180d897d70bb1c47b532ca.receipt.json b/vision-fixhub/ds11-01/63e86b797f951255bee627e914df47068220a4dd16180d897d70bb1c47b532ca.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..ede1484b78bdcf31347eb6a5db6aa943cd099930 --- /dev/null +++ b/vision-fixhub/ds11-01/63e86b797f951255bee627e914df47068220a4dd16180d897d70bb1c47b532ca.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -48, + "dataset": "marble-joined", + "doc_id": "63e86b797f951255bee627e914df47068220a4dd16180d897d70bb1c47b532ca", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "a2e2f1ad1cc306cbff4a0d617b12abe68f8a75fe2d53fb8ebec65e1f1e9ecc9b", + "output_sha256": "d503be0f1bf97f29b2ad860eedabd82723cd67668d2d240cbbe2306d93384b98", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/70db76e11709b0dcdf91c23833da0fb36df631f3dc2293ac0c196c625139b005.md b/vision-fixhub/ds11-01/70db76e11709b0dcdf91c23833da0fb36df631f3dc2293ac0c196c625139b005.md new file mode 100644 index 0000000000000000000000000000000000000000..e528bb39ca9f369a6952ea7d556815195bd595a1 --- /dev/null +++ b/vision-fixhub/ds11-01/70db76e11709b0dcdf91c23833da0fb36df631f3dc2293ac0c196c625139b005.md @@ -0,0 +1,23 @@ +To: +Larry Visoski +From: +Sent: +Sun 4/23/2017 12:36:27 PM +Subject: Re: Flightaware +Thx +Sent from my iPhone +> On Apr 23, 2017, at 8:11 AM, Larry Visoski +wrote: +> +> Disregard the flightaware Notification to Santa Febit was a mistake my rental +pilot filed, sorry. +> +> We will depart at 4:30 PM today from Teterboro +St Thomas +> Arrival ISJ at 7:30pm +> +> Thix +> Larry +> +> Sent from my iPhone +EFTA_R1_00936489 \ No newline at end of file diff --git a/vision-fixhub/ds11-01/70db76e11709b0dcdf91c23833da0fb36df631f3dc2293ac0c196c625139b005.receipt.json b/vision-fixhub/ds11-01/70db76e11709b0dcdf91c23833da0fb36df631f3dc2293ac0c196c625139b005.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..71b677b1c89795b9e33dde40aae98fdd80e7fbcc --- /dev/null +++ b/vision-fixhub/ds11-01/70db76e11709b0dcdf91c23833da0fb36df631f3dc2293ac0c196c625139b005.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": 0, + "dataset": "marble-joined", + "doc_id": "70db76e11709b0dcdf91c23833da0fb36df631f3dc2293ac0c196c625139b005", + "engine": "marble-apple-vision", + "event_count": 0, + "fix_ids": "[]", + "idempotent": true, + "input_sha256": "70c0df721f186f2a952b1e57a7401fb21c8a4383628433808b8dfb617194744f", + "output_sha256": "70c0df721f186f2a952b1e57a7401fb21c8a4383628433808b8dfb617194744f", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/7156e0f27306cf1187bb132d9229dbc773fcf0b0871ff17e8795bb9185d2c55e.md b/vision-fixhub/ds11-01/7156e0f27306cf1187bb132d9229dbc773fcf0b0871ff17e8795bb9185d2c55e.md new file mode 100644 index 0000000000000000000000000000000000000000..07ed176c35eadbfc4194821644f070d4b7a8bb3c --- /dev/null +++ b/vision-fixhub/ds11-01/7156e0f27306cf1187bb132d9229dbc773fcf0b0871ff17e8795bb9185d2c55e.md @@ -0,0 +1,98 @@ +To: +From: +Sent: +Amex Centurian Travell +Lesley Groff +Mon 5/22/2017 12:55:50 PM +Subject: Re: 3d party credit card authorization form +FYI...your colleagues were never able to confirm if the reservation dept rec'd my credit card +authorization paperwork...they called but the dept was closed..can you email your contact +again today... +is there all week so we have time to figure it out...but I'd like to know. I +scanned and emailed the paperwork to Tiffany (your colleague) on Saturday for just in case...let +me know if you need it. Thanks, Lesley +On May 19. 2017, at 3:26 PM, Natalia Molotkova +> wrote: +Sure, let me email them. +Regards, +Natalia (Natasha) Molotkova +Centurion Relationship Manager +Hours: Mon, Wed 9a-4p, 530p-7p +Tue, Thur, Fri 9a - 530p EST +I faxed over JE's Visa, Pasport and filled out paperwork...is there a way you can confirm with the hotel they +On May 19, 2017, at 2:18 PM, Natalia Molotkova < +> wrote: + +correct..I need one of those +On May 19, 2017, at 2:34 PM, Natalia Molotkova < +> wrote: +They accept only Visa or Master card. +Regards, +Natalia (Natasha) Molotkova +Centurion Relationship Manager +Hours: Mon, Wed 9a-4p, 530p-7p +Tue, Thur, Fri 9a - 530p EST +thanks +EFTA_R1_00936408 + + +On May 19, 2017, at 2:18 PM, Natalia Molotkova < +‹Hotel Reservation Form -4-. pdf> +> wrote: +Regards, +Natalia (Natasha) Molotkova +Centurion Relationship Manager +Hours: Mon, Wed 9a-4p, 530p-7p +Tue, Thur, Fri 9a - 530p EST +For to pay reservation, you completing and emailing; +1- The letter form enclosed in this mail (5092,00 Moroccan Dirhams) +2- Hight resolution scanned copy of your credit card from both side. +3- Copy of the passeport of the credit card holder's +4- We accept Visa & Master Card +Cordially +FIKRI Youness +Service Réservation +Hötel Kenzi Farah +Avenue du President KENNEDY|40 000 Marrakech +EFTA_R1_00936409 + +ly % Please consider the environment before printing this e-mail +De : Natalia X Molotkova [) +Envové: vendredi 19 mal 201 16:38 +Objet : 3d party credit card authorization form +Dear Yniss, +Will you be so kind to email me the 3d party credit card authorization form for confirı +I guaranteed her reservation with her boss's card, and he wants to pay for her stay. +Thank you, +Natalia (Natasha) Molotkova|Relationship Manager +American Express Centurion Servicing +Working hours: 9:00am-5:30pm Monday-Friday +Behind every great travel moment is a Journeymaker +who helped make it happen. Journeymakers.com +EFTA_R1_00936410 + + +American Express made the following annotations +"This message and any attachments are solely for the intended recipient and may contain confidential or p +He pie, any died sure or inse or distribution or i ad maine ded in thinese and any +American Express a ajouté le commentaire suivant le +Ce courrier et toute pièce jointe qu'il contient sont réservés au scul destinataire indiqué et peuvent renferr +privilégiés. Si vous n'êtes pas le destinataire prévu, toute divulgation, duplication, utilisation ou distributic +interdite. Si vous avez reçu cette communication par erreur, veuillez nous en aviser par courrier et détruit +Merci. +American Express made the following annotations +"This message and any attachments are solely for the intended recipient and may contain confidential or priv +recipient, any disclosure, copying, use, or distribution of the information included in this message and any at +communication in error, please notify us by reply e-mail and immediately and permanently delete this messa +American Express a ajouté le commentaire suivant le +Ce courrier et toute pièce jointe qu'il contient sont réservés au seul destinataire indiqué et peuvent renferme +Si vous n'êtes pas le destinataire prévu, toute divulgation, duplication, utilisation ou distribution du courrier o +reçu cette communication par erreur, veuillez nous en aviser par courrier et détruire immédiatement le courr +Privacy Statement | Visit the Centurion Card website +To learn more about e-mail security or report a suspicious e-mail, please visit us at americanexpress.com/phishing- +© 2015 American Express. All rights reserved +American Express uses 3rd party concierge service providers who are not authorized to act on behalf of American Express and you acknowledge that Amer +responsible or liable for the actions of the service provider and the only remedy for any claims relating to services or products provided by the service provid +provider and not against American Express. You are responsible for any purchases, shipping charges and/or fees you authorize. We reserve the right to not +for servicing purposes. +EFTA_R1_00936411 diff --git a/vision-fixhub/ds11-01/7156e0f27306cf1187bb132d9229dbc773fcf0b0871ff17e8795bb9185d2c55e.receipt.json b/vision-fixhub/ds11-01/7156e0f27306cf1187bb132d9229dbc773fcf0b0871ff17e8795bb9185d2c55e.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..f2e505a416b2f5c13367a8820359280da9418f40 --- /dev/null +++ b/vision-fixhub/ds11-01/7156e0f27306cf1187bb132d9229dbc773fcf0b0871ff17e8795bb9185d2c55e.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -36, + "dataset": "marble-joined", + "doc_id": "7156e0f27306cf1187bb132d9229dbc773fcf0b0871ff17e8795bb9185d2c55e", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "3f812428c35f64251cc516c2dd5f24e2f507a65ac11ee3a16d1f5cec0e395188", + "output_sha256": "87ba3e23a62edb2ebedd16dfa0bcf0e74ebaf62b1c9ed8f5f3d25e8b43f8d04b", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/7186b49a3b0eab8c2078ee0463234d01b8486ed5053305c490e9c05492b990ca.md b/vision-fixhub/ds11-01/7186b49a3b0eab8c2078ee0463234d01b8486ed5053305c490e9c05492b990ca.md new file mode 100644 index 0000000000000000000000000000000000000000..86e6dfd0cdb4c6836d32d9d5d7b407053be101e7 --- /dev/null +++ b/vision-fixhub/ds11-01/7186b49a3b0eab8c2078ee0463234d01b8486ed5053305c490e9c05492b990ca.md @@ -0,0 +1,25 @@ +From: +Jefffrey Epsteinfjeevacation@gmail.com] +Mon 5/15/2017 6:52:31 PM +Subject: +Bel Air Suite-which suite do you prefer? +Which suite do you prefer at Hotel Bel Air? +https://www.dorchestercollection.com/en/los-angeles/hotel-bel-air/suites-rooms/ +https://www.dorchestercollection.com/en/los-angeles/hotel-bel-air/suites-rooms/ +HOTEL BEL AIR +701 STONE CANYON ROAD +LOS ANGELES CA 90077 +All rooms are King +DELUXE KING ROOM - KING BED - 450 SQFT -- 565.00 USD plus tax. Rollaway 30.00USD +1 BDRM-690 SQFT-64SQMT-GARDEN VIEW - 935.00 +CANYON STUDIO -KING BED - 520 SQFT - - 1035.00 +LOFT STUDIO - KING BED - 650 SQFT - - 1285.00 +BEL-AIR SUITE WITH PATIO- KING BED-690 SQFT - - 1135.00 +CANYON SUITE-KING BED-600 SQFT-GARDEN VIEW- +- 2200.00 +PREMIER CANYON SUITE-KING BED-600 SQFT- +TWO BEDROOM BEL-AIR SUITE-KING BEDS-1275 SQFT-- 1800.00 +GRAND SUITE-KING BED-850 SQFT-- 2400.00 +GRACE KELLY SUITE-COMP ROUNDTRIP LAX AIRPORT - 4000.00 +HERB GARDEN SUITE-COMP LAX AIRPORT ROUNDTRIP - 4000.00 +EFTA_R1_00936458 diff --git a/vision-fixhub/ds11-01/7186b49a3b0eab8c2078ee0463234d01b8486ed5053305c490e9c05492b990ca.receipt.json b/vision-fixhub/ds11-01/7186b49a3b0eab8c2078ee0463234d01b8486ed5053305c490e9c05492b990ca.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..9c2b6bb5731a5718bf907c54695c443170109f33 --- /dev/null +++ b/vision-fixhub/ds11-01/7186b49a3b0eab8c2078ee0463234d01b8486ed5053305c490e9c05492b990ca.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "7186b49a3b0eab8c2078ee0463234d01b8486ed5053305c490e9c05492b990ca", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "e10a7b545171f6f36332621154cc3b0c60d0c867110de146de8e6bf97c5a6615", + "output_sha256": "36d13a1ba3c667a93fe327530d7a678c1de1d22432b4eb7c9982be1e7e90c937", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/7190ef45cd1e3a61fb83275536594b5b666490ef5d5790c54029bd34deb5a129.md b/vision-fixhub/ds11-01/7190ef45cd1e3a61fb83275536594b5b666490ef5d5790c54029bd34deb5a129.md new file mode 100644 index 0000000000000000000000000000000000000000..5a61c3f1acaccc57477b44ef2b0ba2c9c574b2cc --- /dev/null +++ b/vision-fixhub/ds11-01/7190ef45cd1e3a61fb83275536594b5b666490ef5d5790c54029bd34deb5a129.md @@ -0,0 +1,37 @@ +To: +From: +Natalia Molotkova +Sent: +Tue 5/30/2017 1:01:24 PM +Subject: Ticket for +Title: American Express ® +Morning, on it. +Regards, +Natalia (Natasha) Molotkova +Centurion Relationship Manager +o Stockholm June 7 +(877) 877-0987 +Hours: Mon, Wed 9a-4p, 530p-7p +Tue, Thur, Fri 9a - 530p EST +Hi Natasha...I spoke to a colleague today re a trip to Stockholm for +and put a +Norwegian Air flight on hold for June 8th... +has informed me she must go home on June +7th...please, lets look at some connecting flights that are lower priced.. the direct flight on the 7th +was around $2500...coach... we could also check to see if a round trip lowers the price...she +needs to return in August, she just doesn't have a date as of yet for return... +please give me options and pricing... +(FYI-the flight we put on hold never did arrive my email? I didnt call back since she can't take it +anyway...but there should be a record locator if you wanted to find it for her details...l have below +for you also) +Thanks, Lesley +Thank you for your email. I am currently out of the office. +Privacy Statement | Visit the Centurion Card website +To learn more about e-mail security or report a suspicious e-mail, please visit us at americanexpress.com/phishing. +© 2015 American Express. All rights reserved +not against American Express. You are responsible for any purchases, shipping charges and/or fees you authorize. We +reserve the right to note profile and preference data for servicing purposes. +EFTA_R1_00936480 + + +EFTA_R1_00936481 diff --git a/vision-fixhub/ds11-01/7190ef45cd1e3a61fb83275536594b5b666490ef5d5790c54029bd34deb5a129.receipt.json b/vision-fixhub/ds11-01/7190ef45cd1e3a61fb83275536594b5b666490ef5d5790c54029bd34deb5a129.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..b2b7fa835439f9641f810ed090dea9eb95d9af35 --- /dev/null +++ b/vision-fixhub/ds11-01/7190ef45cd1e3a61fb83275536594b5b666490ef5d5790c54029bd34deb5a129.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "7190ef45cd1e3a61fb83275536594b5b666490ef5d5790c54029bd34deb5a129", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "9f1930e03cca00a1b4894abe8e4c00bb31383da0267f0ce6bf1669e310db677a", + "output_sha256": "2dec3d0a6890c55656c88d015a70199ea41328d29f7422357d123cfe7ab387a8", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/76566756493787c5c345476fc85747b44320838fe081fd7d1a247afb2e4710f9.md b/vision-fixhub/ds11-01/76566756493787c5c345476fc85747b44320838fe081fd7d1a247afb2e4710f9.md new file mode 100644 index 0000000000000000000000000000000000000000..b77c76d70fd0f7a6a3106c8436133b65c7f1cc51 --- /dev/null +++ b/vision-fixhub/ds11-01/76566756493787c5c345476fc85747b44320838fe081fd7d1a247afb2e4710f9.md @@ -0,0 +1,42 @@ +To: +Cc: +From: +Lesley Groff +Sent: +Tue 5/30/2017 12:05:38 PM +Subject: Re: Snacks at noon with Maxim and his mom? +Thank you! +Sent from my iPhone +On May 30, 2017, at 8:01 AM, +> wrote: +Sure thing! +On Tue, May 30, 2017 at 8:00 AM Lesley Groff 4 +Morning! Can you organize the below for 12:00 today please? +> wrote: +Sent from my iPhone +Begin forwarded message: +From: "jeffrey E." < +Date: May 30, 2017 at 7:48:36 AM EDT +To: Lesley Groff | +Subject: Re: Snacks at noon with Maxim and his mom? +yes, cookies or small cakes. tea +On Tue, May 30, 2017 at 7:43 AM, Lesley Groff< +> wrote: +Do you want snacks at the noon appt today with Maxim and his +mom? +Sent from my iPhone +- +please note +The information contained in this communication is +JEE +EFTA_R1_00936289 + + +Unauthorized use, disclosure or copying of this +communication or any part thereof is strictly prohibited +and may be unlawful. If you have received this +communication in error, please notify us immediately by +return e-mail or by e-mail to jeevacation@gmail.com, and +destroy this communication and all copies thereof, +including all attachments. copyright -all rights reserved +EFTA_R1_00936290 diff --git a/vision-fixhub/ds11-01/76566756493787c5c345476fc85747b44320838fe081fd7d1a247afb2e4710f9.receipt.json b/vision-fixhub/ds11-01/76566756493787c5c345476fc85747b44320838fe081fd7d1a247afb2e4710f9.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..a84c315f95513d7ffbfe549c133367352ddeeae9 --- /dev/null +++ b/vision-fixhub/ds11-01/76566756493787c5c345476fc85747b44320838fe081fd7d1a247afb2e4710f9.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "76566756493787c5c345476fc85747b44320838fe081fd7d1a247afb2e4710f9", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "a3f2deedea56232349a8e335d38a5fe2a49f21e53b776934d92db877d5b61ae1", + "output_sha256": "80e8374db2993826137723dbdafdb7049c4023093b1d21fa706124e717fabc59", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/78ce27becbb9c05f4e20eef842759d9015dd892756d1ef46f50cb202c26cb61b.md b/vision-fixhub/ds11-01/78ce27becbb9c05f4e20eef842759d9015dd892756d1ef46f50cb202c26cb61b.md new file mode 100644 index 0000000000000000000000000000000000000000..0889986e41c7b2dd9a6c3e332d12747476666371 --- /dev/null +++ b/vision-fixhub/ds11-01/78ce27becbb9c05f4e20eef842759d9015dd892756d1ef46f50cb202c26cb61b.md @@ -0,0 +1,15 @@ +To: +Cc: +Fontanilla +Jefffrey Epsteinlieevacation@gmail.com] +I: merwin dela cruzi +D: Jojo +From: +Sent: +Subject: +Lesley Groff +Thur 5/18/2017 4:49:16 PM +Brad Karp +Brad Karp will join the Kathy Ruemmler meeting tomorrow at 5:30pm..he says he can +stay for about an hour but must leave to introduce someone at a dinner in midtown +EFTA_R1_00936301 diff --git a/vision-fixhub/ds11-01/78ce27becbb9c05f4e20eef842759d9015dd892756d1ef46f50cb202c26cb61b.receipt.json b/vision-fixhub/ds11-01/78ce27becbb9c05f4e20eef842759d9015dd892756d1ef46f50cb202c26cb61b.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..53266cb0d5fa84e4c4f85ba1a0195c8442bae14f --- /dev/null +++ b/vision-fixhub/ds11-01/78ce27becbb9c05f4e20eef842759d9015dd892756d1ef46f50cb202c26cb61b.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "78ce27becbb9c05f4e20eef842759d9015dd892756d1ef46f50cb202c26cb61b", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "2b0824ad48aa1b37d0e18300545b2f4a9947c9ea64adc9f1cad6049bf95c3467", + "output_sha256": "37d277d53b0392b35c071f68414ea1a62b34314c09ddf6531fa7d5e7dd657194", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/7ce9143d92c10bb78794ffdbef3bb9f65659492b1b4c12aeb132ae828c62fac9.md b/vision-fixhub/ds11-01/7ce9143d92c10bb78794ffdbef3bb9f65659492b1b4c12aeb132ae828c62fac9.md new file mode 100644 index 0000000000000000000000000000000000000000..8ab93fa3e2778e2743d249c8c8b6a7829776483f --- /dev/null +++ b/vision-fixhub/ds11-01/7ce9143d92c10bb78794ffdbef3bb9f65659492b1b4c12aeb132ae828c62fac9.md @@ -0,0 +1,160 @@ +To: +From: +Natalia Molotkova +Sent: +Thur 5/4/2017 9:44:13 PM +Subject: Tickets for a couple and their 3 dogs +Title: American Express ® +They do have hit control. +Regards, +Natalia (Natasha) Molotkova +Centurion Relationship Manager +(877) 877-0987 +Hours: Mon, Wed 9a-4p, 530p-7p +Tue, Thur, Fri 9a - 530p EST +Ok super. I'll pass this Along and let them know we will get back to them on climate control. I do +know the Ross's don't want to be a nuisance to other travelers! +Sent from my iPhone +On May 4, 2017, at 4:53 PM, Natalia Molotkova +> wrote: +When carrying on your pet, you'll need to make sure that they can stand up, turn around and lie +down in a natural position in their kennel. Non-collapsible kennels can be a maximum of 19in x +Soft-sided collapsible kennels such as Sherpa bags can be larger if they're made of waterrepellant material, are padded or have nylon mesh ventilation on 2 or more sides. +I will have to call Americans about climate control. +Regards, +Natalia (Natasha) Molotkova +Centurion Relationship Manager +(877) 877-0987 +Hours: Mon, Wed 9a-4p, 530p-7p +Tue, Thur, Fri 9a - 530p EST +I am being asked what the largest size kennel you can bring on the plane is...? also can you find +out if the cargo area is "not too hot"...) guess a better question is: is it climate controlled for pets? +or is it just regular climate so it gets hot...or maybe too cold? geez...I don't know!? !! +EFTA_R1_00936423 + + +On May 4, 2017, at 4:26 PM, Natalia Molotkova < +You will let me know if they will do cargo or in the cabin? In the cabin room for dogs will be +guaranteed. +Regards, +Natalia (Natasha) Molotkova +Centurion Relationship Manager +(877) 877-0987 +Hours: Mon, Wed 9a-4p, 530p-7p +Tue, Thur, Fri 9a - 530p EST +this is great! thank you! +On May 4, 2017, at 4:19 PM, Natalia Molotkova 4| +Checked pets +You can travel with up to 2 checked pets that are at least 8 weeks old. Please note that as +capa tity is limited, we accept checked pets on a first-come basis. When checking a pet, you'l +• Contact Reservations at least 48 hours prior to travel +• Check in at the ticket counter +• Allow extra check-in time (can't check pets more than 4 hours before your flight) +• Complete a checklist with an agent +• Provide a health certificate +To ensure the health and safety of your pet, the health certificate you provide must be issued by a +vet within: +• 10 days of your travel +• 60 days of your return (travel on the same ticket) +• 10 days of your return (travel on a separate ticket) +EFTA_R1_00936424 + + +Regards, +Natalia (Natasha) Molotkova +Centurion Relationship Manager +(877) 877-0987 +Hours: Mon, Wed 9a-4p, 530p-7p +Tue, Thur, Fri 9a - 530p EST +ok +On May 4, 2017, at 4:16 PM, Natalia Molotkova +They are small dogs, I didn't ask about cargo, will do... +Regards, +Natalia (Natasha) Molotkova +Centurion Relationship Manager +(877) 877-0987 +Hours: Mon, Wed 9a-4p, 530p-7p +Tue, Thur, Fri 9a - 530p EST +ok, let me see if they would prefer to have the dogs with them in their kennels +On May 4, 2017, at 4:05 PM, Natalia Molotkova < +actually, let me ask...if they went to cargo would it be $125 per a dog only? +On May 4, 2017, at 4:05 PM, Natalia Molotkova • +EFTA_R1_00936425 + + +OK, dogs are small, they do not need to go to cargo, but, 3 dogs - has to be 3 kennels and they +have only two seats. If they need to take them in the cabin, we will have to book them 3 seats (and +pay fro 3 tickets) plus 125.00 USD fee per dog. +Regards, +Natalia (Natasha) Molotkova +Centurion Relationship Manager +(877) 877-0987 +Hours: Mon, Wed 9a-4p, 530p-7p +Tue, Thur, Fri 9a - 530p EST +lets start with the flight AA936 departing at 9:30am from JFK please. +On May 4, 2017, at 3:48 PM, Natalia Molotkova 4 +Direct option swill be: +DL +465 02JUN JFK STT 0900A 0108P +1ADT 275.10 +TOTAL FARE - USD 550.20 +1 AA +936 N 02JUN F JFK STT 0930A 0139P +1ADT 209.00 +TOTAL FARE - USD 418.00 +Let me know which one is option one, will start with them yo check on dogs. +Regards, +Natalia (Natasha) Molotkova +Centurion Relationship Manager +(877) 877-0987 +Hours: Mon, Wed 9a-4p, 530p-7p +Tue, Thur, Fri 9a - 530p EST +yes please... they need to go direct...! +EFTA_R1_00936426 + + +On May 4, 2017, at 3:30 PM, Natalia Molotkova +Lesley, there is nothing dire ct from EWR, should I go with any other airport? +Regards, +Natalia (Natasha) Molotkova +Centurion Relationship Manager +(877) 877-0987 +Hours: Mon, Wed 9a-4p, 530p-7p +Tue, Thur, Fri 9a - 530p EST +OK +Regards, +Natalia (Natasha) Molotkova +Centurion Relationship Manager +(877) 877-0987 +Yours: Mon, Wed 9a-4p, 530p-71 +Tue, Thur, Fri 9a - 530p ES +make it June 2nd out if Newark instead for the flights... +they will go in crates in a climate controlled luggage area we hope!! +We are hiring this new couple so you can keep them in our profile... they will be the new couple to +run the island for Jeffrey... them and their watch dogs :) +On May 4, 2017, at 2:26 PM, Natalia Molotkova • +EFTA_R1_00936427 + + +I have asked the Ross's for this info ... waiting for their reply... +On May 4, 2017, at 2:26 PM, Natalia Molotkova +Hello +may I have more info about dogs: weight, bread? That will depend how dogs will +travel: in the cabin or cargo. But checking flights meanwhile. +Regards, +Natalia (Natasha) Molotkova +Centurion Relationship Manager +(877) 877-0987 +Hours: Mon, Wed 9a-4p, 530p-7p +Tue, Thur, Fri 9a - 530p EST +Hi Natasha! We will need one way tickets for Michael and Kimberly Ross to fly from JFK to STT +on June 4th, direct, coach. They have 3 dogs that need to go with them...! need to find out their +weight but I beleive all will be considered 'cargo' in crates...? Is it United that does this? +Kimberl Ross +Michael Ross +Privacy Statement | Visit the Centurion Card website +To learn more about e-mail security or report a suspicious e-mail, please visit us at americanexpress.com/phishing. +© 2015 American Express. All rights reserved +not against American Express. You are responsible for any purchases, shipping charges and/or fees you authorize. We +reserve the right to note profile and preference data for servicing purposes. +EFTA_R1_00936428 \ No newline at end of file diff --git a/vision-fixhub/ds11-01/7ce9143d92c10bb78794ffdbef3bb9f65659492b1b4c12aeb132ae828c62fac9.receipt.json b/vision-fixhub/ds11-01/7ce9143d92c10bb78794ffdbef3bb9f65659492b1b4c12aeb132ae828c62fac9.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..cfcbc6dc451d54a31263d6fde598278f9c9a3450 --- /dev/null +++ b/vision-fixhub/ds11-01/7ce9143d92c10bb78794ffdbef3bb9f65659492b1b4c12aeb132ae828c62fac9.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -138, + "dataset": "marble-joined", + "doc_id": "7ce9143d92c10bb78794ffdbef3bb9f65659492b1b4c12aeb132ae828c62fac9", + "engine": "marble-apple-vision", + "event_count": 8, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "78b749ec0ef2d2ea769d283020d3d9157416ac9021897da54337fe57fb78ec4c", + "output_sha256": "bfd2cd7206e77c1bd8eebaf64a60df4f769c1896be022eeeb84f0b68dc2c1182", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/7d37ef6b33e7c7da6fb65a9b38e356dcc3143bb25e314d76a5a733a596028e0b.md b/vision-fixhub/ds11-01/7d37ef6b33e7c7da6fb65a9b38e356dcc3143bb25e314d76a5a733a596028e0b.md new file mode 100644 index 0000000000000000000000000000000000000000..9ea4a10f67289c1d48bf4b2a72b237bdb2f94428 --- /dev/null +++ b/vision-fixhub/ds11-01/7d37ef6b33e7c7da6fb65a9b38e356dcc3143bb25e314d76a5a733a596028e0b.md @@ -0,0 +1,5 @@ +From: +Subject: +Alert - Can Nadia see JE today or tomorrow? Terje's friend +May 18, 2017 1:00 PM : Can Nadia see JE today or tomorrow? Terje's friend +EFTA_R1_00936345 diff --git a/vision-fixhub/ds11-01/7d37ef6b33e7c7da6fb65a9b38e356dcc3143bb25e314d76a5a733a596028e0b.receipt.json b/vision-fixhub/ds11-01/7d37ef6b33e7c7da6fb65a9b38e356dcc3143bb25e314d76a5a733a596028e0b.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..58c5f7e596948dc5314e38f3f74457ceefb6f0a9 --- /dev/null +++ b/vision-fixhub/ds11-01/7d37ef6b33e7c7da6fb65a9b38e356dcc3143bb25e314d76a5a733a596028e0b.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "7d37ef6b33e7c7da6fb65a9b38e356dcc3143bb25e314d76a5a733a596028e0b", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "c6c0caf1f4acf6869b7f65e0d35837acadb46b75bdcf3b9e38183c6a8938d108", + "output_sha256": "7a005a2bb60059e78e006c2c3102985e06e69704b9e8c6f3602fb0bf803dad8a", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/801d8126bcc417cd977ef0db1318dca946943b0ce8ab3cf2d11e29cfbf64ff49.md b/vision-fixhub/ds11-01/801d8126bcc417cd977ef0db1318dca946943b0ce8ab3cf2d11e29cfbf64ff49.md new file mode 100644 index 0000000000000000000000000000000000000000..4c3d577f8c3d96a688664b307e0cb471cb28f794 --- /dev/null +++ b/vision-fixhub/ds11-01/801d8126bcc417cd977ef0db1318dca946943b0ce8ab3cf2d11e29cfbf64ff49.md @@ -0,0 +1,24 @@ +To: +From: +Sent: +Steve Hanson| +Fri 5/19/2017 6:20:59 PM +Subject: 4pm ok for you? +Well, I spoke to soon! +Jeffrey just called me and said 7:30pm is too late…ca +ou come see him at 4pm? He savs he should be home by then. let me know +> on May 19, 2017, at 2:00 PM, Stephen Hanson | +wrote: +> +> • can I actually come at 730 2? Or hair before z +> +> Sent from my iPad +> +>> On May 19, 2017, at 11:55 AM, +wrote: +>> +» Hi Steve please come see Jeffrey at 7:15pm instead of 7pm..having to do a tiny +adjustment with schedule! +>> +>> Thanks, +EFTA_R1_00936335 diff --git a/vision-fixhub/ds11-01/801d8126bcc417cd977ef0db1318dca946943b0ce8ab3cf2d11e29cfbf64ff49.receipt.json b/vision-fixhub/ds11-01/801d8126bcc417cd977ef0db1318dca946943b0ce8ab3cf2d11e29cfbf64ff49.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..397061ccf93225c85f61f83573b6262af62363d9 --- /dev/null +++ b/vision-fixhub/ds11-01/801d8126bcc417cd977ef0db1318dca946943b0ce8ab3cf2d11e29cfbf64ff49.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "801d8126bcc417cd977ef0db1318dca946943b0ce8ab3cf2d11e29cfbf64ff49", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "4b01c3ee029e2bec2e5b1181fa1522f4e7fd4dd7f00a8d61f86458393b5206cf", + "output_sha256": "ec8908effe56bd880d21ca9e3ae483aaa97c2443976f06248e0bae1ffefda355", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/9610164d3599861f8496e2689eab7cda6afbc2b28300c14d559920186acc0064.md b/vision-fixhub/ds11-01/9610164d3599861f8496e2689eab7cda6afbc2b28300c14d559920186acc0064.md new file mode 100644 index 0000000000000000000000000000000000000000..9f90f5872a23d179bd1cb9d5b46b8c809816c60d --- /dev/null +++ b/vision-fixhub/ds11-01/9610164d3599861f8496e2689eab7cda6afbc2b28300c14d559920186acc0064.md @@ -0,0 +1,130 @@ +To: +Lesley Groffi +From: +Mon 4/24/2017 4:34:56 PM +Subject: Re: Itinerary for +27APR17 +Lesley can you send me please, new ticket back to Moscow? +пн, 24 апр. 2017г. в 12:06, Lesley Groff < +check in prior to going to airport to get yourself a seat....it is under airport control... +On Apr 24, 2017, at 11:58 AM, +wrote: +Thank you Lesley +пн, 24 апр. 2017г. в 11:56, Lesley Groff _ +Hi +...here is your ticket to come back to NY on Thursday April +27th... please confirm back receipt... thanks! +Begin forwarded message: +From: "American Express Travel" +avel.d +< +Subject: Itinerary for +Date: April 24. 2017 at 10:51:01 AM EDT +To: +27APR17 +DO NOT REPLY TO THIS EMAIL. This message was sent from a +notification only address that cannot accept incoming +messages. If you have any questions, please contact +Centurion Travel Service at 1-877-877-0987. +If airline tickets are purchased for this itinerary: +Airline Baggage Fee/Rules may apply and can be accessed by visiting: +https://myamextravel.com/baggage +Your travel arrangements are outlined below in the email. Please refer +to the PDF attachment and itinerary for more details +regarding your travel arrangements. Your Centurion Travel +Service travel plans have been posted to a secure website. +Please click on the link to view your trip details and add link +to your bookmarked favorites for easy access in the future: +View your Digital Itinerary +EFTA_R1_00936296 + + +American Express Travel | +Record Locator +Thursday 27 Apr 17 +Other Information +CITIZENS OF RUSSIAN FEDERATION MUST CARRY A VALID PASSPORT +Flight Information +Date +Airline +Airline Record Locator +Flight/Class +Origin +Destination +Departing +Arriving +Arrival Terminal +Estimated Time +Stops +Seats +Confirmed +27 Apr 2017 +American Airlines +AA 936 Q Economy Class +Charlotte Amalie, Cyril E King Airport +New York, John F Kennedy International +02:15 PM +06:32 PM +Terminal 8 +4 Hrs 17 Mins +Non-stop +Unassigned +Entry and Exit Information for Travel +American Express strongly recommends that you periodically review +www.Visacentral.com/amex for the most up to date and accurate entry/exit +requirements for your travel destination. Due to frequent changes, American Express +cannot guarantee the accuracy of the information provided and expressly disclaims any +liability for any inaccurate or incomplete information contained on that site. +You may receive customer service emails even if you have requested not to receive +email marketing offers from American Express. For details about our e-mail practices, +please review the American Express Privacy Statement at +www.americanexpress.com/privacy +EFTA_R1_00936297 + + +See attached itinerary PDF or link for full terms and conditions. +PDF itinerary attachment: +If you are unable to view the PDF attachment, ensure you have Adobe Acrobat Reader. +Refer to website below to download and install this free software. +http://www.adobe.com/products/acrobat/readstep.html +Thank you for choosing American Express Centurion Travel Service and have a +pleasant trip. +Please be advised that certain mandatory hotel-imposed charges, including, but not +limited to, daily resort or facility fees, may be applicable to your stay and payable to the +hotel operator at check-out from the property. You may wish to inquire with the hotel +before your trip regarding the existence and amount of such charges. +Liability Statement. American Express Travel Related Services Company, Inc. and its +parent, subsidiaries, affiliates and representatives (collectively, "Amex") act as an agent +for travel suppliers and you understand and agree that Amex shall not be liable for any +loss, injury, expense or damage to persons or property resulting, directly or indirectly, +from (1) the acts of omissions of travel suppliers, including but not limited to delays, +overbooking's, cancellation of services, cessation of operations, accidents or failures of +equipment, or changes in fares, itineraries or schedules; or (2) acts of God, fires, +earthquakes, floods, climatic aberrations, acts of governmental authorities, civil unrest, +strikes, riots, theft, disease, accidents or failures related to the public internet, +telecommunications lines or facilities, or third party technology systems, or any other +cause beyond the control of Amex. +Intermediary Disclosure. Amex assists you in finding travel suppliers and making +arrangements that meet your individual needs. We consider various factors in +identifying travel suppliers to you and recommending specific itineraries. In this role, we +are acting as an independent third party and not as a fiduciary. We want you to be +aware that certain suppliers pay us commissions as well as incentives for reaching +sales targets or other goals, and from time to time may also provide incentives to our +travel counselors. Certain suppliers may also provide compensation to us for various +marketing and administrative services that we perform for them, such as granting them +access to our marketing channels, participating in marketing programs and supporting +technology initiatives. In addition, we receive compensation from suppliers when +customers use the American Express Card or other American Express products to pay +for supplier products and services. From time to time we may enter into other business +relationships with suppliers and these arrangements, including levels and types of +compensation and incentives we receive, are subject to change. In identifying suppliers +and recommending itineraries, we may consider a number of factors, including supplier +availability and your preferences. The relationships we have with suppliers may also +influence the suppliers we identify and the itineraries we recommend. +EFTA_R1_00936298 + + +California State Seller of Travel Registration Number: 1022318. Washington State +Seller of Travel Registration Number: UBI#600469694. Iowa: TA# 669 Registered lowa +Travel Agency. +EFTA_R1_00936299 diff --git a/vision-fixhub/ds11-01/9610164d3599861f8496e2689eab7cda6afbc2b28300c14d559920186acc0064.receipt.json b/vision-fixhub/ds11-01/9610164d3599861f8496e2689eab7cda6afbc2b28300c14d559920186acc0064.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..19247b22ab7997575d2fe91d9eb6861a39c233d3 --- /dev/null +++ b/vision-fixhub/ds11-01/9610164d3599861f8496e2689eab7cda6afbc2b28300c14d559920186acc0064.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -48, + "dataset": "marble-joined", + "doc_id": "9610164d3599861f8496e2689eab7cda6afbc2b28300c14d559920186acc0064", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "5349b0ad063e4c9fa8d450f974dff8cdfd29b3625048fed29654cfb06f218457", + "output_sha256": "50c1740997a58d97486f73883d8161adaea00b6a885ec361607590405bef8849", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/9f65c4be36d6913fdb827d49198e69fdf6f96233b2ebb48c068e32a782bdf096.md b/vision-fixhub/ds11-01/9f65c4be36d6913fdb827d49198e69fdf6f96233b2ebb48c068e32a782bdf096.md new file mode 100644 index 0000000000000000000000000000000000000000..1b9dac9bae79cb986260ce2cf20a4f895965a047 --- /dev/null +++ b/vision-fixhub/ds11-01/9f65c4be36d6913fdb827d49198e69fdf6f96233b2ebb48c068e32a782bdf096.md @@ -0,0 +1,8 @@ +From: +Subject: Alert - Flight to West Palm Beach (DL 898) +May 21, 2017 10:20 AM : Flight to West Palm Beach (DL 898) +To see detailed information for automatically created events like this one, use the official Google +Calendar app. https://g.co/calendar +This event was created from an email you received in Gmail. +https://mail.google.com/mail?extsrc=cal&plid=ACUX6DPFD8cCB7np7TLsB_1YjltIrS3uOcJc1Q +EFTA_R1_00936302 diff --git a/vision-fixhub/ds11-01/9f65c4be36d6913fdb827d49198e69fdf6f96233b2ebb48c068e32a782bdf096.receipt.json b/vision-fixhub/ds11-01/9f65c4be36d6913fdb827d49198e69fdf6f96233b2ebb48c068e32a782bdf096.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..f4aafbb1b7ae9bac3a8f190b9b3057b68a21166c --- /dev/null +++ b/vision-fixhub/ds11-01/9f65c4be36d6913fdb827d49198e69fdf6f96233b2ebb48c068e32a782bdf096.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "9f65c4be36d6913fdb827d49198e69fdf6f96233b2ebb48c068e32a782bdf096", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "7a28dfb9f08b5d3cbc6ecdaedcc59763a2b51bb2d25b7ffad2b6f95f54e6f3ea", + "output_sha256": "e991aed0855e5b2592548336e31b4e0e04541dbb6291498f32a68110dcec047f", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/a099de3297352f8608b1e68de345dc9c256578b8058c9b2833caac2a4ad3ac26.md b/vision-fixhub/ds11-01/a099de3297352f8608b1e68de345dc9c256578b8058c9b2833caac2a4ad3ac26.md new file mode 100644 index 0000000000000000000000000000000000000000..9f71e1ee538d8c43dc816b19102013e5bd917302 --- /dev/null +++ b/vision-fixhub/ds11-01/a099de3297352f8608b1e68de345dc9c256578b8058c9b2833caac2a4ad3ac26.md @@ -0,0 +1,22 @@ +To: +Karyna Shuliakl +From: +Sent: +Sun 5/21/2017 2:22:34 PM +Subject: Re: Flight dates +On May 20, 2017, at 12:38 PM, Karyna Shuliak < +wrote: +Lesley, Jeffrey asked to also book for Friday if possible please, but keep Thursday for +now. +Thanks so much! +On May 20, 2017, at 9:59 AM, +wrote: +let me know if we should change! :) +On May 19. 2017 at 9:02 PM, Karyna Shuliak +1> wrote: +My current flight to the island is booked for Thursday as you asked, should +we rebook for Friday? since my visa appointment is on +Wednesday and I will most likely be able to pick up my +passport next day, which would be Thursday (it is usually +late afternoon)... +EFTA_R1_00936385 \ No newline at end of file diff --git a/vision-fixhub/ds11-01/a099de3297352f8608b1e68de345dc9c256578b8058c9b2833caac2a4ad3ac26.receipt.json b/vision-fixhub/ds11-01/a099de3297352f8608b1e68de345dc9c256578b8058c9b2833caac2a4ad3ac26.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..647d797d1dd7e4082a1992c98af7e7cac549a743 --- /dev/null +++ b/vision-fixhub/ds11-01/a099de3297352f8608b1e68de345dc9c256578b8058c9b2833caac2a4ad3ac26.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": 0, + "dataset": "marble-joined", + "doc_id": "a099de3297352f8608b1e68de345dc9c256578b8058c9b2833caac2a4ad3ac26", + "engine": "marble-apple-vision", + "event_count": 0, + "fix_ids": "[]", + "idempotent": true, + "input_sha256": "e52370c9658b44cfad0ddd4c14339a902413f384532a3989205d2607fed67af4", + "output_sha256": "e52370c9658b44cfad0ddd4c14339a902413f384532a3989205d2607fed67af4", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/a77eb633e1692b9ea01b147b17e86fed418b61cb4043d936ecf694349609a7b0.md b/vision-fixhub/ds11-01/a77eb633e1692b9ea01b147b17e86fed418b61cb4043d936ecf694349609a7b0.md new file mode 100644 index 0000000000000000000000000000000000000000..0d1d43bcdc16540f9fd786db28bb887530abe838 --- /dev/null +++ b/vision-fixhub/ds11-01/a77eb633e1692b9ea01b147b17e86fed418b61cb4043d936ecf694349609a7b0.md @@ -0,0 +1,6 @@ +To: +From: +Subject: +Alert - 2pm try to call Leon +May 23, 2017 2:00 PM : 2pm try to call Leon +EFTA_R1_00936396 \ No newline at end of file diff --git a/vision-fixhub/ds11-01/a77eb633e1692b9ea01b147b17e86fed418b61cb4043d936ecf694349609a7b0.receipt.json b/vision-fixhub/ds11-01/a77eb633e1692b9ea01b147b17e86fed418b61cb4043d936ecf694349609a7b0.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..6fb78c5aae2eb5c25128ed412e387234a50c8279 --- /dev/null +++ b/vision-fixhub/ds11-01/a77eb633e1692b9ea01b147b17e86fed418b61cb4043d936ecf694349609a7b0.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": 0, + "dataset": "marble-joined", + "doc_id": "a77eb633e1692b9ea01b147b17e86fed418b61cb4043d936ecf694349609a7b0", + "engine": "marble-apple-vision", + "event_count": 0, + "fix_ids": "[]", + "idempotent": true, + "input_sha256": "7f48d08767037228f2291bcc85446e9a86c6ccd86fa658f66bd6a0e148d3b854", + "output_sha256": "7f48d08767037228f2291bcc85446e9a86c6ccd86fa658f66bd6a0e148d3b854", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/af2fd371e9786063c83adb61589b092024c5adc0d80c1d8ff1e5465b71dfff98.md b/vision-fixhub/ds11-01/af2fd371e9786063c83adb61589b092024c5adc0d80c1d8ff1e5465b71dfff98.md new file mode 100644 index 0000000000000000000000000000000000000000..7b302918af7b555022764d74aab9de5011d264ae --- /dev/null +++ b/vision-fixhub/ds11-01/af2fd371e9786063c83adb61589b092024c5adc0d80c1d8ff1e5465b71dfff98.md @@ -0,0 +1,31 @@ +To: +From: +Sent: +Karyna Shuliak +Tue 5/16/2017 8:15:29 PM +Subject: Re: Reservations for visa +f course.I let our Amex, Natasha rep, know…she is quite busy with urgent item. +t the moment but promises to get to it by end of her day (which is around 6 o +7pm I believe..) We may see it tomorrow morning. I will keep on top of it. +> On May 16, 2017, at 4:04 PM, Karyna Shuliak +wrote: +> Thank you!! +>> On May 16, 2017, at 3:47 PM, +wrote: +>> +›> Of course! will do so now for you.. +>> +>>> On May 16, 2017, at 3:26 PM, Karyna Shuliak +> wrote: +>>> +›>> Hil +>>> I hope you are feeling well after the procedure. +›>> Lesley, if you are back to work, could you please help me with reservations +for schengen visa. If you could please book any flight and hotel in Paris +arrival on May 27th and staying for a week until June 3rd. I will need it for my +visa appointment on May 24th. +>>> Thank you so much! +>>> +>>> Karyna +>> +EFTA_R1_00936337 \ No newline at end of file diff --git a/vision-fixhub/ds11-01/af2fd371e9786063c83adb61589b092024c5adc0d80c1d8ff1e5465b71dfff98.receipt.json b/vision-fixhub/ds11-01/af2fd371e9786063c83adb61589b092024c5adc0d80c1d8ff1e5465b71dfff98.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..268d9af977d05dc229cf6f9bdfba14d42f2b1473 --- /dev/null +++ b/vision-fixhub/ds11-01/af2fd371e9786063c83adb61589b092024c5adc0d80c1d8ff1e5465b71dfff98.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": 0, + "dataset": "marble-joined", + "doc_id": "af2fd371e9786063c83adb61589b092024c5adc0d80c1d8ff1e5465b71dfff98", + "engine": "marble-apple-vision", + "event_count": 0, + "fix_ids": "[]", + "idempotent": true, + "input_sha256": "3b42e4cb090a60304a25c35636d643bf252b75457befe84dae8b1d1163978f74", + "output_sha256": "3b42e4cb090a60304a25c35636d643bf252b75457befe84dae8b1d1163978f74", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/b4ad7b1d9433b300bd5a241ae9c8a292e39a3278ed3684225d8255ab355a25fb.md b/vision-fixhub/ds11-01/b4ad7b1d9433b300bd5a241ae9c8a292e39a3278ed3684225d8255ab355a25fb.md new file mode 100644 index 0000000000000000000000000000000000000000..07f8e143ea9bbb585498116c28ec17ba08efe71e --- /dev/null +++ b/vision-fixhub/ds11-01/b4ad7b1d9433b300bd5a241ae9c8a292e39a3278ed3684225d8255ab355a25fb.md @@ -0,0 +1,6 @@ +To: +From: +Sent: +jeffrey E +Sat 5/13/2017 12:40:38 PM +Send aziza 23and me diff --git a/vision-fixhub/ds11-01/b4ad7b1d9433b300bd5a241ae9c8a292e39a3278ed3684225d8255ab355a25fb.receipt.json b/vision-fixhub/ds11-01/b4ad7b1d9433b300bd5a241ae9c8a292e39a3278ed3684225d8255ab355a25fb.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..6ab36306df2149e02c4b15d1b472f87916569b91 --- /dev/null +++ b/vision-fixhub/ds11-01/b4ad7b1d9433b300bd5a241ae9c8a292e39a3278ed3684225d8255ab355a25fb.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -614, + "dataset": "marble-joined", + "doc_id": "b4ad7b1d9433b300bd5a241ae9c8a292e39a3278ed3684225d8255ab355a25fb", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.disclaimer-removal.please-note-florida\"]", + "idempotent": true, + "input_sha256": "2866fa3e701298305c7da9f473642fdb6736acc74ccf0d539b7a6621d6765ec6", + "output_sha256": "d8a86017507c7b21a5e830365d5f7c2140d9a5dd6b8a7642b2814300faf0fcdf", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/b520dad0e407fdd3d375e7472f1e3bb332410bed3164cff9385fda7083e345be.md b/vision-fixhub/ds11-01/b520dad0e407fdd3d375e7472f1e3bb332410bed3164cff9385fda7083e345be.md new file mode 100644 index 0000000000000000000000000000000000000000..380ba51cfe165de51d92aa66a105475538030345 --- /dev/null +++ b/vision-fixhub/ds11-01/b520dad0e407fdd3d375e7472f1e3bb332410bed3164cff9385fda7083e345be.md @@ -0,0 +1,63 @@ +To: +Rich Kahni +From: +Sent: +Mon 5/1/2017 6:43:26 PM +Subject: Re: christopher +ah thanks! I will keep as well for just in case! +On May 1, 2017, at 2:41 PM, Richard Kahn 4 +received from jee +thanks +FYR +Richard Kahn +HBRK Associates Inc. +575 Lexington Avenue 4th Floor +New York, NY 10022 +Begin forwarded message: +From: Karyna Shuliak +Date: May 1, 2017 at 2:27:36 PM EDT +To: Jeffrey , Richard Kahn + +Hi Rich, +Here is their store contact info. Thank you. + +On May 1, 2017, at 2:15 PM, jeffrey E. + wrote: +- Forwarded messag-------- +From: Richard Kahn < richardkahn12@gmail.com> +Date: Mon, May 1, 2017 at 2:14 PM +Subject: Re: +• wrote: +EFTA_R1_00936493 + + +To: "jeffrey E." +can you please send his contact info as lesley does not have it +thank you +Richard Kahn +HBRK Associates Inc. +575 Lexington Avenue 4th Floor +New York, NY 10022 +tel 212-971-1306 +fax 212-320-0381 +cell 917-414-7584 +call christtpher hyland. +On May 1, 2017, at 1:57 PM, jeffrey E. + wrote: +ask for christoper get the exact name of the +met opera charity and send 50k from +gratitude TODAY if possible +please note +The information contained in this communication is +confidential, may be attorney-client privileged, may +constitute inside information, and is intended only for +the use of the addressee. It is the property of +JEE +Unauthorized use, disclosure or copying of this +communication or any part thereof is strictly prohibited +and may be unlawful. If you have received this +communication in error, please notify us immediately by +return e-mail or by e-mail to jeevacation@gmail.com, and +destroy this communication and all copies thereof, +including all attachments. copyright -all rights reserved +-- diff --git a/vision-fixhub/ds11-01/b520dad0e407fdd3d375e7472f1e3bb332410bed3164cff9385fda7083e345be.receipt.json b/vision-fixhub/ds11-01/b520dad0e407fdd3d375e7472f1e3bb332410bed3164cff9385fda7083e345be.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..9287271445fd9b2387a8d1dbcf745fd5023b03d2 --- /dev/null +++ b/vision-fixhub/ds11-01/b520dad0e407fdd3d375e7472f1e3bb332410bed3164cff9385fda7083e345be.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -657, + "dataset": "marble-joined", + "doc_id": "b520dad0e407fdd3d375e7472f1e3bb332410bed3164cff9385fda7083e345be", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.disclaimer-removal.please-note-florida\"]", + "idempotent": false, + "input_sha256": "0ab1d23383f2ddd3ff36b99013a5388be4df571f1ec7b65da2a6de77d859b09d", + "output_sha256": "907203178c9d6aea506d82ac956386f3deed43f534a1e28116de068320156baf", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/bb92f2e71d89d5b7306d7df646829d229439cd70c3f0ab36fc4e19b79350f508.md b/vision-fixhub/ds11-01/bb92f2e71d89d5b7306d7df646829d229439cd70c3f0ab36fc4e19b79350f508.md new file mode 100644 index 0000000000000000000000000000000000000000..1e854e5e052dd6187542eee8763696774230fdf1 --- /dev/null +++ b/vision-fixhub/ds11-01/bb92f2e71d89d5b7306d7df646829d229439cd70c3f0ab36fc4e19b79350f508.md @@ -0,0 +1,11 @@ +To: +From: +jeffrey E +Sent: +Thur 5/18/2017 4:52:01 PM +Subject: Re: Dr. Bard +tell her i will see them on jne 3 if they are n florida +On Thu, May 18, 2017 at 12:47 PM, +wrote: +Laura, Dr. Bard's wife, called...she said Dr. Bard is wondering how you are as they have not +heard from you in awhile...they are checking up on you. diff --git a/vision-fixhub/ds11-01/bb92f2e71d89d5b7306d7df646829d229439cd70c3f0ab36fc4e19b79350f508.receipt.json b/vision-fixhub/ds11-01/bb92f2e71d89d5b7306d7df646829d229439cd70c3f0ab36fc4e19b79350f508.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..b60120e8a42e85777bbc128f95fcf7cf460ebe4b --- /dev/null +++ b/vision-fixhub/ds11-01/bb92f2e71d89d5b7306d7df646829d229439cd70c3f0ab36fc4e19b79350f508.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -627, + "dataset": "marble-joined", + "doc_id": "bb92f2e71d89d5b7306d7df646829d229439cd70c3f0ab36fc4e19b79350f508", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.disclaimer-removal.please-note-florida\"]", + "idempotent": true, + "input_sha256": "4f80c6d7c4f415d328b4046b3f00d65f300823b1cc3c416f6721b9dcc8ab0b79", + "output_sha256": "920ca84f8b9607ff9adf3753e5922cafc8f7873a15ad053a2a97e105068510db", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/bf4afa9cbeea7b612b3e8417259e1172029321a40c9e082db9123afbc655e36f.md b/vision-fixhub/ds11-01/bf4afa9cbeea7b612b3e8417259e1172029321a40c9e082db9123afbc655e36f.md new file mode 100644 index 0000000000000000000000000000000000000000..065d30551ab5f323de430d94fb1e2f31d422fd51 --- /dev/null +++ b/vision-fixhub/ds11-01/bf4afa9cbeea7b612b3e8417259e1172029321a40c9e082db9123afbc655e36f.md @@ -0,0 +1,64 @@ +To: +From: +Natalia Molotova +Sent: +Tue 5/16/2017 8:20:06 PM +Subject: Ticket for +May 21-29 +Title: American Express ® +OK, non refundable coach, DL - $200 change fee, Jet Blue - $150.00. +Regards, +Natalia (Natasha) Molotkova +Centurion Relationship Manager +lours: Mon, Wed 9a-4p, 530p-7 +ue, Thur, Fri 9a - 530p ES +Perfect! Please issue ticket! +thanks +On May 16, 2017, at 4:01 PM. Natalia Molekova +> wrote: +Outbound flight: +DL +898 21MAY LGA PBI 1020A 0128P +TOTAL FARE - USD 206.20 +Return +B6 +62 29MAY PBI LGA 0958A 1248P +TOTAL FARE - USD 278.80 +Regards, +Natalia (Natasha) Molotkova +Centurion Relationship Manager +Hours: Mon, Wed 9a-4p, 530p-7p +Tue, Thur, Fri 9a - 530p EST +EFTA_R1_00936402 + +I figured as much! thanks +On May 16, 2017. at 3:58 PM. Natalia Molotkova +wrote: +Thank you for reminding, it is still on my to do list, got so much stuff for travel sooner, on it right +Regards, +Natalia (Natasha) Molotkova +Centurion Relationship Manager +Hours: Mon, Wed 9a-4p, 530p-7p +Tue, Thur, Fri 9a - 530p EST +Hi Natasha...I think this may have slipped through...never rec'd any ticket info back from you! +On May 16, 2017. at 9:14 AM. Natalia Molotkova +> wrote: +Morning, on it. +Regards, +Natalia (Natasha) Molotkova +Centurion Relationship Manager +Hours: Mon, Wed 9a-4p, 530p-7p +Tue, Thur, Fri 9a - 530p EST +Morning! We need a round trip, coach ticket for +I to fly from NY to FL (preferably +LGA) May 21 return May 29. Flight on 21st around 11am or so...flight on 29th around +10am...Timing is flexible however... What is best price for these dates..? Thanks! +EFTA_R1_00936403 + + +Privacy Statement | Visit the Centurion Card website +To learn more about e-mail security or report a suspicious e-mail, please visit us at americanexpress.com/phishing. +© 2015 American Express. All rights reserved +American Express uses 3rd party concierge service providers who are not authorized to act on behalf of American Express +reserve the right to note profile and preference data for servicing purposes. +EFTA_R1_00936404 \ No newline at end of file diff --git a/vision-fixhub/ds11-01/bf4afa9cbeea7b612b3e8417259e1172029321a40c9e082db9123afbc655e36f.receipt.json b/vision-fixhub/ds11-01/bf4afa9cbeea7b612b3e8417259e1172029321a40c9e082db9123afbc655e36f.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..9d32e59a7d8b541a10b9cbd1e1629068701a6d2b --- /dev/null +++ b/vision-fixhub/ds11-01/bf4afa9cbeea7b612b3e8417259e1172029321a40c9e082db9123afbc655e36f.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "bf4afa9cbeea7b612b3e8417259e1172029321a40c9e082db9123afbc655e36f", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "9c0080dc743b28f869d85b6296de3918add0eac8a2fa260177da134c8c62d642", + "output_sha256": "13f2d7cfe9737dd23210cf44cc48d184124f6ee31b7bafe66fd584d78f1e590e", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/c98f73247ef1a50dbae37452323cde5871fa02a6ddd361fa3e9600d7c5bccc1e.md b/vision-fixhub/ds11-01/c98f73247ef1a50dbae37452323cde5871fa02a6ddd361fa3e9600d7c5bccc1e.md new file mode 100644 index 0000000000000000000000000000000000000000..6a0cec4d09b1ad3daccb4cc33546848e60acbf62 --- /dev/null +++ b/vision-fixhub/ds11-01/c98f73247ef1a50dbae37452323cde5871fa02a6ddd361fa3e9600d7c5bccc1e.md @@ -0,0 +1,19 @@ +From: +Jefffrey Epsteinfieevacation@gmail.com] +Subject: +Tue 4/25/2017 8:53:59 PM +Matthew Hiltzik +Matthew unfortunately cannot make a May 2nd appt....his first availability is Friday May 5th at +4:30 (we have been going back and forth on this all day). He and his colleague, Ben Sosenko, are +confirmed to come see you at 4:30pm on Friday May 5th.. +Fri. May 5, 2017 NY +- +4:30pm Appt w/Matthew Hiltzik and his colleague, Ben Sosenko +6:30pm Doors Open for Terje's Opening of: Oslo +7:00pm Performance of Oslo +Lincoln Center Theater's Broadway Production +At the Vivian Beaumont Theater at Lincoln Center +150 West 65" Street (between Broadway & Amsterdam) +YOU HAVE 4 SEATS +Jojo to drive you!!! +EFTA_R1_00936312 \ No newline at end of file diff --git a/vision-fixhub/ds11-01/c98f73247ef1a50dbae37452323cde5871fa02a6ddd361fa3e9600d7c5bccc1e.receipt.json b/vision-fixhub/ds11-01/c98f73247ef1a50dbae37452323cde5871fa02a6ddd361fa3e9600d7c5bccc1e.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..09eac65dd0889339a3655f75316e9de5935f3dfe --- /dev/null +++ b/vision-fixhub/ds11-01/c98f73247ef1a50dbae37452323cde5871fa02a6ddd361fa3e9600d7c5bccc1e.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": 0, + "dataset": "marble-joined", + "doc_id": "c98f73247ef1a50dbae37452323cde5871fa02a6ddd361fa3e9600d7c5bccc1e", + "engine": "marble-apple-vision", + "event_count": 0, + "fix_ids": "[]", + "idempotent": true, + "input_sha256": "8c949c24d09b0e31115dc40f39a8fc09f1f20f5d4fbaa4e6d7ba6acbe4288dc0", + "output_sha256": "8c949c24d09b0e31115dc40f39a8fc09f1f20f5d4fbaa4e6d7ba6acbe4288dc0", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/d26995656e24e3729e27f6eae46fa77a4f727b03dbfa14c4795561d7d1cfd9e2.md b/vision-fixhub/ds11-01/d26995656e24e3729e27f6eae46fa77a4f727b03dbfa14c4795561d7d1cfd9e2.md new file mode 100644 index 0000000000000000000000000000000000000000..ef860073e53d94dac4c1801e5a2c945aed522360 --- /dev/null +++ b/vision-fixhub/ds11-01/d26995656e24e3729e27f6eae46fa77a4f727b03dbfa14c4795561d7d1cfd9e2.md @@ -0,0 +1,37 @@ +To: +From: +Tes +Sent: +Wed 5/3/2017 12:54:20 PM +Subject: Re: Clean 7J, 3M +Changing the linen and clean the shower. Next is 3M it willprobably take time to +elean after the 2 girls and +• I have to wash it up good and +and I'11 be checking the rest of the guest apartment. Thank you. +Sent from my iphone +> On May 3, 2017, at 8:35 AM, +wrote: +> +> ok. BA you are just checking on and 7J was barely used. You should be ok! +> +> +Sent from my iPhone +> +>> On May 3, 2017, at 8:19 AM, Tes +wrote: +>> +>> So I have 7J, +3M, +and 8A +>> +›> Sent from my iPhone +>> +>>> On May 3, 2017, at 7:31 AM, +wrote: +>>> +>>> Morning. Please clean 7J and 3M today. I know you are to clean +as well. .. anything else still needs to be done? +>>> +>>> Sent from my iPhone +apt +EFTA_R1_00936478 diff --git a/vision-fixhub/ds11-01/d26995656e24e3729e27f6eae46fa77a4f727b03dbfa14c4795561d7d1cfd9e2.receipt.json b/vision-fixhub/ds11-01/d26995656e24e3729e27f6eae46fa77a4f727b03dbfa14c4795561d7d1cfd9e2.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..b7b33d7ba9a70e7d69ea4456bc6d1bb077d070e5 --- /dev/null +++ b/vision-fixhub/ds11-01/d26995656e24e3729e27f6eae46fa77a4f727b03dbfa14c4795561d7d1cfd9e2.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "d26995656e24e3729e27f6eae46fa77a4f727b03dbfa14c4795561d7d1cfd9e2", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "582cc4e13421ee6da7174885ead6e2950874d3b7306cf85d9655a6f383f18626", + "output_sha256": "9114a9a683c7161de8d8255ba4ae8e9666d937fdf160c27db907e21facbc5449", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/db1a03c3310e01d7fec124239abbfe087c02504af3fe233f5a35bd9bda636743.md b/vision-fixhub/ds11-01/db1a03c3310e01d7fec124239abbfe087c02504af3fe233f5a35bd9bda636743.md new file mode 100644 index 0000000000000000000000000000000000000000..d1d4524a3092144040f2e9a62790d2e6e41a8198 --- /dev/null +++ b/vision-fixhub/ds11-01/db1a03c3310e01d7fec124239abbfe087c02504af3fe233f5a35bd9bda636743.md @@ -0,0 +1,13 @@ +To: +merwin dela cruz" +From: +Sent: +Thur 4/27/2017 11:10:34 AM +Subject: Jojo to take , +to airport Friday (tomorrow) +Morning Merwin. +go to the airport tomorrow at 2:15pm.I was going +to have Jojo take her…just want +to make sure you don't need him from about 2pm +on….is that ok? +EFTA_R1_00936455 diff --git a/vision-fixhub/ds11-01/db1a03c3310e01d7fec124239abbfe087c02504af3fe233f5a35bd9bda636743.receipt.json b/vision-fixhub/ds11-01/db1a03c3310e01d7fec124239abbfe087c02504af3fe233f5a35bd9bda636743.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..1ffebe5c4c1f8abbc9d561ee18ea7851e26f62ac --- /dev/null +++ b/vision-fixhub/ds11-01/db1a03c3310e01d7fec124239abbfe087c02504af3fe233f5a35bd9bda636743.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "db1a03c3310e01d7fec124239abbfe087c02504af3fe233f5a35bd9bda636743", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "28de5379f025ac4a4adb3a0ad160f82a13ba4e23037d969043981310a64935b8", + "output_sha256": "f2b3255047912097cc5877d98e9690b74f0781df63fc161cc06d44dcd5a26e08", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/db1d76d64719c21326556a4d517a27afe4d9aefa6f2d75a8818fd94245777ef7.md b/vision-fixhub/ds11-01/db1d76d64719c21326556a4d517a27afe4d9aefa6f2d75a8818fd94245777ef7.md new file mode 100644 index 0000000000000000000000000000000000000000..2ccbb10d2d9abfadb916ab95daaf376d05ab36cd --- /dev/null +++ b/vision-fixhub/ds11-01/db1d76d64719c21326556a4d517a27afe4d9aefa6f2d75a8818fd94245777ef7.md @@ -0,0 +1,33 @@ +To: +merwin dela cruz +From: +Sent: +Fri 4/28/2017 5:59:03 PM +Subject: Fwd: Leisure Fitness Equipment +Begin forwarded message: +From: Howard Olinsky +Subject: Leisure Fitness Equipment +Date: April 28, 2017 at 1:47:18 PM EDT +- +Leisure Fitness - Paramus, NJ +193 Route 17 South +Paramus, NJ 07652 +Hi Jeffrey, +Dear valued customer, +Our Paramus NJ Leisure Fitness will be officially closing on Saturday, April 27th. The next closes +location to you will be our store in Fairfield, NJ. +If you need any service or more fitness equipment, please contact Howard Olinsky, manager of our +Fairfield, NJ location. We are open Mon 10-8, Tues- Fri 10-7, Sat 10-6 and Sun 12-5 +Leisure Fitness +430 US Highway 46 East, Fairfield, NJ 07004 +Store Manager: Howard Olinsky +We thank you for your patronage and look forward to assisting you in anyway possible. +Sincerely. +Howard +EFTA_R1_00936394 + + +be fit. stay fit. live well. +Howard Olinsky +Store Manager +EFTA_R1_00936395 diff --git a/vision-fixhub/ds11-01/db1d76d64719c21326556a4d517a27afe4d9aefa6f2d75a8818fd94245777ef7.receipt.json b/vision-fixhub/ds11-01/db1d76d64719c21326556a4d517a27afe4d9aefa6f2d75a8818fd94245777ef7.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..91ab6a14360c86973bf3d42052bb39310c9dd5e3 --- /dev/null +++ b/vision-fixhub/ds11-01/db1d76d64719c21326556a4d517a27afe4d9aefa6f2d75a8818fd94245777ef7.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "db1d76d64719c21326556a4d517a27afe4d9aefa6f2d75a8818fd94245777ef7", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "a07919ffbdd7a50d44d09facdc7d9b08477e88484b08fcb9940e7252491b6778", + "output_sha256": "9e29f2b49a53508d466f25c8cc80957c14a9c91c8c61ca8f2c607c9562ff92a2", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/decb542e4008201b0d025d59716b12542a50700c563a28ef25455e7800a1afa5.md b/vision-fixhub/ds11-01/decb542e4008201b0d025d59716b12542a50700c563a28ef25455e7800a1afa5.md new file mode 100644 index 0000000000000000000000000000000000000000..00a4638dbc61a2a8abf87d134b81c2df07575bc0 --- /dev/null +++ b/vision-fixhub/ds11-01/decb542e4008201b0d025d59716b12542a50700c563a28ef25455e7800a1afa5.md @@ -0,0 +1,80 @@ +To: +From: +Sent: +Melanie Spinellal +Wed 5/3/2017 12:40:05 PM +Subject: Re: [External] Jeffrey Epstein +Ok. +Thx. +... I'm so ready for nice Weather on a daily basis! +Sent from my iPhone +> On May 3, 2017, at 8:32 AM, Melanie Spinella +wrote: +> Such a nice day - I haven't seen him yet -he landed this morning - he has not +said anything +•--Original Message----- +> From: +> Sent: Wednesday, May 03, 2017 7:41 AM +> To: Melanie Spinella +> Subject: Re: [External] Jeffrey Epstein +> Hi Melanie. Anything from Leon re coming to see Jeffrey either late today or +sometime tomorrow? +(Such a pretty day!!) +> Sent from my iPhone +> +»> on May 2, 2017, at 8:40 AM, Melanie Spinella +wrote: +>> +>> Good morning. Sorry no! +>> +>> +Sent from my iPhone +>> +>>> On May 2, 2017, at 7:32 AM, +wrote: +>>> +>>> Morning! Circling back... any word re leon coming to see jeffrey either wed +or thurs this week? +>>> Sent from my iPhone +>>> +>>>> On Apr 28, 2017, at 8:34 AM, Melanie Spinella +wrote: +>>>> +>>>> Nope! +>>>> +›>>> -----Original Message----- +>>>> From: +>>>> +Sent: +Friday, +April 28, 2017 7:58 AM +>>>> +To: Melanie Spinella +>>>> +Subject: [External] Jeffrey Epstein +>>>> +>>>> Morning Melanie did you hear back from leon re a meeting with Jeffrey next +Wed. or Thursday? Might something work? +>>>> +»>>> +>>> This email and any files transmitted with it are confidential and intende +olely for the person or entity to whom they are addressed and may contai +dissemination or other use of, +EFTA_R1_00936314 + + +›> This email and any files transmitted with it are confidential and intended +solely for the person or entity to whom they are addressed and may contain +onfidential and/or privileged material. Any review, retransmission, +dissemination or other use of, or taking of any action in reliance upon this +information by persons or entities other than the intended recipient is +prohibited. If you have received this email in error please contact the sender +and delete the material from any computer. Apollo Global Management, LLC +» This email and any files transmitted with it are confidential and intended +solely for the person or entity to whom they are addressed and may contain +confidential and/or privileged material. Any review, retransmission, +dissemination or other use of, or taking of any action in reliance upon this +information by persons or entities other than the intended recipient is +prohibited. If you have received this email in error please contact the sender +and delete the material from any computer. Apollo Global Management, LIC +EFTA_R1_00936315 diff --git a/vision-fixhub/ds11-01/decb542e4008201b0d025d59716b12542a50700c563a28ef25455e7800a1afa5.receipt.json b/vision-fixhub/ds11-01/decb542e4008201b0d025d59716b12542a50700c563a28ef25455e7800a1afa5.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..b1ca847671a8a56b7e4aeca25737d2862feec694 --- /dev/null +++ b/vision-fixhub/ds11-01/decb542e4008201b0d025d59716b12542a50700c563a28ef25455e7800a1afa5.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "decb542e4008201b0d025d59716b12542a50700c563a28ef25455e7800a1afa5", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "aaa07697f7f6c8655d341fcd2090df13a45965509da350ff0e17c35712f34c03", + "output_sha256": "1aed796a254468242b146c67875994d870f9ebc7146e389525a0d8ad05fbb400", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/df124642fe649aff0653a70c7c686385b9d855dd74c4aef61df8b196de33b29f.md b/vision-fixhub/ds11-01/df124642fe649aff0653a70c7c686385b9d855dd74c4aef61df8b196de33b29f.md new file mode 100644 index 0000000000000000000000000000000000000000..864f2c105f6c4b47811ff71fb992eb7ff79ad93e --- /dev/null +++ b/vision-fixhub/ds11-01/df124642fe649aff0653a70c7c686385b9d855dd74c4aef61df8b196de33b29f.md @@ -0,0 +1,16 @@ +To: +From: +Sent: +alerts@flightaware.com on behalf of "FlightAware Alerts" +Sat 5/6/2017 9:40:37 PM +Subject: +N415LM has departed KTEB for KPBI +N415LM (GLF5) departed Teterboro (KTEB) at 05:40PM EDT enroute to Palm Beach Intl +(KPBI) for an estimated arrival at 06:32PM EDT +For more information visit http://flightaware.com/live/flight/N415LM. +Want more flight alerts and great premium FlightAware features? Get a premium account - +http://flightaware.com/commercial/premium +To edit or disable these alerts please visit http://flightaware.com/account/manage/alerts/. +FlightAware +FlightAware - Eight Greenway Plaza - Suite 1300 - Houston Texas - 77046 - USA +1-713-877-9010 +EFTA_R1_00936474 diff --git a/vision-fixhub/ds11-01/df124642fe649aff0653a70c7c686385b9d855dd74c4aef61df8b196de33b29f.receipt.json b/vision-fixhub/ds11-01/df124642fe649aff0653a70c7c686385b9d855dd74c4aef61df8b196de33b29f.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..1fbfd2e74d9b731ef7d149e7075ecd7ea855c732 --- /dev/null +++ b/vision-fixhub/ds11-01/df124642fe649aff0653a70c7c686385b9d855dd74c4aef61df8b196de33b29f.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "df124642fe649aff0653a70c7c686385b9d855dd74c4aef61df8b196de33b29f", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "1b1f74f0a5c7512c2d2fc0ca3504815a28820ad987983ef2704d8785de45905f", + "output_sha256": "04a758c55e5564a42cde921262f1cc5a423dd69f3872c1d12f2a2b6df6e5d57a", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/dfe5664e7d11d8673730ba48a70026d7834341be7155838087c6f2aae8bb25ad.md b/vision-fixhub/ds11-01/dfe5664e7d11d8673730ba48a70026d7834341be7155838087c6f2aae8bb25ad.md new file mode 100644 index 0000000000000000000000000000000000000000..82b56f0d91154a3333ce3109df7d8dd591afda50 --- /dev/null +++ b/vision-fixhub/ds11-01/dfe5664e7d11d8673730ba48a70026d7834341be7155838087c6f2aae8bb25ad.md @@ -0,0 +1,15 @@ +Lesley Groffi +Subject: +Sat 5/13/2017 12:41:23 PM +Fwd: Tickets for the girlsto send to them +Hi Les! Is this for me? +- Forwarded message - +From: Lesley Groff < +Date: Sat, May 13, 2017 at 8:25 AM +Subject: Tickets for the girlsto send to them +To: Jeffrey Epstein , +I sent all the tickets for the girls to +receives your approval to do so. +Sent from my iPhone +and requested she send them on to cach girl once she +EFTA_R1_00936453 \ No newline at end of file diff --git a/vision-fixhub/ds11-01/dfe5664e7d11d8673730ba48a70026d7834341be7155838087c6f2aae8bb25ad.receipt.json b/vision-fixhub/ds11-01/dfe5664e7d11d8673730ba48a70026d7834341be7155838087c6f2aae8bb25ad.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..7c8e38cf57314edb12f2e11188feedfcc7754947 --- /dev/null +++ b/vision-fixhub/ds11-01/dfe5664e7d11d8673730ba48a70026d7834341be7155838087c6f2aae8bb25ad.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -4, + "dataset": "marble-joined", + "doc_id": "dfe5664e7d11d8673730ba48a70026d7834341be7155838087c6f2aae8bb25ad", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "1d4d62f87e8fe212df62737358e7cfd8ea7c02cc16ad9f5cbf05978e1be05384", + "output_sha256": "7b85e7c481be48d618f94953267eea4f976ab1954fb969dccabc874482d0a8c7", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/e22d7fbf75e25e07a6957f3ad5273c074012db7915756ad99b59f083f99890cd.md b/vision-fixhub/ds11-01/e22d7fbf75e25e07a6957f3ad5273c074012db7915756ad99b59f083f99890cd.md new file mode 100644 index 0000000000000000000000000000000000000000..48fe5705f15595f1d02cc625d29e739b793a7a16 --- /dev/null +++ b/vision-fixhub/ds11-01/e22d7fbf75e25e07a6957f3ad5273c074012db7915756ad99b59f083f99890cd.md @@ -0,0 +1,50 @@ +To: +From: +Lesley Groffi +Fri 5/12/2017 8:39:55 PM +Subject: Re: Apt for Dangene +Thank you for your help! I appreciate it very much! +Wish you a nice weekend! +Best, +On Thu, May 11, 2017 at 3:44 PM +Thank You very much Lesley!! +Best, +On Thu, May 11, 2017 at 3:37 PM +Yes +It would be great! +Thank you!! +On Thu, May 11, 2017 at 3:36 PM Lesley Groff 4 +Can you do 3pm tomorrow? +wrote: +> wrote: +• wrote: +On May 11, 2017, at 2:35 PM, +wrote: +Thank you Lasley ! +Do they have time tomorrow afternoon? +On Thu, May 11, 2017 at 9:58 AM Lesley Groff < +> wrote: +Hi +unfortunately today will not work and next week they have no lase +ppointments before 9am ... might any other time work with your schedule +On May 10, 2017, at 10:13 AM, +P wrote: +Thank you! +I can every morning before 9. Tomorrow also I Il be able between 12 and 4 +On Wed, May 10, 2017 at 9:41 AM Lesley Groff 4 +• wrote: +EFTA_R1_00936322 + + +Hello +Yes of course.... when is good for you to go? +> On May 10, 2017, at 9:27 AM, +wrote: +> +> Hello dear Lasley! +> Can you please book an apt for me with Dangene to remove my moule on the +nose and my capillaries.? +> +> Looking forward for your answer +> Thank you! +EFTA_R1_00936323 diff --git a/vision-fixhub/ds11-01/e22d7fbf75e25e07a6957f3ad5273c074012db7915756ad99b59f083f99890cd.receipt.json b/vision-fixhub/ds11-01/e22d7fbf75e25e07a6957f3ad5273c074012db7915756ad99b59f083f99890cd.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..1536bae15141fa4bf5808647901a1c6aa160b327 --- /dev/null +++ b/vision-fixhub/ds11-01/e22d7fbf75e25e07a6957f3ad5273c074012db7915756ad99b59f083f99890cd.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "e22d7fbf75e25e07a6957f3ad5273c074012db7915756ad99b59f083f99890cd", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "04ca1f5c6bae098ff3359405f3957c7e4f43932f3ac09e8cf981462eec66bca2", + "output_sha256": "23e3140f445e3f43b319f59cbd8a726180e15a579ea6f6a0584f47c2eddd5ee5", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/f27c562bb13ed2e282e59eae3e5c8cc37426827c299e63e7117bbcf160603c74.md b/vision-fixhub/ds11-01/f27c562bb13ed2e282e59eae3e5c8cc37426827c299e63e7117bbcf160603c74.md new file mode 100644 index 0000000000000000000000000000000000000000..619800dfc0e05ff56a765256a95490df6c8ef030 --- /dev/null +++ b/vision-fixhub/ds11-01/f27c562bb13ed2e282e59eae3e5c8cc37426827c299e63e7117bbcf160603c74.md @@ -0,0 +1,10 @@ +To: +aziza alahmadi +From: +Sent: +Sat 5/13/2017 12:42:57 PM +Subject: Jeffrey Epstein +He3and 21na, Hope all is well. Jeffrey would like me to send you a DNA kit called +Please let me know what address I should send to! +Sent from my iPhone +EFTA_R1_00936479 diff --git a/vision-fixhub/ds11-01/f27c562bb13ed2e282e59eae3e5c8cc37426827c299e63e7117bbcf160603c74.receipt.json b/vision-fixhub/ds11-01/f27c562bb13ed2e282e59eae3e5c8cc37426827c299e63e7117bbcf160603c74.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..e27751cccb8947d702bd1915096da0effa73dd52 --- /dev/null +++ b/vision-fixhub/ds11-01/f27c562bb13ed2e282e59eae3e5c8cc37426827c299e63e7117bbcf160603c74.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "f27c562bb13ed2e282e59eae3e5c8cc37426827c299e63e7117bbcf160603c74", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "3ed3c0178756f2b928869c3c283baaec1777525ffe6932842cf51784febb0b28", + "output_sha256": "82c06d32e56fb01217301d08c4604edda485c56ac98be9aa9e4ccd78180a213e", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/f8ba18df53ebc5755840449272908e0f0e2e51804f910e75652f9e39fc5df44c.md b/vision-fixhub/ds11-01/f8ba18df53ebc5755840449272908e0f0e2e51804f910e75652f9e39fc5df44c.md new file mode 100644 index 0000000000000000000000000000000000000000..f4c3fce7c618533f2aa69d1b864b2cd8d62ad821 --- /dev/null +++ b/vision-fixhub/ds11-01/f8ba18df53ebc5755840449272908e0f0e2e51804f910e75652f9e39fc5df44c.md @@ -0,0 +1,41 @@ +To: +John Woodsl +From: +Sent: +Fri 5/12/2017 5:19:26 PM +Subject: Re: +Hi John....ok thanks for letting us know... +On May 12, 2017, at 1:15 PM, John P. Woods, ALA syuu +wrote: +Unfortunately tied up in meetings until 3. +JPW +Sent from my iPhone +On May 12, 2017, at 11:55 AM, jeffrey E. wrote: +can you take a call now? +On Fri, May 12, 2017 at 3:44 PM, John P. Woods 1 +wrote: +Great! What about 3pm? +JPW +From: jeffrey E. [mailto:jeevacation@gmail.comJ +Sent: Friday, May 12, 2017 8:00 AM +To: John P. Woods, AIA +Subject: +chat today^? +please note +The information contained in this communication is +confidential, may be attorney-client privileged, may +EFTA_R1_00936341 + + +constitute inside information, and is intended only for +the use of the addressee. It is the property of +JEE +Unauthorized use, disclosure or copying of this +communication or any part thereof is strictly prohibited +and may be unlawful. If you have received this +communication in error, please notify us immediately by +return e-mail or by e-mail to jeevacation@gmail.com, and +destroy this communication and all copies thereof, +including all attachments. copyright -all rights reserved +This email has been checked for viruses by Avast antivirus software. +www.avast.com diff --git a/vision-fixhub/ds11-01/f8ba18df53ebc5755840449272908e0f0e2e51804f910e75652f9e39fc5df44c.receipt.json b/vision-fixhub/ds11-01/f8ba18df53ebc5755840449272908e0f0e2e51804f910e75652f9e39fc5df44c.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..dd9017f0bd5a20c5473e9772746bed36feeab887 --- /dev/null +++ b/vision-fixhub/ds11-01/f8ba18df53ebc5755840449272908e0f0e2e51804f910e75652f9e39fc5df44c.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -639, + "dataset": "marble-joined", + "doc_id": "f8ba18df53ebc5755840449272908e0f0e2e51804f910e75652f9e39fc5df44c", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.disclaimer-removal.please-note-florida\"]", + "idempotent": false, + "input_sha256": "9440a55e0e7bb43158f8451cf8d7d325601f900c85d6d631618e6a25fbd75d50", + "output_sha256": "a5b5cb7ed38a73c1538509b60c3ef74b7270a3eb372b9de8c846ab5d62aaa389", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/fc955b42a9a32929f1b149ce64373470021b96ed5cb492179e551022b155c3f7.md b/vision-fixhub/ds11-01/fc955b42a9a32929f1b149ce64373470021b96ed5cb492179e551022b155c3f7.md new file mode 100644 index 0000000000000000000000000000000000000000..c41bfe924492b8bce892b2e36d4d9bb0b02c91f8 --- /dev/null +++ b/vision-fixhub/ds11-01/fc955b42a9a32929f1b149ce64373470021b96ed5cb492179e551022b155c3f7.md @@ -0,0 +1,12 @@ +From: +Sent: +Mon 5122/2017 12:53:42 PM +Subject: Re: Print Welcome Letter for 7J for Bobby Slayton +Morning;) +Will do! +On Mon, May 22, 2017 at 7:16 AM +wrote: +Morning +Can you please print this welcome letter for Bobby Slayton for 7J... he arrives +on Wed. May 24th! OK? :) +EFTA_R1_00936319 diff --git a/vision-fixhub/ds11-01/fc955b42a9a32929f1b149ce64373470021b96ed5cb492179e551022b155c3f7.receipt.json b/vision-fixhub/ds11-01/fc955b42a9a32929f1b149ce64373470021b96ed5cb492179e551022b155c3f7.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..df909722b04f204b93cec05d9deffe8620208ad2 --- /dev/null +++ b/vision-fixhub/ds11-01/fc955b42a9a32929f1b149ce64373470021b96ed5cb492179e551022b155c3f7.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "fc955b42a9a32929f1b149ce64373470021b96ed5cb492179e551022b155c3f7", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "396711c246d4359e7b12035bff7bf6641a93666b6561b230857cbb80ed4cd13d", + "output_sha256": "7b7d0289b9c96db30b00a5ac1b1d711961e9f39e559f91895571731589269148", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds11-01/fd5105ddd8dd9766216fbaa835508ebcf518721bbe4ebb5c00c3e4cacf0118cb.md b/vision-fixhub/ds11-01/fd5105ddd8dd9766216fbaa835508ebcf518721bbe4ebb5c00c3e4cacf0118cb.md new file mode 100644 index 0000000000000000000000000000000000000000..9de426bf74e8929315c4105200f33889721c4af7 --- /dev/null +++ b/vision-fixhub/ds11-01/fd5105ddd8dd9766216fbaa835508ebcf518721bbe4ebb5c00c3e4cacf0118cb.md @@ -0,0 +1,10 @@ +To: +From: +Sent: +Subject: +Jefffrey Epsteinfjeevacation@gmail.com] +Mon 5/15/2017 9:19:14 PM +Reminder: Olivier Colom +Reminder: you want to see Olivier Colom tomorrow, Tues. May 16th ....please advise if you +would like me to reach out to him... +EFTA_R1_00936379 diff --git a/vision-fixhub/ds11-01/fd5105ddd8dd9766216fbaa835508ebcf518721bbe4ebb5c00c3e4cacf0118cb.receipt.json b/vision-fixhub/ds11-01/fd5105ddd8dd9766216fbaa835508ebcf518721bbe4ebb5c00c3e4cacf0118cb.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..6b14de37333fe8a3ee9ad634271285781f520dfe --- /dev/null +++ b/vision-fixhub/ds11-01/fd5105ddd8dd9766216fbaa835508ebcf518721bbe4ebb5c00c3e4cacf0118cb.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "fd5105ddd8dd9766216fbaa835508ebcf518721bbe4ebb5c00c3e4cacf0118cb", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "1b830a638eaf3b61406562ff65d5992078f7d772fc274c7b551e75d299e8fb85", + "output_sha256": "183c63b14fa59a30a67ca36b3adf69f773a6b7b538b3635a130e2f6ab96435f2", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0002d6c6d0f02150443dbe2e3f30044d3508f9acecac2f15a81c9d313116df68.md b/vision-fixhub/ds9-parsed-01/0002d6c6d0f02150443dbe2e3f30044d3508f9acecac2f15a81c9d313116df68.md new file mode 100644 index 0000000000000000000000000000000000000000..6e9a326a6081071bd230ccfeea9157162f2c590c --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0002d6c6d0f02150443dbe2e3f30044d3508f9acecac2f15a81c9d313116df68.md @@ -0,0 +1,32 @@ +From: +To: ' +(USANYS) [Contractor]" +(USANYS)" { +[Contractor]" < +Cc: " +Subject: RE: 3500 production +Date: Tue, 09 Nov 2021 17:24:30 +0000 +Attachments: U.S._V. +_ Ghislaine_Maxwell_3500 +)_Index_(Internal).xIsx +(USANYS) +Hi team - the latest 3500 (TW Production 6 and NTW 3500 Production Z) are organized and stamped on the shared. I +know there will likely be additional 3500 to add today, and I will add those materials when I receive them. The current +index is also attached for your reference. Thanks! +From: | +To +(USANYS) < +Sent: Tuesdav November 9, 2021 10:25 AM +(USANYS) [Contractor] ‹ +Cc: +Subject: 3500 production +(USANYS) [Contractor] +Because of the Daubert hearing tomorrow, we should get another production of 3500 out later today. Can you work on +getting that organized, please? I expect we will have more notes from our meetings today. +Thanks, +Assistant United States Attorney +United States Attorney's Office +Southern District of New York +One St. Andrew's Plaza +New York, New York 10007 +Tel:• diff --git a/vision-fixhub/ds9-parsed-01/0002d6c6d0f02150443dbe2e3f30044d3508f9acecac2f15a81c9d313116df68.receipt.json b/vision-fixhub/ds9-parsed-01/0002d6c6d0f02150443dbe2e3f30044d3508f9acecac2f15a81c9d313116df68.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..6d796e45028e7070e3652289dbab09e265be0a52 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0002d6c6d0f02150443dbe2e3f30044d3508f9acecac2f15a81c9d313116df68.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "0002d6c6d0f02150443dbe2e3f30044d3508f9acecac2f15a81c9d313116df68", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "5681b8e1d73560aef150fcd151b76f68d05a5126b82eff404b700a0bd843ed90", + "output_sha256": "f6e83e3cc935eb062a09d48b42e8d44101f8f134e030978580d30650d7d76447", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/00064b182babec392792bf0679cc572047662a5de23d26469c628e9d795ca1c5.md b/vision-fixhub/ds9-parsed-01/00064b182babec392792bf0679cc572047662a5de23d26469c628e9d795ca1c5.md new file mode 100644 index 0000000000000000000000000000000000000000..b4764fb5fde9efd7b8209febf5b46ffd94169f09 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/00064b182babec392792bf0679cc572047662a5de23d26469c628e9d795ca1c5.md @@ -0,0 +1 @@ +No Images Produced diff --git a/vision-fixhub/ds9-parsed-01/00064b182babec392792bf0679cc572047662a5de23d26469c628e9d795ca1c5.receipt.json b/vision-fixhub/ds9-parsed-01/00064b182babec392792bf0679cc572047662a5de23d26469c628e9d795ca1c5.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..cb420085fdfce30f131031c63ca0b9113926981d --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/00064b182babec392792bf0679cc572047662a5de23d26469c628e9d795ca1c5.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "00064b182babec392792bf0679cc572047662a5de23d26469c628e9d795ca1c5", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "3570a4fd1b1ebdd84256c296e4e40cd9e1052ff8788a908c92fee6c9fcf8a480", + "output_sha256": "3874328764c818fba06683a6d5ddc2edc2d7850aaf4ba18646f81d3f8420a729", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0042464c9f48e002bf36a88fac4389ba1fa46c27385013936f994c682142cefd.md b/vision-fixhub/ds9-parsed-01/0042464c9f48e002bf36a88fac4389ba1fa46c27385013936f994c682142cefd.md new file mode 100644 index 0000000000000000000000000000000000000000..486b09f42d01fe3a98bf8ed967cf8ab79f1142b1 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0042464c9f48e002bf36a88fac4389ba1fa46c27385013936f994c682142cefd.md @@ -0,0 +1,186 @@ +v. Maxwell, 15 Civ. 7433 (RWS), S.D.N.Y. +Non-Confidential Materials +Jeffrey Epstein Deposition Transcripts (Re: Epstein cases) +April 30, 2009 Epstein Deposition Transcript +GJ SUBPOENA RESPONSE | 000002 +May 7, 2009 Epstein Deposition Transcript +GJ SUBPOENA RESPONSE | 000160 +October 8, 2009 Epstein Deposition Trans GiJ SUBPOENA RESPONSE 000496 +February 17, 2010 Epstein Deposition Transcript +GJ SUBPOENA RESPONSE | 000852 +March 8, 2010 Epstein Deposition Transcript +GJ SUBPOENA RESPONSE | 000920 +April 4, 2010 Epstein Deposition Transcript +GJ SUBPOENA RESPONSE | 001481 +Other Witnesses Deposition Transcripts (Re: Epstein cases) +July 29, 2009 Alfredo Rodriguez Deposition Transcript +GJ SUBPÓENA RESPONSE | 000195 +August 7, 2009 Alfredo Rodriguez Deposition Transcript +: 000263 +September 8, 2009 Juan Alessi Deposition Transcript (Vol. I) +GJ SUBPOENA RESPONSE | 000337 +September 8, 2009 Juan Alessi Deposition Transcript (Vol. II) +GJ SUBPOENA RESPONSE | 000357 +November 23, 2009 Michael Reiter Deposition Transcript (Vol. I) +GJ SUBPOENA RESPONSE | 000556 +November 23, 2009 Michael Reiter Deposition Transcript (Vol. II) + +February 16, 2010 Janusz Banasiak Deposition Transcript + +March 19, 2010 Det. +Deposition Transcript (Vol. I) + + + + + + + + + + + + + + + + + +v. Maxwell, 15 Civ. 7433 (RWS), S.D.N.Y. +Non-Confidential Materials +Other Witnesses Deposition Transcripts (Re: Epstein cases) +March 19, 2010 Det. +Deposition Transcript (Vol. II) + + +March 24, 2010 +Deposition Transcript (Vol. I) + + +March 24, 2010 +Deposition Transcript (Vol. II, III) +GJ SUBPOENA RESPONSE | 001374 + +April 13, 2010 +Deposition Transcript + + +Jeffrey Epstein's Jail Visitor Logs (Part 1 and 2) + + +Jeffrey Epstein's Aircraft- Flight Log & Airport Codes + + +Miami Beach Police Report + + +State v. Epstein: E-Materials (CDs) received in response to BSF FOIA Request +State v. Epstein (State Files 1) +Audio and Redacted Control Calls +• Walk Through Video +State v. Epstein (State Files 2) +• Part 1 Audio from Cassettes +State v. Epstein (State Files 3) +• Part 2 Audio from Cassettes +State v. Epstein (State Files 4) +• Part 1 Video Interviews +State v. Epstein (State Files 5) +• Part 2 Video Interviews + +GJ SUBPOENA RESPONSE | 004583 + +GJ SUBPOENA RESPONSE | 004585 +GJ SUBPOENA RESPONSE 004586 + + + + + + + +v. Maxwell, 15 Civ. 7433 (RWS), S.D.N.Y. +Non-Confidential Materials +State v. Epstein: E-Materials (CDs) received in response to BSF FOIA Request +State v. Epstein (State Files 6) +• Part 3 Video Interviews + +State v. Epstein (State Files 7) + +GJ SUBPOENA RESPONSE 004587 + +State v. Epstein (State Files 7) (CD Contents) +• State Files 7: Jeffrey Epstein Part O1 redacted +• State Files 7: Jeffrey Epstein Part 02 redacted +• State Files 7: Jeffrey Epstein Part 03 redacted +• State Files 7: Jeffrey Epstein Part 04 redacted +• State Files 7: Jeffrey Epstein Part 05 redacted +• State Files 7: Jeffrey Epstein Part 06 redacted +• State Files 7: Jeffrey Epstein Part 07 redacted) +• State Files 7: Jeffrey Epstein Part 08 redacted +• State Files 7: Jeffrey Epstein Part 09 redacted +• State Files 7: Jeffrey Epstein Part 10 redacted +• State Files 7: Jeffrey Epstein Part 11 redacted +• State Files 7: Jeffrey Epstein Part 12 redacted +• State Files 7: Jeffrey Epstein Part 13 redacted +• State Files 7: Jeffrey Epstein Part 14 redacted +• State Files 7: Jeffrey Epstein Part 15 redacted +• State Files 7: Jeffrey Epstein Part 16 redacted +• State Files 7: Jeffrey Epstein Part 17 redacted +• State Files 7: Jeffrey Epstein Part 18 redacted + + +001652|001782 + + + + + + +002110 | 002181 + + + + + + + + + + + + + + + + + + + + + + + + + + +OIA CONFIDENTIAL TREATMENT REQUESTED +ED. R. CRIM. P. 6(e) MATERIAI +v. Maxwell, 15 Civ. 7433 (RWS), S.D.N.Y. +Non-Confidential Materials +• State Files 7: Jeffrey Epstein Part 19 redacted +• State Files 7: Jeffrey Epstein Part 20 redacted +• State Files 7: Jeffrey Epstein Part 21 redacted +• State Files 7: Jeffrey Epstein Part 22 redacted +• State Files 7: Jeffrey Epstein Part 23 redacted +• State Files 7: Jeffrey Epstein Part 24 redacted + + + + + + + + + + + diff --git a/vision-fixhub/ds9-parsed-01/0042464c9f48e002bf36a88fac4389ba1fa46c27385013936f994c682142cefd.receipt.json b/vision-fixhub/ds9-parsed-01/0042464c9f48e002bf36a88fac4389ba1fa46c27385013936f994c682142cefd.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..9b5fd26cb6aa69f2731dd1c50a52a648e764c01d --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0042464c9f48e002bf36a88fac4389ba1fa46c27385013936f994c682142cefd.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -1364, + "dataset": "marble-joined", + "doc_id": "0042464c9f48e002bf36a88fac4389ba1fa46c27385013936f994c682142cefd", + "engine": "marble-apple-vision", + "event_count": 89, + "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "0def7ab89a6dc18b7e0c615b465669dba92ba25ad88b4fd825bb34ada273dd3c", + "output_sha256": "9ec59629102ecf5d9f9c3813332ec6c82d56be21109db51733dd1372f0caa14d", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/00467ec301ffdfb4a3595dae56c1e82383ea95698e03b398eafcbdab3853e267.md b/vision-fixhub/ds9-parsed-01/00467ec301ffdfb4a3595dae56c1e82383ea95698e03b398eafcbdab3853e267.md new file mode 100644 index 0000000000000000000000000000000000000000..3878fd5e309ecae85d5315d1224d4ac29a0a4f73 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/00467ec301ffdfb4a3595dae56c1e82383ea95698e03b398eafcbdab3853e267.md @@ -0,0 +1,659 @@ +NYMAQ 530.03 * +PAGE 001 +BUREAU OF PRISONS COUNT SHEET +NEW YORK MCC +OIRG EQ **** +OCTG EQ **** +OUTCOUNT +S +ECT +I ON +08-06-2019 +16:43:21 +V +COUNT +AREA CENSUS +B-A +C-A +E-N +E-S +G-N +G-S +H-A +I-N +K-N +K-S +R-A +Z-A +Z-B +26 +10 +86- +82 +78 +81 +3 +84 +89 +136 +0 +78 +5 +TOTAL +758 +COUNT +VERIFY +I +V +OC +UO +TU +N +T +• 1 +1 +2 +1 +1 +3 +3 +1 +1 +2 +4 +9 +2 +2 +22 +VERIFY +COUNT +COUNT COUNT AREA +26 B-A +10 C-A +84 E-N +79 E-S +77 G-N +79 G-S +3 H-A +83 +I-N +87 +K-N +127 K-S +0 +R-A +76 Z-A +5 +Z-B +736 +12 +1 +XXX +OFFICIAL PREPARING COUNT +OFFICIAL TAKING COUNT +COUNT CLEARED TIME: 4 58 +Food Verbal: 4f + + +UNITED STATE +FEDERAI +OFFICIA +Metropol +New Y +-( +Curr +N R +Date: 08-06-2019 +From: +(Staff Member Supervising In +Approved: +PP +(Operations Lieutenant) +REG...... +LN. +R +B-A +_C-A +E-N_ +E-S +H-A +_I-N_ +K-N 1_K-S +Total Out-Counted: 5 +This Form must be submitted to the Counts ar . +To The affected count. Prepare this form in i: +units. This is to be used only as an Out Count +N +CENT OF JUSTICE +)F PRISONS +JNT FORM +onal Center +ric 10007 +Count Time: 4:00 pm +Location: ENYS +QTR....... +E06-545L +G01-702L +G11-783U +G11-786U +K04-129U +. G-S 2 +Z-A +Z-B_ +is Officer FORTY-FIVE MINUTES PRIOR +- Inmates according to their respective housing + + +NYMAR 530*05 * + +ASSIGNMENT: FNYS +OPER CATG ASSIGNMENT +OPER +NUM ASSIGNMENT REG NO +0001 FNYS +0002 +0003 +0004 +0005 +NAME +INMATE ROSTER +CATG ASSIGNMENT +08-06-2019 +15: 41:35 +GROUP CODE: +FACILITY: NYM +OPER CATG +ASSIGNMENT +OCT DATE +OTR +08-06-2019 G11-783U +08-06-2019 G11-786U +08-06-2019 K04-129U +08-06-2019 G01-702L +08-06-2019 E06-545L +WRK +UNASSG +UNASSG +UNASSG +UNASSG +UNASSG +GO00O +TRANSACTION SUCCESSFULLY + + +METROPOLITAN CORRECTIONAL CENTER +NEW YORK, NY +OFFICIAL OUT COUNT +DATE: +FROM: +APPROVED: +08-06-19 +thomos +(Stri Mamher Prepafing Out Count) +COUNT TIME: +LOCATION: +400pm +Hosp +REG # +(Operations Lieutenant) +NAME +2. +3. +4. +5. +6. +7. +8. +9. +10. +11. +12. +UNIT +EN +REG # +NAME +UNIT +13. +14. +15. +16. +17. +18. +19. +20. +21. +22. +23. +24. +B-A +I-N +C-A +K-N +E-N +K-S +Total Out-Counted: +OUT-COUNT BY UNIT +E-S +R-A +G-N +Z-A +/ +G-S +Z-B +H-A + + +- NYMAQ 530*05 * + +ASSIGNMENT: HOSP +OPER +CATG +ASSIGNMENT +OPER +NUM ASSIGNMENT REG NO +0001 HOSP +NAME +INMATE ROSTER +CATG +ASSIGNMENT +* +08-06-2019 +15:40:34 +GROUP CODE: +FACILITY: NYM +OPER CATG ASSIGNMENT +OCT DATE +OTR +08-06-2019 E01-501U +WRK +SUICIDE OR +UNASSG +G0000 +TRANSACTION SUCCESSFULLY + + +DATE: +8/6/2019 +FROM: +Star superosing Our-Count +Number +METROPOLITAN CORRECTIONAL CENTER +NEW YORK NY +OFFICIAL OUT-COUNT FORM +TIME:_4PM +LOCATION:__F/S. +Name +Unit +Number +Name +1 +2 +3 +4 +Unit +(KS +ES +KS +KS +KS +ES +KS +KS +ES +KS +KS +KS +21 +22 +23 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +31 +32 +33 +34 +35 +36 +37 +38 +39 +40 +OUT-COUNTS +BY UNIT: +B-A +C-A +E-N +E-S +TOTAL ON OUT COUNT: +G-N +G-S +I-N +K-s 9_.. +K-N +Z-A +Z-B +H-A +R-A +Out-counts will be submitted at a minimum of two (2) hours prior to the count. Out-counts WILL be submitted in ink, and legible. Out-counts +should list inmates alphabetically by unit with the inmate's name, register number, and quarters assignment. Please verify all information. + + +METROPOLITAN CORRECTIONAL CENTER +NEW YORK, NY +OFFICIAL OUT COUNT +DATE: +FROM: +APPROVED: +8-6-19 +COUNT TIME: +LOCATION: +400pm +Att conf +(Staff Member Preparing Out Count) +(Operations Lieutenant) +REG # +NAME +1. +2. 16318054 Elsten +A +KN +* 18514054 TarTaglione LA +б. +7. +8. +9. +10. +11. +12. +B-A +I-N +REG # +NAME +UNIT +13. +14. +15. +16. +17. +18. +19. +20. +21. +22. +23. +24. +OUT-COUNT BY UNIT +E-S +G-N +- R-A +- +Z-A +V +C-A +K-N +E-N +K-S +G-S +Z-B +H-A +Total Out-Counted: +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected count. +Prepare this form in ink. Group the inmates according to their respective housing units. This form is to be used only as an +Out-Count. No other form will be accepted in lieu of the Out-Count Form. + + +- NYMAQ 530*05 * + +ASSIGNMENT: ATTY +OPER CATG +ASSIGNMENT +OPER +NUM ASSIGNMENT REG NO +NAME +0001 ATTY +0002 +76318-054 EPSTEIN +0003 +0004 +78514-054 TARTAGLIONE +INMATE ROSTER +CATG +ASSIGNMENT +08-06-2019 +15:41:08 +GROUP CODE: +FACILITY: NYM +OPER CATG ASSIGNMENT +OCT DATE +OTR +WRK +08-06-2019 I04-930U +UNASSG +08-06-2019 Z04-206LAD UNASSG +08-06-2019 K06-145U +UNASSG +08-06-2019 Z06-215UAD UNASSG +G0000 +TRANSACTION SUCCESSPULLY + + +Metropolitan Correctional Center +Official Count Slip +Unit: +h-N' +Date _ +08-06-2019- +count: 87 +• Time: 4:00PM- +Print Name +Signature: +Print Name +Signature. +Unit: +Metropolitan Correctional Center +Official Count Slip +Date: 8-6-209- +:00 +Count: +76 +Time: +Print Name: +Signature: +Print Name: +Signature: +Unit: +Count: +Metropolitan Correctional Center +Official Count Slip +ENT +Date +84 +08-06-19- +Time: _ +Yoon - +Print Name: +Signature: +Print Name: _ +Signature +Unit: _ +Count: +Metropolitan Correctional Center +Official Count Slip +6N - +77- +Date. +8-6-19 +. Time: +4pm- +- +Print Name: +Signature: +Print Name: +Signature. +Metropolitan Correctional Center +New York, New York +Official Count Slip +Time: +4: 00 L +Unit: +Count: +1. +Print Name: +Signature: +2. Print Name: +2. Signature: +Unit: +Metropolitan Correctional Center +Official Count Slip +Date: +Count: +ZB +5 +Time: +Print Name: +Signature: +Print Name: +Signature: +8-6-17 +400 pm - +Unit: +Metropolitan Correctional Center +Official Count Slip +Date +8/6/219 - +Count: +KS - +127 - +Time: +Print Name: +Signature: +Print Name: +Signature +Unit: G-S +Count: +79- +Metropolitan Correctional Center +Official Count Slip +Date: 8-6-19- +00 +Time: 4 pm = +Print Name: +Signature: +Print Name:' +Signature: +Metropolitan Correctional Center +Official Count Slip +Unit: IN = +Date. +816/14 +Count: _ +83 - +Time: 4:00.- +Print Name: +Signature: +Print Name: +Signature, + + +Metropolitan Correctional Center +Official Count Slip +Unit: +BA- +Date: 8/6119- +Count: +26 +Time: +4:00pm- +Print Name: +Signature: +Print Name: +- +- +Signature: +Metropolitan Correctional Center +New York, New York +Official Count Slip +Unit: +Count: +12 +1. Print Name: +1. Signature: +2. Print Name: +2. Signature: +Date: +5/6l19- +Time: +Unit: +Count: +Metropolitan Correctional Center +Official Count Slip +Hosp= +Date: 8/6/19= +/ +Time: _ +4:00 phr +Print Name: +Signature: +Print Name: +Signature: +Metropolitan Correctional Center +Official Count Slip +Unit: _ES +Date: 08-06-19- +Count: 795 +Time: +400pm- +Print Name: +Thromo +Signature: +Print Name: +Signature: +Unit: +Count: +Print Name: +Signature: +Print Name: +Signature: +Metropolitan Correctional Center +Official Count Slip +Date: +3 +Time: +8/6/19- +4i60pí +- +Unit: +Metropolitan Correctional Center +Official Count Slip +Att conf- +Date: +Count: +Time: +8/6/19= +400рм +Print Name: +Signature: +Print Name: +Signature: +Unit: +Count: +Metropolitan Correctional Center +Official Count Slip +CA- +. Date. +10- +816/19 +Time 4: on = +Print Name: +Signature: +Print Name: +Signature_ \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/00467ec301ffdfb4a3595dae56c1e82383ea95698e03b398eafcbdab3853e267.receipt.json b/vision-fixhub/ds9-parsed-01/00467ec301ffdfb4a3595dae56c1e82383ea95698e03b398eafcbdab3853e267.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..8a6e77458ba8b3f190405aa5e175e7ac1fec7204 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/00467ec301ffdfb4a3595dae56c1e82383ea95698e03b398eafcbdab3853e267.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -238, + "dataset": "marble-joined", + "doc_id": "00467ec301ffdfb4a3595dae56c1e82383ea95698e03b398eafcbdab3853e267", + "engine": "marble-apple-vision", + "event_count": 14, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "f16bc6cf8a8fdde09dcf125a1a5a158eeba74b22c1527b3c520d76da1773f08b", + "output_sha256": "6ddc6e52023893ef7033223b85363319103ec50c8e65015210d17551d68607e0", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0049c2046eab6fadd7e4abd1525e2e84459ec423412ef65504d9507325cfa19e.md b/vision-fixhub/ds9-parsed-01/0049c2046eab6fadd7e4abd1525e2e84459ec423412ef65504d9507325cfa19e.md new file mode 100644 index 0000000000000000000000000000000000000000..38dd4ce08fd23bcf08c1d03e701c54823a2f4446 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0049c2046eab6fadd7e4abd1525e2e84459ec423412ef65504d9507325cfa19e.md @@ -0,0 +1,39 @@ +From: ' +To: " +Subject: FW: +Date: Mon, 02 Aug 2021 14:33:55 +0000 +Attachments: +1-pdf +L-pdf; +I.pdf; +Hi C +From: +Sent: Friday, July 30, 2021 4:41 PM +To: +Cc:| +(USANYS) < +Subject: RE: +Attached. +From: | +Sent: Friday, July 30, 2021 4:35 PM +To: / +Cc: +(USANYS) < +Subject: [EXTERNAL EMAIL] - RE: +Could you please save these in the 3500 and witness folders for the respective witnesses in the Maxwell case? Thanks! +Could you please send me these items by Monday? It would be helpful to our determination of whether we need to +schedule a meeting with +in August, in the limited time we have left. +Thanks, +From: | +Sent: Wednesday, July 28, 2021 9:00 AM +To: +Cc: +(USANYS) < +Subject: +Could you please send me the notes/302 from our last meeting, when you have a chance? Same for D +Thanks! +Assistant United States Attorney +Southern District of New York +One Saint Andrew's Plaza +New York, NY 10007 diff --git a/vision-fixhub/ds9-parsed-01/0049c2046eab6fadd7e4abd1525e2e84459ec423412ef65504d9507325cfa19e.receipt.json b/vision-fixhub/ds9-parsed-01/0049c2046eab6fadd7e4abd1525e2e84459ec423412ef65504d9507325cfa19e.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..9bdd3b6ef82c6bee1718c0c7eec1848cb40a364d --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0049c2046eab6fadd7e4abd1525e2e84459ec423412ef65504d9507325cfa19e.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "0049c2046eab6fadd7e4abd1525e2e84459ec423412ef65504d9507325cfa19e", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "cb685a790712c276d5452f9197e1c83ca025e67dd47f98a63df2de05a448ebbc", + "output_sha256": "f5ab11c9aaa2966e4c8635a78979d475f70092d564209bc0aa30e7f6d526f3b5", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/007763e805fa30c81c73fa81d47f9544c843a7b1ddbfdfcc30c0452b445fd57f.md b/vision-fixhub/ds9-parsed-01/007763e805fa30c81c73fa81d47f9544c843a7b1ddbfdfcc30c0452b445fd57f.md new file mode 100644 index 0000000000000000000000000000000000000000..6ba2112bb6f552cda7f9f62a4b4fd6dad54b770e --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/007763e805fa30c81c73fa81d47f9544c843a7b1ddbfdfcc30c0452b445fd57f.md @@ -0,0 +1,23170 @@ +2 +3 +4 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +DIGITALLY RECORDED +SWORN STATEMENT +OF +OIG CASE #: +2019-010614 +DEPARTMENT OF JUSTICE +OFFICE OF THE INSPECTOR GENERAL +OCTOBER 27, 2021 +RESOLUTE DOCUMENTATION SERVICES +28632 Roadside Drive, Suite 285 +Agoura Hills, CA 91301 + + +1 +APPEARANCES: +2 +3 +4 +5 +6 +7 +8 +WITNESS: +2 +OFFICE OF THE INSPECTOR GENERAL +BY: +BY: +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +OTHER APPEARANCES: + + +1 +2 +3 +4 +5 +6 +7 +8 +3 +The recorder is on. My +name is +1, and I am a Senior +Special Agent with the U.S. Department of +Justice, Office of the Inspector General, New +York Field Office, and these are my +credentials. +Okay. Mm-hmm. +This interview with +Federal Bureau of Prisons employee - is it +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +1? 1 +Is being conducted as +part of an official U.S. Department of Justice, +Office of the Inspector General investigation. +Today's date is October 27th, 2021, and the +time is 1:53 p.m. This interview is being +conducted - what is the -? Is it 1515? +I: 515. +515? +•: Yes. +UNKNOWN MALE: Madison Avenue. 31st +f1001. +Okay. 515 Madison +Avenue, 31st floor. New York, New York. Also +present is DOJ/OIG Special Agent + + +1 +2 +3 +4 +5 +6 +7 +8 +As well as -- +UNKNOWN MALE: +attorney. +I'm sorry. What is it? +First name E-D-W-A-R-D. +4 +H-A-Y-E-S. +10 +11 +12 +13 +• +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +representing +Thank you, sir. Who is +This interview will +be recorded by me, Senior Special Agent +could everyone please identify +themselves for the record, and spell your last +name? To start, again, I am DOJ/OIG Senior +Special Agent, +credentials. +| This is DOJ Special Agent +•. And these are my +: Okay. And I am -- +: I can't -- +-- I can't show you any +credentials. +First name -- +And + + +1 +last name +5 +3 +4 +5 +6 +7 +8 +Thank you, sir. Do you +happen to one -- +: I still don't know how he +pronounces his name. Is it -? Yeah. And I'm +so arrogant that I don't carry identification. +You know what I mean? +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +No. That's fine. +: Yeah. But you are sitting +down here, you are willing to pay the fee. +You know who I am. +So, I am looking at Mr. +law enforcement officer credentials. +And it has a picture. And a signature of the +gentleman sitting in front of me. Thank you, +sir. And his attorney, do you mind - and +again, it's +: - - +don't have -. I really -- +NO. +• And I'm sorry, I +That's quite all +right. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +lawyer. +your office. +226/2. +6 +-- as I say -- +But you are - +I'm his +- perfect, and we're in +This is an official +DOJ/OIG investigation into the death of inmate +Jeffrey Epstein and the circumstances +surrounding it, and you are being asked to +voluntarily provide answers to our questions. +Will you agree to a voluntary interview with +the DOJ/OIG? +Yes, I will. +: Thank you, sir. This is +the form that we have to do all interviews, +interviewees. +: Is that form B? +This is the OIG form III- +: Yeah. +But it says is - I'm +going to read it for you - United States + + +7 +1 +2 +3 +4 +5 +6 +7 +8 +Department of Justice, Office of the Inspector +General, Warnings and Assurances to Employee +Requested to Provide Information on a Voluntary +Basis. It says, "You are being asked to +provide information as part of an investigation +being conducted by the Office of the Inspector +General. This investigation is being conducted +pursuant to the Inspector General Act of 1978, +as amended. This investigation pertains to job +performance failure, +and +security failure." +And this is what we are writing for everyone +that we speak to, just because we're looking at +it as a -- +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: - whole of what +happened. +"This is a voluntary interview. +Accordingly, you do not have to answer +questions. No disciplinary action will be +taken against you if you chose not to answer +questions. Any statements you furnish may be +used as evidence in any future criminal +proceedings, or agency disciplinary +proceedings, or both." And there is a waiver +section. +It says, "I understand the Warnings +and Assurances stated above, and I am willing + + +8 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +to make a statement and answer questions. No +promises or threats have been made to me, and +no pressure or coercion of any kind has been +used against me." If you would like to take a +look at it, you may. If you agree to it, if +you want your attorney to look at it, he may, +as well. +You can sign where it +says "Employee Signature." And then, also +write your name. I did read it verbatim. +: I'm sure you did. Okay. +There is no place that said attorneys -- +No, no, no. +: - signatures. +It's not for you to sign. +It's for him, myself, and the witness. It's +just if you wanted to review it, or ask any -- +: No, that's all right. +- questions about it. +: That's all right. I do have a +question. +: Where do you want me to +sign? +: In other words, if you say to + + +9 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +him -- +Oh, so, where it says - +: Right side. +-- "Employee Signature." +: Do you have sex with ducks? +And so, I'm not going to answer that question. +That's the - he can't get in trouble for that? +I won't be asking that +question. +I mean, (Indiscernible +*00:04:18). +(Indiscernible *00:04:20). +(Indiscernible *00:04:22). +(Indiscernible *00:04:21). +Under the interview that +we are doing right now, for voluntary +interviews, he doesn't have to answer our +questions. +okay. Great. +All right. So, thank you +for signing that, sir. +Did you have any +questions on the form? +No, I don't. +All right. So, I'm + + +10 +1 +signing as the signature of the Office of the +2 +Inspector General, Special Agent. I'm printing +3 +my name. +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: Oh, one thing. So, +ordinarily, I would take notes. I've been at +Jim Rad (Phonetic Sp. *00:04:49) for 50 years, +as you saw, to which my body is falling apart. +I had severe arthritis in my neck, and it's +radiated down to my hands. I can't really +basically write. +So, that's why - +Sure. +: — I'm not taking notes. But +I have a pretty good memory, so, yeah. +All right. Great. +, can you just sign as the witness? +: oh. +Put your name and take +care of the rest of the form. +: This is Special Agent +• I'm signing as the witness, and dating +All right. Before +starting the interview, I would like to place +you under oath. l +• can you please +raise your right hand? + + +1 +2 +3 +4 +5 +6 +7 +8 +11 +Do you swear to tell the +truth and nothing but the truth during this +interview? +I do. +your current home address? +: Thank you, sir. What is +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +And what is your date of +birth? +And what -- +: Jesus Christ. +: -- what is the -- +: I'm old. +-- what are the last four +of your social security number? +Is it correct that you +were interviewed regarding the Epstein matter +on August 19th, 2019? +Or in August of 2019. +I know it was some time in + + +1 +August. +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Dix. +Two +weeks. +12 +Correct. Okay. How long +have you worked for the BOP? +: 30 years. And August, +September, October, November. 30 years and +three months. +All right. And what is +your current position with the BOP? +: I'm the Warden at ECI Fort +okay. And what are your +-. You are the warden, you said? +Yes. +Were you previously a +regional director? +: I was the deputy regional +director in Philadelphia. +: And how long have you +been the warden at FCI Fort Dix? +About two or three weeks. +On, so -- +it's a brand -- + + +1 +2 +3 +4 +5 +6 +7 +8 +13 +- new position? +It just got there. Yeah. +Okay. How long were you +the deputy regional director? +I got it in February. +Of 2021. +Okay. And as the deputy +regional director, what were your duties and +responsivities? +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +•: Monitoring he activities of +the 20 institutions in the region, and, you +know, managing the administratives within the +northeast region, and, you know, showing that +institutions were running in an orderly +fashion. +Now, did you supervise +the various wardens at those institutions? +Yes. I was over there. +was the rating official on some of the +evaluations. +And were you a warden +prior to that position? +Yes, I was. +Where were you a warden? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +warden there? +some time in 2020 -- +regional director? +given -- +14 +In New York. MCC. The +Metropolitan Correctional Center in New York. +: And how long were you a +: I came from May of - '17, +'18 - May of '18 until, I forget the date, in +2020. I forget what it was. +Okay. So, May 2018 to +- when you became the +No. The position -- +- prior to that, I was +-- was a liaison to the +regional director. And then, I went into the +deputy position. +Okay. Sounds good. And +August of 2019, though, were you a warden at +the MCC New York? +YeS: +I was. +Thank you, sir. And are + + +15 +1 +2 +3 +4 +5 +6 +7 +8 +you familiar with inmate Jeffrey Epstein, who +was housed within the MCC in July and August of +2019? +Yes. +Yes. Okay. Great. What +I have here is an after-action report that was +written by the BOP. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Have you seen this? +I have not seen that. +All right. So, this is +not something that you are actually familiar +with? +No, I am not. +: No one discussed any +findings or anything like that with you? +No one. +: All right. I'm going to +set this aside just in case we need to, you +know, reference it. So, no role in the afteraction report? +Nothing. I wasn't +interviewed. I wasn't spoken to. +: All right. Do you know +of anybody interviewed, or I mean, talked to + + +16 +1 +2 +3 +4 +5 +6 +7 +8 +and at least about, like, providing the +information that they utilized to this report? +_: No. +: No. +Okay. Fair enough. +After the incident occurred, what was your role +with determining what happened and what didn't +happen after Epstein was found on August 10th, +2019? +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: Well, I responded to the +institution. At the time, when I got there, he +was at the hospital. So, I didn't go up to the +unit, as far as - because it was a crime scene, +and I've always been trained, if it was a crime +scene, if you weren't particularly there, the +least amount of people that, you know, that go +through that crime scene, just don't go into +it. So, I didn't go into it, but you know, +basically gathering information on what +happened, notifying the region, notifying the +FBI. The IG. +: (Indiscernible *00:09:28). +He's already got that phone call. +oh. +: oh, yeah, you know what I +mean? +Jeffrey Epstein -- + + +1 +2 +3 +4 +5 +6 +7 +8 +17 +: - like, fuck it, I'm going to +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +sell. Oh, okay. +:Yeah. +: That's why we do it for the +next six months. +: So, there was a lot of +notification on what happened. Trying to find +out the status of inmate Epstein. And things +more along those lines. +Now, did you help with +gathering information, up until a certain +point, and then, were you told not to anymore, +or did you continue to gather -? +: No, like, my boss was +calling me the regional director. They needed +information. You know, starting a timeline on +what happened. So, I had my executive +assistant there, and, you know, we would just +gather any information, and just, you know, +making sure that, you know, things that were +requested were being provided to them, any +information. +And who was the regional +director at the time? + + +1 +2 +3 +4 +5 +6 +7 +8 +time. +*00:10:21). +18 +It was +at the +Okay. And then, who was +your executive assistant? +(Phonetic sp. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Now, as part of our +investigation, we have to review everyone's +emails, with regard to the incident. +you provided +So, you mentioned that +with timelines -- +-- and things like that. +So, these are just some timelines from - again, +Mr. Epstein, I believe, was found around 6:33 +a.m. +In the Special Housing +Unit. This is a timeline starting with, it +1ooks like, August 10th, 2019, at 11:04 a.m. +So, a few hours after the fact. It just says, + + +19 +1 +2 +3 +4 +5 +6 +7 +8 +it says, "See below. +Just to ensure you know +what is being relayed to DOJ." Now, is this -. +And then, what I have behind it is, these are +different timelines that are all updated +throughout the day. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Here is one that was at +2:21 p.m. Same date. And then, the next one +was 3:42 p.m. And the next one was August +12th. And then, the final one that we have is +the August 13th. So, do these look like the +timelines that you would have been gathering +information and providing +• to +? +Okay. It looks like it. +: Now, where were you +actually obtaining this information from? You +said +was obtaining it for you? +•: He was the exec, we recall, +and in that, I'm not too familiar on the +specifics on how we get it, because there was +so much going on. +: Mm-hmm. +: That, you know, I don't +recall if it was from the logbooks, or, you +know, calling around and trying to find out. + + +20 +1 +2 +3 +4 +5 +6 +7 +8 +So, I don't really recall the specifics. +: All right. well, rather +than get into each one of these, because it +will take too long, I'll just do the very first +one. +It says, it just says, "7/23/2019, at +1:27 a.m., Epstein found in fetal position in +cell, breathing, but would not acknowledge +staff initially." So, that is referring to the +first initial attempt that Epstein may have had +on his life? +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: Let me see which one. Are +we talking the day of, or -? +: No. This is -- +This is July. +: - yeah, July, +(Indiscernible *00:12:40) 27. +Oh, no. This is July. +This is the -- +So, this is the - +- no, the -- +-- timeline. +- this would -. +We would +have probably got this from the SIS +investigation. + + +1 +2 +3 +4 +5 +6 +7 +8 +21 +From that. I thought you +were referring to the actual suicide. This is +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +No. What I meant was -- +-- this is -. +-- just the information +that was all put in there, as far as - +: This was his first attempt. +- well, it's everything. +So, so, it starts July 23rd. The next one is +July 29th. And it goes 8/9/2019. And then, +and then, until -. +So, it's only - there is +only a few. That's why I was going to read it, +just because there is only, like, three +paragraphs, four or five, four or five +paragraphs. +So, this looks to me like we +send the information to the regional director - +- +- and what he did was, +compile this information to send to DOJ. +Okay. Oh, you're right. + + +1 +2 +3 +4 +he is saying -- +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +22 +Ray -- +This is not -- +- sent this to you. +So, +-- yeah, this thing. +-- "see below -- +-- just ensure you know." +so, this is compiled off of +several different documents -- +-- which he condensed. +So -- +From -. +: -- he sent it to you. +I'm sorry. I read that incorrectly. So, +looking at this, then, let's just review it and +make each point, just make sure that it's what +you understand. It says, "On July 23rd, 2019, +Epstein was found in a fetal position in cell, +breathing, but would not acknowledge staff +initially." +"After removed, he +interacted with staff and speaking to staff. + + +1 +2 +3 +4 +5 +6 +7 +8 +Neck was red. Placed on suicide watch, and +medical evaluation. +Epstein receive daily +psychological evaluations while on suicide +watch." Was that your recollection, too? +Yeah. That is what is in +the report. But I want to - +Sure. +- clarify what we went -. +You know, when I, when you first read it to me +23 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Mm-hmm. i +-- I thought you meant the +day of. +rup, yup. +So +Well, we have that, too. +That's -- +- that one is here. And +this one is from you, and this is what I +thought it was starting with, as well. +Because it said timeline +on it. From you to +This initial +one actually talks about Friday, August 9th, + + +24 +1 +2019. It starts with, "8:00 a.m., inmate Reyes +2 +Efrain, +, departs for +3 +court. WAB-USMS-SDNY. Reyes is Epstein's +4 +cellmate." +5 +6 +7 +8 +: So, just starting with +that, then, I do have, we're going to get into +that later, but what does that tell you, if it +says inmate Reyes is departing for court, but +it also says WAB-USMS-SDNY? +: So, that would mean With All +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Belongings. +So, that means he's not +returning. Correct? +Yes. +All right. So, at 8:00 +a.m., Efrain Reyes is actually leaving, not +coming back to the MCC. +_: Mm-hmm. +All right. Great. And +then, it just goes on from there, what happens +throughout that day. And we're going to get +into these things more in detail, so I don't +want to go through each thing, because we're +going to have to get into it later. But so, + + +1 +this information is stuff that you guys were +2 +compiling, and you were providing to Mr. +3 +4 +5 +6 +7 +8 +25 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +That would probably be +information that we sent up to him. +: Okay. Great. And then, +this is all the updates that occurred +afterwards. Let's see. Why is that +highlighted? So, here is something. Do you +know why in this one, it would be updated? +This one is 7:00 p.m., 7:00 p.m., and then, +"7:32 a.m., PIO notified of incident by the +warden." Is that just, put that in the wrong +place or something, and it says, "Inmate Reyes +released from court." +(Indiscernible *00:16:27). +: (Indiscernible *00:16:30) +just in the wrong spot. It was made for August +10th. +Mm-hmm. (Indiscernible +*00:16:34). +Yeah. Okay. So, the +next one, that is the big discrepancy here. It +just shows the next update, you have that under +August - or Saturday - August 10th. + + +1 +2 +3 +4 +5 +6 +7 +8 +26 +This can't be -. This +doesn't make -. I don't know. Because it +says, "PIO notified of incident by the warden." +I was off that day, on Friday. +I wasn't at +work. +Yeah. So, that's why I +think that they -. So, the next one I'm +looking at shows that that point is now under +Saturday, August 10th. +I don't know why it +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +would be -- +So -- +-- under Friday, because I +wasn't -- +-- yeah. okay. +-- I wasn't working. +So, you were actually off +- +I was off -- +- off on August 9th? +- on Friday. Yes. +All right. You and +everyone else. +Huh? +Everybody was off that + + +1 +day. +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +27 +: Yeah. I didn't come back to +work until, when I got called, there was a +suicide at the (Indiscernible *00:17:28). +okay. So, all of this. +So, if I can have that back, if you don't mind. +So, all of this. All right. Is it safe to +assume that, as this went on, and specifically, +the last one that we have is Tuesday, August +13th, 2019. The Tuesday 13th, August 13th, +would be the most accurate timeline? +want to attest to it. +: It should be, but I don't +I mean -- +: Yeah, yeah. +- yeah. +: I'm just saying, based - +is there any reason for you to believe that the +timelines that were provided, or in any way, it +was determined that, you know, we should add a +point that actually didn't occur? Or is it +safe to assume that, the last one that was sent +would be the most accurate one? +: That's how it typically +works. At, you know, but I can't, I can't +attest to it -- + + +1 +2 +3 +4 +5 +6 +7 +8 +28 +And yeah. +-- of whether it was +accurate, but typically, the last one that you +send usually, you know, if you have to make +corrections, you make the corrections. And +information, if you have to. +Sure. Okay. Great. +When I show you things, it's not attesting to +it, but - +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +- I'm going to ask you +just to initial and date, and that's just to +say, specifically, that this is the document we +looked at, and when we spoke. It is absolutely +not attesting to it. +It's not saying that this +stuff is accurate. +•: And so, I write the date -- +If you could - +- and put reviewed on it, +or -? +-- nope. Just your +initial and date. +I'm just going to do this +last one, just the top of it. I'm not going to + + +29 +1 +2 +3 +4 +5 +6 +7 +8 +have you do every single one. And I'm going to +put this in a pile, back in a paper clip, and +I'm going to hand it to my friend over here. +What's the date? The 18th? +1: 27th. +_: 27th. +1: 10/27/21. +Thank you, sir, for +initialing and dating that. All right. I'm +going to just actually, because it's the +timeline, I'm going to keep it in front of me +because we might have to reference it. +: I can tell -- +: All right. +: - this is going to be a long- +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +ass interview. +It's going to be pretty +long. That's where I was trying to -- +: Yeah. Just -. +- you know? All right. +So, July 23rd incident. That was, what do you +recall what happened on July 23rd with inmate +Tartaglione and Mr. Epstein? Do you recall? +: I recall the investigation +that couldn't determine if they had an + + +30 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +altercation, or I believe if it was an attempt +at suicide. +All right. +So -- +- so, something happened +on the July 23rd - +Something happened -- +- where Mr. - +-- in his cell. +: - Epstein was found +with, like, +a - was it a noose around his neck? +_: It wasn't determined. It +was, you know, that he was laying in his cell, +but I don't recall the specifics of the report. +But I know it went back and forth where there +was a suicide attempt, or an issue with inmate +: Tartaglione. +-- with - yeah - +Tartaglione. Yeah. +: All right. So, these are +emails that we reviewed with regard -- +- to that incident. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +female. +you. +31 +So, this one is +specifically from, it says +Was that -- +-- your AW? +That is the AW. +: Send it to you? +: And this is a memo from, +is the +it says Mr. +operations lieutenant. +_: Yeah. Lieutenant. She's a +Right. This is where I +wanted to ask you if you knew -- +-- about this. It +specifically says, so, it was originally, I +guess, sent from Captain +to +_ : +: - from +to +: And her note to you says, + + +32 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +"From the memo attached, the information I +received is not what I was told happened." +So, what I wanted to know +is, and I guess, would you like me just to +refresh your memory, to really quickly read +what she said happened, so we can figure out +what it is that didn't happen? +Okay. Yeah. +All right. So, this is +subject, "Possible suicide attempt." Again, +July 23rd, 2019. It says, "On July -". Let me +just sit back so you can just kind of read +along with me. Would you mind if I sit next to +you? +No. No problem. +I'm vaccinated, just so +you know. It says, "On July 23rd, 2019, at +approximately 1:27 a.m., +• a call for assistance +on the Special Housing Unit was announced by +the control center. +Upon my arrival, I was +informed that an inmate had attempted suicide +and proceeded to cell Z05-124LAD. I observed +inmate Epstein, Jeffrey, number 76318-054, +lying in the fetal position on the floor of his + + +33 +1 +cell, wearing a t-shirt and boxers. +2 +He was breathing heavily, and was snoring. +3 +I called out to inmate Epstein and observed him +4 +flicker his eyes, and continued snoring. His +5 +neck was red with no abrasions. I observed no +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +further injuries to his person. An attempt was +made to get the inmate to stand on his own, +with negative results. The inmate was placed +in hand restraints, and staff was directed to +retrieve the stretcher. +As inmate Epstein was being placed on the +stretcher by responding staff, he would open +his eyes and observe staff. When staff made +eye contact with him, he would hurriedly shut +his eyes. The inmate was taken to HA-Unit." +Was it that? The health care? +: Health. Health Services. +: "Dressed in a suicide +smock, and placed on suicide watch. While +awaiting the arrival of an inmate companion, +inmate Epstein sat on the +of the bed and +began moving forward, as if was attempting to +fall over, head first. When I looked away, he +straightened up. As I turned to look at him +again, he attempted the same act. I laid him + + +34 +1 +down on the bed, and directed him to cease his +2 +action or he would be placed in restraints for +3 +his safety. +4 +At that moment, he stated, 'Okay. I won't +5 +do it again.' And gave the thumbs up. Because +6 +of his unpredictable behavior, the decision was +7 +made to have the staff member observe inmate +8 +Epstein. I had left HA-Unit in order to make +9 +10 +11 +12 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +staff notifications. Moments later, I spoke +with +who stated that Inmate +Epstein was alert and had indicated that his +cellmate, Tartaglione, Nicholas, +had attempted to kill him, and had been +harassing him. +He stated that the inmate had indicated +that he had informed his attorney of this +matter. I photographed and spoke with inmate +Tartaglione, Nicholas, who stated that he was +asleep with his headphones on when he felt +something hit his legs, and said, 'Jeff. What +are you doing?' He didn't answer. So, he got +up, turned on the light," or - so, yeah - "He +got up, turned on the light, and saw him with a +string around his neck. +He stated that he then called the guards, + + +35 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +and they ran down. Upon further questioning, +inmate Tartaglione stated that he sleeps on the +bottom bunk, but gave it to inmate Epstein +because he's old. He stated that he sleeps on +the floor, on a mattress. He stated that, when +he got up, he couldn't remember if he sat up or +stood up to check on Epstein. He stated that +Epstein was sitting on the floor, leaning to +the side, with his eyes opened, but wasn't +responding. +He stated that the last time he saw him, +he was snoring really loud. Inmate Epstein +stated that he comes in from a legal visit at +approximately 8:00 p.m., and staff handed him a +copy of the daily news. Nick was on the floor +reading the daily news. He stated that he had +given it to him. He stated that Tartaglione +mentioned that he had been in court all day, in +Westchester (Phonetic Sp. *00:25:00), and was +carrying on. +At that point, inmate Tartaglione paused, +as if he was making the story up, as he went +along, and stated that Tartaglione stated, +"These fucking N-I-G-G-E-R-S. This place is +inhumane. I wish I could report it. + + +36 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Officer, that N-I-G-G-E-R, hobbit +motherfucker.' He then turned to a page in the +daily news that had his picture on it, and +stated that Epstein was worth 77 million +dollars. +Epstein then stated that he took his +picture, balled it up, and threw it in the +garbage. I asked inmate Epstein what happened +prior to staffs arrival. He stated that at +approximately 1:00 a.m., he had gotten up to +get a drink of water, as he gets up every 30 +minutes. He remembered walking back to his +bunk, and waking up with staff there, in his +cell. I asked if he had waken up and seen +staff, why didn't he respond when we were +calling out to him. +He stated that he only remembered hearing +himself making a noise like snoring. When +asked about the allegations against his +cellmate, he stated that he was told if he hurt +him, staff wouldn't care. Duty medical doctor +-" how do you pronounce that name? +Beaudouin. +B-E-A-U-D-O-U-I-N. "Was +notified and briefed. It was determined that + + +37 +1 +2 +3 +4 +5 +6 +7 +8 +no further medical attention was needed. A +medical assessment was not conducted at the +time of this incident, due to the fact there +was no medical staff available after 10:00 p.m. +Upon their arrival of medical staff, inmate +Epstein was examined and treated by M-I-P-Y." +Joaquin. +Joaquin. J-0-A-Q-U-I-N. +"For a circular line of arrythmia, at the base +of his neck. One section on the front, with +marks of friction, and a small arrythmia on his +left knee." So, sorry that that was so +lengthy. But so, again, the question would be, +is this, does anything in here strike you as +inaccurate? +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +NO. +So, when +says that in the attached memo, "The +information I received is not what I was told +happened." Do you know what she is referring +to? +: I think she - if I recall - +that she told, that said that it was an +attempted suicide, but then she got any +additional information that it might have been + + +38 +1 +2 +Epstein and Tartaglione having an issue in his +cell. +4 +5 +6 +7 +8 +: And what, and my +understanding is that SIS came up with +inconclusive findings. +In the investigation. +What is your belief that +happened? +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: I can't speculate. +: You don't -. +1: I don't want -. I mean, I +don't know, you know, with the injuries on the +neck, I don't know if it was a suicide, and I +don't know, based on Epstein's statement, that +was something done to him. So, couldn't prove +what it was. +Okay. And is it, is +there any reason for us to know or believe that +it was one or the other, though? I know you +are trying not to speculate, but -. +: I mean, I would, you know, +you have there be the medical department, who +did an assessment, and, you know, typically, +you could say you come to a conclusion from +injuries, from physical injuries, but we + + +39 +1 +2 +3 +4 +5 +6 +7 +8 +weren't even able to do that. +: So, according to the +medical assessment, your understanding is that +they weren't able to tell if someone -? +: That, from what I - if I can +- and I don't know - I read it - but I don't +know -. I remember on the report, they were +unable to conclude what would, you know, what, +what -. Did he attempt suicide, or was he +assaulted? +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +And were you satisfied +with that response, or did you think that they +missed something? +: I think they looked into it. +And I think it was, you know, you couldn't 1o0k +into it any further. I mean, either - +: —- it was a suicide, or it +was assault. So, we separated them. +Okay. But there is -. +So, it didn't say, like, keep digging, or you +weren't, you know -? +: I mean, they interviewed +them. They asked the questions. You had the +medical assessment. So, I don't know what + + +1 +other -- +2 +3 +4 +5 +6 +7 +8 +40 +Sure. +-- conclusions could have +been drawn from it. +: And what happened with +inmate Epstein after July 23rd? Or on July +23rd. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +•: I don't specifically +remember what happened. I know we separated +the both of them. +He wasn't - and then, I know +he was on suicide watch. They placed him on a +watch. And then had psychology talk to him. +okay. So, just so, that +is just so you know, if you don't mind just +initialing and dating that one, that we just +read. Okay. So, this next one is from +Charisma +to a Carrie Schleschinger. +(Phonetic Sp. *00:30:05). +She's a psychologist. +Okay. And then, with +UCC. +It says, "sw, +chronological log, re: Epstein." It says, +"C.O. +was assigned to staff watch. + + +1 +2 +3 +4 +5 +6 +7 +8 +However, the wrong book was used. I am +companion 1og, in lieu of staff suicide watch +1og." +41 +Was that something +normal? Was that an easy mistake? +: yeah, I could see it +happening because we have a log that the +inmate, you have an inmate companions that +watch inmates. So, they use the log. And +then, you have, if staff are going to sit on +someone, then they use a certain log. But the +fact that, you know, the documentation took +place, it was just, you know, it was just an +error. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +this +: But they did document, so. +Now, c.o. +Is +that you, are you aware? +: I had two +I don't +know which one it was. +So, if I tell you +it was -- +Officer +No, no, no. It had to be +1, because if it was C.O. + + +1 +2 +3 +4 +5 +6 +7 +8 +he would have been - his title is material +handler. +Okay. So, you don't +believe it was actually +No. I think it was the +officer. +It was Mr. +Just from our records and from +42 +speaking - +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +- with Mr. +Can I see the log -- +Sure. +- how he opened the log? +That is correct, right, +Where does it show that he +started his shift? Because usually, when you +come on shift, you write - +This is what - +- the name. +- was attached to that +email. +Yeah. Typically, when you +start your shift, your start off, you know, + + +43 +1 +you're putting your name, if you are relieved, +2 +or you assume suicide watch. +3 +So, here is the next +4 +email, so you might be able to show me an +5 +example of what you are referring to. It's +6 +this email, is it the same thing you were CC'd, +7 +and this is, like, maybe this is the real 1og +8 +that maybe he should have been using. But +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +here, it shows all the other logs. +So, this is -. +: Hmm. +_: See, this is what I mean by +when someone comes on duty, but this is what +they leave - +This is the -. +- they mix the book up. +But they must have wrote it in the suicide log. +But typically, when you come on, let's say the +shift starts at 8:00, you will state your full +name, as assuming the duties. +: okay. +And you typically say who +you relieved on there. +All right. So, it looks +like they maybe didn't fill it out correctly. + + +1 +2 +3 +4 +5 +6 +7 +8 +correctly. +shows that it was +23rd. +44 +They didn't fill it out +And so, our investigation +- that was on him on the +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +And that wasn't an "I +gotcha, " whatsoever. My question was actually, +is the one that actually found +him on August 10th. Correct? +Yes. +And is that suspicious at +all to you, that he was the one that was +watching him on suicide watch, and then that he +is the one that found him on the 10th? +: No. I mean, typically, we +had so much overtime in the institution, that - +and we go by when you sign up for it. So, +there is a program that you sign up for, and I +don't know how the lieutenant did. They might +have called them, then he signed up for it. +So, I don't know. +I can't say if it was +suspicious or not. + + +45 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Sure. And then, all +these documents that we're reviewing right +here, on these two emails, what are they? +Which one? +Both of them. +The suicide watch log? +Yeah. So, is this +suicide watch log, as well as this? +_: Yeah. The suicide +observation 1og, and this is appears to be the +cover of a logbook, for suicide watch. +Perfect. +All right. Do you mind +just initial and dating this? And again, these +aren't trick questions -- +- I just don't want to, +like, put answers in your -. If I think it is +something, but maybe it's not, you might be +able to tell me what it actually is. +This one, too? +Yes, please. Thank you, +sir. +And this is, this says psych ops. So, +this is another one of those emails. This one + + +1 +2 +3 +4 +5 +6 +7 +8 +is from +to you. Also dated August 10th, +2019. It says, "Psych ops is discontinued on +7/30/2018." I think she means 2019. Correct? +At 8:15 a.m. +So, is this also part of +the suicide watch log? +46 +: That is a log you would also +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +use. +Okay. Great. And does +it say in there, I guess right here, "8:15 +a.m., psych observation is being +discontinued."? +: Yes. +okay. Awesome. Do you +mind just initial and dating this? And +as I am giving these to you, can you try to +keep these in order with regard to - +1: I've just been stacking them. +-- making a note. Don't +stack them on tip, though, keep them, like, +bundled together, so we know this is psych. +This is, like, the psych observation logbook. +1: Okay. + + +1 +2 +3 +4 +5 +6 +7 +8 +47 +So, if you can keep them, +and then write a note on them. +1: Okay. +So that when we are -. +After this thing is transcribed, we can keep +things in order. This one is regarding the +first attempt, and the one we read from +- And can you tell me, sir, what +this is? This is July 30th. So, it is that +same date that he came off of -. What am I +looking at here? +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: So, this is -. Date, name, +signature. Inmate name. Reg number. This is +-. Is this a entrance log to the Special +Housing Unit? +I'm not sure. That's +what I'm saying. +: I'm just, I don't know. It +might be an entrance log. This is 7/30. +These are all dates, but +at least up until 7/30, that he was in the +Special Housing Unit, but this says J. Epstein. +So, I don't know if he would sign himself in. +No, no. +so - . + + +1 +2 +an entrance -- +3 +4 +visits or something? +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +48 +I don't know. It might be +Or is it to the attorney +- it might be attorney +visits. Let me see. 7/30. G tall (Phonetic +Sp. *00:36:57). Signature. Inmate name. +Name. This might be an attorney log. Name. +Fall. Signature. Yeah. This might. This is +probably an attorney -- +- the log into the attorney +room. I think that's probably it. +Here is Epstein again. +It shows 7/30, 7/30, 7/30. +The different attorneys. +He, you know, he could have had one attorney +that comes in early in the morning - +- and then, any time a new +one comes in, they have to sign in, saying who +you came to see. +: okay. +So, he had multiple - +So, this is - + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +*00:37:46). +visiting this person. +to put who -- +for attorneys. +49 +-- (Indiscernible +- an attorney 1og. +This is an attorney log. +He +usually had multiple attorneys. +So, it wasn't Epstein +signing his name. +They are - +No, no. +- saying they were +Whoever comes and visits has +- they are visiting. +So, the visitor logs were +Attorneys. Yeah. +: All right. You mind just +initial and dating that? And again, +• if +you want to write on here, just - +- attorney logbook +visit. So, again, so that we can keep track of +what it is these things are. Now, is this the +same thing we just looked at? This looks like, + + +50 +1 +2 +3 +4 +5 +6 +7 +8 +again, it says, "Inmate companion assumed +duties from staff on 7/23/19, at 7:00 until +7/24/19, at 8:45 a.m. Epstein was transferred +to psych observation on 7/24/2019, at 8:45 a.m. +until 7/30/2019 at 8:15 a.m. Inmate companion +was utilized." +So, this one says July +23rd, 24th. And this one, again, suicide watch +chronological 1og. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: Mm-hmm. +Inmate companion logs. +Does this tell you anything more about +, or anything different? What is this? +This one is the PP-37. What does that tell us? +That's just he's on it? +: Yeah. It just says, you +know, (Indiscernible *00:39:01), let me see. +You got category. I don't know what the MDS +is, but typically, it's an assignment. Like, I +could put in and do a PP-37 and say where he +was housed at. So, I could put quarters. So, +this must be a medical term. Concerning his +medical status. +Okay. Great. And then, + + +51 +1 +2 +3 +4 +5 +6 +7 +8 +this is the first page, it looks like, of the +logbook. Does this tell you -- +-- anything different +than what we looked at before, or is this the +same thing? +It's the same. It's an +inmate suicide watch -- +-- log. +So, it doesn't say +on it, it just -- +: No. It says inmate +companion was watching him. +Okay. You said inmate -. +Oh, so, this is an inmate companion instead of +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Yeah, yeah. +- the actual. Okay. +You have -- +: I got you. So, whatever, +does it tell us which, who the inmate was, that +was his companion? +Inmate companion Estebon +(Phonetic Sp. *00:39:51), and it has his number + + +1 +2 +3 +4 +5 +6 +7 +8 +right there. +inmate Epstein on -. +too. +52 +Okay. Great. +Assumed responsibility for +Perfect. +: So, that's why I was telling +you, the staff one should read just like that, +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +All right. So, this one +is 7/23 is the actual inmate that was -- +: Mm-hmm. +-- Epstein's companion on +7/23 until 7/24. Do you mind just initial and +dating that? +1: And this is right after the +incident. The first incident, right? +: This is - so, July 23rd +or the 24th - yes, this is when he was on +suicide watch, not on observation. +And this is that, it +looks like this one is, again, it's from you to +It says psych ops/suicide + + +53 +1 +watch. And it looks like it's the difference +2 +between the two. +3 +4 +5 +6 +7 +8 +: In laymen's terms, what +is the difference between suicide watch and +psychological observation at the MCC, during +this time period when Epstein was on it? +: So, suicide watch is when we +have determined, or there is a possibility, +through what an individual is saying, that they +might cause self-harm to themselves. Psych ops +is, that person might not admit it, and we +might not have anything to say to put them on +suicide watch, so we just put them on what we +call psychological observation. +: And now, it was my +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +understanding -- +(Indiscernible *00:41:11). +- it's basically the +same thing, aside from what the inmate is +allowed to have, such as clothes. +That, too. +So, is it same +unit, same room, same -- +Same. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +no. +54 +-- same procedures? +Yes. +: Okay. The one thing that +I've learned more recently is, though, during +psychological observation, or I guess I should +ask for them. During suicide watch, as well as +psychological observation, is the inmate +allowed to have attorney visits? +: If they are on that watch, +: What about during +psychological observation? +: I think it would be the same +thing, that they are not allowed to have. And +I'm not sure. Don't quote me to it. Because +typically, when they are on that, we don't have +: Okay. Do you recall if +either yourself or anyone at the institution +was contacted by anyone, such as a judge or +Epstein's attorneys, asking that he be removed +from either psychological observation or +suicide watch, so that he, for any reason? +: They will always call. +mean, they would. There was always a number + + +55 +1 +2 +3 +4 +5 +6 +7 +8 +subject, whether it was to place him in general +population. So, I don't, you know, recall -. +Do you remember ever +being called by a judge? +: No, I don't. I don't +recall. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Speaking with a judge. +All right. Because that +was the rumor we heard, was that a judge +contacted you and said they wanted him removed +from one or the other. +: No. Judges wouldn't +typically call for that. +: But the attorneys +frequently would? +: Yeah, frequently, they +would, you know, call our legal department, +saying, you know, why can't he go to general +population. Why is he, you know, being housed +here? And just not him, if there was any type +of equipment that was requested. Those are the +type of requests you get from the attorney. +Okay. And do you know if +those attorneys were made, though, when he was + + +56 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +on either suicide watch or psychological +observations? +I don't recall that. +: You don't recall. +Sure. That's fine. +Do you know - I know you +said that, and you didn't think that inmates +typically could - but do you know if Mr. +Epstein visited with his attorneys during that +time, between the 23rd and the 30th of -- +I don't know -- +- (Indiscernible +*00:43:28)? +- if he was on that status, +then he would not have been -- +: You don't believe so? +-- I don't believe so. +No. I don't believe +SO. +No problem. All right. +So, this, this one again. Oh, do you mind +initial and dating that? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +an incorrect - +22 +23 +24 +25 +previous question. +57 +okay, +• you can +file that accordingly. This one just goes back +to that first initial timeline, that looked +like it may have been a little messed up. The +initial email from you, it looks like it's a +psych ops. "The logbook shows he was released +on July 30th. He had an attorney visit, +starting at 8:20 a.m. +He was there all day. +will send the attorney log next." And then, +response was, "The timeline we +sent DOJ says 7/29. +Where did we get that +date?" So, are we confident that he stayed +until the 30th? +]: +He stayed until the 30th. +Okay. So, was this just +•: I think that was a typo. +- okay. Oh, sorry. +you mind initial and dating? +Well, this answers your +Do +What's that? +About being on psych ops and + + +58 +1 +2 +3 +4 +5 +6 +7 +8 +seeing an attorney. He didn't go until after +he got off. +Well, it says that he had +an attorney visit -- +: - starting at 8:20 a.m., +but it doesn't say if he had any prior to that +time. +released on July 30th. +Right. Oh, because he was +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +So, just saying, like, +yeah, he was released and -- +- he was visiting with +his attorneys. +And that's something +we've had a little bit of a conflicting +information. +We've heard that he +actually did have attorney visits during that +time. And we've heard that he didn't. So, + + +59 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +that's why I was wondering if you would be able +to clear that up at all, but you're not -- +- to your recollection - +- +-- he wouldn't have? +Yeah. Typically, if you are +on that, you're not going to have an attorney +visit. +: And just talking to +psychology, they would, they said that, no, we +always try to afford an inmate - they have a +right to attorney visits - so, we try to afford +that right. But do you think that maybe they +were mistaken? +: I'm just going from my +experience, like any other of the inmates that +we've had on suicide watch have not gone to an +attorney visit. +: Okay. Now, this, +speaking of psychology, that's the next point. +Let me just make sure that all the information +is on that incident. So, as far as +Tartaglione, or Tartaglione, however it is -. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +selection made? +decision? +60 +How do you think it's -? +Tartaglione. +: okay. +Okay. So, did you have +any involvement with selecting Tartaglione as +Epstein's cellmate? +We did. +Okay. And how was that +: So, we weren't able to get a +whole lot of people, you know, think that how +we could house him to be safe. Tartaglione was +a white male. Another high-profile case. So, +and he is not, you know, there is this +misconception that he was a big hulking +bodyguard, but he lost over 100 something +pounds. So, he was smaller in stature and +frame. So, we said that would have been an +appropriate cellmate for him. +And who made the +Io put them together? +: Mm-hmm. +I did. + + +1 +2 +3 +4 +5 +6 +7 +8 +61 +Okay. Was it in +coordination with both the captain, as well as +Everyone - yeah - would +discuss it, like, you know, I, obviously, I +sent it up the chain, to say, look who we're +going to make him his cellmate, and what was +the reasoning. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +So - +- in talking with the +captain, his recollection was that he brought +the three names, you discussed it with Mr. +he was present for that discussion, and +is the only one who said, I want +Tartaglione, put him with Tartaglione. Do you +recall it to be that way, or do you recall it +to be -? +talking about Tartaglione? +which -? Well, are we +oh, did that happen with +Reyes? +: Well, Reyes and - what do +you call it? - Reyes and, there were two names. +So, I talked to my boss about it. They wanted + + +62 +1 +2 +3 +4 +5 +6 +7 +8 +to see the names. +So, I don't know who they +talked to at Main Justice. So, I sent the +email, and stuff, with all the break down of +the two inmates to the director's office. +(Phonetic Sp. *00:47:45). And +because he was the chief of staff at the time. +And I sent it up, you know, I put my input in, +about as far as if we had to choose between who +was going to get it, was the - what was it? - +the Spanish, the older gentleman who left, like +- +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Efrain Reyes? +- Reyes, that Reyes would +be the most appropriate because we couldn't +find anybody. +Okay. So -- +: And then, they went up, and +then, I got word back that, to go with Reyes. +Okay. So, Reyes was when +the -. So, your superiors actually made the +selection, but for - +Tartaglione. +- Tartaglione, that was +you? +I mean, it was in + + +63 +1 +2 +3 +4 +5 +6 +7 +8 +conjunction. I sent it up and told, you know, +the powers that be that this is who we're going +to be, and it came back and said, you know, +we're good for that. +: Okay. Do you know what +Tartaglione was in for? +: He had - I know it was a big +drug case involving drug dealers, and stuff +like that. So, and - so, yeah, (Indiscernible +*00:48:45) - +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: Some kind of narcotics. +_: —- huh? +: Some kind of narcotics. +: Some kind of narcotics. So, +he - and then, I don't - and I recall there was +murder involved, too. +: Yeah. +: But he was a high-profile +case. +So, I could -. +I had gentlemen in there +that were trying to get in there, but you know, +they would have probably harmed him. I had +another pedophile in there, and everybody in +the unit, they know who's in the unit, I'm not +taking him as a cellmate. You know? +So, we +can't just arbitrarily force another inmate + + +64 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +into the cell upon them. So, Tartaglione was, +you know, the best - +: The other inmates -- +-- inmates -. +: - would not accept Epstein, +nor would not accept a pedophile. +They weren't going to -. +They just weren't going to stab Epstein +*00:49:29). I don't know the reasons. But I +mean, I can't make the decisions and say, all +right, I'm going to force you to take this, and +then something happens to him, and then -. +50r +someone actually +spoke with Tartaglione and he said he was +willing to do it? +: And I'm not sure on there - +who spoke to him, but I don't know. +: It might have been. But I +know we said we were going to put him in, and +this is, this is what -. And he didn't have +any issues. +: Okay. And if someone did +speak with him, who would that have been? +Would that have been captain? + + +1 +2 +3 +4 +5 +6 +7 +8 +65 +It might have been the +captain. Shoot, (Indiscernible *00:50:02). +But it probably would have been the captain, +but - +: - you know, typically, you +know, we're going to make a move, and we're +putting somebody in there, we're not going to, +you know, sit down and consult with an inmate, +if that's okay with you. I mean - +Sure. +- we just have a feel of +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +the unit -- +NO. +- that, who is appropriate +to go in there, okay, I'm not going to put a +drug dealer in there with him. So, you know, +typically, another high-profile inmate would be +appropriate. +: Okay. Now, do you have +any reason to believe that Tartaglione did, in +fact, try to harm Epstein on July 23rd? +: Again=, I can't speculate on +that. +Sure. Just because - + + +1 +2 +3 +4 +5 +6 +7 +8 +66 +I mean -. +- it would be pure +speculation, if you did? +: Yeah. It would be. +I would +be speculating on that. +I can't -. +And you just prefer not +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +to do that? +Yeah. I don't want to +speculate. +okay. Now, so, our +assessment from other people has been that -- +- Tartaglione was trying +to beat his case -- +- and that he had every +reason in the world not to harm Epstein. And +that Tartaglione was actually the person who +notified the guards that Epstein was in need of +help. Is that what you -? Is that a correct +assessment? + + +1 +2 +at the time. +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +attorneys. +67 +: Tartaglione wasn't in the cell +So -- +On July 23rd, he was. +- he was. So, he -- +: He was. Oh, I -- +-- yeah. +: -- yeah, right. +: Yeah. So, here's how I'm +going to put this. As far as Tartaglione, we +and his behavior in the institution, he wasn't +a model prisoner. I mean, we caught him, you +know, with a cellphone. You know, making +calls, you know, and circumventing his case, +and whatever. But so, I don't, I can't +speculate on, you know, whether he would do +something, or he wouldn't do something. So, +that was, you know, my dealings with +Tartaglione, when I was aware of him. Plus, +you know, his case. +: Mm-hmm. +And the request from his +okay. So, following +Epstein's time on suicide watch and + + +68 +1 +2 +3 +4 +5 +6 +7 +8 +psychological observation, was he placed back +in the SHU? +Yes. +So, and I +apologize to read all these, but this is just - +again - we're not going to through them one by +one, but just to show what it is that we have +here. So, this one says it's from an +to +Did I get this from you? +I think this is something that forwarded on. +: She say even gave your own +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +drinking -- +This one says, "Can you +send me notes on Epstein? On his suicide +attempt. Thanks." That was from +it looks like, sent it up. So, +said, "I need this ASAP." And it +says, "Here are his notes." +So, he said Niro (Phonetic +Sp. *00:52:59). I guess the regional is +requesting it. +okay. So, the region +wanted this? +So, this, is this what + + +1 +2 +3 +4 +5 +6 +7 +8 +this is? +Epstein? +69 +Is this the psychology file of +Those are clinical notes. +So, these are all +clinical notes -- +: -- here? +Would this have been, +like, okay, it starts with, it looks like July +31st, and then goes back, July 30th. So, it +looks like these are clinical notes from the +day he got there -- +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +- up until July 31st. +I wonder why. Why would +they only send until July 31st? Do you know? +: You said -- +Not August. +- they sent from where? +Well, it -- +From -? +- started from the day +that he arrived, it looks like, on, it's July + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +8th, 2019. +*00:53:53). +- +70 +: To July 31st, 2019. +It's any encounter you have +with him. Any medical - +: So, did they not - +-- (Indiscernible +- have any encounters +after July 31st, 2019? +: Do you know? +: No. I am not aware of that +because it would only - they would only +annotate if they had encounters with him. +okay. So, you are +unaware of, after July 31st, if anyone had any +kind of, any psychology had any interactions +with him? +No. If it's not in the BEMR +notes, and that, I guess they didn't have any. +So, you would assume that +: -- there wouldn't be? +Do you mind initialing? And do you know + + +1 +why that would be? +2 +: Hold on. If an inmate is +3 +cleared off of - so, and you have to talk them +4 +about it - but most inmates didn't, once you +5 +are cleared off of suicide watch, they have +6 +other things that they do. You can come down +7 +and they give you some (Indiscernible +8 +*00:54:42) courses to take. So, they have +other types of therapy, but it doesn't +necessarily have to be entered in as a medical +71 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +encounter. +Okay. So, this is, so, +psychology could have been still meeting with +them, just not noted as a medical encounter? +: Yeah. You - I mean - you +see them, and you can just, like, if you have +patients, you will go, how is everything going? +You doing all right? Yeah. I'm fine. I'm +okay. So, it doesn't have to be noted as a +medical encounter. +: Okay. So, your +involvement with this, being that he came off +of psychological observation on July 30th, +should psychology had interacted with him more +in that type of setting, where they would have + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +mean, when - +72 +been writing clinical notes? Or do you -- +No. I think they - +: -- or -? +-- did everything. Because +they cleared him at the time. I mean, based on +the SIS investigation, it was inconclusive +whether he committed, you know, tried to -- +Sure. +-- attempted to commit +suicide, and I didn't read all the reports, but +if he's sitting in the report, saying, no, I +wasn't trying to kill myself, and I didn't do +it, that's their assessment of it. +Right. No. I guess what +I'm saying is that, I know you're not a +psychologist, but if the 30th was the day that +they cleared him to go back to the SHU -- +- do you think that they +should have continued at least checking with +him, or no? +well, they probably did. I +- you make your SHU rounds. + + +73 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +You know, seeing him in other parts of the +institution. So, and you would have to ask +them. But there were probably encounters with +him. +: But that didn't require -- +: A report. +: - a report, and a medical +annotation in there. +Okay. So, this next +email, it talks about, it says, "Warden +," and this is from +and +again -- +-- is he the coordinator? +Of, who is he? +Oh. +: Oh, here it is. National +suicide prevention coordinator for the BOP. +: It says, "Thank you for +supporting our scheduling of the psychological +reconstructive for inmate Epstein. I will be +joined by +(Phonetic Sp. +*00:56:44) Correction Service Administration of + + +74 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +the Northeast Region. So, do you know if that +was ever completed? The actual suicide +reconstruction. +They might have, but nobody +talked to me. +Okay. They didn't talk +to you? +Nah. +Okay. Fair enough. And +then, behind it, it looks like, just, it 1o0ks +like a template is attached here. +"(Indiscernible *00:57:00 national suicide +prevention program, suicide reconstruction +materials." +Would have you been the +one that would have gathered these things for +him? +No. You probably -. +Typically, when this happens, this comes from, +when I used to do them, I would make contact +with someone in the institution, to get it. +So, you might - +-- have the executive + + +1 +assistant -- +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +75 +- get the information. +So, it says, "I am +attaching a list of materials we use to +complete the reconstruction. We routinely take +these documents with us, so please ensure that +a copy of any documents you also need." +: It says, "Your assistance +in gathering these documents, appreciate it, +will be helpful." So, you would just, you +would provide that to, like, +or +someone? +: Yeah. We tell the exec, +hey, I need you to gather this information, and +it might not be +. It could be the +chief psychologist. Whoever is assigned to do +okay. But as far as you +know, was that completed? Did he show up and +do that? +I wasn't at the institution. +: oh, okay. +I -- + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +institution. +from the institution? +afte that? +76 +So, you - +- I was removed from the +- when were you removed +Monday. +Yes. +Monday, August 12th? +Okay. That's what I was +kind of asking you before. Maybe I wasn't +clear with my question. I was wondering if +something happened to you after this, that you +were removed and no longer -- +: No. They just told me, go +report to the region. +- all right. So, as of +Monday, August 12th, 2019, you were no longer +at the MCC? +I was no longer at the MCC. +And did you ever go back +No, I didn't. +Okay. So, that was -. +Well, I did today, to go + + +1 +2 +3 +4 +5 +6 +7 +8 +park. +any -. +77 +Okay. But after this +instance, and you were not really involved +after that, then? +: That was it. I didn't have +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: Yeah. You check in today. +Did you just say? +: No, I had to park a vehicle, +because I had to -. I had the government +vehicle, so parking them, I had the prop, so I +parked there, and took the train out, +(Indiscernible *00:58:46). +: I think when we started, and +asked when you started at the regional +office, I think you mentioned 2020. +: So, the problem is, and he +was talking about job title. My job title +still remained the same. +: As warden? +: As the warden in New York, +and it wasn't removed until 2020. +1: Okay. Well, now, but as of +August 12th, 2019, you started reporting to the +region? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +place? +your way. +question. +78 +Yeah. DRD (Phonetic Sp. +*00:59:14) came. I did my - when was it? - I +had an interview at the U.S. Attorney's Office. +And then, my boss came and said, hey, I'm, you +know, we're signing you up to the regional +office. So, I went up, you know, no reason why +I was being removed. And I was just told to go +up there. So, that's what transpired. +1: Was there another warden in +: They brought another one in. +1: So, there was two people with +the title of warden, at that point? +well, they had +(Phonetic Sp. *00:59:52), and Lacome Vitale +(Phonetic Sp. *01:00:01). She is. +1: Okay. +: All right. So, if you +don't mind, just initialing and dating that. +We'll get that out of +So, this looks like this answers our +So, this is an email from + + +1 +AW +to yourself. +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +psychologist at MCC? +psychologist. +79 +: And it just says, "FYI, +from Dr. +I, regarding her last interaction +with Epstein, prior to her departure on +Thursday." +DI. +was the +Yes. +Correct? +She was the chief +Okay. Great. And it +says that, "I visited inmate Epstein in SHU on +Thursday." Thursday, meaning August 8th -- +- 2019. "He was getting +ready to meet with his attorneys for the day, +so I had gone to visit him, right after the SHU +meeting. +: He had a cellmate at the +time, with whom I saw him interact with. He +did not report any medical, or any mental + + +80 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +health concerns, and he denied any suicidal +thoughts or intention. +He was asking the +writer to go to general population and was +making requests for various leads he had at the +time. He wanted social calls without them +being on a speaker phone. He wanted a book he +had left in the suicide watch area. +His mood was not depressed or anxious. +There were no signs of stress. He had planned +on meeting with his attorneys to work on his +legal situation." So, there is that. And +then, there is also, I don't know if this was +attached. +, I don't know how this was +printed, but it also looks like all the +contacts. It says, "15 contacts in one month. +Starting on July 6, 2019, when Epstein arrived. +And after the -". It does say that there was a +contact that looks like, on the 31st. +: What does he mean by +"contact"? +A psychology contact. +• okay. +And then, here's one, +8/1/2019, Dr. Imeri, SRA, was -- + + +81 +1 +2 +3 +4 +5 +6 +7 +8 +- being conducted. What +is SRA? +Do you know? +: It's a seg group. +Segregation review. +: oh. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +So, it says - +form. Suicidal tendencies." +-- it says, "Court sent a +No. That must be a +psychological thing. I thought it said SRO. +If it says SRA, that must be for SHU. +Okay. And it says, "On +August Ist, 2019, he denied any suicide ally, +friends (Indiscernible *01:02:07) supportive +Jewish against his religion, still denied +knowing what happened to him on 7/23/2019, when +he was discovered with a string loosely tied +around his neck. Said his incident report for +self-mutilation was expunged. His cellmate is +talkative, but will give it a chance. Noisy in +SHU, he lives for fighting this case and going +back to his normal life." And again, it say +that the 2019 was with Dr. +what I just + + +82 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +-- read. And on +8/10/2019. So, I guess they did (Indiscernible +*01:02:40), just not in this (Indiscernible +*01:02:40). +Yeah. You don't have to +always. +So, yeah, then maybe +those weren't required. +Yeah, do you mind, maybe +the bottom on this one? +:Mm-hmm. +: That wasn't attached to the +email. That was just a separate document. +Oh, that's a separate +document? Okay. There you go. Can you go to +psychology? All right. And this is the last +one to cover what psychology. This was an +email that was sent out by a +Imeri. +To, it says, "Suicide watch/psych observation +update." On 7/30/2019, at 12:30 p.m., and it +says, "Inmate Epstein is being taken off of +psych observation and needs to housed with an +appropriate cellmate." + + +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +83 +and it just +says everyone who is attached to this sent, +this was sent to. +: Is this something that +they normally do, after someone comes off of +psych observation or suicide watch? Do they +send this out to everyone? Or was it a special +case for this? +: No. It's typical. +: That's typical? +Typical. Because you have +to let the lieutenants, the shift lieutenants, +everyone know, you know, the person is coming +off. And where to house them. Some go back to +their units. In his case, he was going back to +the Special Housing Unit. +Okay. Great. Do you +mind just initial and dating that? And that +was - is it their job to determine if a +cellmate has to be housed with another +cellmate? I mean, an inmate has to be housed +with another inmate. +Well, typically, I mean, + + +84 +1 +2 +3 +4 +5 +6 +7 +8 +it's just - if there's nothing in policy that +sounds, you know, you know, in the correctional +setting, if somebody has been on, you know, +attempted suicide, or attempted to selfmutilation, you usually put them in with +someone. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: Okay. So, were you or +your staff involved with the decision to have +Epstein removed from suicide watch or +psychological observation? +: Psychology makes the +determination that the individual is, you know, +no longer suicide. This is for any inmate. +: Sure. +: Is no longer suicidal. And +there is no reason for him to be on suicide +watch. So, they either get released wherever +they came from, whether it was the general +population unit, or the Special Housing Unit. +So, on background on +that. So, one of the individuals in psychology +department -- +- who would meet with +Mr. Epstein, she said that she discussed this, + + +85 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +one of the steps down with Dr. +as well +as +: And I was informed that +that is kind of pretty routine, that that is +conducted in coordination with executive staff +members. Is that - +Right. That is. +- so, that's where I +want to make sure that I'm understanding -- +: We do. +- what you are saying. +But we also do, we have what +we call a - and if it is an inmate that is in +our Special Housing Unit, we have a weekly +meeting, and if there are any issues, that's +brought up in the meeting. +okay. So, is it solely, +though, up to psychology, if the inmate goes +from, say, suicide watch to psych observation, +and again, psych observation back to a housing +unit? Is that their call, or does the +executive staff, or anyone in the BOP, outside +of psychology, have an influence on that? +Psychology are the subject + + +1 +2 +3 +4 +5 +6 +7 +8 +matter experts. They are the doctors. They +release someone off of suicide watch. I can't +- if an individual is on suicide watch - I +can't turn around and come in there, and say, +take him off. +86 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Sure. +I'm not a trained +psychologist. Now, I can put somebody on +there. But then, you know, after hours, or if +it is an emergency, or he attempted suicide, +any staff member could put him on there. +But as far as taking him +off, you have to have a medical reason, as far +as them coming off. +: So, in that interview +with that individual, they said the decision +was discussed with +and that +individual concurred with that decision. If +they didn't concur, though, would that matter +to them? +didn't concur with it? +what do you mean, if the AW +I mean, I don't want to use + + +87 +1 +2 +3 +4 +5 +6 +7 +8 +the word "courtesy" as a telling, but they're +keeping us informed, saying, okay, we need to +take him off of suicide watch. Now, let's say +I come in and interject and say, no, I want him +on there. What is my reasoning for putting him +on there? +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: What medical degree do I +have to justify keeping an individual on +suicide watch? Because now, it could go the +other way. I decide to turn around and do +something like that, I would be having a +conversation with you about something else. +Sure. +So, is it more to keep +you apprise - +To keep us apprised -- +-- if anything else? +- you know, and saying, +hey, this is the way we're removing an +individual, and we move forward. I mean, +obviously, we will have questions. You know, + + +1 +2 +3 +4 +5 +6 +7 +8 +if we had questions. +: Guys, I want to go for a +second. All right? +: I got to go pee. +: Do you want us to +continue or wait? +88 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: No, just stay by me. Oh, +don't continue. I'll be right back. +: Absolutely. I'm going to +pause this recording then. It is currently +3:00 p.m. on Wednesday, October 27th, 2021. +This is Special Agent +and I +am pausing the recording. +(Whereupon, the above-entitled matter went +off the record and back on the record). +All right. The recorder +is back on. It is 3:04 p.m. after a quick, +short break. +just reminding you +that you are under oath. +_ : +All right. Sorry. +Address these. +oh. +All right. So, the last + + +89 +1 +2 +3 +4 +5 +6 +7 +8 +that we discussed was that psychology said that +Mr. Epstein needed to have a cellmate, and this +is where we talked a little bit about it. It +sounded like the decision to have Efrain Reyes +placed as Epstein's cellmate was actually made +at a higher level than yourself? +Yes. +Okay. And who made that +decision? +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +I don't know. Listen. I +know, I sent it to my supervisor. Actually, +the two inmates that would kind of figured out +there might be a cellmate, we sent those names +to the director's office. +And it was +was +the chief of staff. And because, see, my boss +told me that they had to run it up to the +department. So, I don't know who was spoken to +in the department. And it got back, and my +boss said that, too, you know, that's a good +choice. +And that's + + +1 +again? +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +90 +Yes. +: Okay. Great. But it was +based upon a list that you provided? +_: Yeah. There were some +names. Because I - fast forward - I got a +call, and we were gearing towards getting him +out to general population. +oh, so, you wanted +Epstein to actually be in general pop? +: I didn't want -. That's +what typically happens. You know - +: Sure. +- you don't want an inmate +in segregation. Most of them, we've had a lot +of high-profile individuals that come in the +institution. You know, we do our intelligence +gathering, to see, okay, what would be an +appropriate unit for them to be in? And we +place them. And then, we monitor them. If, +you know, and that is how we move them into +general population. I get a call saying, hold +up on that. He needs to stay where he's at. +: And who called you? +: Did he qualify as a pedophile? + + +1 +2 +3 +4 +5 +6 +7 +8 +didn't -- +91 +I don't -. I didn't -. +: Read. But that's -. +We +: Yeah. +: — you know, so that's not +feasible, why we were able to keep him in. So, +get a call, and they said hold up on that. He +needs to stay where he's at. +: And I'm sorry. Who was +it that called you to say stay? +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +And then, +that's when I had to send up the names. I +guess he had gotten some from the department. +I don't know who he talked to in the +department. +oh, so, coming out of +psych observation, you were looking to send him +back to general pop. +: Or not back to. Into. +When he first came in, the +whole process was -- + + +1 +2 +3 +population. +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +92 +Oh, I see. +- to get him out to general +I gotcha. So, back, you +are talking about July 6th through the 8th -- +Yeah, we're talking about -- +- that timeframe. +- the whole thing, and +then, even, you know, coming out of psych +observations when he got in, the plan was still +to get him into general population. +I mean, we had the attorneys +contacting our legal, why can't he be in +general population? +Sure. +So, and then, that is when I +got the call from my boss, saying - and I don't +know who he talked to in the department - but +it was, like, hold on. +: And on that note, I guess +this would be a good time to talk about this. +Being that it was ultimately decided that he go +into Nine South, or the Special Housing Unit, +was it discussed at all that he be placed on + + +1 +2 +inmates? +93 +Ten South, for the high, you know, the SAMs +3 +4 +5 +6 +7 +8 +: So, here's the problems with +Ten South. It's the terrorist unit, and +there's SAMS things in there. The amount of +attorneys he had coming in there, we couldn't +have those attorneys coming up to that unit +every day, and, you know, breaching the +security of it, and then, tying up the movement +in there, because +when an attorney comes in +there. Now, those guys get attorneys, but it's +planned, and they are in there. Epstein' s +attorneys were coming in early in the morning, +and weren't leaving until late at night. And +it was about four or five of them. So -- +: And guess who's paying his +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +bill? +- right. That's not an +appropriate unit, and that's not what that unit +is for. +: Now, what about, like, +if, you know, an El Chapo (Phonetic Sp. +*01:11:55), or some of the other high levels +that weren't terrorists, how did they deal with +that, or did they have attorneys visiting them + + +1 +or no? +2 +3 +4 +5 +6 +7 +8 +94 +: They did, but it wasn't to +that extent. Like, he, E1 Chapo would have his +attorneys come in, but they came in for a +couple hours, they left. As it got close to +trial, then they would - you would see them +more frequently. But Mr. Epstein, day one at +attorneys, they were in there from the +beginning to end. We even had complaints from +the local attorneys, that they were taking up +the rooms. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Mm-hmm. So -- +.. +: - the primary reason why +he was placed in Nine South was because of the +attorney visits? +: Well, not the attorney +visits, but that is the SAMS unit. +: And he's not a SAMs inmate. +And then -. +: What's a SAMs unit? +: Special Administrative +Measures. +That means, you know, strict +communication. And there's a lot that goes on + + +1 +with that unit. So, he wasn't appropriate to +2 +be up there. +95 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: Now, were some of those +other high-profile inmates, though, such as El +Chapo, and who were some of the people that +were in there? +Yeah. The terrorists up +there. +But the non-terrorists. +Meaning, the people that -. There was a few - +: Well, you had Sholty +(Phonetic Sp. *01:13:05), but he was in for +espionage, and had a SAMs on him. So, he -- +Now, did E1 Chapo have a +SAMs on him? +-- he had -. No. His +status was based on, and I know there was +(Indiscernible *01:13:18), his escape status -- +Sure. +- and stuff. So, he was a +high profile person that had escaped from +another prison before -- +-- so, that was an +appropriate place to place him. + + +1 +2 +3 +4 +5 +6 +7 +8 +96 +: I see. +Sholty was in general +population, and a SAMs was placed on him by his +attorney -- +: What was the other name again? +: - Sholty. And he was +placed up there. +: Can I ask you -- +: Yeah. +: - a totally irrelevant +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +question? +: What was El Chapo like? +: Just like any other inmate. +: Is that right? +Yeah. Just like any other +inmate. +: Polite? +_: Polite. You know, no +problems. But that wasn't the appropriate unit +to be housing inmate Epstein. +: Now, did you even have +the authority to place him in Ten South, if you +wanted to? +I mean, I could have, but I + + +1 +2 +3 +4 +5 +6 +7 +8 +would have had to have, you know, some +justification as to why I'm putting him up +there. And there would have been push back +from his attorneys. +97 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Okay. Because some +people had mentioned that, saying the warden +doesn't even have the ability to do that. That +comes from a higher level. +_: I mean -- +Is that -- +-- in essence -- +-- accurate, or -? +-- in essence, it does +because I would have had to explain and justify +why, you know, certain inmates with certain +crimes are placed up there. Why am I placing +him? +And then, the fact that, you +know, he is a pre-trial individual, and needs +access to his attorneys, that unit is just too +restrictive for that. +Now - and this is a total +Monday morning quarterback -- + + +1 +2 +3 +4 +5 +6 +7 +8 +placed. +98 +- do you stand by the +decision that he would be in Nine South, or do +you think he should have been in Ten South, or +what are your thoughts on that? +: I think he was appropriately +So, Nine South - +- was the -- +That was the appropriate - +- appropriate place for +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +him? +- place for him. +: Quick question. +: Mm-hmm. +: Do you recall if there were +inmates in Ten South during that time? +Where? +: In -- +: Yes, there were. +1: -- yeah. Do you know who +those inmates were? +: El Chapo had left. I got +the one that ran the call with people in + + +1 +2 +3 +4 +5 +in there for? +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +99 +Brooklyn. He was there. +: What was his name? +: I forget. +: What did he do? What was he +_: That's the one that killed +the pedestrians in lower Manhattan and ran -- +: oh, yeah. +- the vehicle into them. +: Yeah, and then the guy kicked +the gun out of his hand. Right? Some guy -- +: — (Indiscernible *01:15:28). +: He was there. I remember +Sholty. There was another guy that was, it had +something to do with Osama Bin Laden. +: Mm-hmm. +_: Who else? We had a younger +terrorist that was in there. So, we had, it +was -. They were all terrorists in, on +espionage charges. +: All right. So, this is +along what we were just discussing. It says +that, this is from an +who's just +a supervisory staff attorney. + + +1 +2 +3 +for? +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +100 +What does this CLC stand +It's the Combined -. He's +the supervisory attorney for Brooklyn and New +York. +At the time. +So, he's kind of, like, +the general counsel for Brooklyn and New York? +: Yeah. He was the +supervisory attorney. So -- +-- he was in charge. +: All right. So, this was +to you, and it was on Saturday, August 10th, +2019. It says, "Warden, per our conversation, +I spoke to two of his attorneys yesterday, +August 9th, 2019, primarily in relation to his +request for access to water in attorney +conference." +"Attorney Mariel Colon," +so, M-A-R-I-E-L. +Next word, C-O-L-O-N. "With +whom I spoke in person in the late morning, had + + +101 +1 +2 +3 +4 +5 +6 +7 +8 +asked, as an aside, whether we would consider +housing him in the cadre." What is the cadre? +Cadre is the camp. +: Is that low level? +It's like our lower security +inmates. Yeah. +So, you have an actual +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +camp at the MCC? +: It's low security inmates. +But remember, they are designated. So, we +couldn't put him in that unit because he's pretrial. We can't mix designated and pre-trial +inmates together. +Okay. It says, "I +advised we could not," since he was a preinmate. +: "Later that day, but +prior to 1:00, close out meeting, I spoke to +attorney +on the phone. He had +asked whether we could house Mr. Epstein alone +in the SHU, to which I replied that we could +not, based on his prior suicide +attempt/gesture." +: It's just, I've never heard of + + +102 +1 +2 +3 +4 +5 +6 +his lawyers. You would think that his lawyers +would be somebody that I was familiar with. +: Yeah. +Since they're probably +charging him $2, 000 an hour. +"He acknowledged that he +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +understood. To my recollection, neither +attorney referenced consideration for suicide +watch or psychological observation during +yesterday's conversation. +Please let me know +if you need any further information." Now, was +this just a request to any contact that he had +with his attorneys? +: He was just keeping me +informed because the attorneys were calling +every day, with different types of requests. +: But this was the day, +obviously, of when he was found. So, this +would -- +-- he's talking about +context, just literally the previous day -- +- that he was looking +for different housing type arrangements. + + +1 +2 +3 +4 +5 +6 +7 +8 +103 +But all right. If -. +: That was $1,000 a phone call. +Excuse me? +: That was $1,000 a phone call. +(Indiscernible *01:18:25) charging. +Oh. Now, this answers +our question from before. +So, this actually +says, it's from you to +, it says +attorney logs. This is that same thing that we +were looking at. +_ : +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +So, it looks like July +30th is highlighted, and Mr. Epstein. And +again, all these - +These are the attorney +assignment. +-- (Indiscernible +*01:18:43). +So, that does now +clarify what it is, because, previously, there +was nothing that was in the subject liner. +Or the body. Okay. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +was off. +10th, 2019? +21 +22 +23 +24 +25 +Saturday. +104 +: Yeah. I'm looking at the +stack, and I'm sitting here, just Jesus Christ. +We're coming to - hey - +we're almost halfway through. +: Well, that's the way you're +looking at it. (Indiscernible *01:19:04). A +little bit different, fellas. I'm thinking +about, I'm going to miss today's workout and +tomorrows. +Well. +Now, you've already +answered this, but did you work at the MCC on +August 9th? +For that -- +: 2019. +- was Friday. Friday, I +What about on August +10th was a Saturday -- +: Correct. +- I was, I worked on +All right. But did you + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +I came in. +work. +105 +work in response to this? +: No. I had to respond, if +the day of the suicide was August 10th -- +: Mm-hmm. +- yeah, I had to respond if +So, but you +weren't scheduled to work? +: No. I wasn't scheduled to +All right. This is just +for - and this is going to be put in here, in +case you need to reference it - these are +emails that were from you to +• with +the staff roster. +And the reason I'm using +these is because these were literally sent on +Sunday, August 11th. So, I know that we can +rely on these -- +]: +: - based upon being so +close. So, this one is for Friday, August 9th. +It's showing who was working that day. And +this one is from Saturday, August 10th. Again, + + +1 +2 +3 +4 +5 +6 +7 +8 +showing who was -- +1: This is a correctional +roster. +-- correct. +•: okay. +: Correct. This is a +correctional roster. Right. +So, who was, basically I +think, involved with Epstein during that date? +So, yes. How many rosters would there be, +aside from correctional? +: Well, the correctional +officers are the only ones that keep a daily +roster. +106 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Like, R&D wouldn't do +anything like that? +: No. Because their staff are +already assigned to where they are working at. +Yeah. And they have rosters +that show where everyone is working at. But +not, like, the correctional officer roster. +okay. So, I'm going to +have you just initial and date. I'm going to + + +107 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +place this, again, here, just in case we need +to reference it, and again, it's just if we +need to look at who was working, and what +position -- +There's two on there. +: - and what. Yes, +please. So, this one would be for the August +9th, that one is for August 10th. This +actually was not - the August 10th one - was +not attached to your email. Right? +: Yeah. You are right. +So, the August 9th one +was attached, but the August 10th wasn't. +1: Yeah. +So, we had to pull +that from -- +- just for full +disclosure, but just so that we have both. The +August 9th one was something that you had sent. +All right. Since Epstein was required to have +a cellmate, who was ultimately responsible to +make sure that all the SHU staff were aware of +this requirement? +: That they were notified? + + +1 +2 +3 +4 +5 +6 +7 +8 +108 +So, how -. +So, Dr. Imeri +or Mrs. Imeri sent out that email, saying - +- Epstein is required to +have a cellmate. The one that we reviewed. +Who was required to make +sure that staff that is working in the SHU is +aware of that requirement? +Well, the captain passes it +on to the lieutenants, and the officers are +then made aware that he, you know, any inmate, +if they are required a cellmate - +- that, you know, that he - +they are to require cellmate, if somebody +leaves or goes out. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: Now, someone such as an +Epstein, who was just coming off of suicide +watch, you know, a week, a week and a half +prior, should all staff know that that person +is supposed to be housed with a cellmate? +: In the Special Housing Unit, +anybody working in there would know that he was +supposed to have a cellmate. + + +1 +2 +3 +4 +5 +6 +7 +8 +109 +: Do you believe that there +was any anybody - especially anybody that's got +a quarterly bit of post there - +- but anybody that's +working in the SHU on August 9th or 10th, do +you believe that there could be a reason why +they would say, we didn't know he was supposed +to have a cellmate? Do you think that would be +an acceptable excuse? +: Because you had the staff +that usually work up there, were up there. It +should be, it should have been annotated on his +- what do you call it? - it's called a 292. +: The hot list, you are +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +referring to, or - +: No. Not the hot list. +: — or what? Oh, you +mean, +oh, the 292. You're talking about the +SHU -- +-- file. +The SHU file. It should be +annotated on the SHU file because, when you +come in, you have to annotate on there his + + +110 +1 +meals, did he eat, the medical rounds. So, it +2 +would have been on there, it would have been on +3 +there, too. So. +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: Would it have also been +on the hot list, though? +: Guys. I need an interpreter. +: Yeah. +What does the hot list mean? +It's just -- +That's -- +-- sorry. +- yeah. I guess the high +risk suicide inmates. +Yeah. So. +: Whether it's suicide, or high +risk for some other kind of problem? +It could be -. It's mainly +for, like, suicide, just to -- +: Medical. +- to watch out for. Yeah. +Medical. Okay. +: Seizures. You know, stuff +like that? +Yeah. So. +So, point being is, do +you think that, if any staff that is working in + + +111 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +that, you know, as we know, Mr. Reyes left - - +-- in the morning of +August +: 9th, Mr. Epstein was found the -- +- the morning of August +10th. +SHU staff that is working +in there at that time, he's 24 hours basically +gone, you know, with no, without a cellmate. +Do you think that this is a reasonable excuse +for them to say that we didn't know he was +required to have a cellmate? +: No, because they did know, +because I - from what I understand - someone +wrote a memorandum, and had it that day, that +they knew. +Okay. Well, yeah, we can +get into that. Now then, so these are -. +: One other question. I want to +open a box. +Absolutely. +: That means I'm going to have +to bring a sharp object in here. Is that going + + +112 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +to bother anybody? +No. No. +No. No. +No, no, no, no. +I'm sorry, I thought you +were talking about, like, this hypothetical +situation of if we were in the MCC or +something. +• oh, no. +No. This is just a - +- +You're just wanting to +know if you can use scissors. Yeah. That's +fine. +: Yeah. +I guess we should wait +until he gets -- +_: Mm-hmm. +- back again. If we +speak loudly, will you be able to hear our +questions? +: All right. We're going +to continue, then. The answer was yes. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +somebody. +office. +knife. +113 +I don't know if that was +1: There might be clients in the +oh. +Huh? +: That's why. +Then we will wait. +: He wasn't kidding about the +Oh. +: You know why I got this? This +movie called Gangs of New York. +: That's a great movie. +And he - and a good movie - +and the lead actress was a woman named Cameron +Diaz. +Sure. +: And I had a wild eyed crush on +Cameron Diaz, and this is the shiv, the knife - +seriously - I found the guy who made the knife +that she carried in the show, and I said, I +want you to make me an exact duplicate. How +sick is that? +Of that knife. And so, this is + + +1 +2 +3 +4 +5 +6 +7 +8 +114 +That's super cool. +: So. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Sorry. I'll ask a few +more questions before we get into these +documents. Were any plans made on how to +address this situation for if Reyes was removed +as Epstein's cellmate? Like, if he -. Because +I know at MCC, inmates certainly leave. +(Indiscernible *01:26:13). +: No. I mean, the plan would +have been, you know, we would have assessed it, +because usually, you get ahead of time, we +would have just said, okay, when is -? When +Reyes leaves, or you know, when he was leaving, +then before he was placed back in that cell, an +assessment would have been made. +Okay. Now, what is your +understanding of what happened with inmate +Reyes on August 9th, 2019? +: When I got back after the +fact, I guess the Marshals came and removed him +from the institution. +So, there is a lot + + +115 +1 +of people we've talked to thought he went to +2 +court, and that at court, it was determined he +3 +wasn't coming back. Had you heard that? +4 +That's what I heard, too. +5 +had heard he was going to court. And then, I +6 +guess word got back that he wasn't coming back. +7 +That's what I heard. So, I never got +8 +(Indiscernible *01:27:00). +: It's either a good day in +court, or a bad day in court. +: Yeah. I never got the +actual story because I was, I was removed. So. +Okay. And again, what +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +does WAB mean? +: It means With All +Belongings. +But I don't know, and I +don't know if people will say that he left, and +then they went and got him from the office. +So, I am not sure. +okay. So, this is - +-- one of those documents +that says -- + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +you. +the subject. +Cellmate." +116 +-- from Charisma +to +With inmate Epstein as +And it says, "So far, +this is the documentation I have in my +possession." +: WOW. +: And if you see, you know, +here, it talks about all the documentation +pertaining to him. These look like all the BOP +database -- +: - things. Then down +here, it says, "Documentation re: Reyes, Efrain +: -- + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +through R&D. +117 +It says, "Court +documentation regarding WAB 8/09 - +'19. +: -- '19. +And then, also SHU file. +So, "Showing court documentation regarding WAB +8/09/19." What documentation is she referring +to there? +I guess whatever came +Our Receiving and Discharge. +They might have gotten -. They must have +gotten information to release him, and that he +was being transferred. +So, would it be at all- I +know R&D creates something called, like, a +court production list, or -- +- would that be what +she's talking about, the court production list, +or would she be, do you think -- +So -- +- or, like, a PP-38, or + + +1 +2 +3 +4 +5 +6 +7 +8 +118 +something, or whatever -? +: I think, and I'm speculating +now, it was probably the court list, and it +probably said, we're sending him off to court. +And it was a possibility that he might be +getting released. +Because the document that +has been alluding me -- +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +-- is that court +production list. Do you know if that was ever +obtained? Do you know, the thing that, that +R&D creates this list, they provide it to the - +- +oh, the court - +- different housing +units. +know what they do with it. +- list. I don't. I don't +They just, they all say +they - +Now -- +- destroy it after that +time. +Yeah, they do, but -- + + +1 +2 +3 +4 +5 +6 +7 +8 +119 +But -- +- with him -- +: - but that's what would +have been used by the SHU staff, in order to +produce Reyes to the R&D. +: No. Not necessarily. What +typically happens is, the R&D staff will call +up to SHU, and say, hey, I need Reyes down. He +has court. Or he's being released. So, there +wouldn't have been a document sent up. +So, everyone that we +talked to said R&D said, yes, we created this +document. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: And the SHU staff, +including the OIC, said, yes, we had +documentation showing that he was WAB. So +then, and they all said it was because it was +this court production list that you sent out +emails to -. +Unless it's sent in the +early morning. +: And it's not something +that's sent electronically. It's something +they said that they generate, print out - + + +1 +2 +3 +4 +5 +6 +7 +8 +120 +-- and hand to +different, the ops lieutenant has one, every +housing unit has one. +Internal goes around and +collects people, based upon it or something. I +think. And then - +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +So -- +- then they basically +destroy it at the end of the day, and nothing +is maintained in the system. They just use a +template, and create a new one for every day. +: So, that must have been the +early court movement. So, I was under the +impression that he was, he left in the +afternoon. So, when typically in the +afternoon, they will just call up and say, hey, +we got one that's leaving. So, I assumed he +had left that afternoon. +So, is it, then, +are you not - then to answer that question - +are you not sure exactly what she's referring +to when she says "court documentation regarding +WAB"? +: Like, the way you explained +it, then that means they were talking about + + +1 +2 +3 +4 +5 +6 +7 +8 +morning courts. +were -- +121 +Well, that's what they +- I'm just talking about +-- specifically, what +she's talking about in this email to you. Do +you -? +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: But when you say WAB, with +All Belongings, it depends on the time of day +they left. +You know? You could have +afternoon court, and you don't have that list +generated, and they say - +: But if -- +- we need all his +belongings. +this in +front of you - +_: +- this might help -- +- and then, we will keep + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +122 +- this might help +explain this. So, this is an email that was +sent from the U.S. Marshal Service, someone +named +(Phonetic Sp. *01:30:50). +On Thursday, August 8th, +2019, at 10:33 a.m. It says, "Transfer of +prisoners from NYM - +TO GEO. +-- to GEO. +The following prisoners +are to be transferred." The second person +listed out of the two is, "Reyes, Efrain." +|. " +"Please schedule the +transfer for Friday, 8/09/2019. Please include +seven days medication with the medical summary. +Thank you." +sent to R&D. Correct? +_: +So, this obviously was + + +1 +2 +3 +4 +5 +6 +7 +8 +: Do we know what kind of +medication he was taking? +Well, that's Efrain +Reyes. +We're not talking about -. +That's Reyes. +we're not -. +: I know. I just am curious. +It's not -- +: We don't know? +: -- relevant. +123 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +• +21 +22 +23 +24 +25 +I don't think it's +relevant. Here is another email that the U.S. +Marshal Service sent. This time, it was at +Georgios. G-E-O-R -- +It says, "Prisoner production." It +looks like it was sent to custody. +On Thursday, August 8th, +2019, at 3:36 p.m. And then, this, this +document, prisoner schedule report is attached. + + +1 +2 +3 +4 +5 +6 +7 +8 +And -- +one. +124 +: You're looking at the second +- so, for the MCC -- +- it shows right here, +the second person listed as Efrain Reyes. +And it just says, "TF, +transfer within. MCC New York." And right +here, it says, Judge MCC Tot, I-O-I. GEO. +What I was told, that +means that he's transferring from the MCC to +GEO. Is that -- +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +- your understanding? +Yes. +: And then, on this one, +this is the PP-38. On the third - for +8/09/2019 - on the third page, it shows Reyes, +from Z06-22. +And that means the SHU. Correct? +Yes. SHU. +To pre-remove. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +clear. +what place? +facility? +the Marshals? +125 +At 8:38 a.m. +So, this was 8:38 a.m. +He's keyed out of our system. We got these two +emails from the U.S. Marshal Service, saying +he's being transferred. +: So, wait. Let me get this +He's being transferred to what place to +From the MCC to GEO. +: And what is GEO? +_: A contract facility. +: And what is a contract +: A private prison. +: Okay. And you had nothing to +do with -? In other words, somebody else +decides to go from one place to another —- +Yes. +: - you (Indiscernible +*01:33:11). Okay. +The Marshals -. +: And would that be the judge or +The Marshals, I guess. +The + + +126 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +judge. I don't know how the Marshals work, but +they - +Prosecutors. Marshals. +Judge. +: okay. +: All in coordination, make +those determinations. But, and then, here is +an email from you to +With what you are talking +about, that memo. +It says, "On Friday, +August 9th, 2019, " but before we even get into +that, now that you have seen this, you have +seen these two emails. +: From the Marshal Service +on August 8th. On August 9th, at 8:38, R&D +actually keys him out. +•: Right. +All of them say preremoved or transferred. +_ : + + +1 +2 +3 +4 +5 +6 +7 +8 +out. +127 +Does that now tell you +anything about this, court documentation +regarding WAB? +: Yeah. Now, it explains that +they had gotten a court order to have him go +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +So, what do you think is +referred to that court documentation? +_: I guess it must be all of +these documents right here. +This? +Yes. +So, what we're actually +looking at, you think she's referring to? +That's, I think, that's what +she was referring to. +All right. +So, court documentation +meaning, documentation from the Marshal +Service, saying that he was going to be +transferred? +: All right. Now, based +upon what you are looking at here, specifically + + +1 +2 +3 +4 +5 +6 +7 +8 +128 +from the Marshal Service -- +-- and the fact that +Efrain Reyes, whom -. Is it -? I've been told +that everyone at the MCC knew who Reyes was +because they knew he was Epstein's cellmate. +But at the very least, +everyone in the SHU should have known who +Efrain Reyes was. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: Because he was Epstein's +cellmate. What should have happened once, on +August 8th, as early as 10:33 a.m., and as late +as 3:33 p.m., the day before Reyes is +transferred, what should have happened? +As far as Epstein getting a +cellmate? +correct. +The notification is being +made that this person is being transferred, +everyone gathers him up. And so, what this, +I'm going to read this just to give you more +information -- + + +1 +2 +3 +4 +5 +6 +7 +8 +129 +- on his backtrack. +This is a memorandum, dated August the 12th, +2019, to the warden - yourself. +: From +who, my +understanding is he was the OIC of the SHU at +the time. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +It says, "Subject passed +information from Special Housing Unit." So, +"On a Friday, August 9th, 2019, at +approximately 1:50 p.m., I, SOS +passed onto oncoming staff member, Officer +Officer +1, and present shift staff, Sos +, that inmate Reyes was going +and +WAB, and possibly may not return. +Also, that inmate Epstein +will be needing a cellmate upon arrival from +his attorney visit." Now, what this doesn't +state is that Officer +,, or SOS +walked, I mean, both Epstein - +: I'll go get that. +-- as well as Reyes, down + + +1 +to R&D -- +2 +3 +4 +5 +6 +7 +8 +130 +- with all belongings. +Spoke with both Epstein +and Mr. Reyes, and stated to Mr. - I think +Reyes stated to I +- make sure you get +him a cellmate. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +I'm not coming back. And +responding to Mr. Epstein, saying, +"Don't worry. We're going to get you a new +cellmate." +: Now, with all that +information, being that he is the OIC, he's +working in the SHU, he knows that he's WAB. +We've got all this stuff +going on. +This is the real big +reason why I want to talk to you - +-- as the warden. + + +1 +2 +3 +4 +5 +6 +7 +8 +131 +This is kind of our +primary purpose - +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +- for us being here. +So, I apologize if you're going into that, but +I want you to have all the information -- +- before I answer. What +should have happened here? So, R&D is +contacted the day before, or two days before +Epstein, or Epstein is found. One day before +Reyes is, you know, gone. They contacted both +custody, as well as R&D. +R&D pre-removes him at +8:38 on 8/09. +The SHU OIC walks him +down, to R&D -- +: - and actually has this +conversation with Epstein and Reyes, saying, I +know you are WAB, we're going to get you a new +staff, we're going to get you a new cellmate. + + +132 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Which means - WAB means what? +With All Belongings, +neans they're not coming back. +: But Epstein is not coming +back? +NO. +His cellmate. +Reyes. +: Reyes. +: His cellmate. +: So, the theory is, if you are +investigating, somebody says that you're not +going to have a cellmate anymore, and in that +conversation, or present during that +conversation, is Epstein? +: Epstein is present. Yes. +: Okay. So, Epstein knows that +he's not going to have a cellmate for the +immediate future? +No. Epstein is going to +attorney conference. So, he's going to be -- +: No, no, but I'm saying -- +- in attorney conference +until about 7:00 p.m.. +: - that Epstein knows that, + + +133 +1 +over the next, say, 24 hours, he's not going to +2 +have a cellee. +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +the OIC, +tells Epstein, as well as Reyes, that they are +going to get him a cellmate. Before he comes +back from attorney/client, his attorney visit. +: okay. So, Epstein would know +that he hasn't - going to have a cellmate. +: Yeah, yeah. So, this +isn't part of the theory. What my question to +your client is, what should have happened based +upon the knowledge that he was WAB? +The +contact with the Marshal Service, telling him +that he's being transferred. The fact that +R&D, you know, the OIC walked him down to R&D, +and R&D actually logged him out of our system. +What should have happened? +: So, what should have +happened was, this information should have been +passed up to the supervisors. +: At what point? +: See, with the, this +information coming in, as far as, you know, +when R&D -- + + +1 +2 +3 +4 +5 +6 +7 +8 +lieutenant? +134 +- typically, it would come +up to the Special Housing Unit. Once it got up +to that, to the Special Housing Unit, the +lieutenants should have been notified. +Okay. And which +Whoever was the SHU +lieutenant, whoever was the operations +lieutenant. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Now, on this case -- +It the -. +-- the SHU lieutenant is +also on leave. +: So, we've got the chief +psychologist on leave, the warden on leave, the +SHU lieutenant on leave. But we do have an ops +lieutenant, we do have an activities +lieutenant. And we do have a captain. +: So, you should have let the +operations lieutenant know, if you didn't have +a SHU lieutenant. They, in turn, would let the +captain know, and the captain would push it up +to the execs then. Then, we would have to come +to a determination on who we were going to + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +house with Epstein. +returning back. +1: Yes. +135 +Now, if the operations +lieutenant, his name is +: -- +If he says, yes, I know +Epstein was gone, but I believe that he was at +court -- +No. You mean -- +- and he might be +- Reyes is gone. +So, +knows +that -. Sorry, did I say Epstein? +: Yeah. You said Epstein. +Yes. +knows +that Reyes is gone. +But I think he's at +court, and then, he might not be coming back. +I didn't pass this information onto my relief, + + +1 +who was +2 +3 +4 +5 +6 +7 +8 +136 +| (Phonetic Sp. *01:39:59). +However, as our +investigation has revealed, the ops lieutenant +also has one of these court production lists, +that lists Reyes -- +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +-- as WAB. +With that knowledge, is +that a reason that he thinks that he went to +court, and might be coming back? +: I can't interpret what his +thought process was, but if it said, you know, +he was leaving, and I don't know what he was +reading at the time. +: He could have been reading, +because sometimes the inmates do go out to +court and come back. So, I don't know. I +can't speak to what he read. Or why he made +that determination. +: So, listen, wouldn't have most +inmates, when they go to court, come back? +The point being here -- + + +137 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +What I'm saying -- +-- he didn't go to court. +: He was transferred. +He was transferred. +: And I know you might have +covered this, in your understanding, in your +experience at the MCC, if an inmate is listed +as WAB -- +-- With All Belongings -- +: Yeah. +1: - what is your +understanding? Are they coming back or are +they gone? +That means he's +transferring. +where they come back? +1: Has there been situations +•: There have been - +: - situations that, you +know, they go out and they have to have them +sending them back, if there was an issue. +: Is that a unique situation, + + +138 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +or it happens quite often? +: No. I wouldn't say. I +would say that it's probably unique. But +usually, WAB, they're gone. +1: So, as the operations +lieutenant, if you see somebody listed as WAB, +should he have understood that that person is +gone, and not coming back? +: Should have. But then, +you're talking off the document. I don't know +what document they read. So, I don't want to +speculate what, you know, was it, you know, +send them to R&D, whether he saw that. I don't +know what document. But I'm saying, if it is +this document, that clearly stated WAB. +Okay. But as far as your +concern, it doesn't sound like what you were +saying is, +who was the OIC at the +time, should have he notified the ops +lieutenant? +Yes. Whoever is - yeah - in +there should have notified the operations +lieutenant, hey, Reyes left, and -- +: He needs a cellmate. +- he needs a cellmate, + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +shift -- +139 +So, would it fall +solely on the shoulders of +: No. I mean, okay, so, +here's the other checks and balance. So, what +about the other people on the other shift? +That's my question. +So, or -- +I mean -- +- or the people that are +working on his same shift. +- yeah. On his own same, +so, who -- +-- if it was the +notification should have been made to the +operations lieutenant. Or the captain. And +said, hey, cellmate left. He needs a cellmate. +: And that cellmate would now, +at some point, he goes back to the cell, but +that's at the end of the day. +: At the end of the day. +: Okay. So, nobody is in a +position to say, hey, he's in a cell by + + +1 +2 +3 +4 +5 +6 +7 +8 +140 +himself. Until the end of the day. +: Right. But the information +is passed onto each other. You know, when you +And they are supposed to +be doing 30-minute rounds, where they would +notice that one cell had zero inmates in it. +: Had zero inmates in it. +: Yeah. +So, I mean -- +: And that's what brings us all +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +to -- +: - here today. +So +Uh-huh. +-- I mean, that's how it +would have made, and when that got pushed up, +we would have said, okay, we would have to +formulate, okay, who can we get a cellmate for, +for Epstein? +And I apologize to ask +this because, but, like, so, on each shift +would be the OIC, that would be responsible for +that. So, for instance, would +be on + + +1 +2 +3 +4 +5 +6 +7 +8 +the day watch shift up until 2:00 p.m., he +would be the one to responsible to provide the +ops lieutenant, but then, the following shift, +would it be -- +141 +Whoever is the -- +: -- the next OIC -- +-- right. +-- or would also the +people that are working in that unit, the other +SHU staff, would they be responsible? Or is +that a chain of command thing? Like, no, the +OIC is really the person making that +notification. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: Everybody has a +responsibility for their safety. Everybody. I +mean -- +Sure. +- I might be the OIC, but I +have some responsibilities. If I know, okay, +you know what? They might need a cellmate, +because I, in essence, I can have an individual +assigned to that post, and they're just filling +in for somebody that, the regular person that's +up there. And then, I have the regular people +working up there, who are familiar with what's + + +1 +2 +3 +4 +5 +6 +7 +8 +going on. +So, it's kind of everyone's +responsibility. You know? +: So, is everyone kind of +equally responsible, then, for this? That was +working there and didn't pass the information +on . +: Can you say? Don't guess. +You know what? +No, as the warden, he +142 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +would be able to say. +: I mean, it should have been, +it should have been passed on. So, I don't +know the dynamics to, as far as what was going +on that day, who was working up there. What +rounds were being made -- +: Mm-hmm. +- up there. You know, was +the lieutenant coming around? Was the captain? +How busy they were. +So, the lieutenant was +not on - the lieutenant of the SHU - was not +on. However, we do have records that the +activities lieutenant at least visited —- +-- the SHU -- + + +1 +2 +3 +4 +5 +6 +7 +8 +143 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +You have -- +- at that point. +-- you have two other +lieutenants. Now, I don't know if you are +familiar with the Special Housing Unit, but it +is a very busy unit. +: Yeah. +You know, you're giving out +showers. You're giving out recreation. You're +doing a whole lot of stuff. You, you know, +running around all day, and, you know, +sometimes things happen. +Understood. But in this +case, wasn't Epstein at your most high-profile +inmate? At that time. +: I mean, besides my terrorist +inmates that I had up there on Ten South. +Well, I guess, at least +the Nine South. +I would say he was a highprofile. +Yeah. He was a high-profile inmate. +: Is it, I mean, on that +note, don't you think that they would have, you +know, found it pretty important to notify? +Especially they - and I don't know that we + + +144 +1 +2 +4 +5 +6 +7 +8 +brought this today - but there was even signs +up that they created, saying, "Mandatory 30- +minute rounds on Epstein, signed by God." Or +something, you know, +along the lines. Not, you +know, meaning, like, do this. You know? Like +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +No, that was me. +: Is that right? +That was me. No. I mean, I +mean, but it was emphasized to them. I mean, +so, no one could say that they didn't know. +So, point being, there +was, like, signs specific to even Epstein, +check on this guy every 30 minutes. +You know, orange signs +that are posted up there. +So, point being, with +this -- +It should have been passed +up. +-- and that is where -. +So, for us, I guess + + +1 +2 +3 +4 +5 +6 +7 +8 +145 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +- again, and I know that +you are probably trying to, you know, hesitate +on maybe saying, like, this person did +something wrong, but really, who dropped the +ball here? Knowing, though, that you could +take a look, the day before, all these people +are the ones who received the email -- +know we see Lieutenant +assuming +- in custody. And so, I +•. I'm sure - I'm +I would be on there. +1: I think +is on there. +Who? +Is +on there? +: It's just -- +: I didn't see +-- maybe. +: But again, this one, that +one is not even as clear. This one +specifically spells out - +1: Yeah. +- this one, you would +actually have to go in and look at this +prisoner's schedule report. +: Okay. Let me just take a + + +146 +1 +2 +3 +4 +5 +6 +7 +8 +look, just so I have, my mind is clear. +There +is a prisoner's schedule. The prisoner's +schedule literally means prisoner's schedule. +: Well, yeah. So, the +prisoner's schedule report is something like +this, but it will tell you that they are either +going to, like, transfer, or they are going to +go to court. Whereas this other document that +was sent to R&D was just specifically about the +transfer. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: Okay. But there is nothing +that says recreation, personnel care. It's +mostly going to and from court, or leaving the +institution. +: Yeah. +Because it's a +prisoner's schedule. +:okay. +: Report. +So, it's, like, what they +are scheduled to do. Sorry. Yeah. No. It's +not, like, what their daily schedule is. Like, +in the institution. +• Right. +It's a U.S. Marshal + + +147 +1 +2 +3 +4 +5 +6 +7 +8 +Service report that they just provided to the +BOP, so that they know which inmates -- +- they need to produce, +and for what reason. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: Okay. Got it. +Now, is that correct? +Yes. +So, yeah. Based upon +what you are looking at here, on the 8th, and +then again, what we know about +at the +very least producing, at 8:00, knowing he was +WAB, and R&D knowing he was WAB. +What should have happened +there? Like, who, in your opinion here, +dropped the ball? +: I think at all levels, it +was the checks and balance. If it went to the +lieutenant's office, somebody should have +picked it up. Working in the unit. It should +have been passed up to the lieutenant's office. +So, there were a couple of safety nets that +could have caught it. +So, pretty much everybody + + +1 +dropped the ball? +148 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: I mean, if we're looking at +it like this, if you're saying going by an +email being sent around. +Well, not only the email, +but I mean, the email, I can understand if +people are busy and they don't always, you +know, this one - +-- it would be hard to - +that one would be hard to -- +- you know, say that you +didn't know. This one, I could see maybe, you +know, the prisoner's schedule - +Well, this one, I don't -- +- (Indiscernible +*01:48:52). +- I mean, I don't know what +gets sent out. I know, if this whole thing, I +don't know if it gets sent out to the staff. I +think more -- +Well, this is - +-- of a condensed version. +- this is with this. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +149 +So, this was what was +sent with this. This was sent specifically, +just that. It's not a document. That's the +body. +Right. That was sent. +: But that is, again, R&D. +But, which again, R&D - +we didn't cover this - R&D is outside of +custody. Correct? +But speaking with R&D, +they said they would have produced this list, +which SHU would have had, as well as ops +lieutenant -- +- the lieutenant's +office, all the housing units, which it listed +Reyes as WAB. +: Do you know if they are +actually looking - like, the lieutenant's +office, people in the lieutenant's office, or +the ops lieutenant, activities lieutenant - are + + +150 +1 +they actually look at that list and saying, or +2 +that's just based upon the busyness of their +3 +day? +4 +5 +Yeah. I wouldn't speculate. +I mean, I don't know. I can't say what —- +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +- lieutenant is looking at +stuff. +I mean, it's, like, the documents. +No. I mean, but should +have they, I guess +is the question? +: As far as what? Emails that +are coming through, on who's leaving? +: No, no, no. This would +be a physical paper that they were provided. +: Internal would go around +and provide everybody with this physical paper +that they create, and then, they apparently +destroy it at the end of the day. +: Right. So, I don't know if +the, you know, when internal gets the forms to +go, they are dropping it off at different +units. So, I don't know if one was passed off +to the lieutenant. The lieutenant would - I +guess this probably be the only document -- + + +1 +2 +3 +4 +5 +6 +7 +8 +151 +No, no, no. +- they tear up. +We are being told, by the +lieutenants, as well as - +: - by R&D, they all have +it, and they all, and it would all - and it +would have said WAB. Unfortunately, I haven't +found that document to show you this is what +I'm referring to. But it's a document they +apparently create, which they call the court +production list. Are you -- +The court list. +- yeah. +I've heard of the court +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +list. +But it's like a -- +And it -. +- from my understanding, +it is an informal document that they are just +providing so that, you know, these are the +people that we need to produce today. +: For internal, yeah. The +internal officer goes around and drops them off +at every, you know, every unit, like hey, I + + +152 +1 +2 +3 +4 +5 +6 +7 +8 +need this guy, I need that guy. It's a court +list. +In the morning. +Exactly. +So, yeah, that's not +anything that's kept on record. +Right. So, I guess the +question, though, being that they had these +court lists, is another one of these checks and +balances? Or is that really just for the +Special Housing Unit? +: I think they -. You mean as +far as the court list, I don't understand your +question, but - +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: Yeah. It's just getting +back to the point of, like, Reyes left. We +were notified on the 8th. He left on the +morning of the 9th. +Epstein was found on the +10th. Didn't have a cellmate for 24 hours, and +we knew for almost 48 hours. What should have +happened, and who didn't do their job? Is +really the question. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +153 +And like I said before, when +the notification, whoever was on the unit, knew +that he was leaving, it should have been passed +up to his supervisor. +: All right. +: This guy is leaving. But +then, okay, let's say the supe, or whoever is +working in there, doesn't do it, and somebody +should have stepped up and said, hey, this guy +needs a cellmate. +And notified the lieutenant +that he needs a cellmate. +: And that goes back to my, +anyone that was working in the SHU, should have +made that notification. +_: Should have said it. It +doesn't just -. Just because you are not OIC, +doesn't mean all the responsibilities falls on +you. It's everybody's job up there to say, +hey, okay, we need to, you know, this is what +we need to do. +: And would that be the +case for, +when he left during the day shift - +-- the next shift is the +night shift, when he would have - I believe + + +154 +1 +2 +3 +4 +5 +6 +7 +8 +during the night shift - he would have come +back -- +- and again, if they +were doing rounds, they would have noticed that +Reyes wasn't there in the first place. But +also, certainly, when they brought - +Epstein back. +: - Epstein back to his +cell. There would have been no cellmate in +there. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +_: You should have known he was +a cellmate. +: And would it be the same +thing for the morning shift? That they would +know that Epstein was in there alone? +: Because if the morning shift +is doing their 30-minute checks, you would have +realized he was in there by himself. +: So, should have every +single shift reported it to the ops lieutenant, +that there is no one -? +: Whoever caught it should +have, you know, let's say one shift missed it, +the next shift should have picked up and said, + + +155 +1 +2 +3 +4 +5 +6 +7 +8 +you know, called and said, lieutenant, we got a +- this guy needs a -- +: A cellmate. +-- a cellmate. +And again, I know we're +Monday morning quarterback because of the +result here, but what is your - as the warden +of the institution, on these days - how do you +interpret this? Is this a really significant +failure on their part, the not have caught this +and passed that information up? +: It's not following the +directive. I mean, and then, look at result. +So, I mean, the result is +what, you know, caused it to be a serious +matter. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: Yeah. +to this memo, do you know why Mr. +wrote this memo/ +Now, as far as going back +: I forgot. I might have +called -. +I might have called Lieutenant +, and said - and I don't know if he was + + +1 +2 +3 +4 +5 +6 +7 +8 +156 +working - said, what happened up there? +: Now, when you say +because he was the ops lieutenant, or are you +talking about +• who was the SHU lieutenant? +• who was the +operations -. Because first, I know when I got +back, somebody told me +wasn't at work, +because that was my first question. Who was +the SHU lieutenant? Where they are at. And +then, I think I did reach out to +, and +said, what happened up there? +And that's when I found that +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +out. +with either +And did you ever speak +about this? +Because by the time I had +gotten it, was the day -. That, I got that the +day of, when I had to go up to, I think the +U.S. Attorney's Office. +Okay. To speak with them +about this? +When I speak up to them, and + + +1 +2 +3 +4 +5 +6 +7 +8 +157 +them the agent had the memorandum. +He already had it on him? +He had it on him. Because +he was during the interrogation, he presented +it to the U.S. Attorney that was there. +: And was that the first +time you had seen it? +: No. I think I -. I don't +recall when I first saw it, but I know I had +gotten it. And I don't know if I had gotten +it, and then sent it up to my boss. And then, +given it to the IG. I forgot. I forget his +name, and who was handling the case. +For the IG? +_: Yeah. +1: +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +If you weren't giving it +to (Indiscernible *01:55:18), it would have +been Dave +Because he sat in there with +us. +David +So, he - I remember - he had +a copy of it. + + +1 +2 +3 +4 +5 +6 +7 +8 +158 +Because we had told him that +they knew that they were supposed to -. +So, not including when +you were speaking with the OIG and the FBI, did +you discuss this at all with anyone from the +BOP, such as +or +No. I just got the +memorandum, and that was it. Because I was, +like, wanting to know, like, what happened. +The, you know, the directives were given. What +happened? +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +And when you asked what +happened, was there a verbal response? +: It was a verbal response. +: And what did you -? What +were you told? +: That they knew he was +supposed to -. That +to other individuals about it. +had passed it on +: Now, do you think that +that -. +What is your thought process of +, who is the one who actually presented +- excuse me - Reyes to R&D and WAB, what is +your thought of him now saying, you know, prior +to the end of my shift at 2:00 p.m., I passed + + +159 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +it on to the next guy, saying that you guys got +to do it. +Now -- +: Do you think he should +have done it, passed the infraction on during +his shift? +: Yeah. Absolutely. It +should have been letting the lieutenant know. +Uh-huh. +That, hey, this is - we got +a guy that needs to be -- +: A cellmate. +: -- that needs a cellmate. +: I should clarify that. +_: What? +: I think on the elevator was +Monge. +: Monge was escorting Reyes +down to R&D. And +was escorting +Epstein over to attorney conference. They just +happened to cross paths, I think - +: Yeah, they were together, +though. +Right? +: - yeah, but I think Monge is + + +160 +1 +2 +3 +4 +5 +6 +7 +8 +the one that brought him down to the - Reyes - +down to R&D. +: Then that would make sense. +Because if Monge is internal, internal takes +him to court. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +And then, if somebody is +going to R&D, I mean, to attorney visit, then +it would be SHU staff taking him. +: All right. So, if Monge +is the one who is actually providing him to +R&D, did he have a responsibility, that if he +was WAB, to make any notifications? +: I don't know if internal -. +You know, Monge was internal, and I don't know +if he knew, you know, the situation. +: And typically, would it +be internals job - if they come and collect +somebody as WAB - would it be their job to tell +control, or the ops lieutenant, to say this guy +is off our books, or anything, or -? +: No. Because we have a lot +of inmates that move in and out. +: Sure. +So, he wouldn't be able to + + +161 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +keep track of every particular inmate that is +going and coming. +okay. Basically, +everyone had a share of responsibility? +(Indiscernible *01:57:54). +All right. Before we +belabor this thing anymore, we want to just +initial and date these both documents. +We can +get them out of your way and move on. +: All of them? +oh, yeah. Top of this, +top of this. +This guy. You know, this +one. +All right. +: Let me take this. +Thank you, sir. Now, +prior to this meeting, did you know that Reyes +was actually transferred at MCC, and didn't go +to court? +wait, prior to when? +: This meeting. +Oh, no. I knew he -. I +heard that. You know? After his death, that +he was -- + + +1 +2 +3 +4 +5 +6 +7 +8 +transferred. +162 +Transferred. +- removed. That he was +When I came in on Saturday. +Were you required - or I +mean - were you aware that the Marshal Service +had sent those emails on August 8th, 2019? +_: I was not aware. +: No? Well, did anyone +ever, prior to August 10th, did anyone ever +make you aware that Reyes was transferred from +the institution? +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Prior to October 10th? +: August 10th. 2019. +I found out when I came in +that morning, because I - +- was, like, where is his +cellmate? +okay. So, you didn't +know that he didn't have a cellmate on August +9th? +No, I did not. +Now, who was ultimately + + +163 +1 +2 +3 +4 +5 +6 +7 +8 +responsible to make sure that Epstein has a +cellmate? +: I mean, if it's the +directive that is given out, I mean, whoever is +working decide - passes it up, and then, that +ensures, you know, to make sure he has a +cellmate. So -. +So, SHU staff. +Whoever was working up +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +there. +Okay. When you say +working up there, does that include, like, +lieutenants doing lieutenant rounds and things +like that? Or -? +: Well, yeah, from what +transpired, it is obvious the lieutenants +didn't know. I mean, they knew he was, based +on the email that, you know, they knew he was +leaving, but as far as when the finality of it +was, when you realize, okay, Reyes is gone. +You take Epstein, you bring him back up in his +cell, and he doesn't have a cellmate. I mean, +something should have went off on somebody to +make some notifications. +Okay. I know we're going + + +164 +1 +2 +3 +4 +5 +6 +7 +8 +to talk about counts. +: Mm-hmm. +: Mm-hmm. +: Wait, wait. The notification. +Would that go up as high as you? If someone +would say? +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +They would send it up to the +lieutenants, then they would tell the captain. +And the captain would let the associate warden +know, and then it would get up to me. +Especially an instance +since you have a say in who -- +- gotcha. +: We would have to sit down +and say, okay, of all the available individuals +that are on the unit now, who can we house +Epstein with? +Now, what about in the +this case, where as you actually weren't +working that day, would that - +-- should have they +called you -- +Whoever is -- + + +1 +2 +3 +4 +5 +6 +7 +8 +warden. +determination? +determination to. +165 +-- on the -? +- whoever was the acting +That would make the +_: She would have made the +who was the acting warden +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +that day, do you know? +I don't know if I left +or l +in -- +- as the acting. +One of those two. +It would be one of those +two. +And it wouldn't be the +NO. +He's the executive +assistance. +Now, what is the +difference between, like, an executive +assistance and an AW? +: The associate warden is a +GS-14, and the executive assistant is a 13. + + +166 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +So, they are not - +- +- but what, is that +executive assistant just mainly to assist you +in your functions? +: He assists in the functions. +I had also given him some other departments to +monitor. +: So, they manage, also, those +other departments. +: I just got a question. I +don't know if you may be asked him about the +backup list. +was there a backup list of names? +For? +: I think, I think we did +talk about it, but if Reyes - we did -- +1: Okay. +-- but -- +• sorry. +-- when we talked about +if Reyes was removed because the institution +always has people coming and going -- + + +1 +2 +3 +4 +5 +6 +7 +8 +167 +- so frequently, was +there, like, a list that was set in place, that +we would now consider these people, or would it +be just the whole new -? +: No. Because we would have +to base it on who was there. +Because of the turnover in +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +the unit. +1: Mm-hmm. +All right. Now, we're +going to get into counts. +So, this is an email sent +It's the count slips +from you to +for -- +-- it was sent on +Saturday, August 10th, 2019, at 5:11 p.m. +_: +This shows, ZA is the +SHU. +Correct? +So, this says, at 8:10, + + +168 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +it shows that the count for ZA was 73. Signed +by M. +and Ms. +And it says, that count +was done, it looks like, at -- +12:01 a.m. +- 12:01 a.m. And then, +we get the next one is at 3:00 a.m. +It goes down to 72. +At 5:00 a.m., there is +72. And here is the count, the institutional +count, it shows 72 at - what time? - 12:00 a.m. +Or no. This one is 3:00 a.m. +3:00 a.m. +I don't know why this is +all out of order. +5:00 a.m. So, at 12:00 +a.m., this says 72. +72. +: I think that was just an -- +: 72. +1: -- attachment to that email +that you sent. +So, but as you know, as +you notice, one of them said -. So, the count + + +1 +2 +3 +4 +5 +6 +7 +8 +slip said 73 for 12:00 a.m., over the +institutional count. And as you see here, for +12:00 a.m., it said 72. +: By the institution, you mean +the SHU? +169 +No. The institution. +It means the whole. +MCC does a count -- +-- and -- +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +-- its' what the official +: The count. +-- number show -- +Yeah. Okay. +- the SHU, these count +slips are supposed to be the -. Actually, let +you, you can answer my question. What is +supposed to be the difference between what +happens with the count slip, and what happens +with the institutional count? So, I'm not +answering your question. +•: So, what happens is, on the +shift, you call the count, and the different + + +1 +2 +3 +4 +5 +6 +7 +8 +count number? +go around and count. +inmate? +170 +units call in the count to control center. +: And how do they get that +From counting. They have to +: Physically counting an +You have to -- +Correct? +- physically count the +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +bodies. +And then, they take that +total amount of inmates, and they call that +into the control center? +: They call that into the +control. +: And where does the +control center get their numbers from? +: This is what is called an +E1. Which is a print out of the number of +inmates in each unit. +: So, if an instance, for +example, we look at BA unit. So, there is +supposed to be 26 in there. If somebody calls + + +171 +1 +2 +3 +4 +5 +6 +7 +8 +it in there, they say, it says 25, they tell me +it's a bad count. +: Mm-hmm. +So, they have to go back and +count again. +: So, the E1 is created +based upon what inmates are listed within your +system. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: The count slips are based +upon how many inmates they actually count. +What they count. +: And the purpose of that +is what? Why are the inmates counting inmates, +and why are they providing that number to +control? +: So, we make sure every +inmate is in the institution. +The countability of the +inmates. Correct? +Yes. +Great. So, the - so, +does that answer your question? +_: Mm-hmm. +So, the next email is + + +172 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +sent about one hour later, at 6:13 p.m., on +August 10th. It says, "why did the count +change from 73 to 72 between 12:00 a.m. and +3:00 a.m.?" +response was to that? +: Do you remember what your +I don't. +And then, this one is +another one from Ray to yourself. +It says, "The 12:00 a.m. +count slip reads 73, and the 12:00 a.m. - +E1. +-- E1 says 72." +So, those kind of go +together. Do you remember what your findings +were there? +: I don't remember. Because +typically what happens on the count, you are +supposed to - the lieutenant is supposed to +take one count at night, and then review +documentation. So, I don't know what happened +with the discrepancy. + + +1 +2 +3 +4 +5 +6 +7 +8 +173 +: I mean, this isn't really that +relevant, because we noted Epstein was there. +1: No. It's relevant for +our investigation. +: All right. So, if you +don't mind, just initialing and dating that, +and then, we can explain to you why that is +relevant. So, you don't, though, recall? You +didn't find out what actually happened? +: I don't recall what the +response is I gave. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +No? And do you remember +looking into it at all? +When was that sent? +That was the day - +When did he send it? +- that was the day of. +The day of. +The day Epstein was +found. +: I don't because it was just +so much going on. +That I can't really remember + + +174 +1 +2 +3 +4 +5 +6 +7 +8 +what, how I responded to them on that day. +: Do you remember learning +anything about the accuracy or inaccuracy of +the counts, on the 9th and 10th? +: What do you mean the +accuracy and inaccuracy? +: Like, if the counts were +actually accurate or not. +: I don't recall that. +You don't recall -- +No. I can't think of that. +- finding out about +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +that? +: Did you recall, did you +find out if the SHU counts and rounds were not +conducted by the SHU on August 9th or 10th, +2019? By the SHU staff. +: If they did rounds or not? +: Correct. Did you find +out if the SHU staff had conducted both 30- +minutes rounds, as well as the institution +counts on August 9th and 10th? +: I don't know if it was after +the fact that I was told that the Officer did + + +175 +1 +2 +3 +4 +5 +6 +7 +8 +make their rounds. And I don't recall if it +was, they put it in the logbook, that they made +rounds, but that in all actuality, it wasn't +done. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: So, that might have been +something that came up afterwards. +: But you are not super -. +You know, this, you don't really know what +happened or didn't happen? +: That day. Because I mean, +it happened that weekend, everything was +moving, and then, by Monday - +Right. So -- +- everything lese just +changed. So -- +- but on the 10th or +11th, you didn't hear - +-- I didn't -- +: -- find out? +- hear anything about, +recall anything about that. +: But had you heard that +they didn't at least conduct some of their +rounds and counts? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +in the morning? +176 +That they didn't? +: That they did not. +: It was - and I don't want to +use the word that it was just, you know, an +assumption, you know, like, because one of +them, I had asked to come up and speak with, +but it was +and he wouldn't come up. +And this was on the 10th +This was on the 10th, when +we got him up, because I wanted to speak with +him because people were telling me he was +distraught. +: So, I wanted to make sure he +was all right. You know? And he just, he +didn't want to come up and talk. +: What are your thoughts of +as an employee? +: I've known +a couple +years. I never had any issues with him. You +know, it was any, you know, like any other +employee, you do something, I correct you on +the spot, and that's it. But I have never +encountered him to do anything, known him not + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +her about that? +something - +everyone? +177 +to count, do his job, you know? +What about Ms. +: She was new. So, she had +just gotten there. You know, she got the same +spiel from me that everybody else does. You +know? You are new. You can't do the things +that somebody at 20, that has 20 years in it. +They're not doing their job, you shouldn't be +following it. +And did you - +So -. +- actually speak with +: Oh, I do that in my +(Indiscernible *02:09:22) class, when they +first come in. +Okay. So, that is +: And I had -. +- you would have said to +oh, I said it clear as day. +And same thing I would say in my ART class. +Annual Refresher Training. +: Because this is -- + + +1 +2 +3 +4 +5 +6 +7 +8 +178 +(Indiscernible *02:09:34). +- one of her excuses, +saying that 20 year guys, I'm following them, +they are not doing it, so I'm not doing it. +Is +that something you clearly entrust - +So, here's my speech -- +- to her? +- my spiel I used to tell +people. I said, go ahead and follow that 20 +year guy, and you are on probation, guess what +happens? He might get some time in the street. +You're getting fired. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: And are you confident +would have heard that speech from +that Ms. +you? +She heard the speech from +me. +Yeah. I'm confident. +That's the speech I gave everybody. Same thing +in the ART. +Good enough. + + +179 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: All right. So, this is +going to go back. This is just my little list +that I wrote of exactly what happened, and then +I'll read to you, but - +: - I just want just for +our purposes, I'm going to just show you, and +you can refer to them. On this one, at first, +going to be the count on the 9th, that was +conducted at -- +: 4:00 p.m. +- is this 4:00 p.m. Is +this the 4:00 p.m. or the 5:00 p.m. here? +_: No. This? +1: 4:00 p.m. +4:00 p.m. count. There's +just signed off -- +No. There's no 4:00 p.m. +count. +- yeah, it's the 5:00. +1: 5:00. Sorry. +Yeah. It's -- +- 12:00. +12:00. +3:00. +And 5:00. + + +180 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +1: No, no. This is afternoon. +Yeah. So, this is +Friday. ( +: I'd say (Indiscernible +*02:10:40) - +All right. Friday. Is +that a - +: -- (Indiscernible *02:10:41) +- 4:00 p.m. - +You told him about overnight. +-- count? +Oh, it's a 4:00 p.m. count. +It's a 4:00 p.m. +Then 4:00 p.m. Then +there is the 8:00 p.m. +1: No, no. 4:00 p.m. 10:00. +4:00 p.m. 10:00 p.m. +Sorry. +: And midnight. +4:00 p.m. +10:00 p.m. +Midnight. +I: 3:00 and 5:00. +3:00. +And 5:00. +so, + + +181 +1 +2 +3 +4 +5 +6 +7 +8 +these are basically the time period in +question. Everywhere from 4:00 p.m. through +the 5:00 a.m. count the next day, on August 9th +and 10th. +: Here are the lieutenant +logs. And these are the emails that, again, +I'm going, just going over these just because, +so I'm not blowing things out of thin air. +These are the -- +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +were able to obtain. +- yeah, emails that we +So, this was from a +Who was the ops +lieutenant at that time. +Fairly regularly. +And during the morning +watch. So, this one was sent, from her, on +Saturday, August 10th, 2019, at 9:26 a.m. It +says, these are the August 10th, 2019. Daily +activity report. And then, we got the daily +lieutenant's log here. + + +1 +2 +3 +4 +5 +6 +7 +8 +182 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +So, where would this -? +This is just out of order. This should have +been first. So, Friday, August 9th, 2019, she +sends one at -. So, first, I want to ask this +question. So, on Friday, August 9th, 2019, she +sends one at 5:11 a.m. +And Saturday, she sends +it at August 10th, 2019, at 9:26 a.m. +And on Sunday, August +11th, 2019, she sends it at 6:15 a.m. +Now, reviewing all of the +lieutenant logs that came out prior to that +time, they are all sent out pretty much between +5:00 a.m. and 6:00 a.m. -- +: - by all the various - +-- ops lieutenants. Do +you find it odd that she didn't send this one +out until 9:26 a.m., being that, I know Epstein +was found at 6:33 a.m., but typically, they +were sent out much earlier than that. + + +1 +2 +3 +4 +5 +6 +7 +8 +183 +Is that -? I know she +sent it out after the incident, and after, you +know, everything happened, but do you think it +was weird that she sent that one out at 9:26 +a.m. versus prior to that 6:33 a.m., when her +shift ends at 6:00 a.m.? +: I mean -. +1: She was relieved at 5:30 a.m. +by Lieutenant +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +That's what I'm saying. She +wasn't at the -. When I got there, Lieutenant +was the lieutenant -- +Correct. +-- who contacted me +regarding -. +She was supposed to be +gone by 5:30 a.m. +So, yeah. I don't know. If +she left at 5:30 or whatever, and I don't know +how they (Indiscernible *02:13:07). +Well, that's when she was +relieved. She didn't leave until after this +was sent out at 9:26 a.m. +I don't recall her being in + + +1 +2 +3 +4 +5 +6 +7 +8 +184 +the institution around then. +She - after Epstein was +found - she actually went into the SHU. She +helped with feeding. And then, she went back, +and she did some things on the computer. +I thought - +: And she sent it. +- I thought +relieved +her, and she left. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: At 5:30 a.m., she was +relieved. She stuck around because she said +she had work to do. After Epstein was found, +she came to the SHU, and assisted +, who also wasn't working in the SHU, but +was there because he was the Comtech guy. And, +at the time, +was gone. +was there. +But at some point, +left. +: And I'm looking at this, but +I was under the impression, when +had told +me he had relieved her, and she left. +So, do you find that odd, +then, that she was still there until - +Until 9:30. +-- at least 9:30 a.m.? +Yeah. I didn't, I didn't -. + + +1 +2 +3 +4 +5 +6 +7 +8 +hearing of this? +talk with her? +185 +This is the first you're +: Yeah. Because when I was +told she was gone. So, unless -- +Because you wanted to +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +-- no. I mean, he relieved +her. So, I guess, technically, when you +relieve somebody, then it becomes your issue. +So, I was talking to Lieutenant +But I +didn't want, you know, I assumed she was the +one that -. But I heard she had left. I +didn't know she had come back. +: She allegedly did not +come back. She allegedly was there -- +There. +: -- the entire time. +So then, that is kind of +odd, because usually, your log is completed +before you leave. +: On your log, you will write +on there, relieved by such and such. +So, is that suspicious to + + +1 +2 +3 +4 +5 +6 +7 +8 +you at all? +employee is +186 +: Kind of. Yeah. But I'm +curious as to why you didn't log it down +something. +Now, why -? What kind of +: Had some issues with her. I +mean, I don't want to -. You know, everything +that is going on is an allegation. So, I don't +want to go speaking on allegations that I have +sent up. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Was she a problem +employee, then? +: I had some issues. Yeah. +: Any reason why she +believed that she might be involved with +Epstein and his death? +: Oh, no. I wouldn't put it +as far as that. +I mean, but it is just, I +wouldn't. And I don't know -- +: She's (Indiscernible +*02:15:29) to tell. +I mean -- +: -- I mean -- +: -- (Indiscernible *02:15:29). +-- that's why I went over -. + + +187 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Can you rephrase your question, like, what are +we saying? +Yeah. I mean, I'm going +all the way to -. I just ramped it up to 100 +miles an hour. I'm just saying all the way to +I can't -- +- to probably, could you +-. Was there any reason to believe that she +could be potentially involved with this? +: As far as doing harm to him? +: Keeping his cell door +open. And letting another cell door open for +someone else. You know -- +:I wouldn't -- +- anything like that. +- I wouldn't see that. +: No? +I couldn't see that. No. +No reason to believe it +would go that far, just maybe insubordination +is the highest that she goes? +Yeah. I would, you know, I +- +She -- + + +1 +2 +3 +4 +5 +6 +7 +8 +188 +- she has the allegations +up. I know you guys were seeing the +allegations. So, I, yeah, but I wouldn't go +that far. +But I can't -. +: Well, is she in a position to +do something like that? +What? +: Io leave the door open, or +something that's egregious? +She does lieutenant +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +rounds. +She's the ops lieutenant. +: She is in position to do that. +: But remember, when you are +going down range and the range door keys, you +can't have both. Somebody would have to let +her down there. +: And those keys. Those keys +go down. +Do you know if she was +particularly friendly with either +OL +I don't know what their + + +189 +1 +2 +3 +4 +5 +6 +7 +8 +relationship was. +She was the shift +lieutenant. So, I don't know what +relationships. Who she's had (Indiscernible +*02:16:48). +1: For the 8th, I just realized +we might not have the daily log for it. +: Fortunately, I brought +backups of different things. So, I think I got +- +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: Jesus Christ. +: The 9th and the 10th is in +there. +: I keep looking at this pile. +I think those eff'ing sons a bitches are +working hard. +I don't think the 9th is +in there. +Just the 10th. +: Yeah. +: No, no. It's the second set. +No, that's the 10th. +: No, the dates are -- +: Can I say -? +1: -- the following dates. + + +1 +Sorry. +2 +3 +4 +5 +6 +7 +8 +190 +Can I see the time +(Indiscernible *02:17:14)? +1: Just, I just want to confirm +with that. +Of course. Yeah, yeah. +That's the August 9th. +1: Yeah. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Okay. Great. +So, those two. +1: That's the previous date we +don't have. +All right. +(Indiscernible *02:17:25) right now. All +right. +So, what did you want to see? +I wanted to see that 9:26 +one. +Yeah. So, that is - +-- and this is what we +were going to show you, is the count numbers, +that's what we are getting at next. +wait. Which is the one -? +So, this is from Friday, + + +1 +2 +3 +4 +5 +6 +7 +8 +August 9th. +watch. +191 +okay. This is at what time? +: This just, that says morning +Ish. +Yeah, but why is it saying +the 10th? +: So, it was, the email was +sent out on the 10th morning. Right? But when +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +1: +So, she was -. Her -- +-- she included everything - +- +previous day. +9th. +-- shift -- +- everything from the +1: Yeah, but this is August +They sent it out the day +after. +Epstein is back. +So, see this one? This +one is sent out on Sunday, August I1th, for the +day prior, starting - +Right. So -- + + +192 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +-- Saturday, August 10th. +- no, I get that. So, she +started. Her shift was morning watch on +Friday. Okay? So, she goes to 12:00. So, she +is relieved by Lieutenant +: So, no, no. +: No, this is -. This should +be Thursday into Friday. +1: Yes. +Okay. No. I -- +: So then, it goes —- +- yeah. See. I thought +this was -- +: —- into day watch. +- the day of. Then you go +to day watch, and it goes to evening watch. +Now, what is the -? Which log is it for the +day of? +So, this is the day of. +1: Mm-hmm. +And this is, we are going +to get into. So, this one is the day before, +August 9th, when Reyes left, and we can look to +see on here, as well, where it says -. So, if + + +193 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +we go to this 8:38 on the lieutenant's log, it +says that Reyes is pre-removed. Right here. +"Reyes to pre-remove at 8:38 a.m." +Okay. So -- +That is August 9th, 2019. +So, we're going to go all the way down to -. +The one thing, I guess -- +: So, the count —- +- we want to look at is, +here, we got this individual, Iam Fernandez +(Phonetic Sp. *02:19:31). Who is on dry cell +with staff in R&D watch. +From the SHU. So, if you +look at the count -. +Where the heck is the -? +Okay. So, I just want to go +back to clarify something with -- +: Yup. +- with Lieutenant +So, we are saying this is at 9:23, she did it. +Right? +9:26. +So - 9:26 -- +She did it. +-- this was on -- + + +1 +2 +3 +4 +5 +6 +7 +8 +morning. +out. +194 +1: The 10th morning. Saturday +-- this is when she sent it +hours after Epstein was found. +Correct. Like, three +And this is -- +(Indiscernible +*02:20:03). +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +-- Friday's log. +Correct. +That that's -. +But they - the same +thing, though - they all seem to sending it out +the day before. +The day before. And then, +she sent the day before logs out on Saturday. +: She combined it. If you look +through it, it has everything combined. +: It goes from morning watch, +day watch, evening watch, into - +But I'm just -. +That should have been done the day before. + + +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +combined. +confused about. +before. +p.m. +10:00 - +195 +I don't think you're +right, bud. I think she's just doing the 9th. +The next day does the 10th. +: Yeah. That's right. +1: Yeah. Okay. +(Indiscernible *02:20:41) +Yeah. That's what -- +- that's why I'm a little +Yeah. No. She's not -- +Because when she came -- +- she does the day +: -- she came on shift at 10:00 +She started her shift at +I: 10:00 p.m. +: -- p.m. +1: Of the 9th -- +And worked until - +1: +-- evening. + + +1 +2 +3 +4 +5 +6 +7 +8 +196 +- 6:00 a.m., but got +relieved at 5:30. +So -- +That's right. +- yeah. +The lieutenants were working +from 10:00. 10:00 to 6:00. +Correct. Because the, we +were told because of traffic issues -- +- or something else. +And short -. Yeah. +So, what we want to, and +I want to kind of reference here is, Iam +Fernandez on dry cell, with SHU staff and R&D. +And the end of this shows +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +72. +: So, on August 9th, 2019, +at 11:59 a.m. - or August 10th, 2019, at 12:00 +a.m. - there is supposed to be 72 inmates, +according to this log that +sent +out. +: There is supposed to only + + +197 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +be 72 inmates there. +Now, look at the shift +for August 10th, when this person started their +shift, there was 73. +So -- +And the institutional +logs -- +- right. +-- show at 12:00 a.m., +there were - or so, that looks like - so, there +is -. Let's go. So, for ZA, there shows 75 at +the 4:00 p.m. count. The 10:00 p.m. count, +there shows 73. And then, at the midnight +count, there it says 72. However, the count +slips, if you recall -- +1: 73. +-- where are the count +slips? +So, it is -- +1: The counts. +-- it says the SHU +submitted a count slip for 73 at 12:00 a.m. +Here you go. So, that is not the count. Oh, +yeah. There. +So, see? +12:00 a.m., they +submit it. +submitted 73. + + +198 +1 +2 +3 +4 +5 +6 +7 +8 +Although, the institutional count says 72. +Now, not +1, but the next one +shows that, the next ops lieutenant shows that +73 is what is written in this. She went back +and changed 72, the day before, with the 9:30, +because it was determined -- +That he was on the outcount, +and on +- oh, yeah. +-- (Indiscernible +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +*02:22:57). +And so, Fernandez was +never removed -. +So, look at -. It shows it +on this. "One SHU correction. Fernandez dry +cell." So, at 12:35 a.m., and we do have +Fernandez right here. +: Looking back. +okay. So, this just +says, this is what happened with him. He was +found to have contraband, that he was providing +to a visitor in the SHU, at approximately, +like, I think 1:00 p.m. on August 9th. He was +moved from the SHU to dry cell. And he was +never -- +Keyed in. + + +1 +2 +3 +4 +5 +6 +7 +8 +should -- +199 +- keyed out. +What - yeah - what they +Keyed out of the SHU. +So, the institutional counts were reflecting - +• : 73. +: - 73. That is what the +SHU continued reporting. 73. Because that is +what - that's what, according to the system, +was supposed to be in there. But if they had +physically - +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Counted. +-- counted -- +They would have known -- +-- it would have -- +-- he wasn't there. +-- been 72. Correct? +So, with this +information, and I guess as the warden, would +that suggest to you that they were not actually +conducting their counts? +: They weren't counting. And +then, there is no count slip here for the +inmate that was on dry cell in R&D. + + +1 +2 +3 +4 +5 +6 +7 +8 +200 +There should have been a +count slip for him over there. So, what should +have happened was, the inmate - him - he should +have been outcounted in R&D. And then, the +R&D, you would have seen one. So, there was a +count slip. Whoever is sitting and watching +him should have did a count slip on him. And +then, whoever his back up was should have done +a count slip. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +And this is, from my +review of everything -- +:Mm-hmm. +- this is what I found. +I don't want to put my words into +mouth, but let me know if this makes sense to +you. It says, "Count discrepancy on the August +9th, 2019. Per the daily activity report dated +August 10th, 2019, and the attachment +lieutenant 10g from August 9th, 2019." So, +that's what we are looking at here. +"The day began with 77 +inmates assigned to ZA." Or the SHU. "The +5:00 a.m. E1 institution count, respective ZA + + +201 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +SHU count slips, eyes on count shows 77. At +8:38 a.m., inmate Reyes is pre-removed from ZA +for count, and taken off the lieutenant log. +The accurate ZA SHU count moves down to 76. +Reyes was removed from the institution and does +not - and should not - appear on any counts at +this time. +At 3:15 p.m., inmate Fernandez was placed +on RA dry cell from ZA, which moves the +accurate ZA count down to 75 on the lieutenant +log. The 4:00 p.m. E1 shows a total of 76 +inmates assigned to ZA." With one in attorney +conference, which was Epstein. "This indicates +that Fernandez was not keyed out of the SHU, +and keyed into RA. The ZA eyes on count slip +shows 75. Inaccurate. +It should have reflected 74 because, +although there were 75 inmates assigned to the +SHU, Epstein was in attorney conference. There +were no inmates assigned to RA on the E1 +institutional count, and there was no count +slip for RA, eyes on count." This is where the +problem begins. +"At 6:34 p.m., inmate + + +202 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Hemingway is moved to ZA, and brings it down to +74. 6:47 p.m., inmate +(Phonetic Sp. +*02:26:10) is moved from ZA to ES, bringing it +down to 73. +At 8:21 p.m., Felix (Phonetic Sp. +*02:26:15) and William is moved to ZA, to +suicide watch, bringing the accurate count down +to 71. +At 8:28 p.m., inmate Garcia Pina +(Phonetic Sp. *02:26:23) is moved from K into +ZA, bringing the accurate count up to 72. +The 10:00 p.m. El shows a total of 73 +inmates assigned to the ZA, but zero inmates +assigned to RA. The ZA eyes on count slip +shows 73." Oh, this is +another one. +I don't +think we brought this. "One of the counts +actually shows 73 plus one." Do we have that +in there? +: The 10:00 p.m. +: I admire your guys' +(Indiscernible *02:26:48). +Yeah. You would also -. +This is all probably -- +I: 73 (Indiscernible *02:26:52) . +-- all Chinese to you. +That's how our count slips - + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +- +language -- +about. +and that. +off. +203 +- now, I did foreign +: I don't understand -- +-- should be done. +: - the fuck are you talking +Yeah, yeah, yeah. +Hun. +This is -- +: All these initials, and this, +-- but the count -- +So, which is interesting +is all of these are, as you notice, crossed +- right. +These two are not crossed +off. +This one says 95 + 1. This one says 73 + +1. The question had been, when did this +happen? +When did they put these +plus ones, or why weren't they crossed out? +But you can't do a -. This + + +204 +1 +2 +3 +4 +5 +6 +7 +8 +is an inaccurate count slip. Because you are +supposed to have the accurate count. You can't +do -. If this is 73 + 1, then you should have +74 on there. +Or, in this case, it +should be 73 minus one because the accurate +count was actually 12. +: No, but you wouldn't write +minus one on there. You would write the actual +count on there. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +So -- +-- either it was 72 or 74. +But there is no -- +All right. Guys, I'm going to +- such thing as -- +: - splash water on my face +again. +- okay. There is no such +thing -- +: You guys are getting ready to +kill me. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +why - +205 +-- there is no such thing as +plus one on the -- +- on that. +You're not allowed to +ghost count. Correct? +No. No. There should have +been an outcount done. So, and this should +have been caught, whoever the shift lieutenant +was, because they have to, you know, on each +shift, conduct a count, and review the count +slips. +: Does this tell you +anything, though, that these were crossed off, +and these weren't? +: Yeah. Unless, I don't know +: Do you think that they +were replaced at a later date, or -? +•: I mean, it gives the +appearance. Because at first, I would want to +know, why you cross out. Why these - +: They cross out because, +as things come in -- + + +1 +2 +3 +4 +5 +6 +7 +8 +206 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +-- you check it off. +: So, that's what I want to +know. Like, whose habit is this? Like, okay, +I'm looking at -. +: So, basically, I think it's +standard practice, as a control officer? +No. I mean, I've worked +control, and what I would do is, I would do the +check off, if I'm doing this. I've never -. +And that's people's style. +That might be their style. +So, I just want to know -. +This one is +(Phonetic Sp. *02:28:46), I believe. +_: Huh? +1 m +So then -- +This one. +-- then that's how +does +So, my question is then, why isn't this +done -- +this, if +-- like that. I mean, +does it like that, then that's + + +207 +1 +2 +3 +4 +5 +6 +7 +8 +his consistent way of checking it out. But if +this is all on that shift -. +: But point being, you will +agree, this indicates that, from 4:00 p.m. on, +the counts were not conducted. Correct? +: No. They weren't done +right. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +The SHU counts? +to really go into too much -- +Okay. Then we don't need +- detail with that. Is +this the first that you are seeing this? +Yeah. I haven't seen that +before. +: This was still on the counts? +:No. +Now, we're going to move +on because the warden agrees that there is not +really reason to really dig further, because he +agrees this clearly shows that the counts were +not conducted in the SHU, from a certain time +on. + + +208 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Fernandez key? +1: Do you want to ask about the +What about it? +: who's responsible? +So, Fernandez -. Oh, can +you just - sorry - would you mind signing, +initialing and just dating? If Fernandez was +actually removed from the SHU - +-- and placed onto R, you +know, RA dry cell, or R&D dry cell, oh, RA and +R&D are interchangeable. Correct? +RA -- +Because RA for - RA, I +believe, is what it shows in the count slip, +but it stands for the R&D -- +That's the R&D -- +- right? +- area. I believe. Yeah. +So, if he's actually +moved there around the 3:00 p.m., on August +9th, 2019, who would have been responsible for +keying him out of the SHU, and placing him into +the RA, so that the count would be accurately +reflected? + + +209 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 ++ = +SHU would have notified +control center, that we are moving one over to +R&D. +: And by that notification, +do they also say, can you please key him out, +and into? Or is that just automatically done +by control? +: Well, the notification is +made to control that inmate such and such is +being placed on dry cell in R&D. And then, you +key the inmate to that area. +Sure. +: So, I'll give you a quick +background. It looks like +: Who is that? +: -- witnessed this. +(Indiscernible +*02:31:02). +]: +Uh-huh. +: And he wrote up the shot. +1: And he called the lieutenant. +He requested the lieutenant. + + +210 +1 +2 +3 +4 +5 +6 +7 +8 +1: And it looks like he +requested the lieutenant, but he never notified +control -- +: - that an inmate was being +moved. Right? If - and I'm (Indiscernible +*02:31:20). +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +well, no, no, no, no. 1 +wouldn't (Indiscernible *02:31:21) -- +: He doesn't recall -- +-- I wouldn't -. +: But then, while the counts +are going on, there is somebody in R&D. So, +whoever is sitting in R&D should know that I +need to do a count slip because I have an +inmate down there. +: Is this where somebody +disappears, that we're looking for? +Again, I told you, this +was more of an administrative thing. Just to +say what does the warden, you know, and the +boss of this place, what is his take on these +matters? Because as you have gathered, a lot +of things went wrong this day. So, we need to + + +211 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +figure out why these things went wrong. So, +this is -. Let me just make sure, before we +move on, that I got everything. All right? +So, first, before we get into rounds, when a +lieutenant conducts a round in the SHU -- +- are they required to +conduct a round of the inmates going up and +down the different tiers, or does the round +consist of just checking +in with the officers +to make sure everything is okay? +: Well, you check the officer +to make sure they are all right, and you check +the documentation. So, you check, you know, +you edit, you would have to review the post +orders also. To state what their duties are. +I mean, all of us had different, you know, I +was a lieutenant, so it was different things +you did, but I always checked the 292s, to make +sure, you know, the officers checked off, you +know, if the person ate or not. Any medical. +I would check to see if medical came up. So, +it would factor and depend on what shift you +went on. You know, the day shift, the inmates +are up, so you're going, you know, you can go + + +1 +2 +3 +4 +5 +6 +7 +8 +around. Evening shift, you can see what's +going on. The midnight shift, they're +sleeping. But you are definitely checking a +30-minute 1og, to see if the inmates are doing +their 30-minute checks. And, you know, just +documentation. +212 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Now, as the warden, did +you expect your lieutenants, though, to go down +range when they were doing their lieutenant +visits in the SHU? Their rounds. And this is +specifically when they are, like, signing off +on the different, like, on, as you can see, +this is what I'm going to be showing you. +These are round sheets that -- +: - you sent to Mr. +, where it shows the different +lieutenants signed on/off that they did their +round. +But what does -- +: So, what does that -? +- what the lieutenants are +checking for is accuracy of the officer's +rounds. +Okay. This is -. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +213 +So, what they are checking +is, okay, were the 30-minute infrequent checks +done? Now, if there is an easy, that they are +not being done, you know, so, you know, then it +needs to be annotated and said, okay, this is +what the issue was. +But if they are signing +it, they are kind of acknowledging that, you +know, that the time that the round will put +down, that they were down. +Now, what would be -? +This is the round, it 100ks lie for 8/8. Can +you think of a reason why these wouldn't be +done? But they would be signed off on right +here? +: Let me see. So, if a +lieutenant made rounds and saw this thing was +empty like this, then it is a problem. +: Because you have this +8/8. And then, there is zero rounds showing +that they were conducted, but this lieutenant +signed it. +That's a problem. +: The same thing. We go, +this whole thing. So, this whole shift looks +like they didn't even sign it until here. On + + +214 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +8/8. +Wait. Did you print these +off the logbook, or -? +This is what you sent to +On Saturday, August 10th, +at 6:21 p.m. +: Now, the only other thing I +can think of, and when I had gathered +something, I might have said, because the +checks are done at, like -. No, these are 30- +minute checks, so they -- +: This is also -- +- you know, these are - +- this is the day, this +is two days before Epstein was found. +- no, this is -. No. I +was thinking of the log. The log did it +electronic. But this, no. This -- +We have the electronic +version. +-- yeah. This is -- +: Which one? +-- no, this is -. That + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +means -- +on that. +215 +So, this is just wrong? +-- yeah. This is wrong. +Should have this +lieutenant signed that? +: No. He should have signed +They should have put something -- +_ : — listed as some +discrepancy, why the checks weren't done. +And on these, whereas it +looks like, this lieutenant is signing, it +looks like probably because these are done. Do +you think that is the reason why this +individual hadn't signed these? Because these +weren't correct? +: Probably. I can't speculate +: Because it says -- +I can't. +-- reviewed by morning +watch lieutenant. +Where they do that, well, +that lieutenant does start signing it here, +where they are now filled out. + + +1 +2 +3 +4 +5 +6 +7 +8 +216 +For the same date. +So, this looks - hey, I +don't know who it was - but this looks +(Indiscernible *02:36:10) worked it. +: Let me see how those 30- +minute. That's the same one. I don't know who +it was. +Who it was. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +okay. So, that was +(Indiscernible *02:36:19). Certainly go 100k, +but whomever it was during those shift. And +then, we get into, it looks like, +(Indiscernible *02:36:30) still. And these. +Here is the 8/9. Where -- +signed off, until 2:00 p.m. +-- it's signed off, +That's a problem. +After that, no sign off. +Same thing. +that time. +That's just when I think +left his shift, or somewhere around +So -. +: The point of this, if I may + + +217 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +ask, is we got a miscount, right? +We're not -- +: This is -- +-- we've moved on from +counts. +Now we're on rounds. +: Okay. Now, counts. The +significance of the counts is, at some point, +Reyes disappears? +No. The significance of +the counts is that, if inmates - or if the +staff members aren't conducting counts and - +counts are to the accountability of the +inmates, to make sure everybody is there. +Rounds -- +: Mm-hmm. +- are basically to make +sure everyone is alive and breathing. Is that +correct, sir? +_: You are right. Counts are +accountability, and then, the 30-minute checks +are basically safety checks. +: So, the point of these +questioning is, it looks like at - what we just + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +conducting -- +218 +finished was counts - we have shown that the +staff members were not conducting their counts. +: Right. Because that is why +you have 72 when it should be -- +Now we are doing rounds. +: — (Indiscernible *02:37:41). +To find out were the +staff members conducting their rounds. +: Got it. +And again, we have, in +this case, a very high-profile inmate that was +deceased. Became deceased at some point. +: And they think -- +: And -- +: — plus it's whether they -- +: - yeah, it -- +: - noticed on their rounds +that the guy was deceased. +- if they were +: Or -. +: -- rounds at all. And if +they were conducting rounds, would that be - +and this is a question to you, like, we'll ask + + +219 +1 +you now, since I'm making that explanation - if +2 +they were conducting their rounds, would that +3 +be a way to at least try to help ensure that +4 +inmates such as Epstein were alive and well? +5 +know it's not going to prevent it in every +6 +case, but is that part of the reason, to make +7 +sure that, if they are conducting a round, you +8 +are checking to see if they are alive, and they +are breathing. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +It is true, but I mean, and +because I mean, an inmate can, you know, you +can do your 30-minute rounds, and if they want +to do their harm to themselves, they are going +to do it. +: Right. And that goes +into play with why - +: They just -- +: - they just look, they do +rounds by looking in their cell. +• So, if you want to -- +: To check. +: - do harm, you just wait +until they go passed your cell. + + +1 +2 +3 +4 +5 +6 +7 +8 +220 +Right. And then, you kind +of figure out the timing of the route. But the +fact remains, if you are not showing on the +form that you did your rounds, then that's a +problem. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: So, when you are looking +at these rounds that you sent +| are +you finding problems because they are not +completed correctly? You know, what we just +looked through. In fact, you know, these are +August 10th. (Indiscernible *02:39:09), +they're not signed off. There's blocks that +are not filled in. +: Yeah. Looking at them now? +What is the question? +: Well, does it show you +that, at least this paperwork doesn't appear to +be filled out correctly? +Yes. +And that is for the 8th, +as well? +Okay. So, that was - +: And that is something, it was + + +1 +2 +3 +4 +5 +6 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +7 +8 +221 +your job to pass that on to +? +No. He requested - +No, no, no, no. +-- the information. +This is just to show that +- what the round sheets +that the warden sent to the regional director +were these rounds. So, it's just a matter of, +hey, do you know if these rounds were -? It +has nothing to do with his, you know, if he did +it right or not. It's, what his staff members +: - doing it right. +: And who was responsible +to make sure the round sheets are done +correctly? +: Well, the staff working up +there are responsible. And then, the +supervisor is supposed to ensure that they are +doing it. +And what is this? This + + +222 +1 +2 +3 +4 +5 +6 +7 +8 +was also attached. What is that right there, +that we are looking at? +Hmm. +: TruScope logs? +Yeah. This looks like +TruScope. This 1o0ks like the log. And so, +like, if they are doing what areas they search. +And these are searches? +Yeah. These looks like +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +searches. +Let me see that. Search. +Did the areas. Visiting. Strip room. +Recreation area. Yeah. These are -- +-- these are search areas. +Does it show anywhere in +there that there was any cells that were +searched, or are they just all, like, common +areas? +No. They searched it. Look +how -. +What is this? Nine South. SHU. +Completed all. These are, these 1ooks like +everything they have done in there. The fire +and safety checks. This is - it looks like the + + +1 +2 +3 +4 +5 +6 +7 +8 +log. +you. +223 +Okay. So, this goes with +So, all to this. This is +something else that we asked for the BOP to +print out for us, and this one specifically one +we asked. When you send us the cell searches +that were conducted on 8/9/2019 -- +-- we got back one. By +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Mr. +It say that it was +conducted at 12:36 p.m. +On 8/9/2019. +Is that a problem? That +only one cell search was conducted in the SHU? +According to, at least according to TruScope. +Because I believe the post +orders state it is supposed to be - and don't +quote me on it -- + + +1 +2 +3 +4 +5 +6 +7 +8 +224 +- you have to look at the +post orders - but they state, I think five a +shift. A minimum of five. +It's five, I believe -- +- for the night watch. +The day watch, I believe, is more. And the +morning - +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: They're supposed to do five -- +- watch is just +(Indiscernible *02:41:59). +: —- cell searches? +: No, no. Each shift is a +minimum of five. +: I don't think -- +And then -- +- that includes that +morning watch, though - +- the morning watch is -- +- because there's -- +-- area. +- right. +Yeah. You are -- +Common areas. +-- picking the common area. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +day. +225 +So, let me get this clear. +: Yeah. +: You are supposed to do five +cell shifts, five cell searches per shift? +Yes. That is -. +: All right. And in this case, +there is only an indication that they did one? +One. Right? +One the whole day. +One the day whole. +Not per shift. The whole +: Okay. Now, whose job is it - +:No. +: - to say why aren't you doing +those? I was going to use the F word. Why +aren't you doing all the cell shifts? +: Well, this is, this is my +question to the warden is, is that a problem, +that there was only one logged into TruScope? +Mm-hmm. It is a problem. +Does that indicate that +the cells were not being searched, to you? Or +that they just weren't logging them in? +And again, whoever was + + +226 +1 +2 +3 +4 +5 +6 +7 +8 +working that day, you're going to have to ask +them. +I mean -- +And we have. +-- looking at -- +And it was just - +- looking on paper, I mean, +it shows you didn't, you didn't conduct your +searches. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +okay • +I mean, now, there might +have been a reason where the person said, okay, +the computers were down or whatever, but it is +highly unlikely for -. +: So, but you are literally +going into a cell and search it? Does that +mean -- +: Yeah, yeah. +: - you throw over the +mattresses, the whole thing? +•: No. You pull them out. You +look at -- +: - look and check the +lockers. +You check under their stuff. You +know, and you typically do it, like on certain + + +227 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +days when the guys are going out to take a +shower, you might go out and do that. +: So, with your suggestion +that computers could be down and things like +that, as you can see from the email attachment +that you said, there are certainly plenty of +searches that were +entered in there -- +Oh. +- but there is only one +cell search. +: And so, I would assume, +would that indicate that the computers are +actually up and running? +: Yes. So, this one, this is +the same day? +What are you looking - +That could be (Indiscernible +*02:43:42). +- yeah, this should be +8/10, and 8/9 and 8/10. +8/9-- +I would think. +-- reg number. Reg number. +It shows the dates here. + + +1 +2 +3 +4 +5 +6 +7 +8 +I just can't see them. +in your opinion? +228 +Yeah. Change base. Yeah. +This is a search one. This is the log. +Okay. So, problematic, +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Yes. It is. +: All right. So, not only +searching them, but is it equally as important +to actually log it in, as well, so that we know +whether things are being +searched? +: Yes. You should log it. +: All right. Now, this, +this comes to the kind of question on this. +When Epstein was found, are you aware that he +was in a cell that didn't coincide with what +his inmate history quarters, and what the BOP +database said, where he should have been? He +was in the wrong cell. +: I did hear, afterwards, that +there were some issues with Sentry and the way +they keyed into the cells. +All right. And what did +you hear? +: I think, just that the cell, +the way the inmates were being keyed in was + + +1 +2 +3 +4 +5 +6 +7 +8 +off, it didn't match this cell. +That. +So, yeah, his assigned +cell within the BOP database was not where he +was located -- +229 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +- in person. At least +when he was found on August 10th, 2019. +: Now, is that something that is +- I should shut up, right? +No, no. I'm good. +•: Go ahead. +: Now, is that something that +goes on up to you? Is that your responsibility +to see where guys are being celled? +No. But I mean -- +Yeah. Most of my +questions to him isn't that -- +_ : +-- it's his +responsibility, it's whose responsibility was +it? +: Okay. Got it. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +230 +And then -. +: So, who should have made +sure that Epstein's cell, in the BOP database, +matched where he was physically located? +Because obviously, people get a hold of the +information that he wasn't in his assigned +cell. You know, that is just more reason to +people not trusting the government. So, we are +just trying to figure out -. +well, and this is not a +problem limited to one person. It is a problem +- and I think it is a Bureau-wide problem, as +far as specific keying in cells. I don't think +this was done in a malicious -. +So, what happened here, +our investigation shows is that when he came +back from -- +- from suicide, or +psychological observation, he was placed into +the cell that it shows on July 30th, on this +form. However, because his - is it CPAP +(Phonetic Sp. *02:46:24)? +CPAP. +His CPAP machine, the + + +231 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +cord didn't reach the plug. +: So, they had to move him +to a different cell. +: So, from July 30th to +August 10th, he was in the incorrectly assigned +cell. No one ever caught that. No one ever, +you know, and my thought being is, well, if +they are doing their cell +searches -- +Oh, I thought you meant - +: -- wouldn't -. +- the cell didn't match up +with -- +No, no, they - +-- (Indiscernible +*02:46:52). +- they logged him into +the cell that he was placed in, coming out of +psychological observation. +_: +On the 30th. Then, they +physically moved him to a different cell. +On the 30th. Because his + + +232 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +CPAP machine wasn't, the cord didn't reach. +: What is a CPAP machine? +It's the snore -. It's +to help you breathe when you are sleeping. +: And he needed a CPAP machine? +Yes, sir. +For the snoring. +So -- +: Don't call me sir. Please. +I'm old. All right? You're reminding me. +: And so, no one ever went +back into the system from, all the way from the +30th up to August 10th, and made that +correction. +Who was responsible for +that? +So, whoever made the cell +change should have contacted control center. +: And is the control center +that actually made the change, not the +individuals in SHU, or the SHU lieutenant? +No. The -- +Because my understanding + + +1 +2 +OIC. +233 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +it would have been the SHU lieutenant of the +: Bed changes? +: To verify their cellmates +where were the -. Wherever the BOP databases +said they are. +•: So, you have to, you would +have to call control center to make that +change. +Okay. So, who should +have called the control center? +Whoever made the change in +Sentry. Because I - and then, don't quote me +if I'm wrong - because I don't believe SHU +staff have control over keying where an inmate +is in. +Yeah. No. I thought the +OIC might, or the that the SHU -- +: No, because -- +-- lieutenant would. +- in that case, beds would +be really messed up. +Right, right, right. +So, the control center is +centralized area. + + +1 +2 +3 +4 +5 +6 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +that call? +7 +8 +happen? +234 +: So, a call should have been +made down to control, saying, hey, this is +where he's being keyed to, and this is what -. +And who should have made +Whoever made the change. +Whoever switched him. +: And my understanding is +that the OIC and the SHU lieutenant were +supposed to review cell assignments, to make +sure inmates were in their assigned cells, at +least on a periodical basis. Is that correct? +: Yeah. You do a, what we +call a bed book check, to make sure. Because +your board, you know, when you are in the unit, +you have a board up there, and you just match +where everyone is at. +: And how often should that +There is no set policy, but +as a good practice, you know, you kind of want +to check what your open cells are, where, you +know, where individuals are. And should it +also be checked if they were doing cell + + +1 +searches? Would that be caught, if they were +2 +doing searches? +235 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: Well, if you are doing a +cell search, all you are going to do is put +down the cell number, and the individual in it. +It wouldn't -. You wouldn't necessarily be +able to find out if it is the correct room. +: And the correct bed in +Sentry. +All right. +: But, you know -. +: So, in this instance, +then, and I'll shut up so I can actually let +you answer, who - +: I have the same problem. +-- who is it that should +have notified control center to make this +change? It sounds like you said whoever +physically moved him, at the time? +: So, what happens is, whoever +physically moved him should have said, okay, +this is where, you know, you are, this is where +we are moving him. And then, you let the - +typically - the OIC know, and then, they will + + +1 +2 +3 +4 +5 +6 +7 +8 +second? +236 +call down to control center. +And if that didn't -. +: Can I speak to my client for a +Sure. +Do you want me -- +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +- do you want me to push +pause? +NO. +Yeah, no. I'll take him to +the other -. +1: Okay. +Sure. Okay. It's 4:46 +p.m., and this is Senior Special Agent +, and I'm pushing pause. +(Whereupon, the above-entitled matter went +off the record and back on the record). +The recorder is back on. +It is 4:53 p.m., after a short break. And I +remind you, sir, you are still under oath. +All right. So, we + + +237 +1 +2 +3 +4 +5 +6 +7 +8 +stopped with the, we were talking about who was +responsible for making sure Mr. Epstein was +logged into the correct cell within the -- +Question. +-- BOP database system. +Were there other cells that +were wrong? +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Do you know that, +1: Not -. We don't know if -. +This, we know only because we checked this. +: Okay. So, I mean, +everything else could have been right, and that +could have been a -- +No. Well, we found out, +this is the reason was because, again, he was +placed into that cell, and then moved because +of the CPAP machine. +No. I was -- +Well, our question was - +: — you know, wondering if it +is a systematic, or an individual problem. +: Correct. +That's why I was just +curious. +Yeah. And that's + + +238 +1 +2 +3 +4 +5 +6 +7 +8 +something that we should probably -. +: Well, and my question is, does +that have any effect on count? I mean, they +still should be able to look in the cells if +there was a (Indiscernible *02:51:28). +Well, when -- +well, the problem comes +in, again, I think is the credibility of, hey, +now we have Epstein, who was found in a cell, +and it's not his assigned cell. So, that just, +you know - +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: But I'm saying — +-- the media says all of +these things that went wrong. +: -- yeah. +One being - +: I've had that. +- wait, he's not even in +the right cell. Well, how did that happen, and +who was responsible? +: Okay. Now, so, my question +is, does it make any difference? I mean, if +they are supposed to do the count, the count is +you look in the cell, and see -- + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +239 +: - whether there's a guy in +there. Well, whatever number he's in, or he's +not in, he's still in his cell. +No. Correct. +: You know? +But because we are doing +this deep dive review - +: Okay. I gotcha. +-- it's showing these +different, you know -- +: Got it. Okay. +- and again, this is, +this is one of those things -- +: You're just being extra +careful. Yeah. It's (Indiscernible +*02:52:14). +-- and not like +(Indiscernible *02:52:15). Yeah. We just have +to, we have to address the fact that -- +: He wasn't in the right cell. +-- Mr. Epstein wasn't in +the cell that he was assigned to. +: Okay. I mean, it's not just +that. +Someone +(Indiscernible *02:52:22) that +he said, oh, he doesn't have a roommate, and, + + +240 +1 +2 +3 +4 +5 +6 +7 +8 +you know, by the way, we also counted the wrong +number of prisoners. +: That's a lot of mistakes. +Right. And we haven't +even gotten involved. +As I'm sure you know. +But -- +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +- so, after the person +who moved him didn't contact and have this +changed, how would have, then, how would we, +then, how would have anyone found out that he +was in the wrong cell? What processes are in +place to ensure that where they are matches up +with the actual database? +Well, I guess if they were +doing -- +You said bed book counts? +: — yeah. Usually, you could +do, you do your bed book counts, to ensure, you +know, that every inmate is in the cell that +they are supposed to be. When you are updating +your accountability board, you would look and + + +1 +2 +3 +4 +5 +6 +7 +8 +see, okay, you got him here, where is he at? +And then, match it up with, you know, with +Sentry. +And who would be doing +those things? +: The staff working up there +in SHU. +241 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Is the lieutenant, the +SHU lieutenant, at all involved, as far as you +know, in making sure that this is all accurate? +: Well, he was spearheading it +to make sure everything was -- +: He was the supervisor. +: - was right. Yeah. He was +the supervisor. But going in and saying, okay, +let's, did this happen? Have we done this? +And have we done that? +: And -. Okay. Just to make me +clear, somebody dropped the ball as to whether +or not he should have a, he had a roommate. +: Okay. And somebody dropped +the ball as to whether he was in the right +cell. + + +1 +2 +3 +4 +5 +6 +7 +8 +242 +: Okay. And then, somebody +would have dropped the ball as to either, +dropped the ball or they maliciously didn't +find out that he wasn't on the count. They had +said we did a count, but they didn't notice +that, or didn't - that he wasn't breathing, you +know what I mean? +: Okay. That starts to be a +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +problem. +So, +just pointed +out to me. On the after-action review -- +- they did review this. +And it says that, +according to their review -- +- this is not my review. +Or +review. +"Significant discrepancies exist within Sentry +regarding cell quarters assignments." ORT. +QTR. +"Although it is well documented, inmate + + +243 +1 +Epstein was housed with two other inmates +2 +during his assignment in SHU. Sentry does not +3 +reflect this information accurately. Inmate +4 +Epstein was found within cell 220, that Sentry +5 +never reflects him being housed within that +6 +cell at any time." But to answer your +7 +question, the first sentence says that there is +8 +significant -- +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +-- discrepancies. +The way that I read that +is, overall, whether they are referring to +specifically Epstein -- +Epstein. +- that, I am not able to +determine -- +-- based upon that +sentence, but it does sound like, overall, that +they had some discrepancies. So, Lieutenant +would have supervised it, but it's really +the staff that would be responsible for doing +these bed book counts, and making sure +assignments are -- + + +1 +2 +- +244 +He did it right there +-- the inmates are in +4 +5 +6 +7 +8 +their assigned -? +- and then, whoever is +moving an inmate from a cell to a cell, you +make the notification. +And is it surprising to +you that almost two weeks later, that wasn't +caught? +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: At two weeks later from +where? +From -. He was placed +into the cell on July 30th, 2019. He's found +August 10th, 2019. That entire time, it was +never caught that he was not -- +: In the right cell. +- locked in the right +cell. +Is that a significant +amount of time that went by without catching +that? +Without catching it. It is. +Now, is that, you know, + + +1 +all staff that was in there, or is it, like, +2 +really -? +245 +3 +4 +5 +6 +7 +8 +: And again, and you probably +have to speak to the captain who was +responsible for doing the checks, and doing the +count. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +So, would the captain +have some responsibility on this, too? +Well, did the captain is in +charge of correctional services. So, that is +the unit he is over. +So, he has overall +responsibility to make sure, you know, in +conjunction with the lieutenant, that the unit +is running the way it is supposed to run. +: And what should have the +captain done in order to make sure that that +was accurate? +: Well, now, there is +different ways of finding out if stuff is +accurate. Like, you have the perpetual audit +system. Where they are responsible - the +lieutenants - are responsible to conduct +perpetual audits. +So, you can find out through + + +246 +1 +2 +3 +4 +5 +6 +7 +8 +those, when you do it. And they are usually +quarterly. But if there is discrepancies and +things are going on in that department of +correctional services, we have what we call +perpetual audits, which he maintained the +records of, and that is another checks and +balance where you would find out if something +is wrong. +And how often are those +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +done? +Those are done quarterly. +: Quarterly? +All right. So, the fact +that this is, we are talking about, like, ten +or 11 days, there is a good chance that they +weren't done during that time period? Or do +you know when they would be done? Are they +done, like, on a certain date? +What, the quarterly? +: It's - and I don't know when +the dates of the quarter starts - but that is +to your checks and balance. You know -- + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +247 +- you do your perpetual +audits, and then you catch it, and say, oh, +wow. We did an audit. And this is wrong. And +then, you come up with the corrective action to +fix it. +So, that's how the +captain could have determined, I guess -- +- but how, in those -- +The captain would find out. +- ten or 11 days, how +would have that been caught? +: Again, you would have to see +your inmate accountability board. +: Mm-hmm. +You know, are you matching +Sentry, if you are pulling off Sentry and +matching it with what is on the board. +: But - and I apologize +that I'm beating - +: - a dead horse here, +but, like, who does that? +: Again, I don't know who, you +know, who the lieutenant assigned it to, who + + +248 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +the OIC. You know, everybody has different +duties, and - +So, it is not like -- +-- different ways that work. +- not like morning watch +does this, or it's just based upon what passed +down from lieutenant to the OIC -- +Right. Like, what - +- to whoever. +- no, but basically, when +you decide to do it. You know, I mean, I can't +see, on the midnight shift, you are doing an +accountability check like that, because the +guys are sleeping, and, you know, you are +looking for a living, breathing body, but you +can't physically see them. +_: You know, so, what shift was +picked to check and say, okay, let's make sure +our cell, the accountability in the cell. So, +I can't -- +You can't really answer +the question. +-- I can't really speak -. +Sure. That's fine. + + +1 +2 +3 +4 +5 +6 +7 +8 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +close. +9 +10 +11 +12 +13 +14 +249 +: All right. Let's get +this stuff out of your way. If you don't mind, +this -- +: Am I right that we are getting +close to the bottom of the pile? +We are. We are getting +take this. I-O-L. +: Because Jesus Christ, I can't +(Indiscernible *02:58:29). +We are -. +(Indiscernible +*02:58:31) with this. +: Yeah. +So, this is the email +with all the rounds, and the SHU assignment. +And these were separate. +: Now, let me ask the question +(Indiscernible *02:58:48) the supervisors. +Your job is the prison. It's your job to 1o0k +down into the prison, as far as these counts +and, you know, accountability boards, and so +forth. +NO. +I mean, that is what +you have a captain for and a lieutenant for. + + +1 +2 +3 +4 +5 +6 +7 +8 +(Indiscernible *02:59:06). You know? +: And then, we touched on +this before, but this is an email that the +captain sent to you. +250 +Regarding the lieutenant +rounds on 8/9 to 8/10. He sent them, he sent +this email on August 11th, 2019. He said, +"Warden, here are the lieutenant rounds for 8/9 +to 8/10. Below are the workstations logged on +to complete rounds." +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +But again, for you, a +lieutenant round, and I don't know if we ever +came to that conclusion, or that we may have +got off topic on that. But a lieutenant round +is used primarily to check in, and it's not +necessarily to go down the different ranges? +: On the midnight shift. So, +they typically not, you know, unless they have +an issue, but like you said, you as a +lieutenant can walk - should walk - around and +see. Now, the midnight shift is hard, but the +other shifts, you, you know, walk around, see + + +1 +what's going on. +2 +3 +4 +5 +6 +7 +8 +251 +: Mm-hmm. +All right. So, should +they, though, be walking down the ranges on +both the morning, or the day watch and the +night watch? Evening watch. +: This is what I will say. +You probably got to look at the post orders and +see -- +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Yeah. The post orders -- +the post orders. +-- aren't clear with +that. +We haven't -- +So, it's not -. +-- we haven't been able +to -- +It's not -- +- specifically +determine. +-- that's what I mean, it's +not a requirement. +You know, for the + + +252 +1 +2 +3 +4 +5 +6 +7 +8 +(Indiscernible *03:00:26), they are in there, +making rounds, checking the books, to see if +you got a problem on the range. You would call +that. But most lieutenants do, you know, just +walk the ranges. Just to see what is going on. +Because most lieutenants +that we talked to -- +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +-- said that they were +absolutely required to do -- +-- a round, just like a +SHU staff member -- +-- was to do a round. +Some lieutenants - +- specifically, +lieutenants that worked that day -- +- said, nope, there's no +requirement to do that. +But -- +So, that's where I'm, as +the warden -- + + +1 +2 +3 +4 +5 +6 +7 +8 +253 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Well -- +- who is right? +: No. The expectation is, +like you hit any unit, you make your rounds +within the unit. The SHU unit is no different. +That you say, hey, I'm going to go in there, +make sure everything is, you know, check on the +inmates. And make sure they are fine. But if +we are talking about the post orders, were they +required to? The post, you know, the post +orders, I don't believe had the requirement +that they have to, you know -- +: okay. +• : — physically go in the +(Indiscernible *03:01:24). +: So, does that - if I +understand you correctly - the expectation was +that they conduct a round, just like a SHU +staff member, but there is no requirement to do +so? +Yeah. You should be walking +around. +All right. +Io see if everything -. +But it's not like you + + +254 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +told them, you gave them a directive, make sure +you are doing this. +: So, there is no -- +: - so, if someone wasn't +doing it, it's not like something they would be +disciplined for? +: See, that's hard. I mean, +to say you would discipline. There +is a +difference between what is written down, and +what you need to be doing. I mean, if you are +coming in, and I enter there +as +a supervisor, I +want to see what's going around the unit. I +might ask the officer, all right, do we have +any problems. The inmates, when you come on, +hey, they know the lieutenants on, hey, +lieutenant, I need to talk to you. So, you are +going down the ranges. +You know, so, when you +are going down the range, you are seeing +something. +You get to another range. The +inmate said, hey, I need to talk to you. So, +it is something you should be doing as part of +your rounds, and going up into SHU. Just +walking around, to make sure everything is -. + + +1 +2 +3 +4 +5 +6 +7 +8 +255 +But if you were still the +warden of the MCC, and found out that your +lieutenants, when they were signing off on +doing rounds - +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: -- and you found out that +they were only checking in with the staff +members, and they were not actually walking +down the ranges, is that something that you +would find problematic? +: I would correct it. +: And when you say correct +it, what do you mean by that? +: I would tell, you know, get +with the captain, and I would tell the captain +they need to be, you know, in inmate grounds, +they need to walk the ranges. +: So, they should be +walking the ranges, then? +: Off of the post orders, it's +not in there, you know - +: I know. I -- +: - any place saying that you +have to do it. But as a supervisor, that like +any unit you walk on, you want to see what is + + +256 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +going on in the unit. So, do I want to use the +word "sound correctional judgement"? You know, +just to see, as a supervisor, what is going on. +I mean, you have some people that go above and +beyond. And then, do their job, and you have +some people that want to do the bear minimum. +But that is something -- +: — from a rounds point of +view, I would say you need to make those +rounds. +: Okay. Let me ask you a +question. +_: Mm-hmm. +: You do the rounds. Does that +mean literally walk up and down this, what we, +what I would call the cell block? +: Yeah. You walk around the +unit. You know, you are interacting with +inmates. You are talking to inmates. Same +thing with the inmates in SHU. You know, you +are walking around. +Hey, what's going on? +So, what you are not +familiar with is the way the SHU is set up. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +different ways. +21 +22 +23 +24 +25 +257 +There is different +levels, and there is different -- +: Yeah, I've been to the SHU. +-- hallways. +: Know what I remember about the +SHU, it's fucking cold. +Yeah. So, like, if you +are just, you can simply go in and go to the +officer's station, and check in with the staff +and say -- +: — everything good? You +got all your paperwork in order? All your +paperwork is actually right here on the desk. +Did you find it problematic that they are +keeping all of their round sheets on the desk +versus on the ranges themselves? +Different places do it +Some -- +: So -. +- some places have it, they +keep it at the end of the range, and you sign + + +258 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +it. Some have it right there, the log, you +know, take the logbook and they just sign it. +So -. +So, the individuals, the +ops lieutenants and activities lieutenant that +we spoke to, that worked on August 9th and +August 10th -- +- a majority of them +said, if not all of them, no, no, no, all I +needed to do was go to that officer's station, +check in with my officers, make sure their +paperwork is done, and then I left. Every +other lieutenant that we talked to said, no. +When you sign that paper, +you are signing it just like you conducted a +round, as if the SHU staff conducted a round. +:Mm-hmm. +You had to go down every +range -- +: — make sure everything +was good to go. You are not just checking on. + + +1 +2 +3 +4 +5 +6 +7 +8 +259 +So, what we are trying to +say is, which one is right? +: Well, now, for the ones that +are saying that I don't have to go down and +check every range, they are going off the post +office. +: The ones that are doing +their job, they are going around and checking +every time. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Making sure the wellbeing of +the inmates, and you are checking on the +wellbeing of your staff. +: All right. So, it kind +of sounds like nobody is right, and nobody is +wrong? They need to change the post orders? +: Well, they would, they would +have - should put in -- +: Yeah. +- their post orders, but +they should be going around, and -- +: So, they should have a rule -- +-- the wellness check. +: - that says, you got to go + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +around? +it? +just do it. +lower. +back on it. +260 +: okay. +So, no one technically +did anything wrong. They should just really do +They should. They should +Okay. Fair enough. +1: The term used was "sound +correctional judgment. +Yes. +All right. So, that - +again - was that email from +the lieutenant rounds. +to you, with +: Damn. That pile is a lot +: Unless you want to go right +: Now, this says - +: Wait a minute. Wait a minute. +I'm fucking out of here. If you bring that +pile back, I'm out of here. Now, I'm going to +give you some of that money back, but I can't + + +1 +2 +3 +from +4 +5 +6 +7 +8 +261 +take this shit no more. +So, this one says it's +To you. +: Who is +? +He aws a unit manager there +for the PCU Unit (Phonetic Sp. *03:06:23). +Okay. At the MCC? +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +It says, subject, "Weekly +rounds -- +- as requested." +So, these are weekly +rounds from August 4th, 10, 2019. What is that +for? +That was for our Wood sec +unit +(Phonetic Sp. *03:06:34). +oh, okay. +So, you actually had your +own separate wood sec unit? + + +262 +1 +2 +3 +4 +5 +6 +7 +8 +So, that is not in SHU? +Or is it? +Huh? No. That's not in +SHU. That is a separate unit all together. +: So, why was this +provided? +For any reason? +Because I like to -. I used +to like to track who was making their rounds +and not making their rounds. +All right. +So, they had to send it to +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +me every week. +So, was this just +coincidental? Nothing to do with Epstein? +: Yeah. This had nothing to +do with him. +This was probably what he +had to send up that week. +It was the end of the week. +: okay. +So, that's what he sent. +So, that had nothing to do with him. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +do with Epstein. +going to -- +staff -- +eight -- +rounds. +I'm doing. +263 +So, this has nothing to +: All right. I'm not even +1: Yeah. +: - you can keep that over +here, so we don't get that confused. +1: Yeah. +All right. So, this one. +As far as this one, it says, from you to Mr. +It says SHU rounds. +What SHU rounds are we +looking at here? This is a new document here. +•: Okay. This is on -. This +is eight, for the -- +This is for executive +- the week starting at +- or-? +-- this is starting for 8/4 +So, this is, these are my rounds that + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +264 +Now, is there some kind +of a requirement that you conduct rounds? +: Yeah. The warden is +supposed to go up and go -. +So, you are supposed to +conduct rounds in the SHU? +Yeah. About once -- +Or is this -- +- a week. Like, you can go +up as many times, but, you know, the warden is +supposed to be going. +: All right. +: Now, that means you are +supposed to conduct rounds in the SHU? +: Yeah. I go in the SHU. I +walk around and do rounds in every area of the +institution. So. +: And is everyone on here +supposed to do a round weekly? Because I have +never seen this round sheet until reviewing +your emails. +No. This is every Bureau +institution has this. This is where you sign +into the Special Housing Unit. This is the +log. And this is showing that they made their + + +265 +1 +rounds. So, these are the lieutenants right +2 +here, showing that they made their rounds. So, +3 +at the end of the week, when they send me the +4 +round sheet, and let's say it looked like this, +5 +my question would be, okay, did they make +6 +rounds, or did they forget to make rounds? +7 +: Is this and this the same +8 +thing? +: For the lieutenants, it +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +would be. +Just the lieutenants? +And no one else? +: Yeah. No one else. This is +computer services. The duty officer has to go +up there. +NOw, so -- +Right there. +- this shows that you +did two rounds. +to do one. +Correct? +: And you are only required +AW programs. +That, she did it on Friday. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +to that. +23 +24 +25 +make rounds. +266 +: So, the fact that Aw +operations has nothing in there, is that +problematic? +: And here is the other thing +could have happened. A lot of times, they make +the rounds, sometimes they forget to initial +and sign it. +All right. +: So, what I would do is, I +would look at it and say, okay, when I got at +the end of the week, what happened? How come +you didn't make rounds? +So, all of these blank +spaces, were these people supposed to be doing +rounds in SHU? +Not everybody is required. +They should have been up there, but they are +not required. Like, the finance facility - +- The correctional judgement -- +•: - food services. +: - would be they could go up +: But health services has to +You're getting it. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +267 +The PA's. +: By the end of the day, man, +I'll be ready to go to MCC myself. I hated +going to prison. +: Psychology. You know? +: So, which ones on here +that are actually required to conduct rounds? +: You have the unit team +that's supposed to go up. The lieutenants. +Well, SIS, it doesn't +appear that they did any rounds. +: That's -. +But I'm assuming they +certainly should have. Correct? +: SIS should have been up +there, to go around. So, and again, I would +look at it and see who was on leave. Somebody +might have been on leave, not on leave. +: And what are - so, when +these type of individuals, it 1o0ks like more +high level such as, I mean, obviously, you are +the highest level, what is a warden round look +like? Do you all have to walk down the range, +or -- +So, what I -- + + +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +268 +- is that what you do? +- what I do is, I walk +around and I go to every cell, and I talk to +the guy, got any issues, any problems? +They're, like, no, I'm good. You might have +some that say, hey, I'm up here for an +investigation. Why am I here? Why am I up +here? So, I take my little notes. Okay. +Fine. Some of it I can address right there, +some of it I can't. But I would typically walk +around what we call is the SHU roster. Which, +that is the reason why you are up there. Why +am I up here? And, you know, +a lot of times, +you go by it, it says - +: It's because you are a fucking +mass murderer, that's why you're up here. +— and, like, you know why +you are locked up. And then, they would say, +well, how come the investigation is taking so +long? And it would depend. If the FBI had it, +if it was an OIG investigation. It would +depend. So, you know, I would usually tell +them, like, you know, it's an outside agency +handling. We are in contact with them. And +somebody will come see. + + +1 +2 +3 +4 +5 +6 +7 +8 +269 +: Some could be up for +administrative, like an incident report. +: So, you went through and +talked to everybody, but were you required to +do that, or is it just because you just were a +good employee? +•: I mean, that's what you +should be doing. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +That's what you should +do. But I mean, like you talked about before, +well, the post orders don't say that. +Well, I don't have post +orders. +Yeah. So, I mean -- +But you are -. But +something does say that you are required to do +it once a week? +•: There's nothing in writing +to tell me you have to do it. But just like I +visit every area, I have to, I visit every area +of the institution. You know, make sure I see +every employee going there on the off shifts. +I would go on the off shifts, you know, to see + + +270 +1 +the staff, but it's - +2 +: It's a surprise. In other +3 +words, you are not telling them you are coming, +4 +you are just going. +5 +: Yeah. I'm coming up. I'm +6 +making my rounds. I'm sitting, talking to +7 +staff. What's your issues? I mean, it's more +8 +the issue of them just work. I mean -. +So, when you say there's +10 +nothing in writing, saying that you should do +11 +it, or is there something in writing saying +12 +these people that didn't do it, that they +13 +should have done it? +14 +_: No. And there could be +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +reasons. Now, they - and this is what I would +get the report and look into - like, there are +people that make the rounds, they come up to +SHU but they forget to sign in. +: So, when I get the report, I +would, you know, talk to the captain, that this +the entrance log, and say, hey, why didn't such +and such make a round? Now, that AW might have +been out that week, and I had this one covering +both. So, they came up with the AW. + + +1 +2 +3 +4 +5 +6 +7 +8 +271 +Now, is there any way to +determine, like, these people that, for +instance, visited on Friday, what time they +visited? Because this is the day that Reyes +was gone. So, it says the captain was in there +on Friday. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Should have he noticed +that Reyes wasn't there? +Not necessarily. If he +didn't go down range. And he could have come +up, and remember, we have Ten South that's +connected. So, I don't know if he came up +there, you know, for an issue for Ten South. +: Mm-hmm. +So, I don't know. And then, +him making his rounds, even if he's making his +rounds, you are going to have empty cells on +the range. +oh, you will? +Well, somebody - +Even if - +- somebody could be at +medical. +Somebody could be on an attorney +visit. + + +1 +2 +3 +4 +5 +6 +7 +8 +272 +So, it wouldn't -- +So -. +-- it wouldn't caused a +red flag, you don't think, if he saw, like, +Epstein's cell empty? +: Well, if empty cell is +empty, the first thing you're saying, he's down +on attorney visit. Because the rounds are made +during the daytime. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +And in that note, would +they say, though, because it says +, and it looks like was there, too - +-- should have those two +people, if they actually did a round, say +Epstein is down there, but where is Reyes? +: I mean, they could have. I +mean, but Reyes could have been in the shower. +You know? I mean -- +But it wouldn't be +something that would be normally asked? +: It was, like, oh -- +Hmm-mm. + + +1 +2 +3 +? +4 +5 +6 +7 +8 +273 +- Epstein, high-profile +guy, where is his cellmate? That wouldn't be - +No. I mean -- +- you're just saying, okay, +Epstein is downstairs, his, you know, or maybe +his cellmate was in attorney visit, it could +have been on a shower day. He could have been +in rec. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +I mean -. +So, you are more +concerned about the people that are there, as +opposed to who weren't there, it sounds like +that? To check in with them. +: That, I mean, you want to +see, making sure you are around, making rounds, +talking to everyone. So, I don't know what, +you know, what the thought process is, or, you +know, if somebody was in the shower or not. +: Mm-hmm. +Sure. No. And I'm not +trying - + + +1 +2 +3 +that. +4 +5 +6 +7 +8 +274 +- to get you to say +: How many days a week can you +take a shower when you're in -? +: The entire of three times. +Monday. Typically, it's Monday, Wednesday, and +Friday. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +And what about this one? +This one is from +to you. Weekly +rounds on August 12th, 2019. Is this -- +The PCU. +- is this -? So, this +is the same thing? +: That's the PCU unit. Wood +sec unit. +The wood sec unit. +: All right. So, this +might be the exact same thing as -. Oh, this +is what I did (Indiscernible *03:14:50). +Sorry. All right. That sounds good. Do you +mind just initialing and dating that? +: Now, we are getting close to +the end. + + +1 +2 +3 +4 +5 +6 +7 +8 +275 +Hmm. +you had two +follow up questions before we move on. Why +don't you ask those? +: If the counts and the rounds +were done -- +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: - as they were supposed to +be done, let's say in the afternoon, by the SHU +C.O.s, would they have caught the fact that +Epstein's cell was empty, and inmate Reyes was +actually not where he was supposed to be? In +terms of that, if he was +: assigned, if Epstein +was required to have a cellmate, and Reyes was +transferred, would they have caught onto the +fact that Epstein needed a cellmate? +: I don't understand what -. +: Let's say Reyes was +transferred, right? +: Mm-hmm. +: If the counts and the rounds +were done, in the afternoon, the 4:00 p.m. +count, the rounds in between, if they were +done, would the SHU C.O.s have caught on to the +fact that Reyes was missing from the cell? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +276 +But they already knew that. +: If the word of mouth -. +: So, the claim is -- +made up that +stuff in the memo. And +never told me that. +says +bullshit, +and he's lying. +That they say that's +The people that he said +were present say the same thing. +He didn't say that. +So, point being is, well, +if +didn't pass that information on, if +they were actually conducting their rounds, +should they have noticed that he wasn't there? +_: Yeah. If they knew that he +didn't -. If they knew, they knew that - +what's his name? - Epstein wasn't supposed to +have a cellmate. So, if you see his cell on +there, that I guess, and on the outside of the + + +277 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +cell, they would have his name and the other +person. Then you should be saying, okay, where +is the cellmate? We know he's not in the +attorney room. +: So. +: I got it. +: So, you know he's down in +the attorney room. So, you would have said, +okay, somebody's got to be in that cell. +: Hmm. Ace bastard. That's a +way to fuck with the other guys. +: Meaning, if they actually did +the rounds and the counts like they were +supposed to, there was more than enough time +for them to turn around and assign another +cellmate, if needed. +: Or to say, of course, to +your point, where they are saying that nobody +ever told them, if you were making your rounds, +you would have saw that there was nobody in +that cell, and then ask you a question, where +he's at. +: And the person whose job it is +to make sure they are doing their rounds is the + + +1 +2 +3 +4 +5 +6 +7 +8 +lieutenant or the captain? +: On the shift, it is the +lieutenant would check. But now, in fairness +to the lieutenant, if you are going off of a +sheet, and the sheet says, hey, you made your +rounds, and then, something like this happens, +then you find out people didn't make their +rounds. +278 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +And I think what +question to you was, does this suggest to you +that they were not actually conducting their +rounds? The fact that Reyes was gone for 24 +hours, and the notifications weren't made? +: It would appear that that is +the appearance. +: (Indiscernible *03:18:07). +: Yeah. I mean. +: I just have one other +question. +: When I do cross examinations, +and it says, it would appear that, yeah, +that's, yeah, somebody found. +: Have you ever heard of C.O.s +pre-filling round sheets? +When he says pre-filling, + + +1 +what he is saying is that, the beginning of +2 +their shift, they are going in and they are +3 +just writing, they are initialing and putting +4 +in the time. At the very beginning, for the +5 +rest of their shift. +279 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: So, let me put it to you +this way. +If I -- +: I saw you smile — +- no, no. +: -- when he asked that. +: Because if I become aware +and know that somebody is doing something like +that, that is reportable misconduct. +I'm going +to report that. So, if somebody came to me and +said, well, this person is pre-filling out +count slips, that would be something that I +would say, okay, you know, I have to do a +referral, or if I don't have enough evidence +for it, I would have a supervisor, you know, +put it out, said, hey, you cannot do pre-count +slips. +So, if we have people +confessing, admitting that they are not only +pre-filling out their count slips, but also +doing it with their round sheets -- + + +1 +2 +3 +4 +5 +6 +7 +8 +280 +- what is your response +to that? How bad of a -? How bad is that? +: Well, that is a referral. I +would have to do a referral for you guys to +look into it. +: And then, if they are +actually pre-filling those out, does that also +suggest to you that they didn't do their counts +of their rounds? +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: Well, I mean, if they're +telling you that we pre-filled it out, it's +obvious that they did not, they are not +counting. +Because if somebody is prefilling out a sheet, that means -- +: They're not counting. +- they have no intention of +counting. +: And does that indicate to +you, as the warden, that they are falsely +certifying rounds and counts that they did not +conduct? +: If they come to you, and + + +281 +1 +2 +3 +4 +5 +6 +7 +8 +they say, hey, we didn't fill out, we haven't +done our count slip, that is an admission of +misconduct. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Right. But a false +certification, as well. Correct? +: Yeah. That is falsifying the +document. I mean, but they have admitted that +to you. But as far as -- +Now, what if you - +me -. +- what if they are +saying - they are a newer employer - and they +are saying, well, we are doing it because we +watched a 20-year guy do it. That's how I +learned. He didn't tell me to do it. But I +watched him do it. +So -- +So, I did that. +- I would -. So, I would +say to you, when did that person come in? +Because anybody that came in under me, you get +the spiel that, hey, I was new, I was an +officer. I know what it is to be new. But I +always, always tell people, you got to know +what's near and dear to you. + + +1 +2 +you specifically - +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +annual training? +I have -- +282 +And that is why I asked +•: Right. +- with +Are +you confident that you gave her that spiel? +: Talk to whoever was in her +class, and you talk to any, any new class that +came through, and they will tell you my spiel. +Okay? You can go into our +annual training, when we have it, talk to +people, and they will tell you about my spiel. +: Do you say that always at +: I cover everything. Because +: Yeah, but do you always say +is, you have to do what you have to do. Don't +do it just because the 20-year-old guy did +that. +I do. I tell people about +doing their job. The same thing when it comes +to use of force. I tell staff all the time. +Use enough force necessary to control the +situation. + + +1 +2 +3 +4 +5 +come in -- +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +283 +But specifically about +not watching the 20-year guy. What is it that +you tell them? +So, what I tell them is, I +: Because it sounds like it +is the same thing you tell them every time. +•: - right. So, what I +basically tell them, I said, you got some good +people that work in the institution. And then, +I had, you got some people with time, that just +want to do what they want to do. And I tell +them, don't follow them around. I said, you've +got one. If you are on probation coming in, +you need to be doing your job. I said, if +someone comes in, and they're not doing their +job, or they're telling you not to do +something, you make sure you let your +supervisor know. +I said, I make rounds, you +can talk to me. +: okay. +: You know? So, the +expectation was clear. But with any other +agency - and I'm not just saying our agency - +there are people that come in and they become + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +followers. +on. +call. +284 +Now, we're going to move +We talked about the phone +On August 9th. What is +your understanding of what transpired with +Epstein being provided a phone call on the +night of August 9th, 2019? +: So, from what I understand, +when you come in, you have to be able to do, +for the monitored calls, the voice analysis and +all that. So, from what I understand +afterwards, Epstein was never available for +that to be done. Because he went down to the +attorney room, and he would come up at night. +So, from what I understand, he was given an +unmonitored call. +: And what do you mean by +an "unmonitored call"? +: An unmonitored call is a +call that is not recorded with the inmate phone +system. + + +1 +2 +3 +4 +5 +6 +7 +8 +285 +: Is it your - +: In other words, they don't +listen to what you say? +Right. They don't. +-- is it your +understanding that anyone physically monitored +the call, or did you -? +: From what I understand, the +individual was standing right there when he +made the call. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +All right. So, it is our +understanding that, "On August 9th, 2019, +Epstein made a request to MCC unit manager, +, to provide him with a phone +call, so that he - Epstein - could call his +mother. +checked Epstein's +pack and PIN, and found out it was not yet set +up. +_ : +: Therefore, +Epstein to a shower area in the SHU, and +plugged a phone into a legal line. +dialed the number. A man answered. +took +He handed + + +286 +1 +2 +3 +4 +5 +6 +7 +8 +the phone to Epstein. And then, +left +for the day. +stayed -". +oh, sorry. +"Then we found out that +the SHU C.O.s were around. +: And +did not +specifically instruct any one of them to +monitor their phone call. Instead, he called +the SHU after he departed from the MCC, to make +sure that the phone was taken away from Epstein +after his allotted time." Had you heard that +before? +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: I have -. What I heard was +he was there and did the monitoring. +: So, your understanding +was there the entire time of +was that, +his call? +That, at the entire time of +his call. +: So, a number of questions +off of that. The fact that +dialed the +number that he gave him, and a man called. A +man answered. Who, he said he was calling his +mother. +A man answered and he gave him the + + +287 +1 +2 +3 +4 +5 +6 +7 +8 +phone. +Is that problematic to you? +: I didn't hear that it was a +-. Who did I -? They said it was his -. +: So, that information might +have come out after. +: It came out after. I didn't +- I heard that after the fact - so, I didn't +hear any specifics, but I heard it was -. I +forgot who they said it was that called, but +then afterwards, they said, whoever they said +it was, was deceased. That he didn't have that +talk. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +I think it was his +mother. +: Yeah. I think it might -. +So, and that, that is what I heard. +: His -- +:Yeah. +: - his mother died during the +time of this investigation. +_ : +Hmm. +1: She was previously deceased. +: Deceased. +: So, wait, wait, wait, wait, +wait. + + +1 +2 +3 +mother. +4 +5 +to his mother. +6 +7 +dead. +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +288 +: So, he calls, looking for his +He said he wanted to talk +: But his mother was already +: And the person who +answered the phone was a male. But he still +gave the phone to Mr. Epstein. Is that +problematic? That he says he wants to talk to +his mother. A man answers. And then gives the +phone to Mr. Epstein. +: Well, remember, I am hearing +this, that it was a call that all along said +I'm calling the mother. I don't know anything +about a man answering the phone. +No, no, no, no, no. I'm +providing this information as in, like, you are +the warden, what is your take on this? Did he +do something wrong there? +: Well, as far as, you know, +you are saying you want to talk to your mother, +and the -- + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +phone. +the phone. +unmonitored line? +isn't recorded? +that it's - +289 +And a man answers the +: - and then, a man answers +the phone. Yeah. It might have been some +questions he should have been asking. +Should have he verified +who it was he was providing -? If he is giving +him an unmonitored call, on an unmonitored +line, should have he verified who it was that +was on that other line? +: Right. If a male picked up +: Why do you know it's an +: Because the legal line +•: Right. +: So, that means unmonitored, +Yeah. That you can't -. +: - it's not recorded. +Correct. +On that note, were there + + +290 +1 +2 +3 +4 +5 +6 +7 +8 +any lines that Mr. +• could have plugged +the phone into, that were monitored, versus if +they didn't have a pack and PIN? +: Not on the ranges, I +believe. I'm not sure. +: No? +I don't think there was +anything on there. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Because, yeah, we had +been told by someone that many, if not most, +BOP facilities have the ability, if a pack and +PIN such as that wasn't set up. There are +lines that you could plug it into, that are +monitored, but at MCC, that wasn't the case -- +-- in SHU? +Not on the ranges. +: You said not on the ranges? +1: Where would it be? +: I'm not sure. I think +religious services might have a line. The +Chaplin. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +speaker phone? +listen. +291 +But not in the SHU? +Not in the SHU. +: Okay. So, not only did +he do that, but he then left the SHU for the +day. Obviously, he was supposed to sit there +and listen to the call. Correct? +Should have he put it on +Either listen to the call, +or if he had somebody else take over the call. +You know, so, somebody +should have been monitoring the call. +Just to stand there and +All right. Now, the fact +that, you know, obviously, +dropped the +ball there. He gave him a call, he just wanted +to talk to his mom, his mom is deceased, and a +male answered. +Second, he didn't stay to +listen to the call. Third, he didn't tell + + +292 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +anybody else to listen to the call. Now, the +fact that the other - he leaves the unit - the +fact that the other people are in the unit, +should have they then, at some point, also +said, like, hey, this guy is on a phone call, +let's go monitor it, or should have that been +something that +Yeah, you couldn't - +- would have directed? +- you couldn't -. But +that's what I'm saying. I don't know the +conversation that took place between them. If +the call was made, and somebody was told to go +monitor it. Did they go over it? Did they not +go over it? +NO. +So, I don't -. +So, MI. +told the +people -- +-- he's on a phone call. +Get it back after - whenever it was - 15 +minutes. +They were giving him an + + +293 +1 +2 +3 +4 +5 +6 +7 +8 +unmonitored call. +: The significance of this is +that, if somebody had monitored the phone call, +they might have found out that he was very +depressed, or he was -? +Well, there is -. Can +you tell us, why is it important for us to know +that what inmates are talking about on their +phone calls? +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +I mean, just for the safety +and the security of the institution. +: Is it true that they +could potentially operate their businesses, +their illegal businesses, from there? +You could. +Or they call a hit on +someone. Or they could, they could do a lot of +different illegal activities, if we are not +monitoring those calls -- +: Right. That's -- +-- that we wouldn't know +: — why we monitor them. +: All right. I have one more +story. + + +1 +2 +3 +4 +5 +6 +7 +8 +294 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Yeah. Right. +: I'm a young lawyer. And I +know it's hard to believe I was ever young. +But I go - I'm supposed to interview a prison - +and I go to the interview, and he says, this +person is the main rat against, and I said, no, +he's not. I said, that person has got no - +fucking nothing to do with it. He don't say +nothing about you. Guy looks at me and says, +oh, man, I better make a phone call. +: So, is it standard +practice to allow inmates to make personal +calls, as +had done? +: You do I, sometimes if they +come in, they don't have a pack number. Like, +you could have a family member that has passed +away, and, you know, you allow them to make a +call under that circumstance. You know, I have +a pack number set up. You know, so, sometimes, +but you should be monitoring that. Sometimes, +you make a call to another agency. And the +inmates, you know, you verify, hey, this is +such and such. But you stay and you listen to +the conversation. +Was there ever an + + +1 +2 +3 +4 +5 +6 +7 +8 +instance that you wouldn't listen to the +conversation? +: On an unmonitored line? +: Mm-hmm. +No. Somebody should be +standing there. +295 +: All right. And what are +your thoughts on this specific matter from what +we just, from what I just told you? +: Like I said, if it's +problematic, if you said, if it's the way you +said it, yeah. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +And is it a serious +concern and safety violation? +: Well, yeah. I mean, it's a +breach. +And why? +Because we don't know what +the conversation was. +Okay. You said -. Okay. +You answered that. These are just on this +note, there is just a couple of these. There +is a phone call. This one says it's from an +Do you know who that is? +Yeah. He's the supervisory + + +1 +attorney. +2 +3 +4 +5 +6 +7 +8 +296 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +So, he is an attorney? +oh, okay. That's the same guy. +Supervisory staff +attorney. It says, "For client Jeffrey +Epstein. Good afternoon. Below, please find +complaints from Epstein's attorneys. Can you +check to see if he has toilet paper, and that +his CPAP is plugged in? I am less concerned +regarding his complaint of having had two +calls, but they were on unmonitored lines. +there is no recording of them. His phone +account is set up, so we could get a call on +the ITS, when 30 days has - +- elapsed. " +So, +So, it looks like this +was actually discussed, and this again, was on +August 6, 2019. Do you know if this was -? It +looks like this was the whole, to the whole +executive staff -- +- team. Was this talked + + +1 +about at all? +2 +3 +4 +5 +6 +7 +8 +297 +: It was sent out, and that's +when, and I don't recall the timeline, I said +he needs to get his stuff set up. Anything -- +: okay. +: - that he needs, needs to +get it set up. So, I believe that was the day +when I sent everybody up there, in the attorney +room area, and said, get his stuff set up. +Now, did you - the +captain, I believe, informed +that he +would give him this call, just make sure it's +monitored. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Prior to that, did the +captain talk to you about this at all? +About what? +: Well, affording this un, +you know, this call on an unmonitored line, but +just making sure it was monitored? +: No? +Hmm-mm. +But what you had said, +make sure his pack and PIN is set up? + + +1 +2 +3 +4 +5 +6 +7 +8 +298 +.. +Yeah. I had to. Because +there was some other things to get set up, and +I said, hey, we got to make sure that we can +get his stuff going. If that's the date, if I +remember, where everyone went up and talked to +him at the, where he was in the attorney room. +Okay. Now, this is one +that's going to be -. Now, did you -. Were +you able to print out that attachment? +: No. That's just our screen. +It's not what they would see. +I was just hoping -. +So, this is one we got. It's something +from +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: And who is that? +That's the communication +guy. +Correct. And he is in +charge of, like, the phones -- +The phones. +: -- the cameras. +Correct? + + +1 +2 +3 +4 +5 +6 +7 +8 +299 +And he's to you, and it +says, +"Phone record 104." +Sent on Saturday, August +10th, 2019, at 3:04 p.m. Now, it has an +attachment here, titled 8.19.19. cap. +That we are unable to +open. Do you know what that would have been? +It appears that it is related to the phone call +that Mr. Epstein made. Do you remember if you +ever received a recording of that phone call? +No. I didn't get any +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +recordings. +: Would it have -- +Nuh-uh. +-- been, maybe, then, the +number that he dialed? +•: I think it might -. And it +might have been the number. I'm not sure. I +can't -. I don't recall. +What that is. +Mr. +Do you remember asking +to provide you with any specific + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +initialing - +that . cap was. +300 +information with regards to the call? +: We might have called him +about the line, and what was the number that +was called. +: And could they have pulled +it up. So, we might have asked him that. +: But it definitely wasn't +an actual recording on the phone? +No. It was -- +- I think it might have +been the number that, you know, I think wanting +to pass on to the FBI. +Great. +Uh-huh. +Do you mind just +: Mm-hmm. +- and dating that? +I just didn't know what +So, we didn't know, oh my + + +301 +1 +2 +3 +4 +5 +6 +7 +8 +gosh, do we have a recording of this thing? +1: The second one, too. +_: okay. +: All right. Now, we are +going to get into the actual incident. +: oh my God. Now, +(Indiscernible *03:34:06) getting ready to get +into. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +We don't have much more. +I promise. I mean, we are way passed the - +: Yeah. +- yeah. What is your +understanding of what occurred in Epstein's +cell on August 10th, 2019? +I don't know. +You don't know? +I didn't go up there. +: Do you -. +I never saw the cell. +Do you believe if -. Do +you know if Epstein took his own life? +: That's what I've been told. +Is that your +understanding of what happened? +That was what was conveyed + + +1 +to me. +2 +3 +4 +5 +6 +7 +8 +302 +Do you have any +information, with regard to anyone else taking +Epstein's life? +: No. +: No. Have you heard that +Epstein's cell door was left opened on the +night of August 9th, 2019, and/or the morning +of August 10th, 2019? +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +I didn't hear that. +You have never heard +that? +Have you heard that any +cellmate's in the SHU - any cells within the +SHU, any of their doors were left opened on the +night of August 9th, 2019 in the morning? +I did not hear that. +On August 9th. No? +Hmm-mm. +Do you know if anyone +harmed Epstein? +: No. I would have reported +All right. So, these are + + +303 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +the - let's see - this is the Bureau of Prisons +Health Services Clinical Encounter. +Did you get to review +this one at all? +It talks about responding +to a body alarm at 6:35 for medical emergency. +_: I think I might have saw the +memorandums, but I don't -. I don't recall +seeing this. +All right. So, let me +just read this, for the record -- +- because it is a very +quick one. It says, "Responded to a body alarm +at 6:35 for a medical emergency on Nine South. +Upon arrival, inmate was received on the floor +of his cell, unresponsive, with CPR in progress +by correctional officers. The inmate was cold +with circumferential bruising around the neck +and posterior mottling. +Pupils fixed and +dilated. No palpus (Phonetic Sp. *03:35:59) +pulses, call place for EMS, CPR continued. +ED placed. No shock advised. +CPR + + +304 +1 +2 +3 +4 +5 +6 +7 +8 +continued. Inmate transported to HSU treatment +room, with CPR in progress. 18G, heplock +(Phonetic Sp. *03:36:12)." No. I'm not going +to read the rest of this. It just talks about +continued CPR in progress. Are you aware, +after Epstein was found on August 10th, 2019, +at approximately 6:33 a.m., did he ever show +any signs of life? +: I never -. I wasn't up +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +there. +Yeah. I just didn't know +if you had heard -- +No. When I -- +-- (Indiscernible +*03:36:34). +- when I got there, he was +already out. +Because they said that, +you know, he was declared deceased at the +hospital. So, my question is, it sounds like, +from this person's report -- +: Yeah. +-- he was -- +-- there was no signs of + + +1 +life. +2 +3 +4 +5 +6 +7 +8 +305 +And that's -- +: And I was just wondering, +had you heard anything from staff? Was there +ever any signs of life, that you are aware of, +while after - from the point he was found, on. +: Well, the impression that I +was given was, he was alive when he left the +institution. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +So, you believed he was +actually alive? +That's what was conveyed. +It was conveyed to you +that -? +: I think he was still alive, +if I remember right. I think he was -. They +did the CPR. And then, they got him out. +: And who -. So, according +to this, again, this person arrived at 6:35 -- +- they're saying the +inmate was cold. You know, "Pupils fixed and +dilated. No palpus pulses." Meaning, I'm +assuming, that means no pulse. You know? +So, you would probably have + + +306 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +to look at the response, the staff responding +memorandums on what -. +: So, up until this date, +did you think that he was alive when he had +left the institution? +: That's what I believed. +That was the impression I had. +: Can I ask a question? Right. +If he was dead when they came, and somebody +found him, or even if he was close to death, +how long would it have been that he tried to +kill himself, and the time that they found him? +In other words, does +that mean he tried to kill +himself 45 minutes before? Does that mean he +tried to kill himself 30 minutes before? You +understand the question I'm asking? +: Sure. I mean, that is +something that the medical examiner, you know, +makes that determination. +: Because obviously, if he was, +had done whatever he did, during the time that +there was supposed to be a round, and somebody +fucked up, you know what I mean? If you are +there, with a towel around your throat, that's +a hint that you are not exactly in the best of + + +1 +moods. +2 +3 +4 +5 +6 +7 +8 +307 +: But the other thing is, you +know, I don't know, like you just said, the +medical examiner determines, you know, if he's +alive or -. +Well, and that was going +to become my follow up. First of all, who - +this person. It says provider, Joseph Columbo, +RN. Is that someone who worked at -? +He was one of the nurses +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +that worked. +: Mm-hmm. +All right. And is it +your understanding, by saying provider, this is +the person who wrote this report? +: Yeah. Typically, who has +the encounter fills it, writes it in the +system. +Okay. So, up until me +reading these out, you actually were under the +assumption that he was alive? +When he left. +I thought he was alive. + + +1 +2 +3 +4 +5 +6 +7 +8 +308 +Yeah. That was my assumption. +Okay. Does that have +anything to do with the fact that the medical +examiner is the only one who can declare him +dead? +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +It does, too. +: All right. And also -- +- I have heard that +inmates don't die at prisons. +: Well, I mean, people say +that, but again, in reality, we - no one in the +prison can declare an inmate dead. +Right, right, right. +Even if -. +But is that what you mean +by that statement, though? Did you -. I mean, +had you heard that he showed signs from life? +From what -- +Because we have heard +this -- +-- from -- +- type of thing -- +-- yeah, from what I -- +-- before. + + +1 +2 +3 +4 +5 +6 +7 +8 +309 +- hear, they were still +performing life-saving measures on him, even +when, from - what do you call it? - EMS coming +in there. So, when you say to me that we are +performing life-saving measures, I'm assuming +that he is still alive. +: Right. Like, there is -- +so - . +- always a chance you +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +could bring him back. +That, you know - +Or you are hoping that +you are going to resuscitate him. But do you +know of any indication of -- +: That he was successful -- +- signs of life? +: -- yeah. +: I didn't. Again, I'm going +off of, assuming that he was still alive +because they were still working on him. +: okay. +: So, and if somebody start, +now, I've been in situations where the +paramedics come in, and, you know, they work on +them, and they say, you know what? There is + + +310 +1 +2 +3 +4 +5 +6 +7 +8 +nothing else we can do. He still hasn't been +declared dead. +Sure. +But they still -. +: But from what I gather, they +were still working on them. +: When you say nobody dies in +prison, you are being facetious? +It's just one of those +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +things that -- +: Yeah. It doesn't -. +- it happens at the - +: Yeah. +- at the hospital. +: Yeah. +That's where they are +declared dead. +: Yeah. +: And that's not, you know, +necessarily true. I mean, it's where you are - +like, sometimes -- + + +1 +2 +3 +4 +5 +6 +7 +8 +311 +It's sort of a joke. +-- yeah. +: To (Indiscernible *03:40:46). +: It's a joke. Because +sometimes, the bodies are still there, and -- +-- and we know he is +deceased. But then, the doctor and the medical +examiner -- +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: Yeah. +-- declares -- +: At the hospital -- +-- (Indiscernible +*03:40:57). +: -- (Indiscernible *03:40:57) +: The guy's got a big +(Indiscernible *03:41:00), you know -- +Uh-huh. +: - whatever they call them, +knives in his chest. +: You know, you can tell he's +not coming back, but I mean, you know what I'm +saying, +(Indiscernible *03:41:04). + + +1 +2 +3 +4 +5 +6 +7 +8 +312 +Uh-huh. +But just, I just want to +be clear, because with that statement, without +me getting a little more clarification, people +are going to read, wait a second, the warden +said that he was still, he thought he was still +alive. Now, I want to make sure I'm clear. +Are you saying that there was a chance for them +to bring him back, or based upon the +conversation with someone - and my follow would +be that, who? - did you believe that he was +still alive? +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +My assumption, from when I +was called, was they were working on him, and +he was - they were being taken to the hospital. +: That's -- +: That was -- +-- that's the term. +: - that -. Wait. You were +called at a certain time. +When the lieutenant +called. +: Okay. Now, the lieutenant +says -. + + +1 +2 +3 +4 +5 +6 +7 +8 +313 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: So, when you came back +and found out, did you ever find out that he +wasn't showing signs of life, when you came in +and talked to people? +: No. Because I - first of +all, when it happened, I wasn't going around +questioning people about -- +: — okay, what's going on +with this, because then, I knew that it was a +criminal case. But not criminal, but there was +going to be an investigation into it. And so, +I didn't want to give the appearance of +anything, that I was interfering with any +investigation. But when I did call, they said +they were working on him, and that, you know, +he was being transported to the outside +hospital. +And who was it that +provided you with that information? +: The lieutenant. Lieutenant +: So, you drew the inference +that that +Uh-huh. + + +314 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: - meant he was still alive? +: Right. I assumed that, you +know, they were still working on him, and he +was still alive. +And after that +conversation, though, and speaking with other +people, you never gathered that, oh, he was, +they were working on him, attempting to bring +him back, but he was not alive? +I didn't -. +From -. +The assumption, my +assumption, was that he was deceased at the +hospital. +Yeah. So. +All right. Do you want +to follow up on that at all, anymore? +MR. A No. +]: +: That kind of covers it. +: Are we through now? + + +1 +2 +3 +4 +5 +6 +7 +8 +315 +oh, god. +We only have, really, +very brief conversations left. All right. So, +this was an email sent from you, to +It just says, subject, "Names." +: It says +and +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Who were -? Why were +those people listed? +: Because he wanted to know +who was working up there that night. +: okay. +Who was the staff working +there that night. +So, why did you write +versus, like, +, or who else was +up there? Was Shack (Phonetic Sp. *03:43:25) +still there? +1: No. +Was +: At least +and +left off for any reason? + + +316 +1 +2 +3 +4 +5 +6 +7 +8 +Because I think L +worked -- +I think this -- +: - until midnight, and +only worked until 10:00. +: No. For - and I don't - +correct me if I'm wrong - I don't know if he +wanted to know who was on the midnight shift. +And then, I included who was on Ten South. I'm +not sure. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +I think +was +the OIC of the shift previous. And then, just +would have -- +-- and +were the ones +from -- +- been two up there. +-- midnight afterwards. +And then -. +1 I think that Ten South was +: Yeah. So, I don't know, +remember it. But I know it had to do with the +question about who was working. + + +1 +2 +3 +4 +5 +6 +7 +8 +317 +So, I don't know the +specifics and why it listed those three. +: And you don't know if, +like, because these were, who we considered the +subjects. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: No. I mean, these two would +have been obvious because they were working up +there on the midnight shift. But I don't know +why +got thrown in there. +Mind just initial and +dating that? +Okay. And this one is an email +from Captain +to you, dated Sunday, +August 11, 2019. And it says, subject, "A +memorandum, Epstein." +And it says that this was +dated August 10th, 2019. +It's from Captain +It says, subject is, "Security expectations +involving inmate Epstein, Jeffrey." +Are you familiar with + + +318 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +this? Did you ever see this, that he sent? +I did. +: Do you know what the +purpose of this was? +Let me read it again. +"(Indiscernible *03:44:56), and while this +could be conducted, I did, I informed staff +(Indiscernible *03:44:59) be dealing with +inmate Epstein, and others were notified. I +explained that lieutenants were to conduct +(Indiscernible *03:45:08), and at that point, +(Indiscernible *03:45:09). I explained I +could, and they would not (Indiscernible +*03:45:15)." Oh, no. I just was asking him +when the thing happened, what is the guidance +he provided? +So, what did he provide +to, like, the SHU staff and the lieutenant? +Because -- +-- at least the last +little point on this first page - +- so, it says, "In +detailed conversations with the SHU lieutenant, + + +1 +he was informed of my expectations regarding +2 +the supervision of inmate Epstein, +319 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +specifically, he was reminded on several +occasions that inmate Epstein was to be housed +with a cellmate." +So, is this all, like, +the expectations surrounding -- +The expectations. +: - Epstein? +Right. Mm-hmm. +And when he says, "During +the week of July 31st, 2019, in order to +address management concerns with inmate +Epstein," do you know what he is talking about +there? With management concerns. +: The housing of them. And in +the Special Housing Unit. +okay. And do you know +if, according to this, it looks like he is +saying that he did perform an informal training +sessions with staff. Do you know if he, in +fact, did that, or is it just based upon -- +Just based upon -- +- what he wrote here? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +you? +that. +320 +- on what he sent out. +Okay. So, there is no +other information, aside from what he's telling +: Right. Yeah. He told me +So, this one is - I want +to get your take on this matter - so, this is +back to +who was relieved +at 5:30, but she stayed at the institution at +least until 9:30, and sent out that email, +detailing, you know, what day, and the +lieutenant's 1og, and the daily activity log. +So, Captain +sent her an email on +8/12/2019, stating, "Lieutenant +1, I am +reminding you to submit your supervisory +memorandum for the inmate Epstein incident that +occurred on 8/10/2019. +Please have it complete and ready for +submission on 8/13/2019." +She responded with +no, addressing nothing, just saying, just +responded simply, "In your email, you state, +quote, I am reminding you.' End quote. I +haven't spoken to you or anyone else regarding +the incident involving inmate Epstein or + + +321 +1 +2 +3 +4 +5 +6 +7 +8 +anything else pertaining to August 10th, 2019. +So, how is it possible for you to be reminding +me? Second, I have been properly relieved, +prior to the incident involving inmate +Epstein." What is your take on that email? +: First of all, any major +incident that takes place in the institution, +we have to do what is called a report of +incident. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Sure. +: He is well within the scope +of his employment, asking, okay, where is your, +where is -. And I don't know if he was asking +her the overall memorandum. Like, you are the +shift lieutenant. You know, when this incident +took place. So, technically, you should have +been doing the packet. So, he is probably +contacting her for that. +Well, she was relieved at +5:30 a.m., but she was still there, and the +incident happened at 6:30. And again, she aws +there at least until 9:30. And she did respond +to the SHU afterwards, helping with the +feeding. Should have she written a memorandum? +Yes. + + +1 +2 +3 +4 +5 +6 +7 +8 +322 +Yes? +I mean, she said she +responded to the incident? +: She didn't respond to the +incident. She responded after the incident, to +help in the SHU with feeding and dealing with +the inmates. +: So, she - Well -. +: So, somebody told her that the +fucking guy hung himself, should she have -. +Right? +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +_: Again, from what I gather, I +am under the impression, when the lieutenant +relieved her, she was gone. Because, and, you +know, and I can't speculate on what was there. +So, if we -. +She said she stuck +around, working on matters that she needed to +catch up on. +Okay. So -- +But it sounds like +manipulating those numbers on the counts and +stuff. +Right? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +- +point. +323 +So, let me ask you this +question. I have, I have a medical emergency. +A suicide, right? That is an emergency +everyone in the institution has to respond to. +Why didn't you respond to it? +: So, you think that she +maybe came back after? +It doesn't make sense to say +: Well, she never sent out +her required logs, though. +_: Right. So, that, but -- +: So, you reviewed her +emails. And I would think that she would have +sent that out, if she had left, I would think +she would have sent that out before she left. +Right? As required. +: Right. So, did you leave +and come back? I mean, because if you are +saying that you were there, you would have been +one of the first responders up to the unit. +: Yeah, +For the emergency. +That's a really good + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +fishy. +of that. +- +and say - +324 +You know? +: In other words -- +: I wish we had -- +: - they're saying it sounds +- I wish we had thought +I mean, so, and then, if you +And if she didn't, why? +- and if you didn't +respond, why didn't you respond? +If she -. Is it a claim +at all, I had been relieved, I wasn't +technically working? +: If you are in the building, +you have to respond. +: Is that right? +It's an emergency. +I mean, as a lieutenant -- +- I would want to respond, +And so, the fact that she + + +325 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +states that she was there, and she was working +on her administrative responsibilities -- +- so, is that a problem, +then, as the warden? What do you mean you are +working on the administrative? You should have +responded to that emergency. +: No. But - and I don't want +to speculate on when you are there - but I +just, there is just some questions -- +: Wait, and I think - +- they just don't -- +: -- that is a yes or a no -- +* - you know, question. +: Yeah. I mean, it's a +problem. If you are saying I am working on it, +okay. Now, at what point did you say, okay, I +need to, because once they had said, hey, I +have a suicide or something going on, which is +probably over, you know, +a real medical +emergency, and you hear the transmission on the +radio, you are going to go up there. +So then, +you say, oh, I went up there later, to help +with the feeding. Either way, you were in the + + +326 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +building. The captain is asking you, it +happened on your shift, you are responsible for +conducting the report of incident. +: So, that answer is yes, +she should have written a memorandum? +: She should have written one. +I don't understand why she didn't, you know? +: And is that at all - +reading how she responded - is that +insubordination at all, to you? +•: Listen. I will put it this +way. I can't speak on other supervisors or how +they tolerate, but if you had given me a +memorandum like this, we would be having a +conversation. You know? +: Is that, at the very +least, inappropriate -- +_: I think -- +-- I think it's +inappropriate. I mean, that's the way —- +I mean, I read it. I +thought it was inappropriate. +-- yeah. +I just didn't know how -- +I would have gone to have a + + +1 +2 +3 +4 +5 +6 +7 +8 +conversation, like, you know, first, are you +all right? And then, secondly, what is this? +But yeah. +Fair enough. +: Okay, listen, one last +question. +327 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Sure. +: Does that give the implication +that she is covering up for somebody, or she +just didn't do her job? +: I don't know. +: We don't know. That's -. +Had you heard anything about her covering up +for someone? Because -. +: I haven't heard anything, +but, you know - +: Did you hear about +inmates saying that she was making statements +that she was going to cover for other people? +: Again, I don't want to make +any statements -- +No, no, I'm asking you - +- that are not factual. +(Indiscernible *03:51:56). +-- did you ever hear -? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +328 +No, I didn't hear anything. +: I would hate to -- +: You never heard it. +: -- I would hate to give my own +client a hard time. +: But, but it sounds to me like +she's got three hours where she knows this guy +is dead. +: You know? And she don't say +much. I mean, you know, if I was him, I would +be drawing an inference, saying, what the fuck +is going on? Excuse my language, by the way. +I have a filthy mouth. +: No. I mean, I understand +what you are saying, but you know, I'm just, my +point of view is - and my concern - is - +: Yup. +-- if you were there -- +: Your concern is, you would +have asked, unlike myself, you would have asked +her a question first -- + + +1 +2 +which is -- +3 +4 +5 +6 +7 +8 +329 +: - rather than jumping into, +: Because I was -- +: - which is what I did. +-- under the impression, +because when Lieutenant +called me, he was +the operations lieutenant, and he had relieved +her. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +She had gone home already. +wel1, he had certainly +relieved her, but -- +- according to her, she +hadn't gone home. +Do you mind just +initialing and dating that? +1: Maybe you asked this +question. And I just want to clarify. Being +that she started this shift 10:00 p.m. the +night before, right? +: Let's say this incident did + + +330 +1 +happen. We're not saying she did. We don't +2 +know. If she went in and she altered the +3 +lieutenant logs, for the previous shift, did +4 +she do something wrong? +5 +well, and again, we are +6 +knowing, though, that she started at 10:00 p.m. +7 +So, that is still her shift. +8 +: Yeah. But - +We've had this +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +conversation -- +: —- no, no, but -- +: -- before. +1: -- let's just say, you know, +the fact that the inmate wasn't moved until +midnight, and then the clarification, and the +count, the count numbers being changed in +there. Now, so, the lieutenant 1og count +numbers are accurate, except the count, the +actual count slips, were completely off. +So, +somewhere along the way, someone altered those +numbers to -- +Well -- +: -- correct it. +- the lieutenant is +required to take a count on each shift. So -- + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +count -- +SHU count. +331 +So, +see, wait. +- you got the - +: - the lieutenant is supposed +to take in a count. Right? +: Right. Just to take one +: He's supposed to -- +-- on shift. +An institutional count. +Institutional count. +Not a physical, in the +: Okay. So, now —- +: But now, if you +(Indiscernible *03:53:53). +: —- I got to shut up. +_: Yeah. Go ahead. +: He's supposed to take a count. +: Right? And he's supposed to +enter the count. +: Right? Okay. And there was a +count entered, right? And there is no question + + +332 +1 +2 +3 +4 +5 +6 +7 +8 +that, at +some point, the count was altered? +1: The count was wrong. +: The count was wrong. +: Okay. Okay. +Well, no -- +: Yeah. (Indiscernible +*03:54:14) -- +- what he's saying is it +was altered. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: -- (Indiscernible *03:54:15) . +: I'm talking about the numbers +- +So, if you recall - +1: +- on the paperwork. +- on August 9th, 2019, +the lieutenant's log says, at midnight, there +was 72 in the SHU. The count slip says 73. +And the lieutenant's log +for the next day at midnight says there was 73. +_ : +: So, what Agent +is +asking is, well, that obviously goes to show +that she went back and changed those numbers to +12, because -- + + +1 +2 +3 +4 +5 +6 +7 +8 +333 +: But what is her motive -- +- that midnight -- +: - to do that? +: - she says she was just +trying to make things accurate. +: But what would be an ulterior +motive that would create the idea that she was +doing something wrong? +It goes back to when you +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +asked -- +: Mm-hmm. +: -- is there something to +do with a cover up? +: So, if - and granted, +mistakes are made in the log - but you also +annotate that in the log. Like, you will put, +okay, late entry. Because typically, if you +say the log is done already, when you go back +and make changes, you make changes for this +reason alone. An investigator comes in, 1o0ks +at it, and says, well, wait a minute, it 1o0ks +like you've been playing, you went back and +just changed the numbers. So, you can put in +there, and you say, okay, late entry, explain +what your change was, and what the mistake was. + + +1 +2 +3 +4 +5 +6 +7 +8 +334 +So, really, with this - +_: You know? +: -- to show a malicious intent +in her part, there's got to be something that +influences her to protect one of the people +that were - no question - were fucking around. +Right? The two guys that were fucking around +ended up getting pinched. Right? So, if one +of them is her friend, then she's got a +malicious motive to go try and cover for that +guy. Like, did $8,000 (Indiscernible +*03:55:58) police officer, he says, well, I +thought he drew a gun on me. +• And I shot him. +: Yeah. +: Oh, okay. Nobody else saw +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +that. +: Yeah. +But you are not aware of +her involvement at all, you said, or - +As far as what? +- covering up for them, +or involvement in Epstein's death? +No. She wouldn't have had + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +that? +335 +that conversation with them. +: And you weren't - until +now, it sounds like - even aware that she was +at the institution after 5:30 a.m.? +I was told she left. +And again, who told you +The operations lieutenant. +Because he called me and he says, hey, I +relieved -- +Sorry. +Okay. And did you have - +before we move on to the next subject - do you +have any more on that? +1: No. +: So now, we are going to +talk about the cameras. +Were the SHU cameras +recording on August 9th and 10th of 2019? + + +1 +2 +3 +4 +5 +6 +7 +8 +were not recording? +conversation. +336 +I didn't physically go check +to see if they were, were recording or not. +: Did you learn that they +: Yeah. We found out +afterwards, that they weren't recording. +: Wait. Wait. We had this +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: The cameras don't work in a +lot of these institutions. Right? +: Yeah. Yeah. +: All right. And that's because +they didn't spend the fucking money to make +sure the cameras work. +Well, it's - +: And I got to stop saying +"fuck." +- that's the issue, too, +funding, and, you know, so, since that +incident, I guess there was some audits done by +the agency, and they realized that it was kind +of a system (Indiscernible *03:57:15) . +: But you see, the issue is, +should you have checked why weren't the cameras + + +1 +working? +2 +3 +4 +5 +6 +7 +8 +337 +Well, that's my question +is, do you know why they were not working? +: I don't know the specific +language that was used, and what was wrong with +it, because I guess, after I left, they kind of +made a determination on what was why -. What +was the reason. I know we were going through +the process of auditing and fixing some +cameras. But those specific SHU cameras, I +wasn't aware of the extent. +Okay. Let's just really +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +quickly review - +-- the SHU camera +documentation. Were you ever provided any +documents of a camera that actually was working +in the SHU? +You mean, the day of the +Epstein thing? +Right, right. At any +time. +I don't recall. +So, were you provided +with this? This is right outside of -- + + +1 +2 +3 +4 +5 +6 +7 +8 +338 +This was a -- +- Ten South. +- that says camera angle +out of Ten South. +Right. Were you ever +provided with that, as far as -- +It looks -- +-- I think from -- +- it looks familiar, but I +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +don't -- +- from +- he might have. +Okay. But you don't +remember specifically? +Yeah. I don't specific. +Okay. And then, just +while we are here, I guess, what are these +doors right to the right of this picture? +This door goes into Ten +South. +: And then, this one, I think +is a utility room door. I'm not sure. +Okay. So, the door that +says +"46" goes into Ten South? + + +1 +2 +3 +4 +5 +6 +at down here? +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +here? +what -. +339 +That looks like the Ten +South door. Oh, wait, wait. Yeah. The phone +is -. Yeah. That is Ten South. It looks like +Ten South. +And what are we looking +So, this is the, right here +is the officer's station area. +And do you - based upon +that - do you know what tier that would be +right there? +Oh, man. You got +(Indiscernible *03:59:02) stopped. Let me see. +Is that G and H tier, I think, if I remember. +And what would be right +to the right of the officer's station? +Oh. wait. G. H. I. J. +A. I don't remember if that was I and J. That +Would this be I tier up +Yeah. I and M tier. That's +So, right up, right to +the right of the officer's station, looking at + + +340 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +this picture - +that where Epstein was housed? +- would be I. And is +I believe he was on the L +tier. +Okay. Do you mind just +initialing and dating that? +So, here is a map that we +were previously provided. Does this look like, +then -? So, this is where we were that this +camera angle is focusing down here on the +officer's station. This is I tier. +On the second level. +And this is where Epstein +would have been housed. +Does that look right? +That looks right. +Okay. Is this I tier +here? +That's I tier. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +scene tape. +been recording? +341 +Does this look like what +would have been Epstein's door? I know you +can't really see because of the police +crossings -- +: — on it. +I noticed it. The crime +Okay. Do you have any +reason to believe that that wouldn't be +Epstein's door? +What do you mean? +: As far as, I know we +can't see the number -- +: Yeah. I don't know the +number, but I'm taking your word for it, that +that is. +okay. Now, if you see, +this is I tier range. And at the very end, you +see this camera. +Should that camera have +Yes. +Okay. And is that a + + +342 +1 +2 +3 +4 +5 +6 +7 +8 +camera that I'm actually looking at right +there? +: That is a camera. +: Was that camera recording? +: Sir, do you know if the +camera was recording? +: I didn't see. After I left, +I guess they said there were camera issues, but +I don't know what, I wasn't provided +information on what specific cameras were +working or not. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +So, they didn't tell you +if they were working or not? +: Well, remember, I was +removed. +: I just didn't know if you +found out on the 10th or 11th. +: No. I was removed on the, +you know, they said there were some camera +issues, and then, what they were doing, they +had the FBI came in, and took hard drives, and +I guess they were working to see what was +working and what wasn't working? +1: Can you initial and date +that? + + +1 +2 +3 +4 +5 +6 +7 +8 +it. I'm - +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +was received. +Who's +343 +I'm not going to get into +this since he wasn't aware that they weren't +recording. +MR. I +_: Mm-hmm. +: Boy, I'm impressed by your +thoroughness, I'll tell you that much. +That's why they put me on +: You're very thorough? +: -- yes. +: You know, if you, if you are a +good trial lawyer, you know, allegedly a good +trial lawyer, a lot of times, you are not +supposed to be thorough. You are supposed to +put an idea in the jury's head, right? Where +you can see they're invulnerable, stay on that +fucking idea, because if you are going to be +thorough, you have to bring out something that +you don't want to bring out. You know, so you +to speak to the things, but you know you got +them. +So, this is an email that + + +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +344 +He's the facilities manager. +Okay. So, is this what I +wanted to show you? Hold on. Now, did you +print out the one that I sent you this morning? +: Is that -. That should be +the last thing on the -. +Okay. I'm not going to +get into those. So, you weren't aware that the +cameras were not - or you are not aware if the +cameras were or were not recording -- +We had camera -- +-- in the SHU? +- no. We had camera issues +throughout the institution. +So, I don't know which +specific one, because we had Mr. +working +on a project, to get some money for it. +: But when it came to that +specific night, I didn't know if they were +working or not. +: Were you ever told that, +either on August 8th or August 9th, that the +cameras were not recording in the SHU? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +afterwards -- +he is found. +cameras. +345 +I heard - yes - I was told +that there were some issues with the cameras -- +: On either the 8th or the +9th, prior to Epstein? +-- no. I'm talking about +Yeah, yeah, no - +- when it happened. +-- I'm saying -. So -- +- August 10th is the day +: On August 9th or August +8th, even, leading up to Epstein being found, +were you ever informed that cameras were not +recording? +No. I wasn't told about +All right. So, based on +our investigation, we learned that MCC, SIS +Lieutenant Doctor -- +-- and that AW + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +346 +: - became aware on August +8th, 2019, that at least some of the MCC +cameras were not recording. They contacted +comtech +notified Captain | +and may have also +• Did you ever +hear anything about that? +•: I knew prior that there was +some cameras in the institution that needed to +be fixed, but not specifically the SHU, no. +: Yeah. +: And would have that been +based upon what they found? The AW +and +SIS Lieutenant Doctor? +: No. Because we had had some +issues with cameras, and we were trying to seek +funding. So, and we were trying to see, okay, +what was working and what to get fixed. But +specifically, in SHU, no. +All right. So, only +because, you said that you were trying to get +funded. Did you know that there were already +cameras at the institution, and that's what +they were able to replace when the FBI took the +cameras on the 10th, they were able to + + +347 +1 +2 +3 +4 +5 +6 +7 +8 +immediately replace them with the cameras that +were onsite? +: So, cameras all -. +Institutions always have, like, backup cameras +to fix what is there. But I was talking about +funding to replace the whole system. +So, this was from fiscal +year 2018 -- +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: -- back in September. +This is a memorandum for +you, from a Jeff Colton, acting facilities +manager. +: And these are all the +different documents that go with it, regarding +a new camera system that was purchased. +It was, it looks like +there was $800,000. +For this total. These +are all the documents that - here you go - this +is an approval of your September 11th, 2018 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +request. +looks like a +*04:05:31). +for administration. +348 +So, this is a memorandum for -- +from, it +_ (Phonetic Sp. +: The assistant director +It says, request to +exceed the spending limit of $50,000 on a work +request number 8158, replace camera system at +MCC New York. This work request is to replace +the current degraded camera system. The total +cost of this work is not to exceed $800,000." +Then, at the bottom, it +says, "If you have any questions, please call +me or have your staff contact," and how do you +say that name? Do you know? Ponchiano +(Phonetic Sp. *04:05:57)? +Ponchiano. +Rangle the Third +(Phonetic Sp. *04:06:00). +Chief facility +manager branch." + + +1 +2 +3 +4 +5 +6 +7 +8 +349 +And it says, "At the +phone number." And then, here are the, you +know, the work orders for that. So, we have +spoken with SigNet, who was the camera provider +- they said that on or +around October or November of 2018, they were +delivered. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +And then, talking with +the (Indiscernible +*04:06:22) - +- city manager, he said +that they started working on the infrastructure +of the camera project on or around March 2019. +_: Mm-hmm. +Io get everything ready +for the new camera system that was onsite to be +installed, and said that -. +: They had to run wires. But +the old system was there. +So, they had to run +wires. And they had to get a contract done. + + +1 +2 +3 +4 +5 +6 +7 +8 +350 +: Uh-huh. +: In order, because you needed +the contechs, and I forget the wording that +they used, is to run the cables, to get the new +camera system in. So. +: And do you know how long +that typically takes to run the new wires and +all that? +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: You would have to have the +staff (Indiscernible *04:06:58). +We didn't +have the staffing. +: So, were there two people +TDY" d, though, in order to do that? +: They started IDY' ing people +in, to come in. +: Wait a minute. Can the staff +run the new wires, or you have to get an +electrician to run the wires? +We have staff that are +qualified to do it, but then, some of them were +new and really didn't know how to do it. So -- +: okay. +- you know, it was -. +so, according to Mr. +it says, "The camera system was + + +1 +2 +3 +4 +5 +6 +7 +8 +scheduled to start March 17th, 2019, and it +started on schedule. When I arrived IDY +February 2019, we only had one communication +technician -- +351 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: - therefore, after +talking to the regional office, they started a +project to assist in funding and labor. So, we +were able to start the week of March 17th, 2019 +for the camera system, and all other +infrastructure throughout the institution. +: St. Patrick's Day. +Below is the email sent +to all the institution from +Bond +(Phonetic Sp. *04:07:49), the northeast +regional -- +-- facilities +administrator." But point being, it looks like +that project had started. Correct? +: It has started, but —- +: And I only say that +because I wanted to make sure you weren't +confused, because you were saying we were + + +352 +1 +2 +3 +4 +5 +6 +7 +8 +looking for funding. +: No. No. I misspoke. What +I'm saying is, I meant that the project +started, but the cameras hadn't been replaced. +Because they were still running wires for the, +to get the new system started. +So, that unit still had the +old cameras. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: Right. But then, the +camera system was actually onsite, and they +were working on it? +well, yeah, but they weren't +- you didn't have enough staff to install, to, +you know, to rewire the whole place, because we +had, we wanted to put one, some on the ranges +that never had cameras. +: Mm-hmm. +So, it was a tedious +project. +I see. +That required us to TDY +staff from other institutions. And then, you +know -. +And were you kept + + +353 +1 +2 +3 +4 +5 +6 +7 +8 +apprise of where they were on that? On the +camera project. +: I would acquire about it, +like, where we were with it. But we were to +the point where we were bringing people in from +other institutions. To get it done. +: Okay. And do you know +when the camera system was scheduled to +actually be installed, or was it ever +scheduled? +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: From - and if I remember +right - it was a matter of before you even +installed it, you had to run the wiring for it. +Right. And that's what - +- +(Indiscernible *04:09:13). +-- I think was -- +- what they were saying +in March of 2019. +But that had -- +: That -. +- been completed. Because +you had to TDY people there. And to get it +done. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +354 +And they never provided +you with an update as far as, like, when it +would actually be completed? +It was +still ongoing. +Now -- +(Indiscernible *04:09:27). +: - but after I left, they +got people in there and completed it. +Yeah. Yeah. +Because I +think, I think that whole week, they were able +to complete the whole thing. Correct? +I don't know when. +You don't know? +: You know, because they had +people come in from different institutions. +Now, is that, did they +ever, did the facilities manager, Captain +Whomever, ever explain to you how bad the +system was, and that it kept on shutting down, +and stopping, you know, cameras weren't +recording? +: I mean, we would have +incidents where, you know, something would +happen, and we tried to go back and find the + + +355 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +tape, and we couldn't. So, and it would break +down, they would fix it. So, I mean, we did +have issues like that before. But it was the +age of the cameras. The -- +: - you know, we had +infrastructure issues. So. +Because, yeah, the +comtech claims that, you know, like, he had +been, I mean, he's a very soft-spoken person, +but like, basically, screaming at the top of +his lungs as much as a very soft-spoken person +can, we need to fix these things, this is a +continual problem. +: So, here is what it is. We +don't have money readily available at an +institution to fix it. That money comes from +what we call buildings and funds. +: Mm-hmm. +: Which is funded by Congress. +So, you would have to talk to somebody in the +region about what the regional budget is, but +other institutions have issues going on. +But being that -- + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +356 +-- we have all these +cameras already onsite, and they had already +done the wiring for, you know, at least six +months prior to this -- +Well, not all the wiring -- +- they -. +-- was done. +: Yeah. He just, he didn't say +the wiring was done. +No, no, no. I'm just +saying, like, is that, I'm just trying to get a +feel for what was the plan here, and who was +responsible. +Well, the plan was to get +the manpower to get it installed, but at the +time, we only had one person. Which was +So, one person can't -- +: Well, and the TDY staff. +- right, but even the TDY +staff came, they did help. You know, but then, +we also had other TDY staff that were coming in +for, because of our staffing issues. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +357 +: Mm-hmm. +: But -. +: Well, that's what +told us. That the IDY staff that was assigned +for him sometimes were getting put on the +custody posts. Do you know if that is accurate +or not? +: We might have had to do it a +time or two because we wanted to staff. +Yeah. Yeah. +And whose responsibility +were the cameras? To make sure that those +things were going to be operational and working +properly. +: Well, it's not a matter of +who was responsible. It's, like, working on +getting it installed. +: So, there was no deadline as +far as, you know, okay, when they had to be up. +You know, they just had to be installed. +Okay. Because we were +told the cameras are the captain's baby. Is +that accurate? + + +1 +2 +3 +4 +5 +6 +7 +8 +358 +No. No. It's not. +: Yeah. That -- +: It's not. +: -- that can't be true. +Captains don't know how to install it. +Yeah. He doesn't -- +(Indiscernible *04:12:11). +No, no, no. Not to +install them. But to make sure that they are +operational, and get the right people to +actually get it done. +Well, I -- +: That can't be right, either. +_: — well, I -- +: Because how the fuck would you +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +know what +- right. I-- +: Well, because -- +: - who the right people is. +-- because what we were +told is that this was constantly happening, +whereas the cameras would stop working. And +then, nothing would be recorded. +So -. +The only way you find out + + +359 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +that that is happening is to physically check +the DVR recording to see if there has a light +on it, or if you try to attempt to rewind, and +you are unable to. +_: Mm-hmm. +: Because everything is +still live monitored feed, showing, so you +can't tell just by looking at the cameras. +It's only when you try to rewind them, that you +can say, oh my gosh, they are not recording. +: Right. But that, it wasn't +just as simple as that. I mean, there were +technical aspects of it that you had to check +to see if the cameras are working or not. +: Oh. Absolutely. +Right. And the captain +basically looking to see if, okay, is the +screen up? And then, is it recording? But +there was some instances where the hard drives +weren't working, and you don't know that until +you get deep into it, into the system. So, I +wouldn't, you know - +: That's -- +- put that -. +: - that's what he just + + +1 +stated. +2 +3 +4 +5 +6 +7 +8 +360 +: Yeah. +: Like, the fact that the only +way we would know if the hard drives were not +working is by going in -- +: - to check the video. And +the video, there is no videos that they can +pull back. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: That's when they know the +hard drives stopped recording. +: Stopped recording. And +then, and look at them. But then, this is, you +know, there was other technical aspects of it +that, you know - +: I can't imagine that -- +-- yeah -- +: - the captain would know. I +sure as hell wouldn't. +-- right. +So, I guess, knowing, +though, that this was, like, a reoccurring +problem, and the fact that, well, what we +didn't say is, it seems, it appears that the + + +361 +1 +2 +3 +4 +5 +6 +7 +8 +cameras actually stopped recording all the back +in July, and for half of the institution. +: Who should have made sure +that that camera system was replaced, and that +we had an operational camera system in there? +Well, the centralized area, +and I don't know where the break down was. So, +if it's a centralized area, then it would be, +you know, within our facility department has +access to -- +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Well, the camera -- +-- the comm -- +- you are asking where +the cameras are? +- no, the comm room. +Yeah. The comm room. +Where these recorders were, were all in the SIS +secured area. +: Right. The actual cameras. +But where - if you go out - where -? And I +don't know the word, what's the word? Where +your centralized main area is for the whole +system. Yeah. That SIS areas has the cameras. +But that's fine. + + +1 +2 +3 +4 +5 +6 +7 +- +8 +362 +Not the control room. +But it's back around where, it's a locked door +within the SIS locked room, where the actual +DVR recording and rack is, and everything. +Yeah, yeah, yeah. That's +But -- +- is that what you are +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +talking about? +•: - that, but there is also +another, should be another area in the +institution, just for the communications. +Where everything comes into. So, I don't know +if it was back there or whatever, but our +facilities department, you know, their +communication guys check that, too, if there is +something intricate with it. +: Now, so, was either Mr. +l, or +1, how do you pronounce his +name? +: Was +, or Captain +were either of them expressing the need +to you at all, to, hey, we need to get these + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +things fixed? +sent up. +onsite. +363 +I mean, the request had been +Yeah, yeah. No. +So, yeah. +And these were all +: Right. So, yeah. IU mean, +we were going through - +: And again -- +•: — the process of getting +the system up and running. +: But there was no set +schedule for when it was actually going to be +completed? +No. Because we had to TDY +people. Sometimes we got them in, sometimes we +couldn't get them. And then, towards the end, +you know, boil down to money, with getting +people in to come fix them. +: And when people are IDY, +do you - when you say boil down to money - does +that come out of -- +It comes out of our -- +-- MCC's pocket? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +know? +364 +-- it comes out of our +budget. It comes out of budget. It comes out +of the region sometimes gives it. Plus, on top +of that, we were for TDY to come to our +correctional post, because we were so short. +: All right. So, what +would you say is the main reason, then, that +the cameras were onsite, but not installed? +Lack of manpower and funding? +: Well, manpower to get it in. +And then, it kind of boiled down to funding. +You know, to keep TDY people, to get it done. +: But do you have money, you can +really keep the IDY people. You don't have +money -- +: Yeah. +: - you can't keep them. You +But again, there is no, +there was no actual set schedule of it will be +operational by the end of this calendar year -- +: - or anything like that? +That wasn't discussed? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +the question. +365 +That wasn't discussed. We +were trying, you know, doing the best we can +with the hand we were dealt. +Okay. And Monday morning +quarterbacking that. Should it have been +discussed, or planned ahead, that these cameras +be installed? +Would -? I don't understand +Well, being that there +is, it seems that there was potentially around +two weeks of no cameras, and in the SHU, no +cameras. Aside from that one outside of Ten +South. +: That were recording. +: But that wasn't known -- +: But it was, according to +the, you know, according to the facilities, as +well as the comtech, they said it was very well +known that this continually happened, and that +the comtech guy continually had to rebuild hard +drives because they kept on crapping out and +not recording. +I mean, it is an antiquated + + +1 +system. +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +366 +Right, right, right. +: So, when you go down, yeah, +obviously, you go fix it. But nobody knew +until after the fact that you, you know, that +you had a system that was out for two weeks. +You know, I mean, you go to any other, any +institution, the cameras go down. +Sure, sure. +And when the system breaks, +somebody discovers it, and they fix it. But as +far as getting the new system up, we were +working on it. +Okay. You want to follow +up with any of that? +: You mentioned no one knew. +But the problem was, according to the comtech, +the system failed, the motherboard had to be +replaced on the 29th -- +: Mm-hmm. +: - they had a failure. +: And then, of course, no one +checked it until the 8th. + + +367 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: August 8th. When the AW and +the Lieutenant Doctor went in and they tried to +- review video. Now, being +that they identified the system wasn't working +that day - +•: Mm-hmm. +1: -- how soon should it have +been fixed? +: What do you mean? When they +-? +1: On the 8th. +: This is two days before that +Epstein was found. If they identified on the +8th that, hey, listen, the camera is not +working. It's technically not recording. How +much of a priority is it to make sure that +those cameras are up and running immediately? +: It's a priority. So, what +happens is, and we have run into this before, +the parts. Sometimes the parts weren't readily +available. So, you have to go somewhere and +call for the parts, and depending on where it + + +368 +1 +2 +3 +4 +5 +6 +7 +8 +is at, it could be in California, or whatever. +So, you got to see how long it takes to get +that part. +: Yeah. +Over to repair. +: And the key part for my +heating system -- +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: — is in fucking Belarus. +: My understanding is they, it +was the hard drive that they needed. Right? +And the hard drive was sitting with the +computer services. +: Yeah. On the 8th. They +weren't able to get it. +: I don't know. +1: Yeah. +: And on the 9th, they got +it. But then, he claims that he wasn't able to +gain access to the room because it was an SIS +shop, and he needed to go until later in the +day, and they were gone. +I mean -- +And on the 10th-. + + +1 +2 +3 +4 +5 +6 +7 +8 +369 +- we have an emergency keys +to get into any area of the institution. So, +if he is saying he couldn't get in to the SIS +office -- +: - you got the captain, you +know, we got the techs that work in there. +We've got their glass is behind - what we call +in control center - behind a box. You know, we +can get that box open. +: So, he said that the only +way to be able to get into it is if he broke +the glass -- +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +He can break the glass. +: - mm-hmm. It's okay +that he would have done that? And then, should +have he? +: Yeah. If you couldn't +reach, you could just -. +well, he should have +gone to the captain or somebody and said, hey, +captain, I need to get into your SIS office. +: Do you think it's at all +acceptable, if knew on August 8th that these +cameras were down, and he didn't actually start +working on it, or at least, I guess he was + + +370 +1 +2 +3 +4 +5 +6 +7 +8 +working on getting the parts, but then got the +parts again on the, some time on the 9th, +claims he didn't work on it because he couldn't +get into it, into the SIS office. So, he was +going to work on it on the 10th, on that +Saturday. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +So, the question - +- and what is your -? +: — the question I would pose +to you is, did he notify anybody that he +couldn't get in there? Did he make any attempt +to contact the captain, or anybody to say, hey, +I need to get into that office to get a part to +do it, because if he had told the captain that, +the captain would have got that office open for +him. +: Yeah. I agree with you. +It's a he says that the MCC was a different -. +So, at any other BOP institution, in the +country, that would have happened with, his +experience taught him that, at the MCC, +basically it could wait until tomorrow. +: They wait until tomorrow. +: So, that's his opinion. But +again, I'm going to pose a question. Who did + + +371 +1 +he bring up the issue to? Because my thing is, +2 +if you know it's an emergency, and it's a +situation to say this is the MCC, is a cop-out. +: And is it, would that be +classified as an emergency? +: If the cameras are down, +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +yeah. +That is an emergency. +So +Let's get them back. +- he should have +absolutely gotten into that room -- +He should have gotten -- +-- one way or another? +: - in there, and he knows he +could have gotten into the room, because you +can, we can break - if he said that stuff was +sitting in there, whatever room he said it in +there, guess what? +You can break glass. +You +can break glass after hours, if you need to, +and it's an emergency to get in, into an area. +: So, his claim is that, he +has rebuilt these things so many times. And +every knew that these cameras needed to be +reinstalled, and he had been saying that they + + +372 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +needed to be reinstalled. And now he's being +looked at as the fall guy. +: You know, it sounds like he +could, you know -. +: I don't -. This is not an +issue of being the fall guy. +: So, let's take every issue +we just talked about. We talked about the +camera project that we were working on. +: Mm-hmm. +: We were getting the people +in there to working. So now, let's talk about +the specific issue that you were talking about. +He did not notify anybody to get into that +room, to get to that part. That part was to +fix the current system. It had nothing to do +with the new system coming in. This is, he is +saying that this was a part that we needed to +fix, get put in, to deal with the current +system. +: Now, what about the fact +that Lieutenant Doctor is saying both she and +the AW knew that the cameras were down on +August 8th. They told +to fix them. And + + +373 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +they also notified Lieutenant Doctor, so that +she not only notified the captain, but wrote a +memo and provided it to him about the cameras +being down on the 8th. +: So, at that point, what +are the responsibility of the captain and the +AW? +: So, what the captain does is +he notifies facilities where +works fOr, +and says, hey, the cameras are broken, you need +to fix them. +So, should the captain +have, on the 9th, ensured that those things +were fixed? +: Well, I don't know what +conversation he had with facilities to say we +are getting, you know, was it being fixed or +not. +: Well, do you know +(Indiscernible *04:23:25). If he knows to tell +somebody on the 9th, is it possible to fix it +on the 9th? +Well, the 9th is a +Friday. So, the 8th is when we are told that + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +of the issue. +is saying. Yeah. +374 +he was told, informed, learned. +: So, we have all Friday on +the 9th to make sure it's done. +: on the 10th, +unfortunately, is when —- +But -- +-- we know the severity +: - but that's my point. You +knew that, okay, you were made aware that the +cameras needed to be fixed. Okay. So, your +answers, what you are saying is, I couldn't get +into a certain area, so -- +Well, that's what +- but that, okay, but - +: But my question is, +should the AW or the captain have followed up +with that, to make sure that it was actually +being done. +: And to them, I don't, you +know, I don't want to make the assumption +because I don't know. There could have been + + +375 +1 +some follow up. I don't want to speak on it, +2 +but you know, if he had told him something on +3 +the 8th, you know, I don't know the +4 +conversations that were taking place between +5 +them. Like, where is that, and what is he +6 +saying? Right now, I'm responding to what he +7 +is saying, and it makes no sense. +8 +: Yeah. No. I would just +think that, you know, being a captain or an AW +would be -- +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +- whoa. The cameras are +down in the institution? +: Well, let's make sure +that those things are back up -- +So, and -- +- so they would at least +check back in on the 9th, and say - +-- and then -- +-- where are we at on +this thing? +: — but then, I don't know, +you know, what that conversation was. I don't +know if, on the 9th, +even came to work. + + +1 +2 +3 +said -- +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +376 +I don't know. He could have +Well, we do - +- oh, well, I'm not going - +- we know. +But yeah. +-- huh? +And we know. +So, I don't know. I don't +want to speculate on that part. +Yeah, yeah, no. That's +what we are trying to tell you. Is, like -- +-- we know he was there. +: On the 8th, he couldn't +get the parts. On the 9th, he got the parts. +But then, he said, he tried to get into the SIS +office. He was told by the - it wasn't an SIS +tech, because there were only two people there. +It was somebody that - +: Monitored. + + +1 +2 +3 +4 +5 +6 +7 +8 +377 +- monitored the +telephones. I think he's now retired. Tay? +Tay. Yeah. +Was there. And he said, +I'm getting ready to leave, and he can't come +in here without me. And then, he said, I +didn't have access to the room after that. So, +my plan was to come in on the 10th, the +Saturday, because I was coming in anyway. And +that's what I was going to work on. +: He's the com shop. He can +go anywhere, where there are computers. +: So, that is not an +acceptable answer that he provided? +: I don't understand that +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +answer. +_: It's because that room is +not in where the SIS shop is. That's the phone +monitor room. That's the camera room. +1: And the key for the camera +room is how, I think it's only the SIS +lieutenant, and the SIA that has the keys for +That's what the SIS + + +1 +office said -- +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +do you mean? +control center. +378 +So, the -- +: - they said that -. +- the phone monitor is, +he's in the SIS, but he draws keys to get into +that room. So, that room is all -. And you +can draw keys to get into that room. +1: When you saw draw keys, what +: Well, you get them from +1: Okay. +You know? +Well, we were told by +Lieutenant Doctor, the only way he could have +gotten them is to break the glass, which he +could have done. +But -. +: You could have broken the +glass. And that time of time it was 8:00. The +captain is there. The security officer who +controls all the keys in the institution is +there. + + +1 +2 +hey, I need - +3 +4 +5 +6 +7 +8 +379 +You can go to them and say, +: The key. +Now -- +-- I need the key. +: - now, did either the +captain or the AW inform you of this issue? +No. I don't - +So, you didn't know -- +-- I don't -- +- anything about this? +- recall anything about +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +that issue. +Should have they? +So, if -- +If it was a Thursday, +they found out, and it was all -. You weren't +there for that. +I weren't there on Friday. +I wasn't there on Friday. +You weren't even -- +-- there on Friday. +So, you know -. + + +380 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +And who - I'm sorry - can +you remind me, who was acting in your stead on +Friday? +I believe it was +I think. +1: Now - +So, you weren't even +there. +: Yeah. +: Our understanding is, I think +Captain +was in the institution, too, +about 8:00 p.m. +On the 9th. +: On the 9th. +1: So +On Friday. +: -- could +have been to +any time during that period? +He could have seen him. + + +381 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +mean, just, you can't -. If it's an emergency +to get something for, I don't understand. That +is not -. +No. That's great to +know. +About this. So, you say +that's not acceptable. +there. +: No. You can, you can get in +So, I don't know -. +: Well, one of the things is, is +in prison, you need a camera. Yeah. +: Right. Especially in the +SHU. +• Right. Especially in the SHU. +: Now, who was responsible +to have the new camera system installed? +_: What do you mean as far as +responsible? +Like, who had overall +oversight on that? +The facilities manager. +Mr. +Mr. +Yeah. So, he - +- + + +1 +2 +3 +4 +5 +6 +7 +8 +382 +All right. +-- gets the people in there, +but we're allocating things. But again, I want +to say, that was, you know, with manpower. +Okay. Now, you've pretty +much answered this, and you can say it's the +same answer, but I just want to read you the +question. What are your thoughts on the fact +that the new camera system was there since +October 2018, but it wasn't installed after the +Epstein incident that occurred on August 10th, +2019? +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +It's the manpower. +Manpower. +: Yeah. You know, getting +people, qualified people in there to do it. +mean, one person couldn't do that. It was, and +we were putting in new cameras in new areas. +So, he needed more people. One person couldn't +do it. +: Okay. Do you mind just +initialing? And don't have to go through this, +just the top is fine. Anything more on the +camera issue? +: Oh, Christ. You got more + + +1 +issues? +2 +3 +4 +5 +6 +7 +8 +up? +383 +No. I think the -. We +have one more issue, and then just a couple of +questions based upon the BOP's findings. It +does say that there's leaks information. Where +are those emails? +1: It was in -. Did we mix that +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Here it is. So, here is +two emails that were sent both from +One to you, and one to +Sp. *04:29:13). +(Phonetic +Yeah. He was the acting +director at the time. +: Director of the BOP? +Okay. So, the first one +was on August 10th, 2019, at 6:14 p.m. to you. +And the subject is, "Urgent request. Potential +leak in hospital regarding Epstein's death." +It looks like -- +¡ You mean — +-- where is the -- +: -- media leak? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +384 +- yeah. It says, +"Please ensure this information is given to the +OIG FBI. Thanks." +And then, this next one, +like you said, is from Ormand to the director. +Subject, "Prison guards skip mandatory checks +before Epstein's death." This, the body says, +"Couldn't see the entire article on my phone, +but I wouldn't be surprised there are staff +that are paid contacts for local media outlets. +This has also been discussed at the department +level, all the way to the White House. And who +knows who may have overheard those +discussions." +: Do you know anything +about leaks in the media from the MCC? +So, what happened was, when +(Phonetic Sp. *04:30:17) came to see me, +the issue we had was - and I told him about it +- was there was a article in the Post that took +a picture of our staff, and our staff rode with +Epstein on it. So, I told +about it, and +I guess they said one of the paramedics had + + +1 +2 +3 +4 +5 +6 +7 +8 +leaked the information. +them, like - +385 +Like, took a picture of +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Took a picture - +: - posing with him? +: - took a picture of them +coming in the room, when they got to the +emergency room. Took a picture of Epstein +being rolled in. And our - what do you call +it? - and our staff. So, I talked to +about that, and then, I had also told him that, +you know, there might be some staff, you know, +because, and I didn't know where it was coming +from, because the information was just coming +out, you know, so quickly, and it was, like, +where is this, you know, coming from? So, I +called and made him aware, you know, told him +about it when he came on Sunday. But the main +one was because of the picture in the Post. +Now, who is it that you +suspect would have been leaking information to +him? +: I couldn't, I couldn't even +tell. But I just was, you know, with this +whole thing. You know, stuff would leak, had + + +386 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +been leaked out to the media, and you are, +like, where is this coming from? +: Do you have any +suspicions, though? +I can't speculate. I mean - +- +: That's my boy. I mean, I +don't know nothing. +: (Indiscernible *04:31:48). +You're talking like an +attorney. +No, I mean -- +: But like that, I don't know +nothing, but what I do know, I don't know. +: I mean, I can't speculate. +I mean, +the half of it was towards me. I mean, +sO - . +Did you leak the +information, you mean? +: No. I said it was towards +me. +oh, you mean the +information -- +Like, the negative press - +- and the negative to + + +1 +you? +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +to me. +know -- +387 +- yeah. It reverted back +Uh-huh. +So, I mean, that's, you +know, and it was just, it was fast and furious. +So, like, negative things +to people, you believe someone in the BOP was +leaking negative information about you? +I don't -. I mean, I, you +Can you give me, like, an +example +: of what was leaked about you? +Well, I mean, you know, +stuff that happened, you know -- +: Listen, the -- +: -- and I'm not saying -- +: -- (Indiscernible *04:32:26) +investigation was going on. +- specifically - +: I mean, you know -- +-- specifically -- +: -- whose fault is it? +-- right. Towards me. But +it was just automatically the blame was, you + + +388 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +know, put on me. +And then, you know, the +other part of it was, I don't know if it came +from the department. I don't know if it came +from the institution. +Because all that information +was going, you know -- +: But did anybody -- +-- up on different levels. +- did anyone tell you +that they believed that a certain person was +leaking information? +No. I didn't hear if it was +a certain person. +I didn't, you know? +: Okay. And did you leak +any information to the media? +: Absolutely not. +Okay. Do you mind just +initialing and dating that? Do you believe, +though, somebody in the BOP was leaking +information? +And I'm not -- +And I don't mean that + + +389 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +personally. I just mean -- +- no. But -- +- you know, you could +always get -- +- I don't -- +-- the second one under +there. +-- it could have been up to +the department, because the information was +going up to them. +I mean +But I just mean, like, +based upon what information was being leaked, +do you believe that someone in the BOP - not +necessarily the MCC, I just mean BOP - was +leaking the information? +I will put it this way. The +Department of Justice might -- +: Yeah. +-- because all the +information -- +Because it could be -- +-- was -. +-- OIG. FBI. +Initial. +Anybody. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +390 +It could have been anybody. +So, I don't want to -- +Gotcha. +- kind of put it -- +Sure. +-- on one person. +All right. The last +actual topic, before we ask a couple about the, +a couple about the findings. Epstein's will. +Do you know anything +about Epstein changing his will just prior to +his death? +MO. +: Had you ever heard that? +After the fact. +: Right. And when you say +after the fact, how did you learn about it +after the fact? +: I don't know. +Reading it. +Or hearing it on the news. +it in an official capacity? +: Did you ever hear about +All right. Do you know + + +1 +2 +3 +4 +5 +6 +7 +8 +if it's true? +brother. Right? +391 +Don't know. +: He left this all to his +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: I -- +: Is that true? +-- I can't comment on +that kind of stuff. But what actions should +have been taken, or you don't know if it was. +If it was learned that Epstein's will had been +changed just prior to his death, do you believe +any specific actions should have been taken? +: I don't know anything. I +mean, I can't comment on that. +Okay. So, that's the +last of the topics. Now, we have - +(Indiscernible *04:34:38) refer to it - I don't +think we have to refer to anything other than +the - where is that? +1: The after action? +: Yeah. Do you have it? +And I don't know what we actually need to cite +(Indiscernible *04:34:53) initial them. This +is the after action report. Is that -? That + + +392 +1 +2 +3 +4 +5 +6 +7 +8 +the BOP created in response. +So, just a few +quick questions on it. It says, "On August +Ist, 2019, at 8:30 a.m., psychology documented +they were notified by correctional systems of a +form received from the United States Marshal +Service, the previous day, stating inmate +Epstein had reported suicidal tendencies." +Do you know anything +about that, and what transpired? +Wait. Read that again. +So, "On August." So, +just to refresh your memory of a time, +timeline. On July 30th, he comes off of +psychological -- +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Psychological observation. +-- observation. +And goes to the SHU. +"Iwo days later" - so, there's July 31st and +August Ist - "8:30 a.m., psychology documented +they were notified by correctional systems of a +form received from the United States Marshal +Service, the previous day." So, I guess on +July 30th. + + +1 +2 +3 +4 +5 +6 +7 +8 +393 +The 31st, I mean. +"Stating inmate Epstein had reported suicidal +tendencies." This was the BOP's finding. Do +you know anything about that? +: I don't know anything about +that. And that's before, when he first came in +the system, or -? +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +No. That was after he +came off of psychological observation. So, +after his actual first attempt at suicide. +Or potential harm from +Tartaglione. +No. I didn't. +You don't know anything +about that? +Nuh-uh. +Okay. And do you know +anything about the suicidal tendencies that he +was showing? +No. All right. And +then, on the same date, August Ist, 2019, +again, this is after the Tartaglione incident. + + +1 +2 +3 +4 +5 +6 +7 +8 +394 +And after coming off of +psychological observation. "1:00 p.m. +Psychology conducts a suicide risk assessment +noting watch is not indicated, with a +recommendation for follow up in one week. The +delay in conducting this assessment is not +justified in the report." Did you learn +anything about that? +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +No. I don't. +Yeah, yeah. +I -- +And again - +-- it's psychological. +-- this is just some of +the -- +: Yeah. +- the negative findings. +We just want to know your +take on it. I don't expect you to know any, +all of this, or anything. +It's just asking because +there's some negative findings. Okay. The + + +395 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +next one. It says, "Significant -- +: Don't bring this guy in on +another case. All right? If the next time +this comes up, and he says, I'm going to bring +this guy, don't fucking do it. +: It says, "Significant +discrepancies exist within Sentry, regarding +admission/release status, ARS." +Sentry does not reflect +inmate Epstein being escorted from the +institution by the U.S. Marshal Service on July +31st, 2019. Although a signed prisoner remand +form is on file, documenting - +: - having received him +from the U.S. Marshal Service. Additional +review revealed inmate Epstein departed the +institution for a total of four court +appearances, and only one of these occasions +was an ARS change made within Sentry. It +appears there is a culture of foregoing this +vital function, due to the likelihood of the +inmate returning from court. This lapse in +procedure is a severe inmate accountability + + +1 +deficiency." +2 +3 +4 +5 +6 +7 +8 +396 +: Well, that statement is +incorrect. I know the regional office looked +into it and said that a pre-trial institution +can outcount an inmate to go into court. So, +he doesn't have to be keyed out on the ARS. +: okay. +: So, the way they were doing +it, they looked at it after the fact, and said +there was nothing wrong with that. +So, they did re-review +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +this matter, and - +Yes. +-- said that there was -- +They were fine -- +- they were doing it -- +-- with it. +Yeah. Because they kept +thinking, when they were looking out, same +thing like you said, he was going out to court, +but they can outcount him in that area. +: All right. And what are +they talking about, like, pre-removing him or +something like that, when he goes to court? + + +397 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +No. Going to court. +: Yeah, yeah. +: And if anyone is going to +court, because you have so much court movement +that you can outcount them. And then, when the +Marshals say, hey, he's not going out, then you +release him out of -- +1: So, this is — +: - this means, on the E1, he +would be listed on the outcount? +_: As court. +1: As court. +: Yeah. +1: Okay• +And that's what they were +actually doing? +That's what they were doing. +They had him on the E1. +So +- so, this is no longer +That's not -- + + +1 +2 +3 +4 +5 +6 +7 +8 +398 +-- an issue. +-- an issue. +: All right. The next one, +it says, "No notations concerning a requirement +for a cellmate were entered into the SHU +program, and subsequently available for SHU +officers to reference." Who would have been +responsible for noting that in the SHU program? +so -. +First of all, what is the +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +SHU program? +The SHU program is - +: Is that the 292? +- with the 292s. So, I +don't know, from what I understand, and was +told after the fact, that they couldn't find +the information on Epstein in the SHU program. +So, I don't know how you came to that +conclusion. +: By the way, let the record +indicate that he is not sweating under his +armpits. +A good sign. +We didn't. BOP came to +these conclusions. +Right. So, I don't know + + +399 +1 +where that conclusion came from because from +2 +what I gather, they couldn't get - they +3 +couldn't find the -. Because usually -- +4 +Well, they found the +5 +292s, but they were just very limited. +6 +: Right. The 292s usually had +7 +to have everything indicated on it. So -. +8 +And on that note, we were +told the 292, his file, was extremely small, +and it should have been larger. Had you heard +anything about people removing documents from +files? +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: From what I understand, and +was told, that there was no file. They +couldn't -. They had every other inmates file, +but not his. +: They couldn't even find +it. You didn't think they could find his file +at all? +: No. That's what was told to +me. +: And who told you that? +: I think I heard that after +the fact. I don't know if the regional +director told me after they came in and did the + + +400 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +check, that they couldn't find it. So, I don't +know. +: That's after they found out +the Hilary Clinton -- +: Yeah. +: -- came down and had them +(Indiscernible *04:40:44) a certain +(Indiscernible *04:40:45). +But back to the original +question, whether it was there or not. +: If it, the cellmate +requirement was not entered in the SHU program, +who should have made sure that it was? +: On the, in the 292? And I +don't know who was doing it. It should have +been the lieutenant, to ensuring that it's all +in there. +So, the SHU lieutenant? +When they - yeah - when they +deny it, or the OIC. So, if the captain +conveyed the information to him, that should +have been put on the 292. +So, either -- + + +1 +2 +3 +the OIC. +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +401 +By the lieutenant. +- the SHU lieutenant or +Now, when you say the +OIC, does one OIC of one shift take more +responsibility than another? +: No. They are all on the +same shift. So, it would depend on -- +So, like, for instance, +was the OIC on the day watch, but - +: -- I think +was the +OIC on the night watch. +: So, would one of them had +more of a responsibility to do this than +another? +_: +No. But that should have +been done on the initial, when the directive +was put out. +So, from Doctor, or Ms. +Imeri saying that here's coming off of +psychological observation, he needs to be +housed with a cellmate -- + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +402 +Right. That would have been +- on July 30th. +- put out, and then, when - +so, who, at that time, +should have noted that in his file? +: Well, you would probably +have to find out from the captain who he +directed to -- +wel1, the captain - +- to doing that. +-- according to his, you +know, his memo that he sent to you - +- it says that he +specifically had these conversations on +multiple occasions, with - +_: The SHU -- +-- Lieutenant +- right. So, it would have +been the SHU lieutenant. Whichever one he had. +If +was the one, then +would have been +the one. +But -- +Okay. "August 9th, 2019. + + +403 +1 +2 +3 +4 +5 +6 +7 +8 +8:00 a.m. Inmate Reyes, the cellmate, departs +for court." +: Again, this claims court, +but if they are seeing WAB. Actually, you know +what? I heard WAB was specific to MCC. Is +that correct? +: Other institutions will tell +you pack up your inmates with all belongings. +That's, you know - +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Because even -- +-- what it is. +- on their findings, +they are showing that he departed for court. +Although, all the +documentation we showed says WAB. +WAB. +And transferred. +Yeah. And it says - +: So, even on here, they +are getting this wrong? +: And that's what the whole +confusion is, is the assumption that he was +going to court + + +1 +2 +3 +document -- +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +404 +Because then it says -- +- when you look at the +-- so -- +-- go ahead. +: - yeah, and then, it +says, "Inmate Reyes does not return to the +institution." +So, and this was when a +lot of things, when we were first starting this +investigation, we heard was court, court, +didn't return from court. +: And then, when we +actually looked through the record, we were, +like -- +-- court. It's -. +I think people thought, +without looking at the documentation, that he +went to court and got released from court. +So then, I'm just going + + +1 +2 +3 +4 +5 +6 +7 +8 +to read the question. If the documents list +Reyes as being WAB, and if they had the +transfer list, why did they say he went to +court and did not return? +I can't answer that. +: Okay. "7:00 p.m. +Epstein was provided a social call by the +institutional duty officer." Does that mean +405 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Yeah. He was the duty +officer at that time, I believe. +And what does the +institutional duty officer mean? +: So, what the duty officer +is, is after hours, they walk around and, you +know, report emergencies, you know -. +: Is that, like, the +highest ranking official there? +: That comes on at night. You +know, there with the lieutenants. But they +just make sure that if we had any issues, you +know, addressing inmate issues, stuff like +that. +: So, they are kind of, +like, the, basically the OIC for the + + +1 +institution? +2 +3 +4 +5 +6 +7 +8 +406 +: Kind of. I wouldn't say the +OIC, but you know, senior staff around. +: Okay. "This call was +done on an unmonitored line. It is extremely +concerning why this call would have been +placed, and why it would be done on an +unmonitored line. Without further interviews, +it is not possible to determine the reason for +this call." Just, why does it say, "extremely +concerning"? +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: I don't know. Both are +report - +But I mean, do you also +find it extremely concerning? Would you +classify it as extremely concerning? +: I mean, it would be -. I +mean, that the choice of words that they use. +So, I wouldn't, you know, necessarily say, use +the word extremely concerning. But I would +think, I would -- +It's certainly wrong. +-- it would be -- +But -. +-- it was an issue. But + + +1 +extremely concerning. +2 +3 +4 +5 +6 +7 +8 +407 +Okay. "On August 9th, +2019, during a shift change in SHU, the SHU +number three, 6:00 a.m. to 2:00 p.m., officer +briefed his 2:00 p.m. to 10:00 relief, and the +other two, 8:00 a.m. to 4:00 p.m. officers, +with the likelihood inmate Reyes would not be +returning, and inmate Epstein would require a +cellmate upon return from an attorney visit. +Inmate Epstein was not placed with a cellmate +upon his return to SHU." My question to you +is, just, how did they know this information? +How would they have obtained that information? +Do you know? +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: I don't know. Like I said, +I don't know who they spoke to during this +after action. +: Were they doing +interviews, though? +I wasn't there. +Were they authorized, +though, if OIG and FBI are doing an +investigation, is the after action team + + +408 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +authorized to come in and interview people? +So, I've done after actions. +And there is a point where you come to it, +where you, if it's an OIG of FBI investigation, +that I can't. I mean, I can't question certain +people because it might impede an +investigation. Like, if you are going to look +at video and all that stuff, or look at it, you +can't because most of the time, it's been +taken. So, I don't know -. +So, possibly from that +memo, though, that was created? If they are +not really supposed to be doing. I mean, I'm +assuming they are not really supposed to be +doing interviews. +•: I mean, I don't know who +authorized them to come in and do the +investigation. I don't know. It was, you +know, who set the parameters on it. +I can't +speak on that. +: And is it a normal for +them to do something like this, when there is +an actual FBI and OIG investigation? +: We do after actions. So, I +don't know -. + + +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +409 +But I mean, do they do +after actions typically, when there is an open, +criminal investigation, though? +Not typically. +No? +: So, I don't know. And +again, I don't want to speculate. I don't know +who authorized it. I don't know if they got +permission from the department to come down and +do it. I don't want to -. +Sure. "August 10th, +2019." +So, this is the day of. +"6:33 a.m. A body alarm +is activated in the Special Housing Unit. SHU +staff report inmate Epstein was unresponsive in +cell Z06-220LAD. Sentry does not reflect this +accurately. Staff entered the cell and +attempted to wake Epstein. Control center +announced a medical emergency, and +cardiopulmonary resuscitation," or CPR, "was +initiated." So, the question here is, I guess +I'll start with. Well, the information that we +have is +and +were there. +immediately went into the cell. + + +1 +2 +3 +4 +5 +6 +7 +8 +410 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Upon finding Epstein. +: Was it appropriate for +him to immediately go into the cell? Or should +have he waited for staff to arrive on site? +1: You should be -- +What? +-- you're trained -- +: To go into the cell, I would +think. +- no, you wait for enough +staff to get there, and a lieutenant, before +you open that door. +: Is that right? +:Mm-hmm. +: In other words, suppose the +fucking guy is in seizure. +Well, the flip side of it +is, he could be trying - +Remember -- +- he could be feigning it. +- we're in a prison. +Yeah. He could be feigning +the suicide, and then come on and attack you. + + +411 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +And guess what? You're the only person there. +Now, he has the keys for every range door on +that door. +And you can lose -- +: Mm-hmm. +- you can lose the unit. +So -- +: Yeah. Okay. I made a +mistake. +-- that wasn't -- +That's the first time -- +So, he did not. +: - you make a notation, +(Indiscernible *04:48:23). +So, he didn't +appropriately (Indiscernible *04:48:25)? +Yeah. He didn't +appropriately. +And should have he known +that from his training experience? +Yeah. Yeah. +"7:36 a.m., inmate +Epstein pronounced dead by the emergency room + + +1 +physician. And we've already addressed this. +2 +My question was, was Epstein alive, or did he +3 +show signs of -? But we dug into that plenty. +412 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +"On August 10th, 2019, +the two assigned morning watch SHU officers +failed to make their designated rounds, or +count the SHU inmates for two counts. At 6:33 +a.m., upon finding inmate Epstein unresponsive +in his cell, with a torn bedsheet around his +neck, staff utilized the body alarm to initiate +a call for assistance. The medical response to +the incident was timely, efficient, and +exhaustive. Staff utilized an AED, as well as +a continuous CPR unit care was assumed by EMS +personnel." Are you aware of how - what +information they obtained to say that the SHU +officers failed to make their designated rounds +or counts? +I don't know. +: No? And I just say this +because I know, in reviewing the emails, a lot +of this information was provided from you to +Ray, and Ray was providing it to whomever, that +were -- + + +1 +2 +3 +though. +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +was. +413 +- was doing this, +So, I was assuming, in +drafting these questions, that a lot of this +information came from you. +But I wasn't here when this +Yeah, yeah, yeah. +think a lot of this stuff, though, was +provided, you know -- +- during the email +review, those first couple of days. +So, that's why I'm asking +these questions, is, like, do you know where +this information came from? +No, I don't. +: No? +Hmm-mm. +"Institution duty +officers do not routinely visit SHU each day, +as required by the institution supplement. + + +414 +1 +2 +3 +4 +5 +6 +7 +8 +Additionally, the IDO reports consistently +document the condition of SHU as satisfactory, +when observations have shown the SHU to be less +than satisfactory." Do you have any comment on +that? Do you agree with that assessment? +: Oh, I don't know what day +they went in there. Again, when these +observations were done, I wasn't the warden in +the institution. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Okay. But prior to, when +you were the warden, do you know about the +institution duty officers not routinely +visiting the SHU each day as required? +: No. I didn't know about +that. +You didn't know about +that. +: I didn't. I ensured +sanitation. You know? I made sure they made, +made sure the areas were clean. So. +: Okay. And what was their +ultimate responsibility when they would visit +the SHU? +: I guess same thing, to make +rounds in the unit. Check on the inmates. + + +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Make sure there are no issues. +: And is that, like you +said, the idea was the guy that's on at night? +That's the duty officer. +The institution duty officer. +: Always at night, though? +They use - they typically +work from, like, 1:00 to 9:00, 12:00 to 9:00. +They cover the evening shift. +Because I thought it was +explained to me, it was kind of, like, the +person in charge when you are not here. +Well, yeah. But then, the +other flip side of it go to the other shifts, +you know, the operations lieutenant is the CEO +in the absence of a warden. +So -- +• : — the duty officer is just +the bridge to the executive staff. +: But they were actually +supposed to be conducting those SHU rounds +every day? +: And then, again, I don't +know if they were or were not. I don't know +what they were, you know, what he was looking +415 + + +1 +at. +2 +3 +4 +5 +6 +7 +8 +416 +Now, why would, was +a reoccurring -- +What? +Was he a reoccurring -? +7: No. The duty officers. +Like, sometimes, you can get it twice a year. +on, okay. +So, I don't -. +But is it, like, a +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +quarterly - +well, remember -- +- submitted post type of +thing? +- remember, he is also, he +is the duty officer, but he is also his unit +manager. +: But was he -- +So -. +- the consistent duty +officer? +: No, no, no, no. +They +rotate. +Every day? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +417 +No. Every week. +Every week. +Yeah. You have other ones, +every week. +So - . +unit managers? +: So, it goes between other +Other unit managers. Other +department heads. So, it kind of goes, you +know? +What is the grade - +1: And do they -. +-- level requirement? +The department heads. It's +usually 12 or higher. +: 12 or higher. +And some, like, maybe some +GS-11s. Our trust fund supervisors. +: What grade level are you? +Huh? +: What level are you? +SES. +Which means? +It's like a general. +No. A staff. +It's what it's + + +418 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +equivalent to. +1: Mm-hmm. +So, if you're looking at +the military equivalent - +: Hey, man. +-- it would be -- +: I can't be too -- +-- the general. +: -- cheap. +: No. No. No. I can't +afford that. +I got kids. +: Well, fuck. Why didn't -- +: Yeah. +: — why didn't somebody tell me +that before? +No, no, no. I got -- +: (Indiscernible *04:52:52). +: - yeah. +: Yeah. +So, the highest level you +can go to in the GS level is 15. And that is +basically a full (Indiscernible *04:53:00) +colonel in the military. SES is the general + + +1 +2 +3 +4 +5 +6 +7 +8 +level. So, don't -. He's being modest. +No. Yeah. +: I always liked him anyway. +I did not know. I +thought, I assumed you were 15 since your AWs +are 14s, though. +: No. But certain +institutions, you are SESs. +And MCC was one of those +419 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +institutions? +: MCC is one. Your pre-trials +are 15s. Your penitentiaries. Your big lows. +Like, Fort Dix. Certain mediums. +And have you maintained? +Are you still an SES now? +: Yes. +Okay. Since this time, +have you ever been demoted or anything like +that? +: You know, man, I really -- +: No. Just got -- +: -- I really got (Indiscernible +*04:53:45) for this guy. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +employee. +of money. +420 +-- no. +(Indiscernible *04:53:45) . +You know how, I always give law enforcement +guys a big, you know, a discount. But I +didn't, he's fuck - he's a fucking +(Indiscernible *04:53:52) -- +I'm (Indiscernible +*04:53:52) a discount. +: — (Indiscernible *04:53:54) +couldn't afford him to pay. +Remember, I'm a federal +Federal boys. It doesn't +matter if you're a general or not. +We don't make any money. +You're not making a lot +: Yeah. +: But -. +Remember, I think the +president makes, what? +400. +250, and he's the - +- 400. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +two something. +-. +about that? +that. +psychology +issue? +421 +Is it 400 now? +And the Vice President makes +Yeah, yeah. No. That's +And never disciplined. When +I was moved, never given a reason why I was +moved. I was just moved. +Okay. So, is the report +also says that, "Psychology intake screening of +Epstein contained errors in identifying +details, including that Epstein was referred to +as a black inmate, and by different inmate +names." +: Oh, no. You're kidding me. +They said he was black? Hell, that was a +mistake. +Do you know anything +_: I don't know anything about +: Would that be a +: That is a psychology, + + +1 +2 +3 +4 +5 +6 +7 +8 +422 +whoever was doing that review. +: All right. "SHU has +multiple cells equipped with video recording +capability. Inmate Epstein was not housed in +one of these cells. And there appears to be no +set guidance on when to utilize these cells." +So, you already said you didn't believe, like, +he should have been. +So -- +Is that correct? +-- let me correct that. +None of the cells, none of the cells that we +had in SHU had cameras in the cells that were +being, working and being used. The only ones +up in SHU that had cameras in the cell is Ten +South. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Okay. So, no -- +So, they -- +- where else in the +institution -- +_ : +-- nowhere else in there had +cameras in the cell. +: Hmm. +: Ten South, we have it in the +cells where you can see -- + + +1 +2 +3 +4 +5 +6 +7 +8 +MR. I +1: That -- +How about, like, Nine +South lower, or something like that? Would +they? +Isn't that, like, the mini Ien South? +That's the - yeah - that's +the -- +423 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Or G tier. +-- G tier. +That's not -- +- what this is. +So, that -- +: Did they have cameras? +-- that did have recording +cameras in -- +Just live cameras? +-- in South, yeah. Just -. +Nope. But then, we had no cameras on there +that had live cameras in the South. +Okay. So, only - +Ten South. +-- Ten South. +Only Ten South. +1: So -- +so -. + + +424 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +-- this statement might +actually associate Ten South as part of the +SHU. +Right. Because a lot of +people that come in, when they first come in, +Ten South is part of there, actually part of +Nine South. We call it -. It's part of an +annex. So, when most people come in, and they +have never been there, they don't +differentiate. +So, being that these are +BOP individuals that did this report, what is +your response to them saying that there appears +to be set guidance on when to utilize these +cells? If they are referring to Ten South. +Was there guidance on that? +: Yeah. Ien South, like I +said, was specifically for the SAMs inmates. +: So, do you -- +-- also believe that that +is an incorrect statement, then? +: If that's what they are +referring to, I do believe it is. +And you believe there was + + +425 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +no other working cameras, outside of Ten South? +Ten South is -- +For a single cell. +-- is the one where we had +our cameras. +Because we had also been +informed that there were cells outside of Ten +South that had cameras in them, specifically I +think G tier. That's inaccurate? +_: G tier. There is no +recording of inmates in those cells. +Just live? +: And I don't even believe +live. I know the only ones we had was Ten +South. +: We also heard that Ten South +wasn't supped to be utilized anymore. It was +actually supposed to be phased out. +: It was supposed to be what? +: Phased out. +What do you mean phased out? +: He was actually brought up, + + +1 +2 +3 +4 +5 +6 +7 +8 +brought out during the time, after 9/11, to +house terrorists inmates. +:Mm-hmm. +: Have you ever heard anything +about the fact that no one was supposed to be +housed up there anymore (Indiscernible +*04:57:12)? +426 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: No. It's not -. It's not +to house terrorists' inmates. It's to house +inmates that have a SAMs on them. So, mostly, +the most of the inmates that have SAMs on them +are terrorist inmates or, you know, maybe an +inmate housed for espionage. You know? And +then - +1: Was it supposed to have been +phased out due to PREA concerns? +: I didn't -. I don't know +anything about that. +: okay. +The next one is, +the report also shows that, "A review was done +regarding the overtime conducted by the C.O.s +at the MCC, and the shortage of staff." It +doesn't say much about it. Do you know what + + +427 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +the overall team's finding was? Do you agree +that there was a shortage of staff? +Yeah, there was. I mean -- +- I'll give you an example. +We were short staffed. I was relieving +officers on their posts, and on some weekends, +I would come in and work a post. I mean -- +You, as the warden? +-- as the warden. I mean, +we had -. We were short. I mean -. +Now, is there a -. Was +there a way to rectify that issue? +We could. I mean, hiring. +We had, I mean, 40 or 50 staff on OWCP +(Phonetic Sp. *04:58:23). +And can you explain what +that is? +Workers compensation. +Oh. And what was the +percentage +there, you said? +About 40 or 50 staff on it. +40 or 50 staff. +Yeah. On there -. +Did they seem to abuse + + +1 +that? +2 +3 +4 +5 +6 +7 +8 +428 +: We all knew it was an abuse. +I mean, we -. We had even had conversations +with the IG about, you know, you're going to +the same doctor. But I mean, I understand. +So +So -- +- every -. +: — they were all using the +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +same doctor? +The same doctor. But again, +I understand, every agency is short. +I mean, so, we just had that +constant problem. +: That's, like -- +: You know? +: - they use some of these -. +Some things, they use the same expert witnesses +all the time. +: Right. The hiring. We had +a lot of department heads that we would use to +cover. Some of my associate wardens, you know, +would cover. So, it was just, you know, had to +make do with what we had. + + +1 +2 +3 +4 +5 +6 +7 +8 +429 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Now, was there, like, a +plan in place to try to get you guys up to +proper staffing levels? +: I mean, we were working on +hiring. You know, and getting people in. But +it's a process. You know? Io get somebody +hired, it takes between six and eight months. +And were there a number +of people in the pipeline? +Not really. I mean, we went +out and did recruiting, because we were +competing with other agencies. +: You know? Other agencies +are hiring, you know, and we had incentives. +You know? Io get people on. So, it was just a +matter of, you know, getting people on board. +: And do you think it could +have been handled better by some, in some way, +by the BOP, in order to rectify that issue? +There's certain things we +don't control. Staffing. You know, the +budget. We don't -. I don't -. +We don't +control that. I mean, we can turn around and +say, I want this, but once the law is passed, + + +430 +1 +and it said, this is what you are getting, you +2 +don't -. We need to work with what we've got. +3 +: No, and I understand +4 +that, that as, like, as +far as the BOP goes. +5 +But I mean, the MCC, especially, you know, +6 +covering Epstein in a lie *05:00:18), and +7 +having such high-profile inmates. Was there - +8 +do you think that there could have been +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +anything done better, though, by the BOP, to +make sure that your institution, specifically +MCC, was better staffed? +_: You could - so, let's go TDY +- we couldn't really, couldn't IDY to a point, +but then, there are other institutions around +the agency that were, you know, the staffing +was an issue. So, they can't send somebody out +to help, you know? And then, it just brought +down the finding. I mean, and getting people +to clear your background. Not everybody can +clear a background to work. I mean, yeah, we +can go out in the street and say, hey, we got a +job for you, but can you pass the guidelines? +And a lot of time, do we +know. + + +1 +2 +3 +4 +5 +6 +7 +8 +431 +All right. So, we're +literally less than half of a page left. +: But this next one is just +going to be, I'm going to have you just kind of +read it -- +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +-- along with me because +it's so long. "He was also an inmate who had +risk factors for assault by other inmates, and +did require careful selection for appropriate +cellmates. Although these issues were noted, +well documented, and communicated, a failure +still occurred by allowing inmate Epstein to be +placed in the cell alone. +Although feasible +for an inmate to effectuate suicide while +housed with a cellmate, the odds of this +occurring are significantly lowered when housed +with another inmate." +The report continues. "It is apparent +various staff at the institution made a point +of ensuring inmate Epstein had an assigned +cellmate. The captain personally instructed +the lieutenants, individually. A mass email +was distributed by psychology, and it is + + +432 +1 +apparent some SHU officers were aware. +2 +Although many people acknowledge this is an +3 +important fact, ultimately, the final staff +4 +responsible for not - or did not ensure the +5 +requirement was met, including vital +6 +directives, such as a cellmate requirement, and +7 +a mass email does not ensure -." (Indiscernible +8 +*05:02:20) -- +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +- including vital +directives, such as a cellmate requirement, and +a mass email does not ensure those who truly +need that information do, in fact, receive it +timely. In this case, inmate Epstein was +actually placed with a cellmate when removed +from psychological - +-- observation. After +that moment, it is clear there was no +additional written directive, or a fail safe +system established, to ensure inmate Epstein -- +- would have had a +cellmate going forward." So, I guess, first +and foremost, do you believe, probably the + + +433 +1 +2 +3 +4 +5 +6 +7 +8 +primary reason why Epstein was able to take his +own life was because he didn't have a cellmate? +On top of the fact that they weren't conducting +rounds in SHU? And counts. +: I can't speak to the +mindset. Only I can speak to is, he killed +himself. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +But what I'm asking is, +would it have certainly helped prevent his +death by one) having an inmate; and two having +rounds and counts conducted? +Oh, if people did their job. +You know? And -. +: Like, obviously, if he +killed himself, he did it. +: But the way that the +government can better ensure that that doesn't +happen is by ensuring that, when it is mandated +that someone has a cellmate, they have a +cellmate. +: And when they do their +job, like you just said, they conduct rounds + + +434 +1 +2 +3 +4 +5 +6 +7 +8 +and counts, that -. Is that what you believe +would have helped keep him alive today, if, you +know, from the government perspective? +I mean, again, I'm going to +just say, I can't say what would have kept him +alive, but I will say, you know, if people made +their rounds, did their job, followed +instructions that they were given, then it +might have -. Could have minimized what, you +know -- +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: The risk. +: - you know, what happened. +The risk. But I can't talk to, you know, if he +would have done it or not done it. If that +would have stopped him. +: Now, as far as this last +sentence, what they wrote, "After that moment, +it is clear there was no additional written +directive, or fail safe system established to +ensure inmate Epstein would have a cellmate +going forward." What do you think could have +been done, and who should have done it? +: So, directives and the +information was conveyed to people verbally, +documented on forms, on what you are supposed + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +435 +to do. There was signs up. +Now, what signs do you +know that were up? +: No, I mean, the one you read +to me, about the sign about doing the 30-minute +checks. +Oh, I think this is - +so -. +- specifically talking +about the cellmate +requirement. +: No. I mean, (Indiscernible +*05:05:02) cellmate requirement. It was put +out by the captain. Directives were given. +Staff was spoken to. You know, it's kind of +boiled down to people not doing their job. I +mean, if I tell you, you have to do something, +it's given to you in writing, what more do we +have to do? +Well, that's kind of my +question, because the BOP is the one who wrote +that finding. So, I'm curious myself -- +I mean, that's - +- what you think - +-- I mean -- +- that could have been + + +1 +2 +3 +4 +5 +6 +7 +8 +done. +opinion. +436 +-- that's somebody's +: You know? That's a Monday +morning quarterback that came in and make an +opinion. I don't know what their ulterior +motive is -- +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Can you think of any -- +-- for making it. +- anything that wasn't +done? Can you think of anything, like, oh, if +this could have helped, or maybe he should have +done that? As far as the cellmate requirement. +: I can't think of anything +they should have done. +No. Okay. +: Can I ask? +I: I know it's bound to - based +on once everything comes up, these are +questions that they're going to have. So, I +got to ask. I know you mentioned that you +couldn't have secondary selection. Like, +another replacement for Reyes, because inmates + + +437 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +keep moving. But is it possible that a list +should have been created? That, you know, +should have told the SHU officers, hey, listen, +if Reyes ever gets removed, here is a list of +maybe possible five inmates that you could +choose from? +But I mean, under, you know, +different inmates, we can do that, but he was a +high-profile inmate that -- +: Mm-hmm. +•: — I would have had to get +that name and run it up to the department, to +see if it was okay. it wasn't just him. I was +going to arbitrarily say, listen, I need you +to, you know, we're going to put this guy -. I +was, just like with the other ones, sent up to +the department. So, again, it would have been +based on who was there. +: And because -- +: If that. +: -- because of that +extreme detail that had to go into selection, I +think what +is asking you is, should have +there been a list of names that the higher ups +signed off on, in case someone was removed, + + +438 +1 +2 +3 +4 +5 +6 +7 +8 +they went to court, they didn't come back, they +were transferred, things like this. +: Like, that's what they list +as a fail safe. Like -- +_: Right. I mean —- +: - as a precautionary +measure. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: - it could have been, but +then it would have still been based on who was +there that day, at the time. +And that's why I think +he's saying, like, a list of five people versus +one or two. So, if this person is not -- +I don't -- +: - there, what about this +one? That one is not there, either. But maybe +this guy. You know, that type of thing. Or +did you - +I just -- +- just stand by a hunch? +- yeah. I just, I just +feel, like, you know -- += Don't know. +- it was, I can't, no. +mean -- + + +439 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +-- again, I'm operating in +hindsight. I mean, at the time —- +- you know, that's what was +done. +: Yeah, we know you do. +Yeah. And we are +absolutely asking you to operate in hindsight. +Saying, like - +-- Monday morning +quarterbacking - +- yourself and your own +institution, I get it. But, like, Monday +morning quarterbacking this situation -- +_: Mm-hmm. +- what do you think +they, you know, they are referring to this as +the BOP, and we are not the experts. +We're coming in. But BOP +is saying this. I'm just saying, what do they + + +1 +mean by this? +2 +3 +4 +5 +6 +7 +8 +440 +Right. But - +: And what are some things +that could have been done? +-- but those are individuals +that are coming in, looking at a situation, +that weren't deeply involved in it. +: You know, they weren't the +ones that were told, hey, okay, I'm talking to +my boss, and it's going all the way up to the +department. That wasn't -. That wasn't privy +to them. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +That was a need to know +basis. +: But unfortunately, everyone +is who going to eventually look at this case - +1: -- is going to be doing the +same exact thing as they are. +: No. But what I'm saying is, +if we're looking at assessing the situation on +what happened in real time, that's what I'm +talking about. So, in real time, now, if they + + +1 +2 +3 +4 +5 +6 +7 +8 +had known that, hey, you know what? These +names had to go up and be, you know, vetted at +the same time, maybe it would have been a +different thought process. +: And was it possible - and +maybe you discussed this - was it possible +that, hey, listen, the SHU officers could have +replaced -? Did they have the ability to +replace Reyes, if they wanted to, or did they +have to come up the chain of command, for the +chain of command to tell them who the new +inmate -? +441 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +They were instructed, hey, +let us know when - where he's to have a +cellmate at all time - and to notify, let +someone know. Because again, due to the +individual that he was, you just don't want to +throw anybody. +: Okay. But doesn't that kind +of hinder them from taking action? Let's say, +at that point on that day, you are not in the +institution, Captain +was there, I +understand. +there. +There was an acting warden +You had the executive staff there. + + +442 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Just because the warden is not there doesn't +mean the institution doesn't run. That's why +you have, you know, people acting on your +behalf. You know? +That could make -- +So, maybe - +-- those decisions. +- maybe, what +you are trying to ask is, would somebody, since +it sounds like you would have to go over your +head to even make that decision, has to go to +the regional director level, would the +associate warden have the ability to go to the +regional director, or would have they known to +go to the regional director? +: So, let's say that did +happen, right? They would have - +: Well, it did happen. +: - no, I'm saying, as far as +finding out that, hey, he needed a cellmate. +So, even though I'm off that day, I'm still +working. +: Mm-hmm. +: Because I got the government +phone. And they're going to call me and tell +me, hey, this is what we got going on. +He + + +443 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +needs a cellmate. And then, I would be, like, +okay, let's see what we have, so we can send it +up. +: So, basically, you were +always available. Someone was always +available, that if the proper notification was +being made, up the chain of command - +1: -- a newer inmate could have +been assigned. +: That's why I carried it. +That's why I had (Indiscernible *05:10:23). +So, to, I get calls all hours of the night, +even if I'm off, I'm not off. If there is an +issue, an emergency, I'm called. Yeah. +: Okay. And if someone does +ask, should the SHU officers have been given +the ability? Your answer to that would have +been, you have that phone with you, someone +should have made that notification. So -- +-- someone in the higher -- +: And they - +: -- of command. +-- and they would contact + + +444 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +me. +1: okay• +: So, it was not, like, I'm +off on paper. Because I am using my leave. +But I'm still on duty because you can call me +on my phone. +1: Okay. +: My last two questions. +Based on your conversation, and after this -- +: Thank God. +- based on your +conversations, and this after-action report +that we just reviewed those topics, what are +the failures of the BOP that allowed Epstein to +die? +: I'm not -. I mean, that's - +• I think -. I can't -. That's -. You know, +like, I - again - I'm speculating, and I'm +giving personal opinions. I'm not -- +: Again, and I'm not asking +you to say why he killed himself. +Or if he could have. +What I'm saying is, what are the failures of + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +the BOP? +- +445 +: He killed himself because he +ain't stupid. He said to himself, holy shit, +I'm going to spend the rest of my life in +prison. +Yeah, yeah, and I'm not - +: Yeah. +- and I'm not, +absolutely not asking -- +: No. +-- as far as what is his +mental state, and could have he had the ability +But I can't -- +- but are the failures, +as you see them, after we reviewed all this, +that you believe -. What did the BOP do wrong, +in this instance? Unless you don't think that +they did anything wrong. +: No. I'm not saying they did +anything wrong. But again, these are things +that you are going to find. I mean, right now, +I can look at it and say, we're looking at +people not making rounds and all that. But + + +446 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +there's still an investigation going on. +So, I +don't want to sit here and speculate -- +No, but we are the ones - +- +-- and say - +- doing the +investigation, and - +-- right. +- you are the leader of +the organization that, you know, of the place. +That's why this is a very relevant question for +you to answer because -- +- you know, this was the +facility that you oversaw. +So -- +So, we're just -. All +I'm simply asking is, what do you think the +problems are, as you see them? After you just +heard everything we just talked about for, it +seems like the last five hours. +: No. I mean, if we would +talk - I mean, you're not counting. You didn't +make your rounds in that unit, to check on an +inmate. I mean, that is, that is the basics + + +1 +right there. +2 +3 +4 +5 +6 +7 +8 +447 +: You know, we can talk about +all the other stuff, but the basic is, you did +not go and make those rounds. +: And would you also, +though, add to that the fact that they didn't +replace Reyes -- +_ : +Oh. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +- like they wer supposed +to? +Yes. +Okay. What actions could +the BOP have taken to possibly prevent +Epstein's death? +: It doesn't sound like -- +: - still, you were nervous. +Totally. +That's all. I mean, you could +have -- +It just, it sounds like +they quote, the answer would be, conduct your +rounds, conduct your counts. +Get a -- +: Do your job. + + +1 +2 +3 +4 +5 +6 +7 +8 +Reyes -. +448 +- do your job. +Get +: 99 times out of a 100, it +wouldn't have happened. +Right. So -- +: You know, it's -. +- but in this case, it +does seem, like, a lot of this was a result of +- like you keep on saying - people not doing +their jobs. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: Jobs. +: But I mean -- +: Yeah. +: - but in all fairness, +we've had, since Epstein died, and before, +we've had almost 60 suicides. +So, it's the +same reoccurring theme. +: You know, people not making +their rounds and doing what they're supposed to +do. +: And is that the same +thing that's happening with them, they're not +doing their rounds or counts? +I mean, and nine times out + + +449 +1 +2 +3 +4 +5 +6 +7 +8 +of ten, every time you look into something, it +is a matter of them doing checks, you know, not +counting, you know? So, it's the normal +things. +Are these other +instances, where we find out that they didn't +have cellmates? +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +•: Single cell. You know, I +mean, you have access to the data. I mean, you +1ook at it, and you look at the numbers of +single cell inmates. But there is instances +where, you know, sometimes you do have to put +somebody in a cell single. +Sure. +: But, you know, there is +other suicides, and they don't stop. You know? +Some of it is, you know, staff had no control +over it, and some staff had control over it. +And I do apologize. I +said that was the last question, but I guess I +should ask. In Monday morning quarterbacking +yourself, is there anything that you should +have done differently? +Hmm. +As the MCC warden? + + +1 +2 +3 +4 +5 +6 +7 +8 +situation? +450 +As far as what? This +Yeah. Just anything that +you feel, like, oh, you know, like, I should +have done this better, or I could have done +this better. That type of thing. +I can't. +Just for the record, let +me just -- +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +I can't think of anything +for that. +-- okay. Anything else +you have? +1: No. +: That's it? +Anything that -- +Jesus Christ. +- you wanted to add to +anything, Warden, anything that -- +: I didn't know if you said -- +- we missed, or you want +to -? +: - generally. +: No. No. That's it. +: Is there anything you think + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +armpits. +- +- +451 +we missed asking about? +: Don't ask him that. +_: Not that I can think of. +: You have a right to remain +silent. (Indiscernible *05:15:06). Guys, +listen, you know? +Yeah. No. We got you. +: Like, I was impressed that you +did that. He couldn't go through this. I +would have been to the bathroom, like, I got to +do this, I got to do this. I mean, I got to +make a phone call. I want to take a nap. He +just sat there and answered all the questions. +I mean, he's not - +: Yeah. +: - even sweating under his +And thank you very much - +-- for your cooperation - +No. I appreciate -- +Especially - +- you guys. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +452 +- the recording is +showing that this is five hours and 15 minutes. +So, this was an epic, epic interview. It is +currently 7:18 p.m. on Wednesday, October 27th, +2021. This is Senior Special Agent +, and I am turning off the recorder. + + +1 +2 +3 +4 +5 +6 +7 +8 +453 +CERTIFICATE +I hereby certify that the foregoing pages +represent an accurate transcript of the +electronic sound recording of the proceedings +before the Department of Justice, Office of the +Inspector General in the matter of: +Interview of +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Brianna Rose Burto +Brianna Rose Burton, Transcriber \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/007763e805fa30c81c73fa81d47f9544c843a7b1ddbfdfcc30c0452b445fd57f.receipt.json b/vision-fixhub/ds9-parsed-01/007763e805fa30c81c73fa81d47f9544c843a7b1ddbfdfcc30c0452b445fd57f.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..8e48b4749a64a660536f1cef0a7fd2c09d56660d --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/007763e805fa30c81c73fa81d47f9544c843a7b1ddbfdfcc30c0452b445fd57f.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -22138, + "dataset": "marble-joined", + "doc_id": "007763e805fa30c81c73fa81d47f9544c843a7b1ddbfdfcc30c0452b445fd57f", + "engine": "marble-apple-vision", + "event_count": 461, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "796fe724dcf9badbe4c48907d83312799bad2b53f15307b5b55eeedb4d50e2e3", + "output_sha256": "d2b1f1ba643986e6d8c21e9c37ee58b3fb7edad3e5d822d27348f190d8198769", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/00a28f0dafec65bf47a66b37ad721b3885b93f25031a60fd4e89e19ef7daae51.md b/vision-fixhub/ds9-parsed-01/00a28f0dafec65bf47a66b37ad721b3885b93f25031a60fd4e89e19ef7daae51.md new file mode 100644 index 0000000000000000000000000000000000000000..60b871984079315cb3be91c88f54cb0461e62cfc --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/00a28f0dafec65bf47a66b37ad721b3885b93f25031a60fd4e89e19ef7daae51.md @@ -0,0 +1,813 @@ +NYMDK 530.03 +PAGE 001 +T +COUNT +AREA +B-A +C-A +E-N +E-S +G-N +G-S +H-A +I-N +K-N +K-S +R-A +Z-A +Z-B +TOTAL +COUNT +VERIFY +CENSUS +25 +10 +84 +78 +71 +88 +1 +88 +89 +142 +2 +78 +5 +761 +2 +2 +X +BUREAU OF PRISONS COUNT SHEET +NEW YORK MCC +QTRG EQ **** +OCTG EQ **** +4 z 3 +OUTCOUNT SECTION +F +F +S +H +M +R +S +TR +N +S +н 0 н: +1 +3 +1 +1 +1 +11 +1 +2 +X +2 +14 +1 +• × X +OFFICIAL PREPARING COUNT: +OFFICIAL TAKING COUNT: +COUNT CLEARED TIME: +good verbal +439 +UO +TU +N +3 +1 +13 +23 +08-01-2019 +16:41:45 +VERIFY +COUNT +COUNT COUNT AREA +X +X +XXXXXXXX +25 B-A +10 C-A +83 E-N +75 E-S +70 G-N +88 G-S +1 +H-A +85 +I-N +89 +K-N +129 +K-S +2 +R-A +76 +Z-A +5 +Z-B +738 + + +METROPOLITAN CORRECTIONAL CENTER +NEW YORK, NY +OFFICIAL OUT COUNT +DATE: +FROM: +APPROVED: +8-1-19 +COUNT TIME: +LOCATION: +4:00pm +Hosp +(Staff Member Preparing Out Count) +(Operations Lieutenant) +NAME +REG # +1 85 771-054 +2. +3. +4. +5. +6. +7. +8. +9. +10. +11. +12. +UNIT +KS +13. +14. +15. +16. +17. +18. +19. +20. +21. +22. +23. +24. +OUT-COUNT BY UNIT +E-S +G-N +•R-A +- +. Z-A +REG # +NAME +UNIT +B-A +I-N +C-A +K-N +E-N +K-S +G-S +Z-B +H-A +Total Out-Counted: | +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected count. +Prepare this form in ink. Group the inmates according to their respective housing units. This form is to be used only as an +Out-Count. No other form will be accepted in lieu of the Out-Count Form. + + +NYMDK 530*05* + +ASSIGNMENT: HOSP +CATG ASSIGNMENT +NUM ASSIGNMENT REG NO +0001 HOSP +85771-054 +NAME +INMATE ROSTER +CATG ASSIGNMENT +* +08-01-2019 +15:38:43 +GROUP CODE: +FACILITY: NYM +OPER CATG ASSIGNMENT +OCT DATE +QTR +08-01-2019 K11-054L +WRK +ES AM +SUICIDE OR +G0000 + + +UNITED STATES DEPARTMENT OF JUSTICE +FEDERAL BUREAU OF PRISONS +OFFICIAL OUT-COUNT FORM +Metropolitan Correctional Center +150 Park Row +New York, New York 10007 +Count Time: 4:00 pm +Location: ENYE +Date: 07-31-2019 +From: +(Stall Member Supervising Inmates) +Approved: +(Operations Ljentenant) +REG...... +76539-067 +39715-013 +LN +EN. +... +QTR..... +G01-704U +I01-904L +B-A +H-A +_C-A +E-N +_IN 1K-N +Total Out-Counted: 02 +_E-S +_K-S +G-N 1 G-S +R-A Z-A +Z-B +This Form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR +To The affected count. Prepare this form in ink. Group the inmates according to their respective housing +units. This is to be used only as an Out Count. + + +NYMDK 530*05* +INMATE ROSTER + +ASSIGNMENT: ENYE +CATG +ASSIGNMENT +CATG ASSIGNMENT +NUM ASSIGNMENT REG NO +NAME +0001 FNYE +76539-067 +0002 +39715-013 +* +08-01-2019 +15:38:19 +GROUP CODE: +FACILITY: NYM +OPER CATG ASSIGNMENT +OCT DATE +QTR +08-01-2019 G01-704U +08-01-2019 I01-904L +WRK +UNASSG +UNASSG +GO000 + + +UNITED STATES DEPARTMENT OF JUSTICE +FEDERAL BUREAU OF PRISONS +OFFICIAL OUT-COUNT FORM +Metropolitan Correctional Center +150 Park Row +New York, New York 10007 +Date: 07-31-2019 +Count Time: 4:00 pm +/ +From: +Location: ENYS +(Staff Member Supervising Inmates) +Approved: +PP +(Operations Lieutenant) +REG... +LN. +FN.. +QTR...... +86553-054 +68283-054 +YIRAN +KARLIEK +E03-517U +K12-071U +B-A +H-A +_C-A +_I-N_ +E-N_ 1_E-S +_G-N_ +•G-S +K-N_K-SIR-A_Z-A +Total Out-Counted: 02 +Z-B +This he alete bomb Prepare the form is ind. Croup ones FOrT tVE i upes PRosing +units. This is to be used only as an Out Count. + + +NYMDK 530*05 * + +ASSIGNMENT: ENYS +CATG +ASSIGNMENT +NUM ASSIGNMENT REG NO +0001 FNYS +86553-054 +0002 +68283-054 +MAME +INMATE ROSTER +CATG ASSIGNMENT +* +08-01-2019 +16: 55:56 +GROUP CODE: +FACILITY: NYM +OPER CATG ASSIGNMENT +OCT DATE +QTR +08-01-2019 E03-5170 +08-01-2019 K12-0710 +WRK +UNASSG +UNASSG +G0000 + + +METROPOLITAN CORRECTIONAL CENTER +NEW YORK, NY +OFFICIAL OUT COUNT +DATE: +FROM: +APPROVED: +8/1/19 +COUNT TIME: +LOCATION: +400 рн +F/S +(Staff Member Preparing Out Count) +(Operations Lieutenant) +REG # +177863-112 += 68683-066 +3.86 764-054 +* 51702-069 +576161-054 +6. 86535-054 +7. 50659-018 +8. 86026-054 +9. 86022-054 +10. 08200-070 +#. 85927-054 +1279652-058 +NAME +UNIT +K-S +ES +K-S +K-S +K-S +K-S +ES +Kis +K-S +E-S +KiS +K-S +REG # +NAME +13.79965-055 Thomas Kis +1401735-007 Vattan. +UNIT +KS +16. +17. +18. +19. +20. +21. +22. +23. +24. +B-A +I-N +C-A +K-N +E-N +OUT COUNT BY UNIT +G-N +K-S IT R-A +Z-A +G-S +Z-B +H-A +Total Out-Counted: +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected count. +Prepare this form in ink. Group the inmates according to their respective housing units. This form is to be used only as an +Out-Count. No other form will be accepted in lieu of the Out-Count Form. + + +NYMBU 530*05 * + +ASSIGNMENT: FS +CATG +ASSIGNMENT +NUM ASSIGNMENT REG NO +0001 FS +77863-112 +NAME +0002 +68683-066 +0003 +86764-054 +0004 +51702-069 +0005 +76161-054 +0006 +86535-054 +0007 +50659-018 +0008 +86026-054 +0009 +86022-054 +0010 +08200-070 +0012 +0013 +0014 +85927-054 +01735-007 +79652-054 +79965-054 +INMATE ROSTER +CATG ASSIGNMENT +OCT DATE +QTR +08-01-2019 K12-062U +08-01-2019 B12-593U +08-01-2019 K12-065U +08-01-2019 K09-025U +08-01-2019 K07-007L +08-01-2019 K11-053U +08-01-2019 E07-556U +08-01-2019 K12-061L +08-01-2019 K12-078U +08-01-2019 E09-571U +08-01-2019 K10-045U +08-01-2019 K07-001L +08-01-2019 K08-074U +08-01-2019 K10-044L +* +08-01-2019 +14:28:39 +GROUP CODE: +FACILITY: NYM +OPER CATG ASSIGNMENT +WRK +ES PM +SUICIDE OR +FS PM +FS PM +SUICIDE OR +ES PM +ES PM +FS PM +FS PM +FS PM +FS PM +ES PM +LAUNDRY 1 +ES PM +ES AM +FS PM +FS PM +GO000 +TRANSACTION SUCCESSFULLY +COMPLETED +• + + +DATE: +FROM: +APPROVED: +REG # +1. +91126-053 +2. +86019-054 +3. 76318-054 +4. +78514-054 +5. +6. +7. +8. +9. +10. +11. +12. +B-A +I-N +METROPOLITAN CORRECTIONAL CENTER +NEW YORK, NY +OFFICIAL OUT COUNT +08-01-19 +(Still +Dut Count) +(Operations Lieutenant) +NAME +UNIT +Epstein +IN +ZA +ZA +COUNT TIME: +LOCATION: +REG # +pM +Atly Cont +NAME +UNIT +13. +14. +15. +16. +17. +18. +19. +20. +21. +22. +23. +24. +H-A +N +C-A +K-N +EN - +K-S +OUT-COUNT BY UNIT +G-N +E-S +Z-A +R-A +G-S +Z-B +Total Out-Counted: +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected count. +Prepare this form in ink. Group the inmates according to their respective housing units. This form is to be used only as an +Out-Count. No other form will be accepted in lieu of the Out-Count Form. + + +NYMDK 530*05 * + +ASSIGNMENT: ATTY +OPER CATG +ASSIGNMENT +NUM ASSIGNMENT REG NO +NAME +0001 ATTY +91126-053 +0002 +76318-054 EPSTEIN +0003 +86019-054 +0004 +78514-054 +INMATE ROSTER +CATG ASSIGNMENT +* +08-01-2019 +15:50:29 +GROUP CODE: +FACILITY: NYM +CATG +ASSIGNMENT +OCT DATE +OTR +08-01-2019 I04-930U +WRK +UNASSG +08-01-2019 Z04-206LAD UNASSG +08-01-2019 I03-9220 +UNASSG +08-01-2019 Z06-215UAD UNASSG +GO000 + + +Metropolitan Correctional Center +Official Count Slip +Date +08-119 +Time: _ +Losin +Unit: — +Count: +Print Name: +Signature: +Print Name: +Signature +Metropolitan Correctional Center +Official Count Slip +65 +88 +Date: 01 412019 +Time: +Metropolitan Correctional Center +Official Count Slip +KN +Date: +Unit: +Count: +Print Name: +Signature: +Print Name: +Signature: +8 + 2019 +Time: +4:00pm. +Metropolitan Correctional Center +Official Count Slip +_ Date_ +Augt, 2019 +Time:_ +Unit: _ +Count: +Print Name: +Signature: +Print Name: +Signature +Unit: +Count: +G +:70 +Print Name: +Signature: +Print Name: +Signature +Metropolitan Correctional Center +Official Count Slip +Date. +5/119 +Time: +4:00pM +Unit: _ +IA +Count: +Metropolitan Correctional Center +Official Count Slip +Date 8. 1.2019 +4 +:0spm +Print Nar +Signature +Print Nan +Signature +Unit: _ +BA +Count: +25- +Print Name: — +Signature: +Print Name: +Metropolitan Correctional Center +Official Count Slip +Date 08/01144 +_ Time: 400? +Signature +Unit: +ES +Count: +Metropolitan Correctional Center +Official Count Slip +8/1719 +Time: +4.00pm +Print Name: +Signature: +Print Name: +Signature +Metropolitan Correctional Center +Official Count Slip +Unit:_ +HA +Date. +Time: +Count: +4:080 +Print Name: +Signature: +Print Name: +Signature, + + +Unit: +Count: +Metropolitan Correctional Center +Official Count Slip +Dato 8/1419 +16 +Time: 4:00 pm +Print Name: +Signature: +Print Name: +Signature. +Unit: FMYS +Count: +Metropolitan Correctional Center +Official Count Slip +Au 01,2019 +Time: +Print Name: +Signature: +Print Name: _ +Signature +Unit: +MOSP +Count: +Print Name: +Signature: +Print Name: +Signature +Metropolitan Correctional Center +Official Count Slip +Dato 08/0119 +me: 400 +RECTARISO +Tones +Unit: +A +Count: _ +Metropolitan Correctional Center +Official Count Slip +_Date _ +Aug At: 2019 +_ Time:_ +Print Name: +Signature: +Print Name: +Signature_ +Metropolitan Correctional Center +Official Count Slip +Unit: +_ Date +Count: +Print Name: +Signature: +Print Name: +Signature +Metropolitan Correctional Center +Official Count Slip +Unit: +Atty +Date: +Count: +Time: +ST 19 +удо +Print Name: +2. 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After +being +advised of the identities of the agents and the purpose of the +interview, JIMENEZ provided the following information: +On Friday (August 09, 2019) and Saturday (August 10, 2019) JIMENEZ was in +I-tier, cell #215, Special Housing Unit. JIMENEZ first got to I-tier on +August Ist at approximately 5AM. +JIMENEZ knew who JEFFREY EPSTEIN was. On the evening of Friday August 09, +2019, JIMENEZ was awake and listening to the radio in his cell. JIMENEZ +advised there was a male and woman working that night. JIMENEZ described the +woman as small and chubby, and as someone JIMENEZ recognized as someone he +had seen work in the SHU before. JIMENEZ advised the male was also a usual +worker in SHU. JIMENEZ described the male as a black male with a medium +build. +JIMENEZ recalled the guards did a few rounds that night but could not +recall the exact times of the rounds. +JIMENEZ recalled waking up around 6am on Saturday, August 10, 2019 and +hearing possibly a male voice saying "breathe." The last time JIMENEZ saw +EPSTEIN was when he was on a stretcher being taken out of his cell. JIMENEZ +could not recall if there were any marks on EPSTEIN's face. JIMENEZ advised +EPSTEIN's eyes were closed. +JIMENEZ advised he could not see inside EPSTEIN's cell but could see +EPSTEIN's door. JIMENEZ recalled food being brought to EPSTEIN's cell on +friday evening +and believes EPSTEIN's roommate was not in the cell with +EPSTEIN that night. JIMENEZ does not recall seeing anyone go into or out of +Investigation on +08/16/2019 +at New York, New York, United States (In Person) +File # +90A-NY-3151227 +Date drafted 08/19/2019 +by +This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your agency; it and its contents are not +to be distributed outside your agency. + + +90A-NY-3151227 Serial 48 +FD-302a (Rev. 5-8-10) +90A-NY-3151227 +Continuation of FD-302 of 054) +(U) Interview of Edward Jimenez (79466- +, On +08/16/2019 +_ Page 2 of 2 +EPSTEIN's cell after EPSTEIN was given food that night. JIMENEZ did not +recall hearing any doors pop open that evening. diff --git a/vision-fixhub/ds9-parsed-01/00a4470c66ed8c8668b4b7428f268270fd0576adeab50300ab74c4ec5baaf5a5.receipt.json b/vision-fixhub/ds9-parsed-01/00a4470c66ed8c8668b4b7428f268270fd0576adeab50300ab74c4ec5baaf5a5.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..970c6f515ecc72f3e1b9412792a2a82badeea193 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/00a4470c66ed8c8668b4b7428f268270fd0576adeab50300ab74c4ec5baaf5a5.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "00a4470c66ed8c8668b4b7428f268270fd0576adeab50300ab74c4ec5baaf5a5", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "5a1ef5ce6d5cf741c482ceb367555c076de6e87736969d432972ecbccaa0bfff", + "output_sha256": "5370f979f62b2cb7b1aa0a264478f3db96ac6dea7ea75ea9364a227967d5fe70", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/00a894b2e2e5bdd53189559ad403bde98871f4918944e282a57aa1609e03fa5e.md b/vision-fixhub/ds9-parsed-01/00a894b2e2e5bdd53189559ad403bde98871f4918944e282a57aa1609e03fa5e.md new file mode 100644 index 0000000000000000000000000000000000000000..b78ba889b0b43a9b60d58fca820f805fb81c5d28 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/00a894b2e2e5bdd53189559ad403bde98871f4918944e282a57aa1609e03fa5e.md @@ -0,0 +1,90 @@ +EDWARDS +POTTINGER LLC +Florida Office +Bradley J. Edwards *0t +Seth M. Lehrman "+ +Brittany N. Henderson *0 +Matthew D. Weissing *f +425 North Andrews Avenue +Suite 2 +Fort Lauderdale, FL 33301 +Telephone (954)524-2820 +Fax (954)524-2822 +October 21, 2020 +FOIA PRIVACY EXEMPTION +VIA E-MAIL AND FEDEX +The Honorable Geoffrey S. Berman +United States Attorney for the +Southern District of New York +New York Office +J. Stanley Pottinger ‡ +• ramire imitat in Callois +• Admittal in Florida +1 and Cried Gird Trial ayer +Assistant United States Attorney +86 Chambers Street, Third Floor +New York, New York 10007 +Re: +Request for Tangible and Documentary Evidence (Touhy Request) +Dear +In follow up to our previous communications, please accept this as our formal written request for +documentary and tangible evidence currently in the in the possession, custody, and control of the +Department of Justice by way of the Southern District of New York relating to the sexual abuse of +one of Jeffrey Epstein's many victims, +C.S.. R. et seg, Should you Find here to be any date is why neu request please not 2% +' To protect her anonymity, our client, +have referred to her herein as +has elected to proceed as a +As such, we + + +Page 2 +We specifically seek copies of the following documents that we believe are currently in the +possession of the Government: +1) Photographs of +2) Videos of +3) Arovides oratoreys dence between Jeffrey Epascin, his agens employes, medical +4) Any and all records of purchases of gifts or anything of value purchased for or sent to +5) Any and all records showing that a letter or package was sent via U.S. Mail, UPS, FedEx, +or by any other means of shipping from Jeffrey Epstein, his agents, or his employees to +6) Any and all records of payments made to medical providers on behalf of +7) Any and all documents including +true name; +8) Any and all lists including +true name; and +9) Any and all other documentary materials relating in any way to +Pursuant to the Touhy regulations set forth by the Department of Justice, the Deputy or Associate +Attorney General assesses the following considerations in determining whether disclosure is +warranted: +(a)(1) Whether such disclosure is appropriate under the rules of procedure +governing the case or mater in which the demand arose; +(a)(2) Whether disclosure is appropriate under the relevant substantive law of +privilege. This request satisfies both of these considerations. As explained +previously, the requested non-privileged documentary evidence directly concerns +the allegations in +civil case. +Due to the establishment of the Epstein Victim Compensation Program that is currently underway, +seeks this information in order to properly submit her claim for consideration, and if +necessary, to proceed by way of formal litigation. The requested information is within the scope +of ordinary practice and does not seek disclosure of information prohibited by statute or regulation. +Furthermore, this request does not seek information that is classified or that would reveal the +source or identity of any informant. To that effect, +specifically does not request any +investigatory records compiled for law enforcement purposes that would interfere with ongoing +law enforcement proceedings. +simply requests information in the Government's +possession that will assist in the prosecution of her claims and ultimately, aid in her ability to + + +Page 3 +finally obtain the justice that she deserves. To the extent that the requested materials can be made +available to +on an expedited basis, it would be greatly appreciated. +Please contact us at your earliest convenience to discuss the identity of L +which time we are fully prepared to answer any questions that you may have. +in more detail, at +Very truly yours, +EDWARDS POTTINGER LLC +BEe +Bradley Edwards +Brittany Henderson diff --git a/vision-fixhub/ds9-parsed-01/00a894b2e2e5bdd53189559ad403bde98871f4918944e282a57aa1609e03fa5e.receipt.json b/vision-fixhub/ds9-parsed-01/00a894b2e2e5bdd53189559ad403bde98871f4918944e282a57aa1609e03fa5e.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..2c5d58c8e9030e0e3859f3d3d652c97184fd9e94 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/00a894b2e2e5bdd53189559ad403bde98871f4918944e282a57aa1609e03fa5e.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -36, + "dataset": "marble-joined", + "doc_id": "00a894b2e2e5bdd53189559ad403bde98871f4918944e282a57aa1609e03fa5e", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "c38a7ae659fffdba31a35989bf6352e2d48e50466744d10818bf51397ca0d127", + "output_sha256": "5da4f669b3d244eaf2a00a43104061a517b45ea8a6a53a18d54310fd48c6ed3d", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/00bc1c5d9730c316bdd43978267a5c57ae66b0f7d2712ef776fc2872a7c802c0.md b/vision-fixhub/ds9-parsed-01/00bc1c5d9730c316bdd43978267a5c57ae66b0f7d2712ef776fc2872a7c802c0.md new file mode 100644 index 0000000000000000000000000000000000000000..0440ec917a35d0922fa06ab02d016d4bdf4d7ae2 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/00bc1c5d9730c316bdd43978267a5c57ae66b0f7d2712ef776fc2872a7c802c0.md @@ -0,0 +1,1573 @@ +DATE: +FROM: +APPROVED: +7-23-19 +(Staff Member Preparing Out Count) +COUNT TIME: 400in +LOCATION: Ate +REG # +NAME +176318-054 Sostanc +UNIT +HA +REG # +13. +14. +15. +NAME +UNIT +3. +4. +5. +6. +7. +8. +9. +10. +11. +12. +16. +17. +18. +19. +20. +21. +22. +23. +24. +B-A +IN +C-A +K-N +E-N +K-S +OUT-COUNT BY UNIT +E-S +G-N +R-A +Z-A +G-S +Z-B +H-AL +Total Out-Counted: +1 +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected count. +Prepare this form in ink. Group the inmates according to their respective housing units. This form is to be used only as an +Out-Count. No other form will be accepted in lieu of the Out-Count Form. + + + +NUM ASSIGNMENT REG NO +NAME +0001 ATTY +76318-054 EPSTEIN +07-23-2019 +15:28: 55 +GROUP CODE: +FACILITY: NYM +OCT DATE +eTR +07-23-2019 H01-001L +WRK +TRANSACTION SUCCESSFULLY +COMPLETED + + +DATE: +FROM: +APPROVED: +7/24/19 +COUNT TIME: +4:00 pm +LOCATION: +AttY-CONE. +(Staff Member Preparing Out Count) +(Operations Lieutenant) +REG # +NAME +UNIT +I 76318-054 EPStEiN HA +278514-054 TARtAGLiONEZA +4. +5. +6. +7. +8. +9. +10. +11. +12. +REG # +NAME +13. +14. +15. +16. +17. +18. +19. +20. +2I. +UNIT +B-A +I-N +C-A +K-N +E-N +K-S +24. +OUT-COUNT BY UNIT +E-S +G-N +_ R-A +Z-A +G-S +Z-B +H-A +Total Out-Counted: +2 +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected count. +Prepare this form in ink. Group the inmates according to their respective housing units. This form is to be used only as an +Out-Count. No other form will be accepted in lieu of the Out-Count Form. + + +- NYMAQ 530*05 * + +NUM ASSIGNMENT REG NO +NAME +0001 ATTY +76318-054 EPSTEIN +0002 +78514-054 TARTAGLIONE +CATG ASSIGNMENT +* +07-24-2019 +15:37:50 +GROUP CODE: +FACILITY: NYM +OCT DATE +OTR +WRE +07-24-2019 H01-001L +07-24-2019 Z06-215UAD UNASSG + + +DATE: +7-25-19 +COUNT TIME: +FROM: +APPROVED: +(Staff Member Preparing Out Count) +operations Literan +REG # +NAME, +UNIT +126318-054 Epstein t-A T +13. +9079/- 054 ELANSKY G-AC +14. +378514-054 TArTASTONe ZiA +15. +16. +5. +17. +6. +18. +7. +19. +8. +20. +9. +21. +10. +22. +11. +23. +12. +24. +LOCATION: +400 Pm +Atty +REG # +NAME +UNIT +B-A +I-N +C-A +K-N +E-N +K-S +OUT-COUNT BY UNIT +E-S +G-N +- RA — +Z-A +H-A 1 +Total Out-Counted: +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected count. +Prepare this form in ink. Group the inmates according to their respective housing units. This form is to be used only as an +Out-Count. No other form will be accepted in lieu of the Out-Count Form. + + +NYMDK 530*05 * + +NUM ASSIGNMENT REG NO +NAME +0001 ATTY +90791-054 ELANSKY +0002 +76318-054 EPSTEIN +0003 +78514-054 TARTAGLIONE +CATG - ASSIGNMENT +* +07-25-2019 +15:36:23 +GROUP CODE: +FACILITY: NYM +ASSIGNMENT +OCT DATE QTR +WRK +07-25-2019 G01-703L UNASSG +07-25-2019 H01-001L +07-25-2019 Z06-215UAD UNASSG + + +DATE: +1-26-19 +COUNT TIME: +FROM: +LOCATION: +(Staff Member Preparing Out Count) +APPROVED: +(Operations Lieutenant) +REG # +NAME +UNIT +1.19735-104 +Mones-C Gis +3. 76318-054 Epstein HA +4. +5. +6. +7. +8. +9. +10. +11. +12. +REG # +13. +15. +16. +17. +18. +19. +20. +21. +2z. +23. +24. +OUT-COUNT BY UNIT +E-S +G-N +R-A +Z-A +400pm +AHY +NAME +UNIT +B-A +I-N +C-A +K-N +E-N +K-S +G-S +Z-B +H-A L +Total Out-Counted: +2 +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected count. +Prepare this form in ink. Group the inmates according to their respective housing units. This form is to be used only as an +Out-Count. No other form will be accepted in lieu of the Out-Count Form. + + +NYMH3 530*05 * + +ASSIGNMENT +NUM ASSIGNMENT REG NO +NAME +0001 ATTY +76318-054 EPSTEIN +0002 +19735-104 MONES-CORO +* +07-26-2019 +15:14:09 +GROUP CODE: +FACILITY: NYM +OCT DATE +QTR +07-26-2019 HO1-001L +07-26-2019 G07-756U +WRK + + +DATE: +FROM: +APPROVED: +7-27-19 +COUNT TIME: 10:00AM +LOCATION: _ +Alty +(Staff Member Preparing Out Count) +(operations Lieutenant +REG # +NAME +UNIT +178514 - 054 Tartaglione ZA +276317-054 EPSTEIN HA +REG # +NAME +UNIT +4. +5. +6. +7. +8. +9. +10. +11. +12. +13. +14, +15. +16. +17. +18. +19. +20. +21. +22. +23. +24. +B-A +I-N +C-A +K-N +E-N +K-S +OUT-COUNT BY UNIT +E-S +G-N +R-A +Z-A +G-S +Z-B +H-A L +Total Out-Counted: +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected count +Prepare this form in ink. Group the inmates according to their respective housing units. This form is to be used only as an +Out-Count. No other form will be accepted in lieu of the Out-Count Form. + + +NYMCO 530*05 * + +CATG ASSIGNMENT +CATG ASSIGNMENT +NUM ASSIGNMENT REG NO +NAME +0001 ATTY +76318-054 EPSTEIN +0002 +78514-054 TARTAGLIONE +* +GROUP CODE: +07-27-2019 +09:35:3 +FACILITY: NYM +OCT DATE QTR +WRK +07-27-2019 H01-001L +07-27-2019 Z06-215UAD UNASSG + + +DATE: +FROM: +APPROVED: +7-27-19 +COUNT TIME: +400 Pm +LOCATION: +ty +(Staff Member Preparing Out Count) +(Operations Lieutenant) +NAME +• UNIT +176319-054 ERStRIN HA +REG # +NAME +UNIT +3. +4. +5. +6. +7. +8. +9. +10. +11. +12. +13. +14. +15. +16. +17. +I8. +19. +20. +21. +22. +- +23. +24. +B-A +I-N +C-A +K-N +E-N +K-S +OUT-COUNT BY UNIT +E-S +G-N +R-A +Z-A +G-S +Z-B +H-A +Total Out-Counted: +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected count. +Prepare this form in ink. Group the inmates according to their respective housing units. This form is to be used only as an +Out-Count. No other form will be accepted in lieu of the Out-Count Form. + + + +NUM ASSIGNMENT REG NO +NAME +0001 ATTY +76318-054 EPSTEIN +CATG ASSIGNMENT +* +07-27-2019 +15:21:57 +GROUP CODE: +FACILITY: NYM +09-20-2019 H02-0022 +WRK + + +07/28/19 +DATE: +FROM: +(Staff Member Preparing Out Count) +10:00Am +COUNT TIME: +гостох. Aty ConF +APPROVED: +/(Operations Lieutenant) +REG # +NAME +136943-054 +MACK +285984-054 CABA BAtiSA +3. +76318-054 Epstein +4. +5. +6. +7. +UNIT +REG# +8. +9. +10. +11. +12. +13. +14. +15. +16. +17. +18. +19. +20. +21. +22. +23. +24. +UNIT +B-A +I-N +C-A +K-N +E-N +K-S +OUT COUNT BY UNIT +G-N +Z-A +1 +G-S +Z-B +H-A 1 +Total Out-Counted: +3 +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected count. +Prepare this form in ink. Group the inmates according to their respective housing units. This form is to be used only as an +Out-Count. No other form will be accepted in lieu of the Out-Count Form. + + +NYMBH 530*05 * + +CATG +ASSIGNMENT +OPER CATG ASSIGNMENI +NUM ASSIGNMENT REG NO +NAME +0001 ATTY +85984-054 CABA BATISTA +0002 +76318-054 EPSTEIN +0003 +86943-054 MACK +* +07-28-2019 +09:38:57 +GROUP CODE: +FACILITY: NYM +ASSIGNMENT +OCT DATE +QTR +07-28-2019 K03-123U +07-28-2019 H01-001L +07-28-2019 GO5-737U +WRK +UNIT 11N + + +DATE: +7/28/19 +COUNT TIME: +FROM: +' +LOCATION: +(Staff Member Preparing Out Count) +APPROVED: +(Operations Lieutenant) +REG # +NAME +UNIT +185942-054 Cazarez KS +2.76318-054 +Epstein HA +3. +4. +5. +6. +7. +8. +9. +10. +11. +12. +REG # +13. +14. +15. +16. +17. +18. +19. +20. +21. +22. +23. +24. +B-A +I-N +OUT-COUNT BY UNIT +E-S +G-N +T R-A +Z-A +4:00pm +Atty conf +NAME +UNIT +C-A +K-N +E-N +K-S +G-S +Z-B +Total Out-Counted: +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected count. +Prepare this form in ink. Group the inmates according to their respective housing units. This form is to be used only as an +Out-Count. No other form will be accepted in lieu of the Out-Count Form. + + + +CATG ASSIGNMENT +NUM ASSIGNMENT REG NO +NAME +0001 ATTY +85942-054 CAZAREZ +0002 +76318-054 EPSTEIN +CATG ASSIGNMENT +* +37-28-201 +5:51:2 +GROUP CODE: +FACILITY: NYM +OCT DATE +OTR +07-28-2019 K10-046L +07-28-2019 H01-001L +WRK +GO0OO + + +NEW YORK, NX +07/28/19 +DATE: +FROM: +APPROVED: +(Staff Member Preparing Out Count) +COUNT TIME: +10:00Am +LOCATION: Atty ConF +REG # +NAME +136943-054 MACK +285984-054 CABA BAtiSA +3. 76318-054 Epstein +4. +5. +6. +7. +8. +9. +10. +11. +12. +UNIT +REG # +NAME +UNIT +13. +14. +15. +16. +17. +18. +19. +20. +21. +22. +23. +24. +OUT-COUNT BY UNIT +E-S +G-N +R-A +Z-A +B-A +I-N +C-A +K-N +E-N +K-S +G-S +Z-B +H-A 1 +Total Out-Counted: +3 +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected count. +Prepare this form in ink. Group the inmates according to their respective housing units. This form is to be used only as an +Out-Count. No other form will be accepted in lieu of the Out-Count Form. + + +NYMBH 530*05 * + +ASSIGNMENT +NUM ASSIGNMENT REG NO +NAME +0001 ATTY +85984-054 CABA BATISTA +0002 +76318-054 EPSTEIN +0003 +86943-054 MACK +CATG ASSIGNMENT +* +07-28-2019 +09:38:57 +GROUP CODE: +FACILITY: NYM +OCT DATE QTR +07-28-2019 K03-123U +07-28-2019 H01-001L +07-28-2019 G05-737U +WRK. +UNIT 11N + + +DATE: +FROM: +07-31-19 +- +Tromas +(Staff Member Preparing Out Count) +APPROVED: +(Operations Lieutenant) +REG # +NAME +1. 91126-653 Araujo +2. +3. +76318.054 Epstein +4. +5. +6. +7. +8. +9. +10. +11. +12. +UNIT +IN +ZA +COUNT TIME: +LOCATION: +REG # +13. +14. +15. +16. +17. +18. +19. +20. +21. +22. +23. +24. +OUT-COUNT BY UNIT +E-S +G-N +-R-A +Z-A +400 pm. +Atly +NAME +UNIT +B-A +I-N +C-A +K-N +E-N +K-S +G-S +Z-B +H-A +Total Out-Counted: +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected count. +Prepare this form in ink. Group the inmates according to their respective housing units. This form is to be used only as an +Out-Count. No other form will be accepted in lieu of the Out-Count Form. + + + +CATG ASSIGNMENT +NUM ASSIGNMENT REG NO +NAME +0001 ATTY +91126-053 ARAUJO +0002 +76318-054 EPSTEIN +CATG ASSIGNMENT +* +07-31-2019 +15:34:37 +GROUP CODE: +FACILITY: NYM +OCT DATE +WRK +07-31-2019 I04-930U +07-31-2019 Z04-206LAD UNASSG + + +COUNT TIME: +DATE: +FROM: +08-01-19 +hones +(Staff Member Preparing Out Count) +LOCATION: +400 pm +Atly Cont +- +APPROVED: +(Operations Lieutenant) +UNIT +NAME +REG # +NAME +REG # +1. +91126-053 ARAUTO +2. +86019-054 Myrie +UNIT +IN +IN +ZA +3. 76.318-054 Epstein +4. +78514-054 TARTAGIONe ZA +5. +6. +13. +14. +15. +16. +17. +18. +19. +20. +7. +8. +21. +22. +9. +23. +10. +11. +24. +12. +OUT-COUNT BY UNIT +G-N +G-S +H-A +E-S +Z-A +R-A +Z-B +E-N +C-A +B-A +K-S +K-N +I-N +Total Out-Counted: +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected cou +Prepare this form in ink. Group the inmates according to their respective housing units. This form is to be used only as a +Out-Count. No other form will be accepted in lieu of the Out-Count Form. + + +NYMDK 530*05* + +ASSIGNMENT +CATG ASSIGNMENT +NUM ASSIGNMENT REG NO +0001 ATTY +91126-053 ARAUJO +0002 +76318-054 EPSTEIN +0003 +86019-054 MYRIE +0004 +78514-054 TARTAGLIONE +* +08-01-2019 +15:50:29 +GROUP CODE: +FACILITY: NYM +OCT DATE +08-00-20291049300 +WRK +08-01-2019 Z04-206LAD UNASSG +08-01-2019 I03-922U +08-01-2019 Z06-215UAD UNASSG + + +DATE: +812/88 +FROM: +(Staff Member Preparing Out Count) +APPROVED: +(Operations Lieutenant) +REG # +NAME +76318.051 +91/26.053 +ARANTO +UNIT +ZA +IN +COUNT TIME: +LOCATION: +y: Ph +ATTY +REG # +1. +2. +3. +4. +5. +6. +7. +8. +9. +10. +11. +12. +B-A +I-N +13. +14. +15. +16. +17. +18. +19. +20. +21. +22. +23. +24. +OUT-COUNT BY UNIT +E-S +R-A +G-N +Z-A +NAME +UNIT +C-A +K-N +E-N +K-S +G-S +Z-B +H-A +Total Out-Counted: +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected count. +Prepare this form in ink. Group the inmates according to their respective housing units. This form is to be used only as ar +Jut-Count. No other form will be accepted in lieu of the Out-Count Form + + +NYMDW 530*05 * + +CATG ASSIGNMENT +NUM ASSIGNMENT REG NO +NAME +0001 ATTY +91126-053 ARAUJO +0002 +76318-054 EPSTEIN +* +08-02-2019 +16:30:09 +GROUP CODE: +FACILITY: NYM +OCT DATE +QTR +WRK +08-02-2019 104-930U +08-02-2019 204-206LAD UNASSG +TRANSACTION SUCCESSFULLY +COMPLETED + + +8•3. 19 +COUNT TIME: +4pm +LOCATION: Atty. Conf +DATE: +FROM: +APPROVED: +1. +REG # +76318-054 +2. +3. +4. +5. +6. +7. +8. +9. +flember Proparing Out Count) +(Operations testenant) +NAME +Epstein +UNIT +ZA +NAME +UNIT +REG # +13. +14. +15. +16. +17. +18. +19. +20. +21. +22. +23. +24. +B-A +I-N +C-A +K-N +E-N +K-S +OUT-COUNT BY UNIT +G-N +E-S +Z-A +R-A +1 +G-S +Z-B +H-A +Total Out-Counted: +1 +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected cou +Prepare this form in ink. Group the inmates according to their respective housing units. This form is to be used on ly as at +Out-Count. No other form will be accepted in lieu of the Out-Count Form. + + + +ASSIGNMENT +CATG ASSIGNMENT +NUM ASSIGNMENT REG NO +NAME +0001 ATTY +76318-054 EPSTEIN +* +08-03-2019 +15:55:18 +GROUP CODE: +FACILITY: NYM +OCT DATE +QTR +WRK +08-03-2019 Z04-206LAD UNASSG + + +DATE: +FROM: +APPROVED: +8-3-19 +COUNT TIME: +00 +10 Am +LOCATION: Att7. Conf. +(Staff Melber Preparing Out Count) +(Operations Lieutenant) +NAME +worris +Epstein +UNIT +KS +2A +REG # +1.86407-054 +2.76318-054 +3. +4. +5. +6. +7. +8. +9. +10. +11. +12. +REG # +NAME +UNIT +13. +14. +15. +16. +17. +18. +19. +20. +21. +22. +23. +24. +OUT-COUNT BY UNIT +E-S +R-A +G-N +Z-A +! +B-A +I-N +C-A +K-N +E-N +K-S +G-S +Z-B +H-A +Total Out-Counted: +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected count. +Prepare this form in ink. Group the inmates according to their respective housing units. This form is to be used only as an +Out-Count. No other form will be accepted in lieu of the Out-Count Form. + + +NYMA3 530*05* + +NUM ASSIGNMENT REG NO +NAME +0001 ATTY +76318-054 EPSTEIN +0002 +86407-054 NORRIS +CATG ASSIGNMENT +* +08-03-2019 +09:30:02 +GROUP CODE: +FACILITY: NYM +OCT DATE +OTR +WRK +08-03-2019 Z04-206LAD UNASSG +08-03-2019 K12-069L + + +DATE: +8/04/19 +COUNT TIME: +10:00 AM +FROM: +(Staff Member Prepáring Out Count) +APPROVED: +Operations Lieutenant) +REG # +NAME +UNIT +.. / +1. 86943-054 MAcK +2. 78514-051 TARTAGLIONE ZA +376318-054 Restein +ZA +5. +6. +7. +8. +9. +10. +11. +12. +13. +14. +15. +16. +17. +18. +19. +20. +21. +22. +23. +24. +LOCATION: +Alty conF +REG # +NAME +UNIT +B-A +I-N +C-A +K-N +E-N +K-S +OUT-COUNT BY UNIT +E-S +G-N +R-A +Z-A +2 +G-S +Z-B +H-A - +Total Out-Counted: +3 +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected count. +Prepare this form in ink. Group the inmates according to their respective housing units. This form is to be used only as an +Out-Count. No other form will be accepted in lieu of the Out-Count Form. + + +NYMBH 530*05 + +CATG ASSIGNMENT +NUM ASSIGNMENT REG NO +NAME +0001 ATTY +76318-054 EPSTEIN +0002 +86943-054 MACK +0003 +78514-054 TARTAGLIONE +* +08-04-2019 +09: 57:51 +GROUP CODE: +FACILITY: NYM +OCT DATE +QTR +WRK +08-04-2019 204-206LAD UNASSG +08-04-2019 G05-737U +08-04-2019 206-215UAD UNASSG +GOOOO +TRANSACTION +SUCCESSFULLY COMPLETED + + +3/5/19 +DATE: +FROM: +APPROVED: +COUNT TIME: +LOCATION: +4pм +Athy conf +(Staff Member Preparing Out Count) +REG # +NAME +176318-034 EpsTEIN. +2 71126-055 ArAUjo +3. 86020-054 Toros +477750-0541 Popol +6. +7. +8. +9. +10. +11. +12. +REG # +NAME +UNIT +13. +17. +19. +20. +21. +22. +23. +B-A +I-N +C-A +K-N +E-N +K-S +OUT-COUNT BY UNIT +E-S +G-N +R-A +Z-A +G-S +Z-B +H-A +Total Out-Counted: +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected count. +Prepare this form in ink. Group the inmates according to their respective housing units. This form is to be used only as an +Out-Count. No other form will be accepted in lieu of the Out-Count Form. + + + +NUM ASSIGNMENT REG NO +NAME +0001 ATTY +0002 +91126-053 ARAUJO +76318-054 EPSTEIN +0003 +77980-054 ROPER +0004 +86020-054 TORRES +CATG ASSIGNMENT +* +08-05-2019 +15:20:04 +GROUP CODE: +FACILITY: NYM +ASSIGNMENT +OCT DATE +OTR +WRK +08-05-2019 I04-930U +08-05-2019 204-206LAD UNASSG +08-05-2019 I01-904L +08-05-2019 Z03-110LAD UNASSG +GOO0O +TRANSACTION +SUCCESSFULLY COMPLETED + + +DATE: +FROM: +APPROVED: +8-6-19 +COUNT TIME: +400 pM +LOCATION: Att conf +(Staff Member Preparing Out Count) +(Operations Lieutenant) +REG # +NAME +1 91126053 ARcuso +2 16318054 Epsten +3. 14532104 Moore +* 78Sin054 TarTagLione +5. +6. +7. +8. +ZA +Kl +N +LA +9. +10. +11. +12. +REG # +NAME +UNIT +13. +14. +15. +16. +17. +18. +19. +20. +21. +22. +23. +24. +B-A +I-N +C-A +K-N +E-N +K-S +OUT-COUNT BY UNIT +E-S +G-N +R-A +Z-A +G-S +Z-B +H-A +Total Out-Counted: +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected count. +Prepare this form in ink. Group the inmates according to their respective housing units. This form is to be used only as an +Out-Count. No other form will be accepted in lieu of the Out-Count Form. + + + +NUM ASSIGNMENT REG NO +NAME +0001 ATTY +91126-053 ARAUJO +76318-054 EPSTEIN +0003 +14532-104 MOORE +78514-054 TARTAGLIONE +CATG ASSIGNMENT +* +08-06-2019 +15:41:08 +GROUP CODE: +FACILITY: NYM +OCT DATE +OTR +WRK +08-06-2019 I04-930U +08-06-2019 204-206LAD UNASSG +08-06-2019 K06-145U +08-06-2019 Z06-215UAD UNASSG + + +DATE: +8-7-19 +COUNT TIME: 4:00pM +LOCATION: Attorney Conf. +FROM: +(Start Member Hang at County +- +APPROVED: +REG # +176318-054 +2. +3. +4. +5. +6. +NAME +Epstein +UNIT +ZA +13. +14. +15. +REG # +NAME +UNIT +16. +17. +8. +9. +18. +19. +20. +21. +22. +23. +24. +B-A +I-N +C-A +K-N +E-N +K-S += +OUT-COUNT BY UNIT +G-N +E-S +R-A +Z-A +G-S +Z-B +H-A +Total Out-Counted: +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected count +Prepare this form in ink. Group the inmates according to their respective housing units: This form is to be used only as an +Out-Count. No other form will be accepted in lieu of the Out-Count Form. + + + +NUM ASSIGNMENT REG NO +NAME +0001 ATTY +76318-054 EPSTEIN +CATG. ASSIGNMENT +* +08-07-2019 +15:29:04 +GROUP CODE: +FACILITY: NYM +00- 7-2029 204-206 LAD VIRASSG + + +DATE: +8/3/9 +COUNT TIME: +LOCATION: +Hitty. +CoNE +FROM: +(Staff Member Preparing Our Count) +APPROVED: +(Operations Lieutenant) +NAME +REG # +1. 91126:053 firfujo +2 76318-05+ EpstEin +3. 7776-018 IMZANTY +4. +5. +6. +7. +8. +UNIT +I +G +9. +10. +11. +12. +NAME +REG # +UNIT +13. +14. +15. +16. +17. +18. +19. +20. +21. +22. +23. +24. +B-A +I-N +C-A +K-N +E-N +K-S +- +OUT-COUNT BY UNIT +G-N +E-S +R-A +Z-A +G-S +Z-B +1 +H-A +Total Out-Counted: +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected coun +Prepare this form in ink. Group the inmates according to their respective housing units: This form is to be used only as an +Out-Count. No other form will be accepted in lieu of the Out-Count Form. + + +NYMDK 530*05 * + +NUM ASSIGNMENT REG NO +NAME +0001 ATTY +91126-053 ARAUJO +0002 +76318-054 EPSTEIN +0003 +71776-018 IRIZARRY +CATG +ASSIGNMENT +* +08-08-2019 +15:15:05 +GROUP CODE: +FACILITY: NYM +OCT DATE +QTR +WRK +08-08-2019 I04-930U +08-08-2019 Z04-206LAD UNASSG +08-08-2019 G0B-759U \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/00bc1c5d9730c316bdd43978267a5c57ae66b0f7d2712ef776fc2872a7c802c0.receipt.json b/vision-fixhub/ds9-parsed-01/00bc1c5d9730c316bdd43978267a5c57ae66b0f7d2712ef776fc2872a7c802c0.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..dc30f382dd6f1266b232ec9bf56db20a3f068066 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/00bc1c5d9730c316bdd43978267a5c57ae66b0f7d2712ef776fc2872a7c802c0.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -4498, + "dataset": "marble-joined", + "doc_id": "00bc1c5d9730c316bdd43978267a5c57ae66b0f7d2712ef776fc2872a7c802c0", + "engine": "marble-apple-vision", + "event_count": 58, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "38a5fd9896f86e53f4ce07c31eacde5b9d4142d320f027b2e2039c5587d28c3e", + "output_sha256": "c27cecfc49ce8dd6a4d332b62569526e3674ac2a25076094355e519f376712fe", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/00bd8d640b8d133397d8a23ff48bbfb557d6d72e04d76e9e40543579459aa99c.md b/vision-fixhub/ds9-parsed-01/00bd8d640b8d133397d8a23ff48bbfb557d6d72e04d76e9e40543579459aa99c.md new file mode 100644 index 0000000000000000000000000000000000000000..dd32729de6c4e9376f1db336d0f6fb73166b8ae0 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/00bd8d640b8d133397d8a23ff48bbfb557d6d72e04d76e9e40543579459aa99c.md @@ -0,0 +1,35 @@ +From: " +To: " +Subject: FW: +Date: Wed, 17 Feb 2021 23:15:51 +0000 +(USANYS)" +Can you guys give me a call if you have a moment? +From: +To: +Cc: +Subject: RE: +Sent: Wednesday, February 17, 2021 6:12 PM +(USANYS) +was an AUSA who worked in both he Civil and Criminal Divisions before going to work for the +U.S. Bankruptcy Trustee. Sadly, she passed way within the past month. I don't think she had any connection to +the SD Fla. She worked a lot with +when he was Chief of Public Corruption. She was really a great +person. +From: +Sent: Wednesday, February 17, 2021 6:08 PM +To: +Pi +Cc: +(USANYS) < +Subject: +Hi +Hope you're both doing well! +and +land I are currently briefing some issues in the Ghislaine Maxwell case, +and we've come across a factual issue that we were hoping you might be able to help us with. The name "I +appears to be referenced in a file from the Southern District of Florida, and the defense is suggesting that this person +worked at SDNY. If you could possibly help us figure out whether this person ever worked here, that would be incredibly +helpful. +Thanks so much, +Assistant United States Attorney +Southern District of New York diff --git a/vision-fixhub/ds9-parsed-01/00bd8d640b8d133397d8a23ff48bbfb557d6d72e04d76e9e40543579459aa99c.receipt.json b/vision-fixhub/ds9-parsed-01/00bd8d640b8d133397d8a23ff48bbfb557d6d72e04d76e9e40543579459aa99c.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..9db01c5d21451a2808d4d0714c9c2cf792189c31 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/00bd8d640b8d133397d8a23ff48bbfb557d6d72e04d76e9e40543579459aa99c.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "00bd8d640b8d133397d8a23ff48bbfb557d6d72e04d76e9e40543579459aa99c", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "e49237890f24583c9433f4e5a432ee73b00d31a66b9cb1a3dd4a275ed5701bd6", + "output_sha256": "830b72ff0f57557f5f32e23d1543eb0055cacef3850e58f952aff97ff5ba9f9c", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/01019bee8c8a5a2d33880c71006a31fad7460f14384728f54826b4d0468085fc.md b/vision-fixhub/ds9-parsed-01/01019bee8c8a5a2d33880c71006a31fad7460f14384728f54826b4d0468085fc.md new file mode 100644 index 0000000000000000000000000000000000000000..812060bdaa83f227387a254ddf94d61327da186e --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/01019bee8c8a5a2d33880c71006a31fad7460f14384728f54826b4d0468085fc.md @@ -0,0 +1,55 @@ +Grand Jury Subpoena +United States District Onurt +SoUTHeRN DISTRICT OF NEW YorK +TO: +GREETINGS: +Appearance Date: +August 20, 2019 +Appearance Time: 10:00 a.m. +to testify and give evidence in regard to an alleged violation of : +18 U.S.C. $$ 371, 1001, 1519 +and not to depart the Grand Jury without leave thereof, or of the United States Attorney, and that you +bring with you and produce at the above time and place the following: +Personal appearance is required unless excused by the U.S. Attorney's Office for the Southern +District of New York. Please see the attached riders. +Failure to attend and produce any items hereby demanded will constitute contempt of court and will +subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law. +DATED: New York, New York +August 15, 2019 +Geoffeys. Bermn. +GEOFFREY S. BERMAN +United States Attorney for the +Southern District of New York +Assistant United States Attorneys +One St. Andrew's Plaza +New York, New York 10007 +Telephone: +Email: +rev. 02.01.12 + + +RIDER +(Grand Jury Subpoena to +dated August 15, 2019) +Advice of Rights +1. You may efuse to answer any question if a trubful answer to the question would tend 10 +2. Anyhing that you do say may be used against you by the grand jury or in a subsequent legal +3. If you have a lawyer, the grand jury will permit you a reasonable opportunity to step outside the +grand jury room to consult with your lawyer if you so desire. +4. If you would like a lawyer but do not have funds to retain one, you may make an application to +the United States Magistrate Judge who will decide whether to appoint a lawyer to represent you. +Instructions and Definitions: +1. This subpoena calls for the production of categories of documents, records, correspondence, +other written material (including electronically stored material), and physical items, as specified +below, in your possession, custody or control. +2. This subpoena covers all responsive documents wherever they may be found, including on +computers, email accounts, iCloud accounts, servers, cellphones, and other personal electronic +devices, whether in the United States or any foreign jurisdiction. +3. This subpoena does not call for the production of any documents protected by a valid claim of +privilege, although any responsive document over which privilege is being asserted must be +preserved. Any documents withheld on grounds of privilege must be specifically identified on a +privilege log with descriptions sufficient to identify their dates, authors, recipients, and general +subject matter. +Materials to be Produced: +All materials relating to Jeffrey Epstein including, but not limited to, any text messages, emails, +social media messages or posts, documents, or notes. diff --git a/vision-fixhub/ds9-parsed-01/01019bee8c8a5a2d33880c71006a31fad7460f14384728f54826b4d0468085fc.receipt.json b/vision-fixhub/ds9-parsed-01/01019bee8c8a5a2d33880c71006a31fad7460f14384728f54826b4d0468085fc.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..cbc4cd1625235f213de00a434b795139cb41c655 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/01019bee8c8a5a2d33880c71006a31fad7460f14384728f54826b4d0468085fc.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "01019bee8c8a5a2d33880c71006a31fad7460f14384728f54826b4d0468085fc", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "b534f40d82af3cc13d959525d3034e51fb40392d545e7acce8fb5f65e3f8e243", + "output_sha256": "09545fe31cab6cb3a135c44b953f046ca055071dda826e43a245ad598227c94c", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0101a93ab2bde8e926234c26be3bbd0649d9bb68c0aa485ca29f22112462050f.md b/vision-fixhub/ds9-parsed-01/0101a93ab2bde8e926234c26be3bbd0649d9bb68c0aa485ca29f22112462050f.md new file mode 100644 index 0000000000000000000000000000000000000000..da770254d54c8c85fee652fb96cbadc7b8d37ef2 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0101a93ab2bde8e926234c26be3bbd0649d9bb68c0aa485ca29f22112462050f.md @@ -0,0 +1,878 @@ +Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 1 of 30 +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +THE NEW YORK TIMES COMPANY, +Plaintiff, +-- X +-v- +FEDERAL BUREAU OF PRISONS, +20 Civ. 833 (PAE) +Defendant. +---- X +MEMORANDUM OF LAWIN SUPPORT OF THE FEDERAL BUREAU OF PRISONS'S +MOTION FOR SUMMARY JUDGMENT +AUDREY STRAUSS +eting United States Attorne +outhern District of New Yor +86 Chambers Street, Third Floor +11. 10007 + + +Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 2 of 30 +TABLE OF CONTENTS +PRELIMINARY STATEMENT +BACKGROUND +Criminal Proceedings Against Jeffrey Epstein. +II. Criminal Proceedings Against Tova Noel and Michael Thomas +I. Criminal Proceedings Against Nicholas Tartaglione +IV. The Times's FOIA Requests and This Action. +ARGUMENT +I. FOIA and the Summary Judgment Standard +II. BOP Conducted an Adequate Search for Responsive Records +III. BOP's Withholdings Were Proper.... +IV. BOP Has Satisfied Its Duty to Segregate and Release Any Non-Exempt Information. +CONCLUSION... +1 +2 +2 +2 +3 +3 +4 +4 +5 +. 6 +22 +.23 + + +Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 3 of 30 +TABLE OF AUTHORITIES +Page(s) +Cases +ACLU v. DOD, +389 F. Supp. 2d 547 (S.D.N.Y. 2005) +ACLU v. DOJ, +844 F.3d 126 (2d Cir. 2016) +Adamowicz v. L.R.S., +552 F. Supp. 2d 355 (S.D.N.Y. 2008) .... +Allard K. Lowenstein Int'l Human Rights Project v. Dep'tof Homeland Sec., +626 F.3d 678 (2d Cir. 2010) +Am. Civil Liberties Union v. United States Dep't of. +Def., 901 F.3d 125 (2d Cir. 2018). +Amnesty Int T USA v. CIA, +728 F. Supp. 2d 479 (S.D.N.Y. 2010) . +Associated Press v. U.S. Dep'tof Defense, +554 F.3d 274 (2d Cir. 2009) +Barney v. I.R.S., +618 F.2d 1268 (8th Cir. 1980) .. +Billington v. U.S. Dep'tof Justice, +301 F. Supp. 2d 15 (D.D.C. 2004) +Carney v. DOJ, +19 F.3d 807 (2d Cir. 1994) +CIA v. Sims, +471 U.S. 159 (1985) +Contiv. U.S. Dep'tof Homeland Sec., +No. 12 Civ. 5827 (AT), 2014 WL 1274517 (S.D.N.Y. Mar. 24, 2014) +Crooker v. Bureau of Alcohol, Tobacco, and Firearms, +789 F.2d 64 (D.C. Cir. 1986) +Ctr. for Nat'l Sec. Studies v. U.S. Dep't of Justice, +331 F.3d 918 (D.C. Cir. 2003) +DOD v. FLRA, +510 U.S. 487 (1994).. +Doherty v. U.S. Dep'tof Justice, +775 F.2d 49 (2d Cir. 1985) +Eil v. U.S. Drug Enf't Admin., +878 F.3d 392 (1st Cir. 2017) +.21,22 +15, 16 +..5 +.20 +..5 +7, 15, 16 +.18 +8 +.20 +..5 +..4 +22,23 +8 +. 8 +18 +.20 +.19 +ii + + +Case 1:20-Cv-00833-PAE Document 25 Filed 08/05/20 Page 4 of 30 +Ferguson v. FBI, +957 F.2d 1059 (2d Cir. 1992) +Ferguson v. FBI, +No. 89 Civ. 5071 (RPP), 1995 WL 329307 (S.D.N.Y. June 1, 1995). +Garcia v. U.S. Dep'tof Justice, +181 F. Supp. 2d 356 (S.D.N.Y. 2002) +Grand Cent. P'ship v. Cuomo, +166 F.3d 473 (2d Cir. 1999) +Hopkins v. U.S. Dep'tof Housing and Urban Dev., +929 F.2d 81. +Human Rights Watch v. BOP, No. 13-CV-7360 (JPO), +2015 WL 5459713 (S.D.N.Y. Sept. 16, 2015) +In re County of Erie, +473 F.3d 413 (2d Cir. 2007) . +John Doe Agency v. John Doe Corp., +493 U.S. 146 (1989). +Jordan v. U.S. Dep't of Justice, +668 F.3d 1188 (10th Cir. 2011) +Judicial Watch, Inc. v. U.S. Dep'tof Commerce, +337 F. Supp. 2d 146 (D.D.C. 2004). +Kansi v. U.S. Dep'tof Justice, +11 F. Supp. 2d 42 (D.D.C. 1998) +Kay v. F.C.C., +976 F. Supp. 23 (D.D.C. 1997) +Kidder v. FBI, +517 F. Supp. 2d 17 (D.D.C. 2007) .. +Leopold v. Office of Director of National Intelligence, +No. 16-2517 (CKK), 2020 WL 805380 (D.D.C. Feb. 18, 2020) . +Maynard v. C.I.A., +986 F.2d 547 (Ist Cir. 1993). +N.L. R.B. v. Robbins Tire d Rubber Co., +437 U.S. 214 (1978).. +N.Y. Times v. Dep't of Justice, +872 F. Supp. 2d 309 (S.D.N.Y. 2012) +NAACP Legal Def. & Educ. Fund, Inc. v. U.S. Dep'tof Hous. & Urban Dev., +No. 07 Civ. 3378 (GEL), 2007 WL 4233008 (S.D.N.Y. Nov. 30, 2007).. +National Archives & Records Administration v. Favish, +541 U.S. 157 (2004).. +Nat'l Assoc. of Homebuilders v. Norton, +309 F.3d 26 (D.C. Cir. 2002). +8 +5 +5 +13,14 +13 +9,10, 11, 20 +..14, 17 +.4 +9, 10, 21, 22 +20,21 +..8 +..7 +..8 +.15 +..5, 6 +. 7, 8, 12 +5 +.15 +.19 +.17 +ili + + +Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 5 of 30 +New York Times Co. v. Dep'tof Justice, +No. 14 Civ. 03776 (AT) (SN), 2016 WL 5946711 (S.D.N.Y. Aug. 18, 2016). +New York Times Co. v. Nat'l Aeronautics & Space Admin., +782 F. Supp. 628 (D.D.C. 1991) . +NLRB v. Sears, Roebuck, +421 U.S. 132 (1975). +North v. Walsh, +881 F.2d 1088 (D.C. Cir. 1989) +Oglesby v. U.S. Army, +920 F.2d 57 (D.C. Cir. 1990) +Pinson v. Dep'tof Justice, +236 F. Supp. 3d (D.D.C. 2017) +Radcliffe v. IRS, +536 F. Supp. 2d 423 (S.D.N.Y. 2008) ... +Renegotiation Bd. v. Grumman Aircraft Eng'g Corp., +421 U.S. 168 (1975) +Robbins, Geller, Rudman & Dowd, LLP v. United States Sec. & Exch. Comm'n, +No. 3:14-CV-2197, 2016 WL 950995 (M.D. Tenn. Mar. 12, 2016). +SafeCard Servs., Inc. v. S.E.C., +926 F.2d 1197 (D.C. Cir. 1991) +Shapiro v. U.S. Dep't of Justice, +37 F. Supp. 3d 7 (D.D.C. 2014) +Tigue v. U.S. Dep't of Justice, +312 F.3d 70 (2d Cir. 2002) +U.S. Dep'tof State v. Washington Post Co., +456 U.S. 595 (1982).. +United States ex rel. Touhy v. Ragen, +340 U.S. 462 (1951). +United States v. Schwimmer, +892 F.2d 237 (2d Cir. 1989) +W. Journalism Ctr. v. Office of Indep. Counsel, +926 F. Supp. 189 (D.D.C. 1996) +Williams v. F.B.I., +730 F.2d 882 (2d Cir. 1984) +Wilner v. NSA, +592 F.3d 60 (2d Cir. 2009) +Statutes +5 U.S.C. § 522 +8,9, 11 +.19 +.13 +8 +5 +22 +..7, 8 +.13 +22 +. 5 +. 9 +13 +17 +.16 +.14 +11 +..9,10 +... 5 +•passim +iv + + +Case 1:20-CV-00833-PAE Document 25 Filed 08/05/20 Page 6 of 30 +Regulations +28 C.F.R. $ 16.21 …•••••• + + +Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 7 of 30 +PRELIMINARY STATEMENT +The New York Times (the "Times") seeks records at the core of a pending criminal +prosecution of two former Federal Bureau of Prisons ("BOP"') employees on duty the night +Jeffrey Epstein died. Some of the same records could also affect the penalty phase of a pending +death penalty case against Epstein's former cellmate. Congress did not intend the Freedom of +Information Act, 5 U.S.C. § 552 et seq., to interfere with pending criminal prosecutions. To +make sure this would not happen, Congress expressly exempted records that could reasonably be +expected to interfere with law enforcement proceedings from public disclosure under FOIA. See +5 U.S.C. § 552(b)(7)(A). Many of the records sought by the Times fall at the heart of this +exemption. +Other FOLA exemptions also justify BOP's withholding of records in response to the +FOIA request. BOP properly withheld information reflecting its predecisional deliberations +about how to respond to Epstein's apparent suicide attempt on July 23, 2019, his later suicide on +August 10, 2019, and related matters. See 5 U.S.C. § 552(b)(5). BOP also properly withheld +information where disclosure clearly would, and/or could reasonably be expected to, result in an +unwarranted invasion of privacy of Epstein's surviving family members, such as photographs of +Epstein's body following his suicide, or third parties other than Epstein, such as BOP employees +or other inmates. See 5 U.S.C. § 552(b)(6), (7)(C). The personal information of BOP employees +is also protected because its disclosure could place those employees at risk of harm. See 5 U.S.C. +§ 552(b)(7)(F). Some of the withheld records are protected by an additional FOIA exemption +because their disclosure would reveal sensitive law enforcement techniques or procedures, +including those relating to investigating and preventing inmate suicides. See 5 U.S.C. +§ 552(b)(7)(E). + + +Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 8 of 30 +BOP has logically and plausibly established that its search was adequate and its +withholdings under each of these FOIA exemptions were proper. Accordingly, the Court should +grant summary judgment in BOP's favor. +BACKGROUND +Criminal Proceedings Against Jeffrey Epstein +On July 2, 2019, the United States Attorney's Office for the Southern District of New +York ("USAO-SDNY") charged Jeffrey Epstein with one count of conspiracy to commit sex +trafficking and one count of sex trafficking. See Indictment, Dkt. No. 2, United States v. Epstein, +No. 19-ct-490 (RMB) (S.D.N.Y.). Epstein was arrested on July 6, 2019, and thereafter +incarcerated at the Metropolitan Correctional Center ("MCC") until his death. Declaration of +Russell Capone, Counsel to the Acting United States Attorney for the Southern District of New +York ("Capone Declaration") 9 4; see Docket Entry dated July 8, 2019, United States v. Epstein, +No. 19-ct-490 (RMB) (S.D.N.Y.). On July 23, 2019, Epstein apparently attempted suicide in his +cell at the MCC. Capone Decl. 9| 6. On August 10, 2019, Epstein committed suicide in his cell at +the MCC. Id. 17. +II. Criminal Proceedings Against Tova Noel and Michael Thomas +On August 9-10, 2019, the night of Epstein's death, Tova Noel and Michael Thomas +were correctional officers on duty at the MCC's Special Housing Unit, where Epstein was then +housed. Capone Decl. 1 9. As alleged in the November 19, 2019, indictment against Noel and +Thomas, they repeatedly failed to perform mandated counts of prisoners under their watch, +including Epstein, and to conceal this failure, they repeatedly signed false certifications attesting +to having conducted multiple counts of inmates. Id.; see Indictment, Dkt. No. 1, United States v. +Noel, No. 19-cr-830 (AT) (S.D.N.Y.) (the "Noel Indictment"). As a result of their actions that +2 + + +Case 1:20-Cv-00833-PAE Document 25 Filed 08/05/20 Page 9 of 30 +night, Noel and Thomas have been charged with one count of conspiring to defraud the United +States and to make or use a false writing or document, and five counts of making or using a false +writing or document. See Capone Deel. 19; Noel Indictment. The Noel prosecution is pending +before the Honorable Analisa Torres, U.S.D.J., with trial scheduled to begin on January 4, 2021. +Capone Decl. 9 9. +Ill. +Criminal Proceedings Against Nicholas Tartaglione +Nicholas Tartaglione has been charged with fifteen criminal violations arising from the +murders of Hector Gutierrez, Martin Luna, Urbano Santiago, and Miguel Luna. Id. 9 10; see +Superseding Indictment, Dkt. No. 120, United States of America v. Tartaglione, No. 16-CR-832 +(KMK) (S.D.N.Y.). On April 19, 2019, the USAO-SDNY filed a Notice of Intent to Seek the +Death Penalty against Tartaglione. Capone Decl. 9| 10; Notice of Intent to Seek Death Penalty, +Dkt. No. 121, United States of America v. Tartaglione, No. 16-CR-832 (KMK) (S.D.N.Y.). +Tartaglone has been detained since he was arrested on December 19, 2016. Capone Decl. 9| 11. +For certain periods in July 2019 including on July 23, 2019, the night of Epstein's apparent +suicide attempt- +—Tartaglione was housed at the MCC with Epstein as his cellmate. Id. +IV. The Times's FOIA Requests and This Action +On August 13, 2019, the Times submitted two FOIA requests to BOP collectively +seeking twenty different categories of documents relating to Epstein. See Declaration of Kara +Christenson ("Christenson Decl.") 11 5-6. On September 23, 2019, BOP denied the Times's +requests in full based on its determination that any responsive records were exempt from +disclosure, in full or in part, under FOIA Exemptions 5, 6, 7(A), 7(C), 7(E), and/or 7(F). +Christenson Decl. 9| 7. +3 + + +Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 10 of 30 +The Times subsequently sent BOP two additional FOIA requests. On December 12, 2019, +the Times requested six categories of documents relating to Epstein, id. 99, and on January 2, +2020, the Times requested recordings of Epstein's last three phone calls, id. 9 10. +The Times +commenced the present action on January 30, 2020, seeking production of +records responsive to its four FOIA requests. See Complaint, Dkt. No. 1. Over the course of three +productions on June 22, July 7 and July 10, 2020, respectively, BOP produced approximately 584 +pages of responsive records with appropriate redactions. Christenson Decl. 9|47. Through an +agreement between the parties, BOP will continue to produce certain responsive records after the +filing of this submission, with the basis for any partial withholdings explained herein. See id. 947. +ARGUMENT +I FOIA and the Summary Judgment Standard +FOIA generally requires federal agencies to make documents and other material +"available to the public," see 5 U.S.C. § 552(a), but specifically exempts nine categories of +information from that requirement, see id. § 552(b). Congress adopted this structure "to reach a +workable balance between the right of the public to know and the need of the [glovernment to +keep information in confidence." John Doe Agency v. John Doe Corp., 493 U.S. 146, 152 (1989) +(quoting H.R. Rep. No. 89-147 at 6 (1966), reprinted in 1966 U.S.C.C.A.N. +2418, 2423)). The nine FOIA exemptions reflect Congress's determination that "public +disclosure is not always in the public interest." CIA v. Sims, 471 U.S. 159, 166-67 (1985). +Summary judgment is warranted in a FOIA case if the agency submits declarations that +(1) supply "facts indicating that the agency has conducted a thorough search" and (2) give +"reasonably detailed explanations why any withheld documents fall within an exemption." +4 + + +Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 11 of 30 +Carney v. DOJ, 19 F.3d 807, 812 (2d Cir. 1994). ' The agency's declaration is "accorded a +presumption of good faith," and discovery is "unnecessary if the agency's submissions are +adequate on their face." Id. (internal quotation marks omitted); accord Wilner v. NSA, 592 F.3d +60, 69 (2d Cir. 2009). An agency's justification for asserting an exemption "is sufficient if it +appears logical and plausible." Am. Civil Liberties Union v. United States Dep'tof Def., 901 F.3d +125, 133 (2d Cir. 2018), as amended (Aug. 22, 2018). +II. BOP Conducted an Adequate Search for Responsive Records +"If an agency demonstrates that it has conducted a reasonable search for relevant +documents, it has fulfilled its obligations under FOIA and is entitled to summary judgment on +this issue." Garcia v. U.S. Dep'tof Justice, 181 F. Supp. 2d 356, 366 (S.D.N.Y. 2002). The +agency must demonstrate that its search was "reasonably calculated to discover the requested +documents." SafeCard Servs., Inc. v. S.E.C., 926 F.2d 1197, 328 (D.C. Cir. 1991). An agency's +search may be reasonable even if it does not return every responsive document. See Adamowicz +v. I.R.S., 552 F. Supp. 2d 355, 361 (S.D.N.Y. 2008). An agency must only search those "files +likely to contain responsive materials (if such records exist)." Oglesby v. U.S. Army, 920 F.2d 57, +68 (D.C. Cir. 1990). Where an agency's declaration demonstrates that it has conducted a +reasonable search, "the FOIA requester can rebut the agency's affidavit only by showing that the +ageney's search was not made in good faith." Maynard v. C.I.A., 986 F.2d 547, 560 (Ist Cir. +1993). +BOP's declarations demonstrate that its search was reasonable and adequate. Multiple +offices at BOP undertook searches for documents responsive to the Times's requests. First, as +' Because an agency declaration can satisfy the government's burden on a motion for summary +judgment, +, "Local Civil Rule 56.1 statements are not required." N.Y. Times v. Dep'tof Justice, +872 F. Supp. 2d 309, 314 (S.D.N.Y. 2012); Ferguson v. FBI, No. 89 Civ. 5071 (RPP), 1995 WL +329307, at *2 (S.D.N.Y. June 1, 1995), aff'd, 83 F.3d 41 (2d Cir. 1996). +5 + + +Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 12 of 30 +detailed in the Christenson Declaration, BOP's Central Office searched five electronic systems +for records responsive to the Times's requests: SENTRY, TRUVIEW, TRULINCS, +GROUPWISE, and TRUINTEL. See, e.g., Christenson Decl. 19 14, 22, 34, 37, 44-46. For the +search of each electronic system, the Christenson Declaration explains what the system is, what +information it contains, the search methods, and the search parameters that BOP used. See, e.g., +id. "i 14, 22, 34, 37, 44-46. Each search of an electronic system returned responsive records, see +id., except for the search of the TRULINCS system, as Epstein apparently did not send or receive +emails on that system, see id. 1 37. +In addition to these searches conducted by the Central Office, individual staff at the MCC +conducted searches for records responsive to the Times's request. As detailed in the Declaration +of Nicole McFarland, BOP staff conferred to determine which MCC staff members would be +likely to have records responsive to the Times's request and identified eight such individuals. See +Declaration of Nicole McFarland ("McFarland Decl.") 9 5. Each individual searched his or her +electronic and non-electronic files for records responsive to the FOIA requests. Id. 9| 6. These +searches located memoranda, reports, photographs, and other material responsive to the Times's +request, including forms and reports created following Epstein's July 23, 2019, apparent suicide +attempt and his August 10, 2019, suicide. See Christenson Decl. 1 32; McFarland Decl. 191 24, +25. +Based on the foregoing and as described in the Christenson and McFarland Declarations, +BOP conducted reasonable and adequate searches, and BOP's motion for summary judgment as +to the sufficiency of its search should be granted. +II. +BOP's Withholdings Were Proper +A. BOP Properly Withheld Records and Information Pursuant to FOLA Exemption 7(A) +6 + + +Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 13 of 30 +i Exemption 7(A) +As indicated in the index submitted by BOP, see Christenson Decl. Attachment 8, all of +the records BOP withheld in full fall within the scope of FOIA Exemption 7(A), except two +pages of draft letters and one set of emails discussed below that were properly withheld in full +under Exemption 5.2 +Exemption 7(A), 5 U.S.C. § 552 (b)(7)(A), exempts from disclosure "records or +information compiled for law enforcement purposes, but only to the extent that the production of +such law enforcement records or information ... could reasonably be expected to interfere with +enforcement proceedings." "To fit within Exemption 7(A), the government must show that (1) a +law enforcement proceeding is pending or prospective and (2) release of the information could +reasonably be expected to cause some articulable harm." Amnesty Int'l USA v. CIA, 728 F. Supp. +2d 479, 525 (S.D.N.Y. 2010) (internal quotation marks omitted). The term "enforcement +proceedings" as used Exemption 7(A) encompasses criminal and civil proceedings, and +proceedings must be either pending or reasonably foreseeable at the time of the withholding. See, +e.g., Kay v. F.C.C., 976 F. Supp. 23, 37-38 (D.D.C. 1997) (citing N.L. R.B. v. Robbins Tire & +Rubber Co., 437 U.S. 214, 220 (1978)). +The government's burden to establish the applicability of Exemption 7(A) is not high; the +government need only show that "disclosure of particular kinds of investigatory records... +would generally interfere with enforcement proceedings." Robbins Tire, 437 U.S. at 236 +(quotation marks omitted); Radcliffe v. IRS, 536 F. Supp. 2d 423, 437 (S.D.N.Y. 2008). The +2 For the records withheld in full by BOP, the Court need not reach the applicability of other +exemptions if it concludes that BOP's withholdings under Exemption 7(A) were proper, except +for the following documents identified on the BOP index: 2 pages of draft letters withheld under +Exemption 5's deliberative process privilege and 56 pages of emails withheld under Exemption +S's attorney-client privilege. +7 + + +Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 14 of 30 +government need only demonstrate a "rational link" between the requested public disclosure and +interference with the government's ongoing or prospective investigations or proceedings. See +Crooker v. Bureau of Alcohol, Tobacco, and Firearms, 789 F.2d 64, 67 (D.C. Cir. 1986); New +York Times Co. v. Dep'tof Justice, No. 14 Civ. 03776 (AT) (SN), 2016 WL 5946711, at *7 +(S.D.N.Y. Aug. 18, 2016) ("NY Times"). Moreover, Exemption 7(A) permits the categorical +withholding of records. See Robbins Tire, 437 U.S. at 236. In contrast to some other exemptions, +the government is not required to make a specific factual showing with respect to +each withheld document that disclosure would actually interfere with a particular +enforcement proceeding. Rather, federal courts may make generic determinations +that, with respect to particular kinds of enforcement proceedings, disclosure of +particular kinds of investigatory records while a case is pending would generally +interfere with enforcement proceedings. +Radcliffe, 536 F. Supp. 2d at 437 (quoting Barney v. I.R.S., 618 F.2d 1268, 1273 (8th Cir. 1980)). +"Exemption 7(A) ... is designed to block the disclosure of information that will genuinely harm +the government's case in an enforcement proceeding or impede an investigation." North v. +Walsh, 881 F.2d 1088, 1097 (D.C. Cir. 1989) (R.B. Ginsburg, J.). 3 +ii. +The Records Were Compiled for Law Enforcement Purposes +As a threshold matter, all of the documents withheld by BOP were "compiled for law +enforcement purposes," and thus satisfy the threshold requirement of Exemption 7. 5 U.S.C. +$ 552(b)(7). +The government has the burden of proving that records were compiled for law +enforcement purposes, see Ferguson v. FBI, 957 F.2d 1059, 1070 (2d Cir. 1992), but "[bJecause +the DOJ is an agency specializing in law enforcement, its claim of a law enforcement purpose is +entitled to deference," Ctr. for Nat'l Sec. Studies v. U.S. Dep't of Justice, 331 F.3d 918, 926 +" Exemption 7(A) also protects records that, if released, could interfere with post-trial criminal +proceedings, such as an appeal. See, e.g., Kidder v. FBI, 517 F. Supp. 2d 17, 27-28 (D.D.C. +2007); Kansi v. U.S. Dep't of Justice, 11 F. Supp. 2d 42, 44 (D.D.C. 1998). +8 + + +Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 15 of 30 +(D.C. Cir. 2003) (quotation marks and brackets omitted). Records qualify as "compiled for law +enforcement purposes" if they "relate to anything that can fairly be characterized as an +enforcement proceeding." Shapiro v. U.S. Dep't of Justice, 37 F. Supp. 3d 7, 29 (D.D.C. 2014) +(quotation marks omitted). The Tenth Circuit has adopted a "per se rule" that "for an agency like +the BOP, whose primary function is law enforcement, all records and information it compiles are +in furtherance of its law enforcement function ...." Jordan v. U.S. Dep'tof Justice, 668 F.3d +1188, 1193-97 (10th Cir. 2011) (characterizing case law from the First, Second, Sixth, and +Eighth Circuits as adopting a "per se rule" that all records of law enforcement agencies are +compiled for law enforcement purposes) (citing, inter alia, Williams v. F.B.I., 730 F.2d 882, 883- +86 (2d Cir. 1984) (noting that "[t]hroughout the debate on the 1974 amendments, Congress +assumed that all investigatory records of the FBI were compiled for a law enforcement +purpose"); but see Jordan, 668 F.3d at 1193-94 (noting that an alternative approach, a "rational +nexus test" has been adopted by the Third, Ninth, and D.C. Circuits). In Human Rights Watch v. +BOP, No. 13-CV-7360 (JPO), 2015 WL 5459713 (S.D.N.Y. Sept. 16, 2015), Judge Oetken +concluded that Williams did not require the per se rule, did not adopt the Tenth Circuit's per se +rule for BOP records, and followed a "practical approach," observing that "It]he ordinary +understanding of the term [law enforcement] includes proactive steps designed to prevent +criminal activity and maintain security." Id. at *5 (quotation marks and ellipses omitted); see +also Opinion and Order, Dkt. No. 59, Gonzalez v. ICE, No. 19-cv-2911 (JGK) (S.D.N.Y. July +29, 2020), slip op. at 27-28 (requiring a "rational nexus" between withheld records and an +agency's law enforcement duties). +As the Tenth Circuit recognized in Jordan, documents created by BOP are compiled for +law enforcement purposes because "It]he BOP is an integral component of a comprehensive +9 + + +Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 16 of 30 +federal law enforcement system" and because statutory amendments to FOIA have preserved the +broad scope of Exemption 7's language. Jordan, 668 F.3d at 1195; see id. at 1196-97 (discussing +amendments to Exemption 7); see also Williams, 730 F.2d at 884-85 (discussing amendments to +Exemption 7). But even applying a "practical approach" or "rational nexus" standard, the +withheld records readily qualify as "compiled for law enforcement purposes." As explained in +the Christenson Declaration, the withheld records were compiled to help BOP take "proactive +steps designed to prevent criminal activity and maintain security" within the MCC. Human +Rights Watch v. BOP, 2015 WL 5459713 at *5; see Christenson Decl. 953. They were compiled, +inter alia, to prevent suicides by inmates awaiting trial or sentencing at BOP facilities; to protect +the safety, security, and orderly operation of BOP facilities, particularly the MCC, a pretrial +detention facility; and to facilitate investigation of the incidents addressed in the records, +including Epstein's suicide, which gave rise to a criminal investigation and prosecution. See id. +Even if the Court does not apply a per se rule, BOP's declarations show that the records at issue +were compiled for law enforcement purposes. +ili. +Disclosure of the Records Would Interfere with Multiple Pending +Criminal Proceedings +Disclosure of the records withheld under Exemption 7(A) would interfere with the +pending prosecutions against Noel, Thomas, and Tartaglione, as logically and plausibly +explained in the declaration of Russell Capone, who serves as Counsel to the Acting United +States Attorney for the Southern District of New York and has a supervisory role with regard to +the prosecutions. Capone Decl. 99 1, 9-10, 13-32. The withheld records include possible exhibits +at the Noel trial, information about which numerous witnesses are expected to testify, and +information and documents authored by potential trial witnesses. See id. 11 14-25. Premature +disclosure of these records or the information contained therein could reasonably be expected to +10 + + +Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 17 of 30 +influence witnesses' potential testimony at trial, allow witnesses to alter their testimony to +conform to other evidence, and/or influence potential juror's perceptions of witness testimony or +evidence. See id.; W. Journalism Ctr. v. Office of Indep. Counsel, 926 F. Supp. 189, 192 (D.D.C. +1996) (Exemption 7(A) applies where "[w]itnesses with access to such information could easily +alter, conform or construct their testimony depending upon the information disclosed"). This is +more than sufficient "to trace a rational link between the nature of the document and the alleged +likely interference." NY Times, 2016 WL 5946711, at *7. +In addition to interfering with Noel, release of a subset of the withheld records that +discuss or refer to Tartaglione (the "Tartaglione Records") would also interfere with the +prosecution of Tartaglione. The Tartaglione Records contain information about Tartaglione's +conditions of confinement and his interactions with Epstein, which have been put directly at +issue by Tartaglione's defense counsel, specifically in connection with the potential penalty +phase of the case against Tartaglone. Capone Decl. 1 29. The Capone Declaration explains how +premature release of the Tartaglione Records could reasonably be expected to influence witness +testimony and potential juror perceptions of any interactions between Epstein and Tartaglone. +See Capone Decl. 111 29-31. These explanations similarly "allow the court to trace a rational link +between the nature of the document and the alleged likely interference," NY Times, 2016 WL +5946711, at *7 (brackets omitted), and provide independent basis for BOP's withholding of the +Tartaglione Records under Exemption 7(A), independent of the likely interference with Noel. +The Capone Declaration's categorical descriptions of the withheld records, and how their +premature disclosure under FOIA is reasonably likely to interfere with pending criminal +prosecutions, satisfies BOP's burden to justify its withholdings under Exemption 7(A). The +Supreme Court has instructed that federal courts may make "generic determinations" "that, with + + +Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 18 of 30 +respect to particular kinds of enforcement proceedings, disclosure of particular kinds of +investigatory records while a case is pending would generally interfere with enforcement +proceedings." Robbins Tire, 437 U.S. at 236 (quotation marks omitted). The particular "kinds of +enforcement proceedings" at issue here are among the most sensitive pending federal criminal +prosecutions, including +one where the government is seeking the death penalty. And the Capone +Declaration logically and plausibly explains how the particular kinds of records at issue-MCC +staffing records, BOP records relating to Epstein's apparent suicide attempt and suicide, certain +medical and psychological records, documents related to counts of inmates, an August 8, 2019 +review of SHU inmates, and emails relating to Epstein could "generally" be expected to +interfere with enforcement proceedings. See Capone Decl. 11 18-23. The Capone Declaration +further explains how subcategories of withheld emails emails pertaining to Epstein's apparent +suicide attempt, +his incarceration, and his mental health and emails pertaining to Epstein's +death would generally be expected to interfere with enforcement proceedings. See Capone +Decl. 19 24-25. It is entirely rational, logical and plausible that, as articulated by a senior +prosecutor overseeing the prosecutions at issue, each of these categories and subcategories of +documents could improperly influence witnesses and jurors. Under the approach ratified by the +Supreme Court in Robbins Tire, BOP properly withheld these records under Exemption 7(A). +B. BOP Properly Withheld Records and Information Pursuant to FOLA Exemption 5 +i Exemption 5 and Applicable Privileges +Exemption 5 of FOIA, 5 U.S.C. § 552(b)(5), exempts from disclosure "inter-agency or +intra-agency memorandums or letters which would not be available by law to a party... in +litigation with the agency." 5 U.S.C. § 552(b)(5). Exemption 5 encompasses the "deliberative +process' or "executive" privilege, which protects the decisionmaking processes of the executive +12 + + +Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 19 of 30 +branch in order to safeguard the quality and integrity of governmental decisions." Hopkins v. +U.S. Dep'tof Housing and Urban Dev., 929 F.2d 81, 84 (2d Cir. 1991). Information in an agency +record must satisfy two criteria to qualify for the deliberative process privilege: it "must be both +"predecisional' and 'deliberative.'" Grand Cent. P'ship v. Cuomo, 166 F.3d 473, 482 (2d Cir. +1999) (quoting Renegotiation Bd. v. Grumman Aircraft Eng'g Corp., 421 U.S. 168, 184 (1975)). +A document is "predecisional" when it is "prepared in order to assist an agency +decisionmaker in arriving at his decision." Grumman, 421 U.S. at 184. While a document is +predecisional if it "precedes, in temporal sequence, the 'decision' to which it relates," Grand +Cent. P'ship, 166 F.3d at 482, the government need not "identify a specific decision" made by +the agency to establish the predecisional nature of a particular record. NLRB v. Sears, Roebuck, +421 U.S. 132, 151 n. 18 (1975); accord Tigue v. U.S. Dep't of Justice, 312 F.3d 70, 80 (2d Cir. +2002). Rather, so long as the document "was prepared to assist [agency] decisionmaking on a +specific issue," it is predecisional. Id. +"A document is "deliberative" when it is actually ... related to the process by which +policies are formulated." Grand Cent. P'ship, 166 F.3d at 482 (internal quotation marks omitted; +alteration in original). In determining whether a document is deliberative, courts inquire as to +whether it "formed an important, if not essential, link in [the agency's] consultative process," +Grand Cent. P'ship, id. at 483, reflects the opinions of the author rather than the policy of the +agency, id. at 483; see Hopkins, 929 F.2d at 84-85, or might "reflect inaccurately upon or +prematurely disclose the views of [the agency]," Grand Cent. P'ship, 166 F.3d at 483. +Separate from the deliberative process privilege, the attorney-client privilege requires +"ItJhe relationship of attorney and client, a communication by the client relating to the subject +matter upon which professional advice is sought, and the confidentiality of the expression for +13 + + +Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 20 of 30 +which the protection is claimed." United States v. Schwimmer, 892 F.2d 237, 243 (2d Cir. 1989). +"IT]he traditional rationale for the [attorney-chient] privilege applies with special force in the +government context." In re County of Erie, 473 F.3d 413, 419 (2d Cir. 2007). +il. BOP Properly Withheld Records Pursuant to Exemption 5 +Some of the withheld records are protected in full or in part by Exemption 5 and the +deliberative process privilege. As logically and plausibly explained in the Christenson +Declaration, BOP withheld records or information pertaining to four sets of decisions made by +BOP. See Christenson Decl. 19 49. Each set of records satisfies the two-prong test to fall within +the scope of the deliberative process privilege. +First, prior to Epstein's suicide, BOP made decisions concerning how to house Epstein +and whether or not to house him with a cellmate. See Christenson Deel 19 49a, 49d. The incident +report of Epstein's July 23, 2019, apparent suicide attempt, as well as information contained in +emails and related documents about Epstein's incarceration prior to his death, are predecisional +because they were prepared to assist BOP in making such decisions about Epstein's +incarceration. Id. 19 49a, 49d. The documents and withheld information are deliberative because +they were part of the process by which BOP made these decisions and "bear on the formulation +or exercise of policy-oriented judgment," namely, how to appropriately house Epstein during his +incarceration, including following his apparent suicide attempt. Grand Cent. P'ship, 166 F.3d at +482; see Christenson Decl. 19| 49a, 49d +Second, following Epstein's suicide, BOP undertook an investigation into his death and +made decisions about how to conduct that investigation and what conclusions including +concerning possible changes to BOP's policies at MCC-should be drawn from it. See id. +19149b, 43f. The psychological reconstruction of Epstein's suicide and internal BOP responses +14 + + +Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 21 of 30 +thereto, as well as information contained in emails and related documents discussing Epstein's +suicide and BOP's response to it, are predecisional because they were prepared to assist BOP in +making decisions following Epstein's suicide, including possible changes to BOP's suicide +prevention policy at MCC. They are deliberative because they bear on BOP's policies relating to +preventing inmate suicides at facilities like MCC, investigating suicides when they occur, and +reviewing BOP's policies at MCC. See id. 1949b, 49f. For example, the psychological +reconstruction of Epstein's suicide contains multiple recommendations—and responses to certain +recommendations-for how MCC should change its suicide prevention policies and measures, +such as recommendations about double-celling and direct observation of inmates. See id. 9149b. +Third, the draft letters withheld by BOP are predecisional and deliberative because they +precede final versions of those letters, and represent iterative versions as BOP determined how +best to present the information in question. See Christenson Decl. 9 49c. "It is well-settled that +draft documents, by their very nature, are typically predecisional and deliberative. They reflect +only the tentative view of their authors; views that might be altered or rejected upon further +deliberation by their authors or by their superiors." Amnesty Int'l USA v. CIA, 728 F. Supp. 2d +479, 518 (S.D.N.Y. 2010) (quotation marks and brackets omitted); see ACLU v. DOJ, 844 F.3d +126, 133 (2d Cir. 2016); NAACP Legal Def. & Educ. Fund, Inc. v. U.S. Dep't of Hous. & Urban +Dev., No. 07 Civ. 3378 (GEL), 2007 WL 4233008, at *11 (S.D.N.Y. Nov. 30, 2007) ("Draft +documents, by their very nature, are typically predecisional and deliberative.") +Fourth, BOP properly withheld information in emails pertaining to press inquiries +concerning Epstein and his death and how BOP would respond to them. "Governmental +decisions and policies can include the formulation of an agency's statements to the public and +other outside entities." Leopold v. Office of Director of National Intelligence, No. 16-2517 +15 + + +Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 22 of 30 +(CKK), 2020 WL 805380, at *5 (D.D.C. Feb. 18, 2020); see id. at *6 (collecting cases, including +from this district, on both sides of the question whether agency communications about how to +interact with the public may be subject to the deliberative process privilege and concluding, +including by relying on the Second Circuit's decision in ACLU, 844 F.3d at 133, that "[a]s long +as communications are pre-decisional and deliberative, internal agency communications about +public statements can be protected by the deliberative process privilege"). The withheld +information in the emails in this case is predecisional and deliberative because it was prepared to +assist BOP in its determination of, and were part of the process by which BOP decided, whether +and how to change its policies at MCC and whether and how to respond to press inquiries +concerning Epstein and his death. See Christenson Decl. 9|43e. In addition, some of the emails +also contain predecisional and deliberative material because they include draft responses to press +inquiries. See id.; Amnesty Int'l, 728 F.Supp.2d at 518. +Separate from the deliberative process privilege, one set of emails withheld in full under +Exemption 5 is protected by the attorney-client privilege, as indicated on the BOP index. This +group of emails consists of communications between BOP employees and Assistant United +States Attorneys in the Civil Division of the USAO-SDNY, which represented BOP in +connection with litigation requests for documents related to Epstein, and how to respond to these +requests pursuant to Department of Justice regulations (known as Touhy regulations). See +Christenson Decl. 1| 50; see also United States ex rel. Touhy v. Ragen, 340 U.S. 462 (1951); 28 +C.F.R. § 16.21 et seq. As confidential communications between attorneys and a client for the +purpose of obtaining and providing legal advice, see Christenson Decl. 9| 50, these emails are +privileged and were properly withheld under Exemption 5. +16 + + +Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 23 of 30 +Under the FOIA Improvement Act of 2016, "[a]n agency shall ... withhold information +under [FOIA] only if ... (I) the agency reasonably foresees that disclosure would harm an +interest protected by an exemption described in subsection (b); or (II) disclosure is prohibited by +law." 5 U.S.C. § 552(a)(8)(A)(i). The legislative history of this amendment expressly +acknowledges that it "does not alter the scope of information that is covered under an +exemption." H.R. Rep. No. 114-391, at 10 (2016). The Christenson Declaration explains how +disclosure of the materials withheld under Exemption 5 would harm interests protected by +Exemption 5, primarily by hampering the ability of BOP employees to frankly discuss and assess +and conditions and incidents at BOP facilities, as well as related BOP policies. See Christenson +Decl. 1|49. In addition, disclosure of the emails protected by the attorney-client privilege would +impair BOP's ability to seek out and receive frank and complete advice from legal counsel, +which is particularly important for a government agency. See Christenson Decl. 9 50; Erie, 473 +F.3d at 419. +C. BOP Properly Withheld Information Pursuant to FOIA Exemptions 6 and 7(C) +FOIA Exemption 6, 5 U.S.C. § 552(b)(6), protects from disclosure "personnel and +medical files and similar files the disclosure of which would constitute a clearly unwarranted +invasion of personal privacy." 5 U.S.C. § 552(b)(6). The statutory language concerning files +"similar" to personnel or medical files encompasses any "information which applies to a +particular individual ... sought from government records." U.S. Dep'tof State v. Washington +Post Co., 456 U.S. 595, 602 (1982). Under Exemption 6, a court considers whether the "public +interest in disclosure outweighs the individual privacy concerns." Nat'l Assoc. of Homebuilders +v. Norton, 309 F.3d 26, 35 (D.C. Cir. 2002) (internal quotation marks omitted). But the "only +relevant public interest in disclosure to be weighed in this balance is the extent to which +17 + + +Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 24 of 30 +disclosure would ... contribut[e] significantly to public understanding of the operations or +activities of the government." DOD v. FLRA, 510 U.S. 487, 495 (1994). +Even more protective of privacy interests, Exemption 7(C), 5 U.S.C. § 552(b)(7)(C), +exempts from disclosure records or information compiled for law enforcement purposes where +its production "could reasonably be expected to constitute an unwarranted invasion of personal +privacy." 5 U.S.C. § 552(b)(7)(C). Under Exemption 7(C), a court again "balance[s] the public +interest in disclosure against the [privacy] interest." Associated Press v. U.S. Dep't of Defense, +554 F.3d 274, 284 (2d Cir. 2009). In this analysis, "It]here is only one relevant public interest, +that of opening agency action to the light of public scrutiny." Id. at 284 (quotation marks and +brackets omitted). "The [FOIA requester] must show that the public interest sought to be +advanced is a significant one, an interest more specific than having the information for its own +sake and ... must also show the information is likely to advance that interest." Id. +Some of the records withheld by BOP contain personal information about third parties +that, if publicly disclosed, would constitute a clearly unwarranted invasion of privacy, and ata +minimum, could reasonably be expected to constitute an unwarranted invasion of personal +privacy. These records contain two general categories of personal information: details of +Epstein's death and images of his body, and the names, contact information, and other personal +details of third-party individuals other than Epstein. 4 +One category of records implicates the privacy interests of Epstein's surviving family +members because these records contain highly personal details about his death, including images +* As a threshold matter, each of the records withheld under Exemptions 6 and 7(C) qualifies for +for Exemption 7(C) because, as discussed supra, they were compiled for law enforcement +purposes. +18 + + +Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 25 of 30 +of his body after his suicide. Christenson Decl. 1 62. The Supreme Court and lower courts have +recognized surviving family members's privacy interests in medical records and details of a +relative's death. For example, in National Archives & Records Administration v. Favish, 541 +U.S. 157, 165-71 (2004), the Supreme Court held that Exemption 7(C) protected death-scene +photographs held in law enforcement files because their release could be painful and invasive for +surviving family members. See also Eil v. U.S. Drug Enf't Admin., 878 F.3d 392, 400 (Ist Cir. +2017) (protecting under Exemption 7(C) medical and death-related records that had been exhibits +at criminal trial); New York Times Co. v. Nat'l Aeronautics & Space Admin., 782 F. Supp. 628, +631-32 (D.D.C. 1991) (protecting under Exemption 6 audio recording of Challenger astronauts" +final moments). On the other side of the Exemption 6 and 7(C) balance, the Times cannot show +that disclosure of the information in these records is likely to offer any significant insight into +BOP operations. Particularly in light of the New York City Medical Examiner's public +conclusion that Epstein hanged himself, the specific details of his suicide or the appearance of +his body shortly thereafter do not shed any substantial light on BOP operations. +The second category of the materials withheld under Exemptions 6 and 7(C) consists of +personally identifying information of BOP employees, BOP inmates other than Epstein, visitors +or senders of funds to BOP inmates (including but not limited to Epstein), legal counsel for BOP +inmates (including but not limited to Epstein), USAO-SDNY employees, and journalists. See +Christenson Decl. 9| 61. The Christenson Declaration explains how the balancing test weighs in +favor of protecting personally identifying information under Exemptions 6 and 7(C) for each of +these categories of individuals. +See id. Moreover, the publicity and unfounded speculation +surrounding Epstein's death make it more likely that disclosure of personally identifying +information of an individual who interacted with Epstein or participated in the response to his +19 + + +Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 26 of 30 +death would cause an unwarranted invasion of privacy. See Christenson Decl. 11 58-59. +Accordingly, the personally identifying information of third parties other than Epstein contained +in these Records is protected from disclosure by Exemptions 6 & 7(C). See Human Rights +Watch, 2015 WL 5459713, at*9-10 (upholding application of Exemptions 6 and 7(C) to withhold +details about inmates BOP documents); Billington v. U.S. Dep'tof Justice, 301 F. Supp. 2d 15, +19-21 (D.D.C. 2004) (upholding application of Exemption 6 to withhold identity of journalist). +D. BOP Properly Withheld Records and Information Pursuant to FOIA Exemption 7(E) +Exemption 7(E), 5 U.S.C. § 522 (b)(7)(E), exempts from disclosure law enforcement +records where release "would disclose techniques and procedures for law enforcement +investigations or prosecutions, or would disclose guidelines for law enforcement investigations +or prosecutions if such disclosure could reasonably be expected to risk circumvention of the +law." Exemption 7(E) contains "two alternative clauses," one covering "techniques and +procedures," and the other addressing "guidelines." Allard K. Lowenstein Int'l Human Rights +Projectv. Dep't of Homeland Sec., 626 F.3d 678, 680-81 (2d Cir. 2010). The first clause of +Exemption 7(E) provides categorical protection to information that would disclose law +enforcement "techniques and procedures," without requiring any showing of harm as a result of +disclosure. See id. at 681. While Exemption 7(E) generally covers only "investigatory records +that disclose investigative techniques and procedures not generally known to the public," +Doherty v. U.S. Dep'tof Justice, 775 F.2d 49, 52 n.4 (2d Cir. 1985), "even commonly known +procedures may be protected from disclosure if the disclosure could reduce or nullify their +effectiveness," Judicial Watch, Inc. v. U.S. Dep'tof Commerce, 337 F. Supp. 2d 146, 181 +(D.D.C. 2004) +20 + + +Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 27 of 30 +As indicated on the BOP index, some of the records withheld by BOP fall within the +scope of Exemption 7(E) because they contain information or discussion of sensitive law +enforcement techniques and procedures. As explained in the Christenson Declaration, release of +these records would disclose BOP's law enforcement techniques and procedures for preventing +and investigating suicides, suicide attempts, and other incidents within its facilities. See +Christenson Decl. 911 65-68. Release of these records, particularly the Inmate Investigative +Report, would reveal how BOP responds to and investigates certain incidents at facilities. And +although BOP need not make a specific showing of a risk of circumvention of the law in order to +withhold techniques and procedures under Exemption 7(E), BOP has explained that releasing +these records would make it easier for inmates to circumvent measures designed to prevent +suicides, as well as BOP's investigatory techniques and procedures. Id. Accordingly, BOP +properly withheld these records under Exemption 7(E). See Jordan, 668 F.3d at 1201 (upholding +application of Exemption 7(E) to BOP psychological records). +E. BOP Properly Withheld Information Pursuant to FOIA Exemption 7(F) +Exemption 7(F), 5 U.S.C. § 522 (b)(7)(F), exempts from disclosure law enforcement +records where release "could reasonably be expected to endanger the life or physical safety of an +individual." "Exemption 7(E) was enacted to protect the safety of individuals involved in law +enforcement investigations." ACLU v. DOD, 389 F. Supp. 2d 547, 576 (S.D.N.Y. 2005). +Application of Exemption 7(F) "is appropriate ... where disclosure of identifying information +would put the life and physical safety of law enforcement agents and other third parties in +danger." Gonzalez No. 19-cv-2911, slip op. at 34. "An agency's burden to prove that disclosure +" As discussed supra, all of these records were compiled for law enforcement purposes. +21 + + +Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 28 of 30 +would result in the endangerment of life or physical safety is a low one." Gonzalez, No. 19-cv- +2911, slip op. at 33 (quotation marks omitted). +The personally identifying information of BOP employees described above as protected +under Exemptions 6 and 7(C) is also protected by Exemption 7(F). As described in the +Christenson Declaration, BOP employees work with inmates who, during or after their +incarceration, might target such employees for reprisals. Christenson Decl. 9| 25. Releasing the +personally identifying information of such individuals would increase the risk of such targeting +by making it easier for government staff to be identified and located. See id. These concerns are +heightened because of the media attention and public speculation surrounding Epstein's death. +See id. Accordingly, BOP properly withheld the personally identifying information of BOP +employees under Exemption 7(F). See Jordan, 668 F.3d at 1198 (upholding application of +Exemption 7(F) to BOP Supermax roster); Pinson v. Dep't of Justice, 236 F. Supp. 3d 388, 370 +(D.D.C. 2017) (upholding application of Exemption 7(F) to BOP assignment rosters). +IV. BOP Has Satisfied Its Duty to Segregate and Release Any Non-Exempt +Information +FOIA requires that "[a]ny reasonably segregable portion of a record shall be provided to +any person requesting such record after deletion of the portions which are exempt under this +subsection." 5 U.S.C. § 552(b). Where, as here, an agency asserts Exemption 7(A) by describing +the categories of records it has withheld, the government satisfies this obligation by explaining +why those categories of records do not contain reasonably segregable non-exempt information. +See, e.g., Robbins, Geller, Rudman & Dowd, LLP v. United States Sec. & Exch. Comm'n, No. +3:14-CV-2197, 2016 WL 950995, at *9 (M.D. Tenn. Mar. 12, 2016) (citing examples). +Moreover, nonexempt portions of documents may "be withheld if they are inextricably +intertwined with the exempt portions." Contiv. U.S. Dep'tof Homeland Sec., No. 12 Civ. 5827 +22 + + +Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 29 of 30 +(AT), 2014 WL 1274517, at *25 (S.D.N.Y. Mar. 24, 2014) (quotation marks omitted). "The +agency is entitled to a presumption that it complied with its obligation to disclose reasonably +segregable material." Id. +In the present case, BOP has already produced 584 pages of records, with appropriate +redactions, in response to the Times's FOIA requests and intends to produce more. Christenson +Decl. 9|47. The records withheld in full by BOP do not contain any reasonably segregable nonexempt information. See Christenson Decl. 91 47. With regard to the records withheld in full +under Exemption 7(A), the Capone Declaration explains that, to the extent there is non-exempt +information contained in the records withheld under Exemption 7(A), that information is +intertwined with exempt information and cannot reasonably be segregated without risking +interference with the Noel and Tartaglione prosecutions. Capone Decl. 9| 34. The public +speculation and unfounded theories about Epstein's death make segregation particularly difficult +because the provision of information related to Epstein without complete context risks +compounding the unfounded speculation about Epstein's death, and heightening the risk of +interference with Noel and Tartaglione. Id. As to the remaining records withheld in full, either +the records are privileged in their entirety (e.g., as attorney-client communications or draft +documents) or any non-exempt information in the documents is inextricably intertwined with +exempt information, such that segregating any non-exempt information would be of little to no +informational value. See Christenson Decl. 9| 47. Accordingly, BOP has satisfied its obligation to +reasonably segregate any non-exempt portions of the records withheld in full. +CONCLUSION +For the foregoing reasons, the Court should grant the government's motion for summary +judgment. +23 + + +Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 30 of 30 +Dated: New York, New York +August 5, 2020 +Respectfully submitted, +AUDREY STRAUSS +Acting United States Attorney for the +Southern District of New York +Counsel for Defendant +24 diff --git a/vision-fixhub/ds9-parsed-01/0101a93ab2bde8e926234c26be3bbd0649d9bb68c0aa485ca29f22112462050f.receipt.json b/vision-fixhub/ds9-parsed-01/0101a93ab2bde8e926234c26be3bbd0649d9bb68c0aa485ca29f22112462050f.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..a89a98be574aea52f208a877fd275e11ced1fad8 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0101a93ab2bde8e926234c26be3bbd0649d9bb68c0aa485ca29f22112462050f.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -362, + "dataset": "marble-joined", + "doc_id": "0101a93ab2bde8e926234c26be3bbd0649d9bb68c0aa485ca29f22112462050f", + "engine": "marble-apple-vision", + "event_count": 31, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "50e1dea6f39294a772d7e6996125ad732661186b853fa2f4de106f132e265522", + "output_sha256": "41841a0981db1375f61010b5cfb6417870a9b7c6e92505a7ed44ae44b6a62e28", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0104cb725a7fcf63a4f200764bf059ea013e4f8e8ab3d8644435c6b0484cdacc.md b/vision-fixhub/ds9-parsed-01/0104cb725a7fcf63a4f200764bf059ea013e4f8e8ab3d8644435c6b0484cdacc.md new file mode 100644 index 0000000000000000000000000000000000000000..28e023f9ca95f1475d66b60674a6062b0fa58fe7 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0104cb725a7fcf63a4f200764bf059ea013e4f8e8ab3d8644435c6b0484cdacc.md @@ -0,0 +1,188 @@ +U.S. Department of Justice +Criminal Division +VAA:WHG:TNB:AF:ss +DOJ No. CRM-182-76636 +Office of International Affairs +Washington, D.C. +FROM: +The Central Authority of the United States +TO: +The Central Authority of France +SUBJECT: Request for Assistance in the Prosecution of Ghislaine Maxwell +DATE: +January 13, 2021 +INTRODUCTION +The Central Authority of the United States requests the assistance of the appropriate +authorities in France pursuant to the 1998 U.S.-France Mutual Legal Assistance Treaty, as +supplemented by the 2004 U.S.-France Mutual Legal Assistance Instrument (collectively, +"the Treaty"). The United States Attorney for the Southern District of New York ("the +prosecutor") and the Federal Bureau of Investigation (collectively, the "U.S. authorities") +are prosecuting charges of violations of United States criminal law concerning Ghislaine +Maxwell and her role in the sexual exploitation and abuse of multiple minor girls by Jeffrey +Epstein from at least in or about 1994, up to and including at least in or about 1997. +1 + + +TIME CONSTRAINTS +A trial date of July 12, 2021, has been set in United States v. Ghislaine Maxwell in +the United States District Court for the Southern District of New York. In light of the +upcoming trial date, the U.S. authorities would like to interview the witness as soon as +possible. +REQUEST FOR CONFIDENTIALITY +This request is sensitive in that it recounts specifies and evidentiary detail that may +not be known, the exposure of which could impede the prosecution of Maxwell and the +U.S. authorities' ongoing investigation with regard to the integrity of evidence and witness +accounts. +Premature notification of this request could seriously jeopardize the +2 + + +investigation or compromise the trial of Maxwell, by prompting a witness to alter or +prepare his/her answers to specific questions, by prompting others to destroy or tamper +with evidence; change patterns of behavior; intimidate potential witnesses; or alert others +who could do the same. +Accordingly, pursuant to Article 14 of the Treaty, please keep this request +confidential in all respects, and do not share its contents, its subject matter, or the fact that +the request has been made with any private persons (including the subjects) of the +investigation), or any government officials whose knowledge is not absolutely necessary +for purposes of executing this request. In addition, please advise all who must be made +aware of this request for assistance that the request, its contents and its subject matter are +to be kept confidential and should not be shared except as described above. +In order to avoid disclosure to third parties (including parties civiles), if a related +criminal investigation exists in France, please ensure that this mutual legal assistance +request is NOT placed in the French criminal dossier without the express authorization of +the United States; instead, we ask that this request for assistance be placed in a separate +mutual legal assistance dossier. If this request cannot be executed without breaching +confidentiality, please notify +for the United States, whose contact information is listed below. +THE FACTS +U.S. citizen Jeffrey Epstein is alleged to have engaged in the sexual abuse of minor +girls during the period of approximately 1994 through 2005. On or about July 2, 2019, a +grand jury in the Southern District of New York returned an indictment charging Epstein +3 + + +with violations of U.S. criminal laws in connection with his sexual abuse of minors, +including with engaging in a conspiracy to sexually traffic in minors. Epstein was arrested +pursuant to the indictment on or about July 6, 2019, and had been detained pending trial in +New York. +On or about August 10, 2019, Epstein committed suicide in his cell. +Notwithstanding Epstein's death, the investigation that led to his indictment remains +ongoing. That investigation has revealed evidence of additional criminal conduct by +Epstein and his associates, including Ghislaine Maxwell. +On or about June 29, 2020, a grand jury in the Southern District of New York +returned an Indictment charging Maxwell with violations of U.S. criminal laws in +connection with her role in assisting, facilitating, and contributing to Epstein's sexual abuse +of minors by, among other things, helping Epstein to recruit, groom, and ultimately abuse +victims known to Maxwell and Epstein to be under the age of 18. The Indictment alleges +that from at least in or about 1994, up to and including at least in or about 1997, Maxwell +enticed and conspired with Epstein to entice and cause minor victims to travel to New +York, which Maxwell knew and intended would result in their grooming and subjection to +sexual abuse by Epstein. Finally, the Indictment also alleges that Maxwell provided false +and perjurious statements, under oath, regarding, among other subjects, her role in +facilitating the abuse of minor victims by Epstein. Maxwell was arrested pursuant to the +Indictment on or about July 2, 2020, and has been detained pending trial in New York since +that date. +4 + + +THE OFFENSES +Title 18, United States Code, Section 371 +Conspiracy +Title 18, United States Code, Section 2423 +Transportation of Minors +(a) Transportation with intent to engage in criminal sexual activity +(1) A person who knowingly transports an individual who has not attained +the age of 18 years in interstate or foreign commerce, or in any +commonwealth, territory or possession of the United States, with intent +that the individual engage in prostitution, or in any sexual activity for +which any person can be charged with a criminal offense, shall [have +committed a crime and be] imprisoned not less than 10 years or for life.' +Title 18, United States Code, Section 2422 +Coercion and Enticement +(1) (b) Whoever, using the mail or any facility or means of interstate or foreign +commerce, or within the special maritime and territorial jurisdiction of the United +States knowingly persuades, induces, entices, or coerces any individual who has +not attained the age of 18 years, to engage in prostitution or any sexual activity for +which any person can be charged with a criminal offense, or attempts to do so, shall +[have committed a crime and be] imprisoned not less than 10 years or for life.? +Title 18, United States Code, Section 1623 +Perjury +(a) Whoever under oath (or in any declaration, certificate, verification, or statement +under penalty of perjury as permitted under section 1746 of title 28, United States +Code) in any proceeding before or ancillary to any court or grand jury of the United +' The penalties stated herein apply to conduct that occurred after July 27, 2006. For conduct +that occurred prior to that time, the penalties would be lower and may not include +mandatory minimum sentences. +2 The penalties stated herein apply to conduct that occurred after July 27, 2006. For conduct +that occurred prior to that time, the penalties would be lower and may not include +mandatory minimum sentences. +5 + + +states knowingly makes any false material declaration or makes or uses any othe +nformation, including any book, paper, document, record, recording, or othe +laterial, knowing the same to contain any false material declaration, shall be fine +nder this title or imprisoned not more than five vears. or bot +RELEVANT ENTITIES AND INDIVIDUALS +Name: +Date of birth: +Place of birth: +Citizenship: +Name: +Date of Birth: +Place of Birth: +Citizenship: +Ghislaine Maxwell +ASSISTANCE NEEDED +6 + + +PROCEDURES TO BE FOLLOWED +7 + + +8 + + +COORDINATION WITH U.S. LIAISON MAGISTRATE IN FRANCE +Please coordinate the general execution of this request for assistance with +9 + + +CONCLUSION +Thank you in advance for your assistance with the prosecution of Ghislaine +Maxwell. +January 13, 2021 +Date +Associate Director +Office of International Affairs +Criminal Division +10 + + +11 + + +ATTESTATION OF AUTHENTICITY OF OFFICIAL RECORDS +I, +_, attest that my position with the +(Name) +Government of France is +and that in that +(Official Title) +position I am authorized by French law to attest that the +documents attached hereto and described below: +(1) +are true copies of official records which are authorized by the laws of +France to be recorded or filed in . +(Name of Public Office or Agency) +which is a government office or agency. +(2) +set forth matters which are required by the laws of France to be reported +and recorded or filed. +Description of Documents: +(Signature) +(Official Seal) +(Date) +12 diff --git a/vision-fixhub/ds9-parsed-01/0104cb725a7fcf63a4f200764bf059ea013e4f8e8ab3d8644435c6b0484cdacc.receipt.json b/vision-fixhub/ds9-parsed-01/0104cb725a7fcf63a4f200764bf059ea013e4f8e8ab3d8644435c6b0484cdacc.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..7a704d893cd3ab021861dc40bd7f8743c88e64b9 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0104cb725a7fcf63a4f200764bf059ea013e4f8e8ab3d8644435c6b0484cdacc.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -144, + "dataset": "marble-joined", + "doc_id": "0104cb725a7fcf63a4f200764bf059ea013e4f8e8ab3d8644435c6b0484cdacc", + "engine": "marble-apple-vision", + "event_count": 12, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "aecafb8572bc029e075616aa88054c3f1c089189e2f8197b022257938107b394", + "output_sha256": "c5353e22f0e69b1e8338c3d62bb8472dfd3bf7d6b66a8787cb516ec5f31e45c7", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/010d9deb7f82b24a09a3d8ebe23140ba526fda9fecdeb463215950b5137b9f36.md b/vision-fixhub/ds9-parsed-01/010d9deb7f82b24a09a3d8ebe23140ba526fda9fecdeb463215950b5137b9f36.md new file mode 100644 index 0000000000000000000000000000000000000000..6c27f5f103c0d328d618108128b8f24dfb3773ee --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/010d9deb7f82b24a09a3d8ebe23140ba526fda9fecdeb463215950b5137b9f36.md @@ -0,0 +1,25 @@ +From: +To: +Cc: +@bop.gov» +bop.gov>,| +@bop.gov». +(USANYS)" +Bec: "USAHUB-USAJournal111" < +Subject: Re: Laptop for Ghislaine Maxwell (Reg. No. 02879-509) +Date: Tue, 17 Nov 2020 13:59:24 +0000 +Embedded: Re:_Laptop_ +for_Ghislaine_Maxwell_(Reg._No._02879-509).msg +Sender: +Subject: Re: Laptop for Ghislaine Maxwell (Reg. No. 02879-509) +Message-Id: +To: +@bop.gov +Cc: l +@bop.gov +Ce: +@bop.gov +Cc:/ +Cc: +Cc: +Cc: diff --git a/vision-fixhub/ds9-parsed-01/010d9deb7f82b24a09a3d8ebe23140ba526fda9fecdeb463215950b5137b9f36.receipt.json b/vision-fixhub/ds9-parsed-01/010d9deb7f82b24a09a3d8ebe23140ba526fda9fecdeb463215950b5137b9f36.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..c89df9bf9f56bbd12986f8769570d1b3aa657721 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/010d9deb7f82b24a09a3d8ebe23140ba526fda9fecdeb463215950b5137b9f36.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "010d9deb7f82b24a09a3d8ebe23140ba526fda9fecdeb463215950b5137b9f36", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "e1e46298664ecf33d568349c57f60fb58792a7f5a181a1bdf696ff8ffa4273ee", + "output_sha256": "d51c0ff86fa7a429ddeffcbd88c458210f37050b0eaf9c324c9733ca299ef786", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/012cf574dad2adaf792a0fc7dff723ce506a4448f60d5f6f188d18a5dbfe57e3.md b/vision-fixhub/ds9-parsed-01/012cf574dad2adaf792a0fc7dff723ce506a4448f60d5f6f188d18a5dbfe57e3.md new file mode 100644 index 0000000000000000000000000000000000000000..ae4dd2ddc50ae4451c614a6b0600a77e76b62258 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/012cf574dad2adaf792a0fc7dff723ce506a4448f60d5f6f188d18a5dbfe57e3.md @@ -0,0 +1,60 @@ +U.S. Department of Justice +United States Attorney +Southern District of New York +The Silvin I. Mollo Building +One Saint Andrew's Plaza +New York, New York 10007 +July 2, 2020 +The Honorable Katharine H. Parker +United States District Court +Southern District of New York +500 Pearl Street +New York, New York 10007 +Re: +Unsealing of Indictment 20 Cr. 330 +Dear Judge Parker: +The Government respectfully requests that Indictment 20 Cr. 330 be unsealed and that a +United States District Judge be assigned to the case. A proposed order to that effect is attached. +This case is designated as a Wheel Č case. +Respectfully submitted, +AUDREY STRAUSS +Acting United States Attorney +By: +Assistant United States Attorneys +Tel.: +Enclosure + + +UNITED STATES DISTRICT COURT +UNITED STATES OF AMERICA +- v.- +GHISLAINE MAXWELL, +Unsealing Order +20 Cr. 330 +Defendant. +Upon the application of the United States, by the Acting United States Attorney for the +Southern District of New York, Audrey Strauss, +by Assistant United States Attorney +Alex Rossmiller; +It is found that the Indictment in the above-captioned case is currently sealed and the United +States Attorney's Office has applied to have that Indictment unsealed, and it is therefore: +ORDERED that the Indictment in the above-captioned action be unsealed and remain +unsealed pending further order of the Court. +Dated: +New York, New York +July 2, 2020 +Kathare HAmk +HONORABLE KATHARINE H. PARKER +UNITED STATES MAGISTRATE JUDGE + + +UNITED STATES DISTRICT COURT +UNITED STATES OF AMERICA +v. +GHISLAINE MAXWELL, +Defendant. +ORDER +20 Cr. 330 ( ) +(18 u.s.C. S$ 2422, 2423 (a), 1623, 371, & 2.) +AUDREY STRAUSS +Acting United States Attorney. \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/012cf574dad2adaf792a0fc7dff723ce506a4448f60d5f6f188d18a5dbfe57e3.receipt.json b/vision-fixhub/ds9-parsed-01/012cf574dad2adaf792a0fc7dff723ce506a4448f60d5f6f188d18a5dbfe57e3.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..eeaed49b8651d01d467b43a5b43321d7e046737d --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/012cf574dad2adaf792a0fc7dff723ce506a4448f60d5f6f188d18a5dbfe57e3.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -127, + "dataset": "marble-joined", + "doc_id": "012cf574dad2adaf792a0fc7dff723ce506a4448f60d5f6f188d18a5dbfe57e3", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "1d1b45e8819f22b947367a9ebc23ef28c9cdf6df43463b89962c11c1ba2fc2bb", + "output_sha256": "6e94a722c73ea8dafc80c8e55c83bf492ef0b5e000504d099ca5daf31dd235f6", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/01322d708c5f001202ec91c4a403a562f77affc2c91b4c7b953cc1d69d89ea8f.md b/vision-fixhub/ds9-parsed-01/01322d708c5f001202ec91c4a403a562f77affc2c91b4c7b953cc1d69d89ea8f.md new file mode 100644 index 0000000000000000000000000000000000000000..0f88996c041182b4ef01654ca240534ec4fbe23f --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/01322d708c5f001202ec91c4a403a562f77affc2c91b4c7b953cc1d69d89ea8f.md @@ -0,0 +1,27 @@ +From: +To: +Subject: RE: Call +Date: Mon, 20 Sep 2021 17:11:19 +0000 +Inline-Images: image001 jpg; image002 jpg; image005 jpg +Can we do 1:30 pm today? +US +Special Agent +U.S. Department of Justice • Office of the Inspector General • New York Field Office +New York, NY 10004 +From: +To: +Subject: RE: Call +Sent: Monday, September 20, 2021 12:38 PM +Hi - Want to talk today? When are you free? +From: +Sent: Thursday, September 16, 2021 9:15 AM +To: +Subject: Call +Good Morning +Please let me know if you have a few minutes to speak with myself and SSA +Thank you. +regarding the Epstein case. +US +Special Agent / +U.S. Department of Justice • Office of the Inspector General • New York Field Office +New York, NY 10004 diff --git a/vision-fixhub/ds9-parsed-01/01322d708c5f001202ec91c4a403a562f77affc2c91b4c7b953cc1d69d89ea8f.receipt.json b/vision-fixhub/ds9-parsed-01/01322d708c5f001202ec91c4a403a562f77affc2c91b4c7b953cc1d69d89ea8f.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..be1f83e07b77e51caa6c0b8caabc05703786d3c5 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/01322d708c5f001202ec91c4a403a562f77affc2c91b4c7b953cc1d69d89ea8f.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "01322d708c5f001202ec91c4a403a562f77affc2c91b4c7b953cc1d69d89ea8f", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "d78280d215bcb7438c0626933545437e8e9f1e45fb81fea98501df53a88b6f76", + "output_sha256": "6c2625e1ebbcda29837ad8993eed1469a6adf31f87e2c7d941219309dfb7e075", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/015cc902072754c4f9b704c6259d45a4e6724729f36f7cebdd70ea8ed527ba9a.md b/vision-fixhub/ds9-parsed-01/015cc902072754c4f9b704c6259d45a4e6724729f36f7cebdd70ea8ed527ba9a.md new file mode 100644 index 0000000000000000000000000000000000000000..91ff9079808815d797b73ddd4fc95f89919f481c --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/015cc902072754c4f9b704c6259d45a4e6724729f36f7cebdd70ea8ed527ba9a.md @@ -0,0 +1,313 @@ +UNITED STATES DEPARIMENT OF JUSTICE +Shift-Day-Date: M/W Thursday, August 01, 2019 +Beginning Count: 763 +Daily Sensitive Information: +M/W +I/M Melendez #85799-054 at Local Hosp. w/USMS Guards +I/M +#86307-054 on Psych Obs. w/inmate companion +TIME +12:00 +AM +CHRONOLOGICAL EVENTS +Lieutenant +assumes duties as +the Morning Watch +Operations +Lieutenant. +The +fire alarm and sprinkler system are +operational +w/exception +of Control Center Fire Panel. +PREA +announcement conducted via the Institution Public Address System +and/or Radio. +Restraint Equipment Cage inventory conducted. All +equipment +accounted +for. Metal Detector checks conducted. All +operative w/the exception of Rear Gate/Facilities/R&D. +Roof Check +completed. All secure. Temporary Chit Inventory: #1:2; #2:5; #3:5; +#4:6; #5:5; #6:0; Hosp:0 +12:00 +AM +12:00 +AM +12:10 +AM +12:30 +AM +12:36 +AM +1:01 +AM +1:08 +AM +3:00 AM +3:35 +AM +3:36 AM +4:15 +AM +Institution Count in progress +NYPD Phone Check #1690 +Body Alarm testing in progress +Watch Calls cont. +Body Alarm testing completed +Good Verbal count announced +Clear Institution count announced +Institution Count in progress +Good Verbal count announced +Clear Institution count announced ++3 SHU: +Jimenez #79466-054, +Reyes +#79102-054, Vega #79099-054 +(Pend SIS) +5:00 AM +Institution Count in progress +5:46 AM +Good Verbal count announced +5:48 AM +Clear Institution count announced +8:00 AM +Relieved of duties by It. +as D/W Operations Lieutenant +SIG International Terrorist phone calls monitored: +WITSEC inquiry(s) was/were received during my tour of duty: +The following Inmate(s) were placed in Administrative Detention: +Reg: Number +Reason +Unit +Time +SHU: 73/5 +BC +763 +SHU +73/5 +763 +73/5 +763 +73/5 +763 +763 +73/5 +73/5 +AD Order +Ops It. +осал нодр: 027 3/4 0853 001 -84 085: 50, В 08110 00 + + +UNITED STATES DEPARTMENT OF JUSTICE +SHIFT-DAY-DATE: D/W - Thursday, August 01, 2019 +Beginning Count: 763 +D/W +Daily Sensitive Information: +I/M I/M Melendez #85799-054 at Local Hosp w/USMS Guards. +I/M Davis #89380-053 on dry cell. w/staff +8:00 AM +Lieutenant +assumes duties as the Day Watch Operations +Lieutenant. The +fire alarm and pump system is inoperable at this +time. Fire Watch is in Progress. Unable to conduct PREA +announcement over the Institution Public Address System, due to, +system malfunction. Restraint Equipment Cage inventory conducted. +All equipment accounted for. Metal Detector checks conducted. All +operative w/the exception of Rear Gate. +Roof Check completed. All +secure. Temporary Chit Inventory: #1:0; #2:5; #3:5; #4:6; #5:6; +#6:5; Hosp: 0 +Daily Hand Stamp : DJBE /RIGHT HAND +8:00 AM +8:10 AM +8:30 AM +8:31 AM +11:00 AM +11:17 PM +NYPD Phone Check #1670 +Body Alarm Test Initiated. +AM Census count +Body Alarm Testing Complete. +Mainline feeding in progress. +-4 HLD REMOVE: Diaz #78018-054, Gupta +#84831-054, Perez #86198- +054, Torres #85896-054 +11:35 AM +4 I/M Placed in SHU Cooper #92299-054, Ferrer +#79793-054, Dockery +#60685-050, Marat #76003-054 +11:40 AM +12:30 PM +1:05 PM +2:15 +PM +3:13 +PM +3:45 +PM +4:00 PM +I/M Martinez #85976-054 out to L-Hosp +PM Census count +I/M Martinez #85976-054 return from I-Hosp ++1 I/M Ryan #34249-045 ++1 Gonzalez #87064-054 +Institutional lockdown for count. +Continuation of duties by It. +| E/W Operations Lieutenant. +Visitation: +Inmates +Adults +Children +ION SCANNING TESTED HITS: 0 +STG/High Alert phone calls monitored: +WITSEC inquiry (s) was/were received during my tour of duty: 0 +The following +Inmate (s) were placed in Administrative Detention: 0 +Name +Reg Number +Reason +Unit +TIME +Cooper +Ferrer +Dockery +Marat +Ops It +Act It +92299-054 +113 +ES +12:20 +PM +79793-054 +108 +ES +12:20 +PM +60685-050 +331 +ES +12:30 +PM +76003-054 +312 +IN +1;30 +PM +Ending Count: 760 ; SHU: 80; 10-South: 05; SHU OBS: 00; +Local Hosp: 01; H/A OBS: 01; B/A OBS: 00; Dry Cell: 00 +SHU: 76/5 +763 +76/5 +759 +76/5 +759 +80/5 +758 +80/5 +759|80/5 +760 | 80/5 +761|80/5 +761 +80/5 +Total +A/D Order + + +UNITED STATES DEPARTMENT OF JUSTICE +SHIFT-DAY-DATE: E/W - Thursday, August 1, 2019 +|Beginning Count: 761 +Daily Sensitive Information. +E/W +I/M Burnett #76254-054 at Goldcrest nursing facility w/USMS Guards +I/M Davis #89380-053 on Dry Cell/ under BOP staff watch +TIME +CHRONOLOGICAL EVENTS +Lieutenant +assumes duties as the Evening Watch Operations +Lieutenant. Unable to conduct PREA announcement over the +institution Public Address System, due to, system malfunction +4:00 PM +estraint Equipment Cade inventory conducted. Al1 equipment +accounted for. Metal Detector checks conducted. All operative +w/the exception of Rear Gate. +Roof Check completed. All secure. +Temporary Chit Inventory: #1:0; #2:0; #3:0; #4:0; #5:1; #6:0; +4:00 PM +4:01 PM +4:18 PM +4:39 PM +4:42 PM +4:54 PM +5:39 PM +6:00 PM +6:40 PM +7:00 PM +Institution count in progress. +NYPD Phone Check #1736 +Body Alarm testing in progress. +Good verbal announced. +Body alarm testing completed. +Clear institutional count. +-1 hld remove; I/M Webster #39715-013 +Watch call in progress +3 from special housing to general population ++6; Alamo #70105-050, Binns #67290-054, Guerrero #44543-054, +Jimenez #87067-054, Nieves #86340-054, and Niftalijev #87066-054 +8:01 +PM +Trash run in progress +8:40 +PM +Trash run complete +9:00 PM +transferred to special housing +I/M Guerrero #44543-054 +10:00 +PM +Institutional count in progress. +10:41 PM +Good verbal count announced. +10:44 PM +Clear institutional count announced. +12:00 AM +Relieved of duties by It. +as the M/W Lieutenant. +VISITING: 9 North +INMATES +ADULTS +27 +CHILDREN +8 +STG/High Alert phone calls monitored: +ITSEC inquiry(s) was/were received during my tour of duty: +he following Inmate(s) were placed in Administrative Detention: +NAME +REG NUMBER +REASON +UNIT +TIME +SHU: 80/5 +в/C +761 +SHU +80/5 +761| 80/5 +760 +80/5 +760 | 77/5 +766| 77/5 +766| 78/5 +766 | 78/5 +766| 78/5 +TOTAL +53 +A/D ORDER +Ops. It. +Act. Lt. +Ending Count: 766 ; SHU: 78; 10-South: 05; SHU OBS: 00; +Local Hosp: 01; H/A OBS: 01; B/A OBS: 00; Dry Cell: 00; +B/A SHU: 00 \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/015cc902072754c4f9b704c6259d45a4e6724729f36f7cebdd70ea8ed527ba9a.receipt.json b/vision-fixhub/ds9-parsed-01/015cc902072754c4f9b704c6259d45a4e6724729f36f7cebdd70ea8ed527ba9a.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..e2d89c1a9655b529e43d493799c6eb7eff19058b --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/015cc902072754c4f9b704c6259d45a4e6724729f36f7cebdd70ea8ed527ba9a.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -263, + "dataset": "marble-joined", + "doc_id": "015cc902072754c4f9b704c6259d45a4e6724729f36f7cebdd70ea8ed527ba9a", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "9c70b538bc5ef395d1d00e41e90f91b42ebee18b1dee1d9b06f64d55a6edfb24", + "output_sha256": "1451b9336172bd17a39f59e59580fe90204b4546e515e8908a335b479d875635", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/01686f54d229e48105966eb61cb91e6914c44199f28513d23155ec6d1a19dd4f.md b/vision-fixhub/ds9-parsed-01/01686f54d229e48105966eb61cb91e6914c44199f28513d23155ec6d1a19dd4f.md new file mode 100644 index 0000000000000000000000000000000000000000..7c4d2ed135f8d096b2b4a045ba48d109cdaf489e --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/01686f54d229e48105966eb61cb91e6914c44199f28513d23155ec6d1a19dd4f.md @@ -0,0 +1,104 @@ +From: +To: +Subject: +Date: +RE: Interview +Tuesday, October 5, 2021 8:24:56 AM +is a BOP Electrician from Butner he was TDY. We were working together doing conduit, installing +equipment cabinet and doing power. +The problem in August 2019 was bad hard drives The equipment is at the end of life there where no parts. I was +able to get a second hand hard drives. I was on the phone the whole time with Signet to complete the install. | +removed the hard drive and replaced and did some minor programing. +2. The Facilities office should have all paper work regarding the camera system on file such a work orders, +purchase orders, and paper work to the business office for the camera project. +3.I will supply all bop/signet emails. +4. MCC Camera Issues +- Facilities Manger +• General Forema +• Engineering Tect +- Special Investigative Agent +Computer - Service Manger +- Electronics Technician +5. When we spoke on the 29th of September that was the first time I heard about this issue. +6. I will supply you with any other information that I have. +Communication Technician +US Department of Justice +MCC-New York +150 Park Row +New York, NY 10007-1704 +Phon +Fa +2>> +• 10/1/2021 10:07 AM >> +Good morning Mr. +Thank you again for taking the time to speak with us on Wednesday, September 29, 2021. Per our +conversation, can you please provide the following as soon as you are able. +1 - Identifying information for Hughes and a brief explanation with regard to his connection to the +MCC camera issue in August 2019. +2 - Any and all purchase orders and additional information, to include all communication, with regard +to the order, receipt, and request to install the new camera system that was on site at the MCC in +August 2019. + + +3 - Any and all email communication between you and BOP/SigNet employees regarding any and all +issues with the camera system on and prior to August 10, 2019. +4 - Additional information on +and Jeffrey Colton, to include their +involvement with the camera issue(s). +5 - Any and all information surrounding the system failure of DVR 2 on July 29, 2019, including the +date(s) you worked on the system, why you were working on the system, what you did, and all +communications you had with regard to the work you performed on or around that time (with both +BOP and SigNet employees). +6 - Any and all addition information, to include all emails, with regard to MCC camera issues, and your +request to resolve those issues, prior to August 10, 2019. +Thank you very much in advance. Your continued cooperation with this matter is greatly appreciated. +Have a great day/weekend. +U.S. Department of Justice +OIG Boston Area Office +*Please note the above phone number change +From: | +Sent: Tuesday, September 28, 2021 1:22 PM +To: +Subject: RE: Interview +okay that is fine +>>» +Good afternoon Mr. +• 9/28/2021 12:51 PM >>> +I also want to thank you for agreeing to meet with us tomorrow to help us better understand the +information we have received since we last spoke regarding the previous MCC camera system. I have +a hard stop time at approximately 10 am due to another matter. Can you please arrive at our building +no later than 8:15 am, so that we may begin no later than 8:30 am? Thank you very much in advance. +I look forward to speaking with you tomorrow. Have a great day. +U.S. Department of Justice + + +OIG Boston Area Office +*Please note the above phone number change +From:| +Sent: Tuesday, September 28, 2021 11:29 AM +To: +Cc:/ +Subject: RE: Interview +Good Morning Mr. J +Thank you for agreeing to come in for a voluntary interview tomorrow, September 29 at 8:30am. +When you arrive at the lobby of 1 Battery Park Plaza, please give Senior Special Agent I +call at +He will come down and escort you to our office. If you have any questions, +please give me a call at +Thank you. +a +Special Agent +U.S. Department of Justice • Office of the Inspector General • New York Field Office +One Battery Park Plaza, 29** Floor, New York, NY 10004 +Cell: +From: +Sent: Monday, September 27, 2021 1:41 PM +To: +Subject: Re: Interview +Good afternoon +I will be available. +Communication Technician +US Department of Justice +MCC-New York +150 Park Row +New York, NY 10007-1704 diff --git a/vision-fixhub/ds9-parsed-01/01686f54d229e48105966eb61cb91e6914c44199f28513d23155ec6d1a19dd4f.receipt.json b/vision-fixhub/ds9-parsed-01/01686f54d229e48105966eb61cb91e6914c44199f28513d23155ec6d1a19dd4f.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..f96deeb24a6259067800b0a1af11cb618c22a618 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/01686f54d229e48105966eb61cb91e6914c44199f28513d23155ec6d1a19dd4f.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -36, + "dataset": "marble-joined", + "doc_id": "01686f54d229e48105966eb61cb91e6914c44199f28513d23155ec6d1a19dd4f", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "b367da75c07a7514e80a5a1ade7554c1a85d3e742372cf97bebd9c34b3d401d1", + "output_sha256": "4bbfb211178a288add8a294be6738c0793e6427c33ae023da0be052fa5dc76b8", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/016f8302234a4c76ac6528b382a9f0fc7d938ba72347381233bec5a19c8184b2.md b/vision-fixhub/ds9-parsed-01/016f8302234a4c76ac6528b382a9f0fc7d938ba72347381233bec5a19c8184b2.md new file mode 100644 index 0000000000000000000000000000000000000000..0990b7f99364ee8cb7a1a703b634a97feb6b1c72 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/016f8302234a4c76ac6528b382a9f0fc7d938ba72347381233bec5a19c8184b2.md @@ -0,0 +1,4448 @@ +Sex: +Encounter Date: 07/09/2019 12:35 +Provider: +Thorax: +Contour Normal: Yes +Increased AP Diameter: No +Asymmetrical Expansion: No +Lungs Clear: Yes +Wheezes: No +Crackles:No +Rhonchi: No +Rales: No +Accessory Muscle Use: No +Comments: +Spine: +Deformity: No +Full ROM: Yes +Tenderness:No +Comments: +Cardiovascular: +RRR: Yes +Normal S1/S2: Yes +Murmurs: No +Carotid Bruits: No +JVD: No +Arteries: +Bight +Radial: +Femoral: +Dorsalis Podis: +Post. Tibialis: +Comments: +Lett +M +Race: WHITE +Reg #: +Facility; +Unit: + + + +Encounter Date: 07/09/2019 12:35 +Abdomen: +Normal Contour: Yes +Scaphold: No +Obese: No +Gravid: No +Hernias: No +Bruits: No +Masses:No +Scars: No +Tenderness: No +Organomegaly: No +Active Bowel Sounds: Yes +Comments: +Extremities: +Nails Clubbing: No +Nails Cyanosis: No +Lower Extremity Edema - Right: None +Lower Extremity Edema - Left: None +Atrophy: No +Amputations: No +Other Deformities: No +Varicosities:No +Calf Tenderness: No +Pulse Deficit: No +Strength: +Right +Arm: +Leg: +Full ROM: +Arm: +Leg: +Bight +Yes +Yes +Comments: +Sex: +Provider: +Race: WHITE +Reg #: +Emility: +HỘ1 +Yes +Yes + + + +Encounter Date: 07/09/2019 12:35 +Reflexes: +Biceps: +Patellar: +Brachioradialis: +Achilles: +Sensation: +Vibratory: Yes +Light Touch: Yes +Pin Prick: Yes +Comments: +Bight +Left +GU: +Chaperoned By: +Rectum: Not Done +Comments: Refused. +Male Genitalia: Not Done +Comments: Refused. +Skin: +Normal: Yes +Rash: No +Redness: No +Abnormal Pigmentation: No +Abnormal Lesions/Growths: No +Comments: +Lymphatics: +Adenopathy: No +Comments: +Potential Items For Follow-up: +Item +Travel Outside US +Other Infectious Disease History +Rectum Not Done +Male Genitalia Not Done +PPD Administration Not Performed +Comments: +Patient has a history of constipation. +Generated 07/09/2019 13:03 by | H +Sex: +Provider. +Race: WHITE +Reg #: +Emility: + + + +Encounter Date: 07/09/2019 12:35 +Sex: +Provider: +Cleared For Food Services: Yes +Health Problems Newly Identified During This Encounter: +Health Problem +Constipation, unspecified - Current - +New Medication Orders: +Bx#l +Medication +Bisacody! +. Tablet +Indication: Constipation, unspecified +Follow-up at Sick Call as Needed +• Race: WHITE +Order Date +07/09/2019 12:35 +Instructed inmate how to obtain medical, dental, and mental health care. +Copay Required: No +Cosign Required: Yes +Telephone/Verbal Order: No +Completed by +on 07/09/2019 13:03 +Requested to be cosigned by +Cosign documentation will be displayed on the following page. +Reg #: +Facility: +Unit: +H01 +Prescriber Order +5 mg Orally at bedtime PRN × 10 +day(s) + + + +Encounter Date: 07/09/2019 12:35 +Cosigned by | +Cosign/Review +Sex: +Provider: +on 07/11/2019 22:41. +Reg #: +Race: +Facility: + + +Inmate Local Hospital +SENSITIVE BUT UNCLASSIFIED - This information is confidential and must be appropriately safeguarded. +Transfer To: +Transfer Date: 08/10/2019 +Health Problems +Health Problem +Hyperlipidemia, unspecified +HYPERTRIGLYCERIDEMIA +Sleep apnea +Essential (primary) hypertension +BY HX. +Constipation, unspecified +Low back pain +Neuralgia and neuritis, unspecified +No Diagnosis +Prediabetes +Status +Current +Current +Current +Current +• Current +Current +Current +Current +Current +Injury, unspecified +R/O self inflicted injuries. +Body mass index (BMI) 27.0-27.9, adult +Current +Medications: All medications to be continued until evaluated by a physician unless otherwise indicated. +Bolded drugs required for transport. +Jocusate Sodium 100 MG Cap Exp: 08/11/2019 SIG: Take one capsule (100 MG) by mouth twice daily for 30 day +Jocusate Sodium 100 MG Cap Exp: 01/22/2020 SIG: Take one capsule (100 MG) twice daily by mouth with plent +of water +Milk of Magnesia Susp (OTC) (473ML) 400MG/5ML Exp: 10/28/2019 SIG: shake well take 10ml by mouth twice +daily AS NEEDED +Omega 3 (Vascepa) 1 GM Capsule Exp: 01/13/2020 SIG: Take two capsules (2 GM) twice daily by mouth with food +OTCs: Listing of all known OTCs this inmate is currently taking. +None +Pending Appointments +Time +07/24/2019 +00:00 +01/07/2020 +00:00 +07/01/2020 +00:00 +07/09/2020 +00:00 +Activity +Chronic Care Visit +Chronic Care Visit +PPD Administration +Optometrist +Mid-Level Provider +Physician 01 +Nurse +Pending Non-Medication Orders: +Order +Order Date +EKG +07/06/2019 +Focal Occult Blood +07/06/2019 +Frequency +One Time +One Time +Duration Details +66 y/o male +3 different stools +TB Clearance: Yes +Last PPD Date: 07/09/2019 +Last Chest X-Ray Date: +TB Treatment: +Induration: 0mm +Results: +Sx free for 30 days: Yes +TB Follow-up Recommended: No +Sickle Cell: +Sickle Cell Trait/Disease: No +Generated 08/10/2019 07:00 by +Page 1 ol 2 + + +SENSITIVE BUT UNCLASSIFIED - This information is confidential and must be appropriately safeguarded. +Limitations/Restrictions/Diets: +Cell: lower bunk - 10/09/2019 +Cleared for Food Service: Yes +Other diet restrictions: FISH ALLERGIES. -- 07/30/2020 +Comments: +Allergies +No Known Allergies +Devices / Equipment +Pap +Direct Travel: No +Travel Restrictions: None +UNIVERSAL PRECAUTIONS OBSERVED WHEN TRANSPORTING ANY INMATE: +Transfer From Institution: NEW YORK MCC +Phone Number: 6468366300 +Address 1: 150 PARK ROW +Address 2: +City/State/Zip: NEW YORK, New York 10007 +Name/Title of Person Completing Form: I +Inmate Name:_EPSTEIN, JEFFREY EDWARD +_Reg#:_ 76318-054_ DOB:_01/20/1953 +Date: +08/10/2019 +Sex: +Generated 08/10/2019 07:00 by + + + +Vitals All +End Date: +08/10/2019 +Rog#: +Temperature: +Time +Eahrenheit Celsius Lecation +07/24/2019 13:12 NYM +97.8 +36.6 Oral +Orig Entered: 07/24/2019 13:14 EST IN +07/23/2019 06:30 NYM +97.5 +36.4 Oral +Orig Entered: 07/23/2019 08:33 EST I +07/09/2019 12:49 NYM +97.3 +36.3 Oral +Orig Entered: 07/09/2019 12:51 EST I| +Pulse: +Rate +Time +Rate Per Minute +Location +07/30/2019 13:02 +94 +Orig Entered: 07/30/2019 13:04 EST | +07/30/2019 09:40 +88 Via Machine +Orig Entered: 07/30/2019 13:04 EST | +07/30/2019 09:30 +87 Via Machine +Orig Entered: 07/30/2019 12:59 EST I +07/28/2019 20:28 +81 +Orig Entered: 07/28/2019 20:29 EST | +07/28/2019 06:57 +82 +Orig Entered: 07128/2019 06:58 EST I +07/24/2019 13:12 +83 +Via Machine +Orig Entered: 07/24/2019 13:14 EST I +07/23/2019 06:30 +92 Via Machine +Orig Entered: 07/23/2019 08:33 EST +07/09/2019 12:49 +82 +Via Machine +Orig Entered: 07/09/2019 12:51 EST I +Rhythm +Regular +Regular +Regular +Respirations: +07/30/2019 +Ilme +Rate Per Minute Provider +09:30 NYM +12 +Orig Entered: 07/30/2019 12:59 EST | +07/28/2019 +20:28 NYM +14 +Orig Entered: 07/28/2019 20:29 EST +07/28/2019 +06:57 NYM +14 +Orig Entered: 07128/2019 06:58 EST +07/23/2019 +06:30 NYM +Orig Entered: 07/23/2019 08:33 EST | +07/09/2019 +12:49 NYM +16 +16 +Orig Entered: 07/09/2019 12:51 EST | + + + +Reg i: +Blood Pressure: +Iime +Value +Lecation +07/30/2019 13:02 NYM 114/84 +Left Arm +Orig Entered: 07/30/2019 13:04 EST # +07/30/2019 09:40 NYM 125/60 +Right Arm +Orig Entered: 07/30/2019 13:04 EST ( +07/30/2019 09:30 NYM 108/86 +Left Arm +Orig Entered: 07/30/2019 12:59 EST 1/ +07/28/2019 20:28 NYM 157/91 +Orig Entered: 07/28/2019 20:29 EST | +07/28/2019 06:57 NYM 138/80 +Orig Entered: 07/28/2019 06:58 EST +07/24/2019 13:12 NYM 132/89 +Right Arm +Sitting +Orig Entered: 07124/2019 13:14 EST / +07/23/2019 06:30 NYM 140/85 +Right Arm +Sitting +Orig Entered: 07/23/2019 08:33 EST +07/09/2019 12:49 NYM 117/66 +Right Arm +Sitting +Orig Entered: 07/09/2019 12:51 EST / +Blood Glucose: +Time +Value (mg/al) +Iype +08/04/2019 +08:30 +156 +Non-Fasting +Orig Entered: 08/04/2019 09:08 EST I +08/02/2019 +06:30 +97 +Non-Fasting +Orig Entered: 08/02/2019 08:16 EST I +08/01/2019 +06:30 +103 +Non-Fasting +Orig Entered: 08/01/2019 09:00 EST || +07/31/2019 +06:15 +108 +Non-Fasting +Orig Entered: 07/31/2019 08:36 EST +SaO2: +Time +Value(%) Air +07/30/2019 +09:30 NYM +98 Room Air +Orig Entered: 07/30/2019 12:59 EST | +07/28/2019 20:28 NYM +Orig Entered: 07/28/2019 20:29 EST +07/28/2019 06:57 NYM +Orig Entered: 07/28/2019 06:58 EST [ +07/24/2019 13:12 NYM +96 Room Air +Orig Entered: 07/24/2019 13:14 EST | +07/23/2019 06:30 NYM +96 Room Air +Orig Entered: 07/23/2019 08:33 EST | +07/09/2019 12:49 NYM +97 Room Air +Orig Entered: 07/09/2019 12:51 EST |I +Height: +Generaled 08/10/2019 11:02 by I +End Date: +08/10/2019 +Position +Standing +Cuff Size +Standing +Sitting +Adult-regular +Adult-regular +Adult-regular +Regular Insulin + + + +End Date: +08/10/2019 +Reg #: +Time +Inches +cm +07/09/2019 12:49 NYM +70.0 ' +177.8 +Orig Entered: 07/09/2019 12:51 EST J +Weight: +Ilme +Les +07/30/2019 +09:30 NYM +194.2 +88.1 +Orig Entered: 07/30/2019 12:59 EST I/ +07/09/2019 12:49 NYM +194.4 +88.2 +Orig Entered: 07/09/2019 12:51 EST J +Kg Waist Circum, Provider +Generaled 08/10/2019 11:02 byL + + + +Admin: +Lecation +07/06/2019 21:39 Right Forearm +Orig Entered: 07/06/2019 21:43 EST +Total: 1 +PPDs +Reading: +Induration +07/09/2019 12:47 +0 mm +Orig Entered: 07/09/2019 12:47 EST +Generated 08/10/2019 11:02 by i! + + + +Ord, Data +07/30/19 +14:21 +Exp. Data +07/31/19 +10:01 + +Ord. Date +07/31/19 +10:00 +Exp. Date +08/07/19 +09:59 +122160- +EPSTEIN, JEFFREY +Medication Orders +ect regular Insulin subcutaneously F +ding scale: twice dally **pill ling* fo +days +Medication Administration Record +JULY 2019 +Time 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 +PRN +Insulin Reg (10 ML) 100 UNITS/ML Inj +Inject regular insulin subcutaneously par +sliding scale: each morning for 7 days ***pil +line** +PRN +Insuln Reg (10 ML) 100 UNITSIML In) +Providers: HAHAR +Documentation Codes: ORD = Order | NI = Dose Not Indicated +Registration #: 76318-054 +PL Name: EPSTEIN, JEFFREY +DOB: 01/20/53 +Report information is current as of the date and lime of printing: 08/10/2019 11:02 EST + + +rd. Dat +EPSTEIN, JEFFREY +Medication Orders +Medication Administration Record +AUGUST 2019 +2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 +Time +PRN +122160- +Insulin Reg (10 ML) 100 UNITSIL In) +Providers: +Documentation Codes: ORD = Order | NI = Dose Not Indicated +Registration #: 76318-054 +Pr. Name: EPSTEIN, JEFFREY +BOB: 0172053 +Report information is current as of the date and time of printing: 08/10/2019 11:02 EST + + +Start Date: 07/07/2019 +Reg #: +Device/Equipment +L-Pap +07/30/2019 14:05 EST MINI +Total: 1 +Devices and Equipment +Stop Date: 08/10/2019 +Start Date Stop Date +Rate Returned +Obtained From Comments +07/30/2019 +Personal +PHILIPS RESPIRONICS SYSTEM ONE CPAP +MACHINE. +SERIAL #: P11312813B1ED. + +ЛОРЛОС + + +Pain Management +Reg #: +Intervention +07/12/2019 13:25 +MEDROL DOSE PACK +Orig Entered: 07/12/2019 13:28 EST +Pain Quality +Shooting +ind Date: +08/10/2019 +nmate Name: EPSTEIN, JEFFREY EDWARE +Location +Pre Post +Back-Middle 5 +ЛОРЛОС + + + +Types of Diets: +_ Clear Liquid +Low Fat +_ Mechanical Soft +Low Cholesterol +Low Triglyceride +Renal +_ Full Liquid +— Sodium Controlled +_ Snack +- Diabetic +Calorie Controlled +* Other: FISH ALLERGIES. +Comments: +Inmate Name +Generated 07/30/2019 14:57 by +Modified Diet Request +Exp Date: +Exp Date: +Exp Date: +Exp Date: +Exp Date: +Exp Date: +Exp Date: +Exp Date: +Exp Date: +Exp Date: +Exp Date: +Exp Date: 07/30/2020 +Health Service Staff +Reg# +07/30/2019 + + + +Allergy +No Known Allergies +Orig Entered: 07/06/2019 21:40 EST +Total: 1 +Allergies +Date Noted +07/06/2019 +Reaction +Generated 08/10/2019 11:02 by [ + + + +Rog#: 76318-054 +Patient Education Assessments & Topics +Assessments +Years ef Education Barriers Te Educatien +None +Assessment +07/09/2019 +Total: 1 +Learns Rest Bx +Primary Language +Speaking/Listening English +Orig Entered: 07/09/2019 12:52 EST +Topics +Date Initiated +07/30/2019 +07/30/2019 +07/28/2019 +07/28/2019 +07/24/2019 +07/24/2019 +07/23/2019 +07/23/2019 +07/14/2019 +07/12/2019 +Format +Handout/ToRic +Counseling +Access to Care +Orig Entered: 07/30/2019 13:33 EST | +Counseling +Plan of Care +Orig Entered: 07/30/2019 13:34 EST +Counseling +Plan of Care +Orig Entered: +07/28/2019 07:22 EST +Counseling +Plan of Care +Orig Entered: 07/28/2019 20:30 EST +Counseling +Access to Care +Orig Entered: 07/24/2019 13:23 EST / +Counseling +Preventive Health +Orig Entered: 07/24/2019 13:23 EST +Counseling +Access to Care +Orig Entered: 07/23/2019 09:04 EST +Counseling +Plan of Care. +Orig Entered: 07/23/2019 09:04 EST +Counseling +Diagnosis +Orig Entered: 07/14/2019 18:11 EST +Counseling +Diagnosis +Outcome +Verbalizes Understanding +Verbalizes Understanding +Verbalizes Understanding +Verbalizes Understanding +Verbalizes Understanding +Verbalizes Understanding +Verbalizes Understanding +Verbalizes Understanding +Verbalizes Understanding +Verbalizes Understanding + + + +Rog#: 76318-054 +Topics +Date Initiated +Total: 10 +Format +Handout/Topic +Orig Entered: 07/12/2019 13:33 EST | +Outcome +Generated 08/10/201911:02 by HOP/D + + + +Blood Glucose +End Date: +08/10/2019 +Rog #: +Inmato Name: EPSTEIN, JEFFREY EDWARD +(Reference Range: Random or Fasting 70 - 100, 2 hour post-prandial 70 - 140) +Time +Value +TYpe +Somments +08/04/2019 08:30 NYM 156 +Non-Fasting +Orig Entered: 08/04/2019 09:08 EST +08/02/2019 06:30 NYM 97 +Non-Fasting +Orig Entered: 08/02/2019 08:16 EST +08/01/2019 06:30 NYM 103 +Non-Fasting +Orig Entered: 08/01/2019 09:00 EST +07/31/2019 06:15 NYM 108 +Non-Fasting +Orig Entered: 07/31/2019 08:36 EST +Total: 4 +Generated 08/10/2019 11:02 by| + + + +Description +Hyperlipidemia, unspecified +07/12/2019 13:48 EST +HYPERTRIGLYCERIDEMIA +Sleep apnea +07/12/2019 13:56 EST +Essential (primary) hypertension +07/30/2019 13:13 EST +BY HX. +Constipation, unspecified +07/09/2019 12:58 EST +Low back pain +07/12/2019 13:30 EST +Neuralgia and neuritis, unspecified +07/12/2019 13:30 EST +No Diagnosis +07/09/2019 10:28 EST +Prediabetes +07/30/2019 13:26 EST +Injury, unspecified +07/23/2019 09:04 EST +R/O self inflicted injuries. +Body mass index (BMI) 27.0-27.9, adult +07/30/2019 13:14 EST +Total: 10 +Health Problems +Axis Code Type +Current +Generated 08/102019 11:02 by | +Code +E785 +G4730 +110 +K5900 +M545 +M792 +No Dx +R7303 +T1490 +26827 +Diag. Date Status +07/12/2019 Current +07/12/2019 Current +07/30/2019 Current +07/09/2019 Current +07/12/2019 Current +07/12/2019 Current +07/09/2019 Current +07/30/2019 Current +07/23/2019 Current +07/30/2019 Current +Status Date +I DSM-IV + + + +Encounter Date: 07/12/2019 13:10 +Sex: +Provider: +Race: WHITE +Unit: Z05 +Chronic Care - 14 Day Physician Eval encounter performed at Health Services. +SUBJECTIVE: +COMPLAINT 1 +Provider: +Chief Complaint: ENDO/LIPID +Subjective: +66 YR OLD WHITE MALE WITH HX OF +HYPERTRIGLYCERIDEMIA X 5 YEARS ON VASCEPA FOR 1 YEAR. STATES TRIGL WAS +800 , NOW 434. STATES HE COULD NOT TOLERATE OTHER ANTI-TRIGLYCERIDE +MEDS DUE TO THEIR GI SIDE EFFECTS. +HX OF OBSTRUCTUVE SLEEP APNEA X 5 YEARS FOR WHICH HE USED A CPAP +MACHINE. STATES HE HAD HIS CPAP MACHINE WITH HIM WHEN HE ARRESTED. +STATES THE FBI/LOKELY HAS +L4 - L5 SEVERE STENOSIS CASUING NUMBNESS AND SHOOTING PAIN IN THE +LOWER EXTREMITIES. +SURGICAL HX: NONE +MENTAL HEALTH HX: NONE +Pain: +Pain Assessment +Date: +07/12/2019 13:25 +Location: +Quality of Pain: +Shooting +Pain Scale: +5 +Intervention: +Trauma Date/Year: +Injury: +Mechanism: +Onset: +5+ Years +Duration: +5+ Years +Relieving Factors: +Reason Not Done: +Comments: +Amendment +Back-Middle +MEDROL DOSE PACK +Exacerbating Factors: NO EXERCISE +MEDROL DOSE PACK +Seen for clinic(s): Endocrine/Lipid, Pulmonary/Respiratory, Orthopedic/Rheumatology +Added to clinic(s): Endocrine/Lipid, Pulmonary/Respiratory, Orthopedic/Rheumatology +OBJECTIVE: +Exam: +General +Appearance +Yes: Appears Well, Alert and Oriented × 3 +No: Appears Distressed, Dyspneic, Appears in Pain, Writhing in Pain, Pale, Pallor, Cyanotic, Diaphoretic, +Disheveled, Unkempt, Acutely III +Nutrition + + + +Encounter Date: 07/12/2019 13:10 +Exam: +Eyes +Sex: +Provider: +M +General +Yes: PERRLA, Extraocular Movements Intact +Pulmonary +Auscultation +Yes: Clear to Auscultation +Cardiovascular +Auscultation +Yes: Regular Rate and Rhythm (RRR), Normal S1 and S2 +No: M/R/G +Abdomen +Auscultation +Yes: Normo-Active Bor +Palpation +Yes: Within Normal Limits +Musculoskeletal +Tibia / Fibula +No: Edema +Back +Yes: Tenderness +Neurologic +Cranial Nerves (CN) +Yes: Within Normal Limits +Motor System-General +Yes: Normal Exam +ASSESSMENT: +Constipation, unspecified, K5900 - Current +Hyperlipidemia, unspecified, E785 - Current +Low back pain, M545 - Current +Neuralgia and neuritis, unspecified, M792 - Current +Sleep apnea, G4730 - Current +PLAN: +New Medication Orders: +Rx# +Medication +Magnesium Hydroxide Susp +Indication: Constipation, unspecified +Methy|PREDNISolone Tab 4 MG ( Dose +Pack 21 tab) +Indication: Neuralgia and neuritis, unspecified +Race: WHITE +Reg#: 76318-054 +Unit: +Z05 +Amendment +Order Date +07/12/2019 13:10 +07/12/2019 13:10 +Prescriber Order +30 CC Orally - Two Times a +Day PRN x 2 days) +AS DIRECTED Orally - daily x +6 days) + + + +Encounter Date: 07/12/2019 13:10 +Sex: +Provider: +M +Race: WHITE +Follow-up at Sick Call as Needed +Other: +WILL CONTINUE NOTES TO ADDRESS THE NFDR AND FOLLOW-UP. +Patient Education Topics: +Date Initiated Format +07/12/2019 +Counseling +Unit: Z05 +Copay Required: No +Telephone/Verbal Order: +Completed by +Handout/Topic +Diagnosis +Cosign Required: No +ee +on 07/12/2019 14:20 +ee Amendment +Amendment +Outcome +Verbalizes + + + +Encounter Date: 07/12/2019 13:10 +Sex: +Provider: +M +Race: WHITE +Unit: +Z05 +Chronic Care - 14 Day Physician Eval encounter performed at Health Services. +SUBJECTIVE: +COMPLAINT 1 +Provider: +Chief Complaint: ENDO/LIPID +Subjective: +66 YR OLD-WHITE MALE WITH HX OF +HYPERTRIGLYCERIDEMIA X 5 YEARS ON VASCEPA FOR 1 YEAR. STATES TRIGL WAS +800. NOW 434. STATES HE COULD NOT TOLERATE OTHER ANTI-TRIGLYCERIDE +MEDS DUE TO THEIR GI SIDE EFFECTS. +HX OF OBSTRUCTUVE SLEEP APNEA X 5 YEARS FOR WHICH HE USED A CPAP +MACHINE. STATES HE HAD HIS CPAP MACHINE WITH HIM WHEN HE ARRESTED. +STATES THE FBILOKELY HAS +L4 - L5 SEVERE STENOSIS CASUING NUMBNESS AND SHOOTING PAIN IN THE +LOWER EXTREMITIES. +SURGICAL HX: NONE +MENTAL HEALTH HX: NONE. +Pain: +Yes +Pain Assessment +Date: +Location: +Quality of Pain: +Pain Scale: +Intervention: +MEDROL DOSE PACK +Trauma Date/Year: +Injury: +Mechanism: +Onset: +5+ Years +Duration: +5+ Years +Exacerbating Factors: NO EXERCISE +Relieving Factors: +07/12/2019 13:25 +Back-Middle +Shooting +5 +amendment +MEDROL DOSE PACK +Reason Not Done: +Comments: +Seen for clinic(s): Endocrine/Lipid, Pulmonary/Respiratory, Orthopedic/Rheumatology +Added to clinic(s): Endocrine/Lipid, Pulmonary/Respiratory, Orthopedic/Rheumatology +OBJECTIVE: +Exam: +General +Appearance +Yes: Appears Well, Alert and Oriented × 3 +No: Appears Distressed, Dyspneic, Appears in Pain, Writhing in Pain, Pale, Pallor, Cyanotic, Diaphoretic, +Disheveled, Unkempt, Acutely III +Nutrition + + + +Encounter Date: 07/12/2019 13:10 +Exam: +Eyes +Sex: +Provider: +M +Race: WHITE +Unit: Z05 +General +Yes: PERRLA, Extraocular Movements Intact +Pulmonary +Auscultation +Yes: Clear to Auscultation +Cardiovascular +Auscultation +Yes: Regular Rate and Rhythm (RRR), Normal S1 and S2 +No: M/R/G +Abdomen +Auscultation +Yes: Normo-Active Bo +War sounds +Palpation +Yes: Within Normal Limits +Musculoskeletal +Tibia / Fibula +No: Edema +Back +Yes: Tenderness +Neurologic +Cranial Nerves (CN) +Yes: Within Normal Limits +Motor System-General +Yes: Normal Exam +ASSESSMENT: +Amendment +Constipation, unspecified, K5900 - Current +Hyperlipidemia, unspecified, E785 - Current +Low back pain, M545 - Current +Neuralgia and neuritis, unspecified, M792 - Current +Sleep apnea, G4730 - Current +PLAN: +New Medication Orders: +Rx# +Medication +Magnesium Hydroxide Susp +Order Date +07/12/2019 13:10 +Prescriber Order +30 CC Orally - Two Times a +Day PRN x 2 days) +Indication: Constipation, unspecified +Methy|PREDNISolone Tab 4 MG ( Dose +Pack 21 tab) +Indication: Neuralgia and neuritis, unspecified +07/12/2019 13:10 +AS DIRECTED Orally - daily x +6 days) +Generated 07/12/2019 14:20 by M + + + +Encounter Date: 07/12/2019 13:10 +Follow-up at Sick Call as Needed +Sex: +Provider: +Race: WHITE +Other: +WILL CONTINUE NOTES TO ADDRESS THE NFDR AND FOLLOW-UP. +Patient Education Topics: +Date Initiated Format +07/12/2019 +Counseling +Reg#: 76318-054 +Unit: Z05 +Copay Required: No +Telephone/Verbal Order: No +Completed by +Handout/Topic +Diagnosis +Cosign Required: No +on 07/12/2019 14:20 +ée Amendment +Outcome +Verbalizes + + + +See Amendment +Sex: +Encounter Date: 07/14/2019 17:36 +Amendment made to this note by +M +on 07/14/2019 18:11. +Reg #: +Race: +Facility: + + +Date of Birth +Vote Date: +07/12/2019 09:06 +Sex: +Provider: +Bace WHITE +Reg #: +Facility: +20S +Admin Note - Orders encounter performed at Health Services. +Administrative Notes: +ADMINISTRATIVE NOTE 1 +Provider: | +PATIENT REQUESTED TO HAVE A COLACE RX, INSTEAD OF TEH BISACODYL FOR CONSTIPATION. +New Medication Orders: +Rx#l +Medication +Docusate Sodium Capsule +Order Rate +07/12/2019 09:06 +Prescriber Order +TAKE ONE 100 MG CAP Orally +- Two Times a Day x 30 day(s) +Indication: Constipation, unspecified +Discontinued Medication Orders: +Rx# +Medication +121757-NYM +Bisacody! +- 5 MG TAB +Order Date +07/12/2019 09:06 +Prescriber Order +Take one tablet (5 MG) by mouth +at bedtime AS NEEDED for 10 +days +Discontinue Type: When Pharmacy Processes +Discontinue Reason: discontinue +Indication: +Copay Required:No +Telephone/Verbal Order: No +Completed by +Cosign Required: No +on 07/12/2019 09:10 +Generated 07/12/2019 09:10 by + + + +Note Date: +07/07/2019 00:17 +Provider: +Reg #: +Faility: +Cosign Note - Intake Cosign encounter performed at Health Services. +Administrative Notes: +ADMINISTRATIVE NOTE 1 +Provider: +MED CL:1 +NO CCC APPT. +Discontinued Laboratory Requests: +Details +Lab Tests-H-Hemoglobin A1C +Erequency +One Time +Lab Tests--CBC w/diff +Lab Tests-L-Lipid Profile +Lab Tests--Comprehensive Metabolic Profile +(CMP) +Lab Tests-U-Urinalysis w/Reflex to Microscopic +Additional Information: +66//o male, elevated BP +Labs requested to be reviewed by: +New Laboratory Requests: +Details +Chronic Care Clinics-Diabetic-CBC w/diff +Erequency +One Time +Chronic Care Clinics-Diabetic-Lipid Profile +Chronic Care Clinics-Diabetic-Hemoglobin A1 +Lab Tests-H-HIV 1/2 +Lab Tests-R-RPR +Chronic Care Clinics-Diabetic-Comprehensive +Metabolic Profile (CMP) +New Radiology Request Orders: +Details +Erequency +End Date +General Radiology-Chest-2 Views +One Time +Specific reason(s) for request (Complaints and findings): +66 YR OLD MALE WITH NO PMHX, REFERRED FOR ROUITNE CXR. +Copay Required: No +Cosign Required: No +Telephone/Verbal Order: No +Completed by +on 07/07/2019 00:30 +Rue Date +08/05/2019 00:00 +Due Date +07/25/2019 00:00 +Due Date +07/25/2019 +E06 +Priority +Routine +Priority +Routine +Priority +Routine +Generated 07/07/2019 00:30 by + + + +History & Physical +Sex: +Encounter Date: 07/09/2019 12:35 +Provider: +M Races: WHITE +Seizures: +Diabetes: +Cardiovascular: +CVA: +Hypertension: +Respiratory: +Sickle Cell Anemia: +Carcinoma/Lymphoma: +Allergies: +Denied +Denied +Denied +Denied +Denied +Denied +Denied +Denied +Denied +Tuberculosis: +Hx of Previous Disease: No +Blood-tinged Sputum: No +Night Sweats: No +Weight Loss: No +Fever: No +Cough: No +Comments: +Infectious Disease Risk Factors: +IV Drug Use: No +IV Drug Use Needles: +Sexual Partner IV Drug Use: No +Sexual Partner IV Drug Use Needles: +Female Sexual Partners (Last 5 Yrs): 10+ +Male Sexual Partners (Last 5 Yrs): 0 +Condom Use: Sometimes +Sexual Contact With HIV+ Individual: No +Blood Product Transfusion: No +Travel Outside US: Yes +Tattoos: No +Comments: Born in US +High school diploma +Banker +Traveled to Paris × 3 weeks up until arrest +No tattoos +Reg #: +Facility: + + + +Encounter Date: 07/09/2019 12:35 +HIV History: +When Tested: +Test Result: +2019 +When Diagnosed AIDS: +Last CD4: +Comments: +Hepatitis: +Denied +Other Infectious Diseases: +Syphilis: +No +Syphilis Last Treatment: +NIA +Genital Warts: +No +Chlamydia: +Yes +Gonorrhea: +No +Herpes: +No +Chicken Pox: +Yes +Other: +No +Comments: Chlamydia in 2015, treated +Chicken pox in childhood +Abuse History: Denied +Physical: No +Emotional: No +Sexual: No +Comments: Denies +Sex: +Provider: +Race: WHITE +Reg #: +Facility: + + + +Encounter Date: 07/09/2019 12:35 +Mental Health: +Level of Consciousness: Alert and Oriented +Psychomotor Activity: Normal +General Appearance: Normal +Behavior: Cooperative +Mood: Appropriate to Content +Thought Process: Goal Directed +Thought Content: Normal +Hx of Mental Health Treatment: None +Hx of Head Injury: None +Current Mental Health Treatment: No +Current Mental Health Complaint: No +Hx of Loss of Consciousness: No +Hx of Hearing Voices: No +Past History of Suicide Attempt: No +Current Suicide Ideation: No +Suicide Prevention Initiated: No +Comments: +Substance Use History: Denied +Current Painful Condition: +Denied +Other Health Issues: +Current Medical Conditions: +Other Current Treatments: +Pregnant: +N/A +Dental Condition: Denied +Sex: +Provider: +M Race: WHITE +Reg#: +Facility: +Unit: +Generated 07/09/2019 13:03 by I + + + +Sex: +Encounter Date: 07/09/2019 12:35 +Provider: +Observations: +Draining Skin Lesions: No +Signs of Lice: No +Signs of Scabies: No +Signs of Recent Trauma: No +Recent Tattoos: No +Needle Marks: No +Signs of Rash: No +Open Sores: No +Wounds: No +Body Deformities: No +Tremors: No +Sweating: No +Comments: +Y BA WHITE +Reg #: +Facility: +HOM +Generated 07/09/2019 13:03 by! + + + +Encounter Date: 07/09/2019 12:35 +Sex: +M +Provider: +Race: WHITE +Immunizations: +Hepatitis A and B (TwinRx) Series Administration: History Unknown, Not Administered +Documented Date: 07/09/2019 12:51 EST +Immunization Date: +Location: +Drug Mfg: +Lot Number: +Dosage: +Route: +Exp Dt: +Comments: +Measles/Mumps/Rubella Series Administration: History Unknown, Not Administered +Documented Date: 07/09/2019 12:51 EST +Immunization Date: +Provider: !!! +Location: +Drug Mfg: +Lot Number: +Dosage: +Route: +Exp Dt: +Comments: +Smallpox Series Administration: History Unknown, Not Administered +Documented Date: 07/09/2019 12:51 EST +Immunization Date: +Provider: WHI! +Location: +Drug Mfg: +Lot Number: +Dosage: +Route: +Exp Dt: +Comments: +Tetanus Administration: History Unknown, Not Administered +Documented Date: 07/09/2019 12:51 EST +Generated 07/09/2019 13:03 by HIM +Reg #: +Facility: +Unit: +HOT + + + +Encounter Date: 07/09/2019 12:35 +Sex: +Provider: +Immunization Date: +Provider: I| +Location: +Drug Mfg: +Lot Number: +Dosage: +Route: +Exp Dt: +Comments: +Varicella Series Administration: History Unknown, Not Administered +Documented Date: 07/09/2019 12:51 EST +Immunization Date: +Provider: | +Location: +Drug Mfg: +Lot Number: +Dosage: +Route: +Exp Dt: +Comments: +Temperature: +07/09/2019 +Time +12:49 NYM +Eatratele Saida Oration +36.3 Oral +Pulse: +Time +07/09/2019 12:49 +Rate Per Minute +82 +Location +Via Machine +Respirations: +07/09/2019 +Time +12:49 NYM +Rate Per Minute Provider +16 +Blood Pressure: +Time +Value +07/09/2019 12:49 NYM 117/66 +Location +Right Arm +Position +Sitting +Sa02: +07/09/2019 +Time +12:49 NYM +Value(%) Air +97 Room Air +Height: +Time +07/09/2019 12:49 NYM +Inches +70.0 +Genorated 07/09/2019 13:03 by +Cm +177.8 +Race: WHITE +Reg#: +Facility: +Unit: +H01 +Rhythm +Regular +Cuff Size +Adult-regular + + + +Encounter Date: 07/09/2019 12:35 +Time +Inches +Weight: +Time +07/09/2019 12:49 NYM +Libs +194.4 +Prosthetic Devices/Equipment: Denied +Tobacco Usage: Denied +General Social History: +Foreign Travel: +Born in USA: +Yes +Country of Birth: USA +Patient Education Assessments: +Ed Yes Occupation +07/09/2019 +12 Banker +Family History - Father: +Age at Death: 74 +Cause of Death: Diabetes complications +Significant Illnesses: +Diabetes +Heart Disease +Comments: +Family History - Mother: +Age at Death: 81 +Cause of Death: Kidney Failure +Significant Illnesses: +Heart Disease +Comments: +Family History - Sibling: +Number of Siblings: 1 +Significant Illnesses: +Comments: +Past Hospitalization: +Reason +Acute Appendicitis +Complications: None +Comments: +Head: +Normal: Yes +Comments: +Sex: +Provider: +Race: WHITE +Cm Provider +Ka Waist Circum, Provider +88.2 +Reg#: +Faility: +H01 +Learns Best By +Primary Language Barriers to Education +Speaking/Listening English +None +Location +Mount Sinai Hospital +When +1990 + + + +Encounter Date: 07/09/2019 12:35 +Eyes: +EOMI: Yes +Icterus:No +Conjunctival Inflammation: No +Pupils PERRLA: Yes +Pupil Size Rt: +Pupil Size Lt: +Pupils Comments: +Fundi Vessels Nicking: No +Fundi Vessels Discs Flat: Yes +Fundi Vessels Discs Sharp Margins: Yes +Fundi Vessels Grounds Abnormal: No +Eyes Comments: +Vision Screen +07/09/2019 12:52 +Blindness: +Distance Vision: OD: 100 +Near Vision: +OD: +OS: 70 +OS: +Ishihara Color Test: +Tonometry: L: +R: +Comments: Needs evaluation with optometrist. +Ears: +Right Ear: Canal patent +Left Ear: Canal patent +Ears Comments: +Nose: +Nares Patent: Yes +Septum Midline: Yes +Septum Intact: Yes +Drainage/Discharge:No +Polyps: No +Nose Comments: +Provider: +M. +Race: WHITE +Reg #: +Facility: +Unit: +H01 +OU: +OU: +With Corrective +OD: +OD: +OS +OS: +OU: +OU: +Generated 07/09/2019 13:03 by HI + + + +Encounter Date: 07/09/2019 12:35 +Mouth +Lesions: No +Oral/Buccal Mucosa: Yes +Gums Normal: Yes +Tonsils Present: Yes +Tonsils Normal: Yes +Pharynx: Normal Color +Teeth Poor Dentition: No +Teeth Count:Mostly Present +Dentures: No +Mouth Comments: +Cranial Nerves: +Intact Il-XIl: Yes +Cranial Nerves Comments: +Neck: +Full ROM: Yes +Masses/Nodes: No +Trachea: Midline +Thyroid: Normal Size +Comments: +Breasts: +Normal: Yes +Masses:No +Tenderness:No +Scars: No +Dimpling:No +Nipple Discharge: No +Nipple Retraction: No +Instructions for Self Breast Exam Given: No +Comments: +Sex: +Provider: +MARCE WHITE +Reg #: +Facility: +Unit: +Gonerated 07/09/2019 13:03 by HI + + + +Vision Screens +Vision Screen on 07/09/2019 12:52 +Blindness: +Distance Vision: OD: 20/100 +Near Vision: +OD: +With Corrective +Distance Vision: OD: +Near Vision: ( +OD: +Present Glasses - Distance +Sphere +Cylinder +Axis +Add +R: +L: +Color Test: +Tonometry: +R: +L: +Comments: Needs evaluation with optometrist. +Orig Entored: 07/09/2019 12:54 EST +OS: 20/70 +Os: +OS: +OS: +Refraction - Distance +Sphere +Cylinder +OU: +OU: +Ou: +OU: +Axis +Add + + + +Reg#: +Immunization +Immunization Date +Hepatitis A and B (TwinRx) +Orig Entered: 07/09/2019 12:51 EST +Measles/Mumps/Rubella Series +Orig Entered: 07/09/2019 12:51 EST +Smallpox Series +Orig Entered: 07/09/2019 12:51 EST +Tetanus +Orig Entered: 07/09/2019 12:51 EST +Varicella Series +Orig Entered: 07/09/2019 12:51 EST +Total: 5 +Immunizations +End Date: +08/10/2019 +Administered Lecation +Dosage Drug Mig. +History Unknown +History Unknown +History Unknown +History Unknown +History Unknown +Let# +Exp Rate + + + +Medical Duty Status +• Inmate Name: EPSTEIN, JEFFREY EDWARD +Housing Status: +_ confined to the living quarters except +- on complete bed rest: +X cell: +cell on first floor +_ other: +Physical Limitation Restrictionit +— all sports +_weightiting +upper body +→ cardiovascular exercise: +meals +pill line +treatments +*bathroom privileges only +single cell X lower bunk _airborne infection isolation +Exp. Date: +Exp. Date: +Exp. Date: +Exp. Date: +B094003 +lower body +running +jogging +football - +basketball +Exp. Date: +Exp: Date: +Exp. Date: +walking +handball +_softball +stationary equipment +Exp. Date: +→ other: +May/have hetallow/hequipment/his Ther.possession./ +Equipment +-Pap +PHILIPS RESPIRONICS SYSTEM ONE CPAP MACHINE. +SERIAL #: P11312813B1ED. +Work Restrictiony Limitation: +Cleared for Food Service: +Yes +X No Restrictions +Comments: N/A +Start Date +07/30/2019 +End Date +Health Services Staff +Inmate Name: _ +ALL EXPIRATION DATES ARE AT 24:00 +Reg #: +Quarters:_ +07/30/2019 +Z04 +TEIN +10/09/2019 +Return Date +Generaled 08/10/2019 +11:02 by + + + +Medical Duty Status +Housing Status +_ confined to the living quarters except meals +pill line +_reatments +- on complete bed restip +- bathroom privileges only +X cell: +_cell on first floor. single cell lower bunk _airborne infection isolation +_other: +Phystarentaton Restaction +_ all sports +_ weighjint +cardiovascular exercise: +_upper body +lower body +_running jogging +walking +_softball +football +basketball +_handball stationary equipment +Exp. Date: +Exp. Date: +Exp. Date: +Exp. Date: +Exp. Date: +Exp. Date: +Exp. Date: +Exp. Date: +a other: +May have tho following oculpment in his ber possession: +Work Restriction/ Limitation: +Cleared for Food Service: +Yes +X No Restrictions +Comments: N/A +Health Services Staff +EPSTEIN, JEFFREY EDWARD/ +ALL EXPIRATION DATES ARE AT 24:00 +Reg #: +07/09/2019 +_Quarters:204 +PSTEIN, +Generated +08/10 +/2019 +11:02 by| +10/09/2019 + + + +Medication Summary +Historical +Complex: NYM-NEW YORK MCC +Inmate: EPSTEIN, JEFFREY EDWARD +Reg #: +Medications listed reflect prescribed medications from the begin date to end date on this report. +Allergies: +Denied +End Date: 08/10/2019 +Quarter: Z04-206LAD +Active Prescriptions +Bisacody! | 5 MG TAB +Take one tablet (5 MG) by mouth at bedtime AS NEEDED for 10 days +Rx#: 121757-NYM +Doctor: +Start: 07/09/19 +Exp: 07/19/19 +D/C: 07/12/19 +Docusate Sodium 100 MG Cap +Take one capsule (100 MG) by mouth twice daily for 30 days +Rx#: 121823-NYM +Doctor: +Start: 07/12/19 +Exp: 08/11/19 +Docusate Sodium 100 MG Cap +Take one capsule (100 MG) twice daily by mouth with plenty of water +Rx#: 122084-NYM +Doctor: +Start: 07/26/19 +Exp: 01/22/20 +Milk of Magnesia Susp (OTC) (473ML) 400MG/5ML +shake well take 2 tablespoonful twice daily by mouth +Rx#: 121835-NYM +Doctor: +Start: 07/12/19 +Exp: 07/14/19 +Milk of Magnesia Susp (OTC) (473ML) 400MG/5ML +shake well take 10ml by mouth twice daily AS NEEDED +Rxt: 122150-NYM +Doctor: | +Start: 07/30/19 +Exp: 10/28/19 +methy|PREDNISolone 4 MG Tab (21 count Pack) +Take the tablet by mouth as directed +Rx#: 121836-NYM +Doctor: | +Start: 07/12/19 +Exp: 07/18/19 +methy/PREDNISolone 4 MG Tab (21 count Pack) +Take the tablet by mouth as directed +Rx#: 122149-NYM +Doctor: +Start: 07/30/19 +Exp: 08/05/19 +Pharmacy Dispensings: 10 TAB in 32 days +Pharmacy Dispensings: 60 CAP in 29 days +Pharmacy Dispensings: 30 CAP In 15 days +Pharmacy Dispensings: 473 ML in 29 days +Pharmacy Dispensings: 473 ML in 11 days +Pharmacy Dispensings: 21 tab in 29 days +Pharmacy Dispensings: 21 tab in 11 days + + + +Complex: NYM-NEW YORK MCC +Inmate: EPSTEIN, JEFFREY EDWARD +Reg #: +End Date: 08/10/2019 +Quarter: Z04-206LAD +Active Prescriptions +Omega 3 (Vascepa) 1 GM Capsule +Take two capsules (2 GM) twice daily by mouth with food +Rx#: 121885-NYM +Doctor: +Start: 07/17/19 +Exp: 01/13/20 +Pharmacy Dispensings: 180 Cap in 24 days +Insulin Reg (10 ML) 100 UNITS/ML Inj +Inject regular insulin subcutaneously per sliding scale: twice daily ** ill line** for 7 days **ill line** +Rx#: 122148-NYM +Doctor: +Start: 07/30/19 +Exp: 08/06/19 +DL: 07/31/19 +Pharmacy Dispensings: 0 ML in 11 days +Insulin Reg (10 ML) 100 UNITS/ML Inj +Inject regular insulin subcutaneously per sliding scale: each morning for 7 days **il line*.. *il line. +Rx#: 122160-NYM +Doctor: +Start: 07/31/19 +Exp: 08/07/19 +Pharmacy Dispensings: 0 ML in 10 days +Generated 08/10/2019 11:02 by| + + + +Dental Health History Screen +Sex: M Race: WHITE +Encounter Date: 07/26/2019 07:54 +Provider: I +I HI +ASSESSMENTS: +Health Problems as of Dental Health History Encounter date: 07/26/2019 07:54 +Health Problems +Heallh Problem +Hyperlipidemia, unspecified +HYPERTRIGLYCERIDEMIA +Sleep apnea +Constipation, unspecified +Low back pain +Neuralgia and neuritis, unspecified +No Diagnosis +Injury, unspecified +RIO self inflicted injuries. +Medical History as of Dental Health History Encounter date: +07/26/2019 07:54 +Medical History: +Allergies: +Selzures: +Diabetes: +Cardiovascular: +CVA: +Hypertension: +Respiratory: +Sickle Cell Anemia: +Carcinoma/Lymphoma: +Denied +Denied +Denied +Denied +Denied +Denied +Denied +Denied +Denied +HIV History: +When Tested: +Test Result: +2019 +When Diagnosed AIDS: +Last CD4: +Comments: +Hepatitis: +Denied +Reg#: 76318-054 +Unit: +H01 +Status +Current +Current +Current +Current +Current +Current +Current +Generated 07/28/2019 07:59 by + + + +Encounter Date: 07/26/2019 07:54 +Other Infectious Diseases: +Syphillis: +No +Syphilis Last Treatment: +N/A +Genital Warts: +No +Chlamydia: +Yes +Gonorrhea: +No +Herpes: +No +Chicken Pox: +Yes +Other: +No +Comments: Chlamydia in 2015, treated +Chicken pox in childhood +Other Health Issues: +Other Medical Conditions And Treatment: sleep apnea +Current Medical Conditions: +Other Current Treatments: +Pregnant: N/A +ex: M FRIE +rovider: +Dental Observations as of Dental Health History Encounter date: 07/26/2019 07:54 +History: +Alcohol: +No +Methamphetamine: +No +Tobacco products: +Other drugs: +Sensitive teeth: +Bleeding gums: +Food impaction: +Pain around ear: +Toothache: +Wear partial dentures: +Unusual sounds while eating: +Snoring: +Blisters on lips or mouth: +Clenching or grinding: +Swelling or lumps in mouth/throat: +Burning tongue: +Bad breath: +Decayed teeth: +Loose teeth: +Wear dentures: +None: +No +No +Yes +Yes +No +No +No +No +Yes +No +Yes +No +No +No +No +No +No +No +Comments: +Generated 07/28/2019 07:59 by +Reg #: +Unit: +H01 + + + +Sex: M Race: WHITE +Encounter Date: 07/26/2019 07:54 +Provider: +Cardiac Condition Requiring Prophylaxis: No +Prosthetic joints): +Radiation history of head or neck: +Excessive bleeding: +Bisphosphonates: +No : +No +No +Comments: +Unit: +H01 +Medications as of Dental Health History Encounter date: +07/26/2019 07:54 +Medications: +Docusate Sodium 100 MG Cap Exp: 08/11/2019 SIG: Take one capsule (100 MG) by mouth twice daily for 30 days +Omega 3 (Vascepa) 1 GM Capsule Exp: 01/13/2020 SIG: Take two capsules (2 GM) twice daily by mouth with food +OTCs: Listing of all known OTCs this inmate is currently taking. +Instructed inmate how to obtain medical, dental, and mental health care. +Copay Required:No +Cosign Required: No +Telephone/Verbal Order: No +Completed by +MIM on 07/26/2019 07:59 +Generated 07/28/2019 07:59 by | + + + +Dental A&O Exam +Sex: M +Provider: +Encounter Date: 07/26/2019 07:47 +Reg #:. +Fictity: +Reviewed Health Status: Yes +Occlusion: ClassI +Oral Hygiene: Fair +CPITN: +3 +3 +3 +3 +Hard and soft tissue examination performed and documented on BP618 form: Yes +Head & Neck/Soft Tissue within normal limits? +No +Comments: +moderate to advanced upper posterior gingival recession +Decayed: +Missing: +Filled: +0 +1 +14 +Comments: +Lower anterior crowding +Approved for hygiene appointment and radiographs: +Instructed inmate how to obtain routine and emergency dental care. Oral hygiene instructions given: Yes +Dental A&O Screening Exam findings entered on EPSTEIN, JEFFREY EDWARD by A +07/26/2019 07:47. +Generated 07/26/2019 08:00 by + + + +Dental Soap/Admin Encounter +Encounter Date: 07/18/2019 13:48 +Provider: +Screening encounter at Dental Clinic +Reason Not Done: Unavailable +Reg #: +Facility: +Unit: +205 +on 07/19/2019 13:49. +Generated 07/19/2019 13:49 by + + + +U.S. Medical Center for Faderal Prisons +Prisons +Name EPSTEIN, JEFFREY +Reg # 76318-054 +DOB 01/20/1953 +Sex M +Facility MCC New York +'Sensitive But Unclassified"** +Collected 07/09/2019 13:34 +LIS ID + +CHEMISTRY +Sodium +137 +Potassium +4.7 +Chloride +99 +C02 +27 +BUN +17 +Creatinine +1.05 +137-148 +3.5-5.0 +99-114 +22-30 +1-22 +0.66-1.25 +mmol/L +mmol/lL +mmol/L +mmol/L +mg/dL +mg/dL +eGFR (IDMS) +a a cute are a get one he is a round over month period.. +Calcium +8.5-10.9 +Glucose +102 +70-110 +AST +H +57 +11-55 +ALT +62 +11-66 +Alkaline Phosphatase +64 +41-133 +Bilirubin, Total +Total Protein +1.1 +0.2-1.3 +7.3 +6.0-8.2 +Albumin +Globulin +4.4 +3.6-5.1 +2.9 +Alb/Glob Ratio +1.50 +2.0-3.7 +1.00-2.30 +mg/dL +mg/dL +UNL +Un +mg/dL +g/aL +g/aL +g/dL +Anion Gap +10.2 +9.0-19.0 +BUN/Creat Ratio +16.1 +5.0-30.0 +Cholesterol +H +216 +<200 +mg/dL +Triglycerides +H +413 +10-150 +mg/dL +Calculation of LDL is not appropriate for samples with a triglyceride greater than 400 mg/dL. Therefore the LDL is not calculated. +HDL Cholesterol +40-60 +mg/dL +Cho/HDL Ratio +H +6.9 +0.0-4.0 +HEMATOLOGY +WBC +NR80% +RBC +Hemoglobin +Hematocrit +MCV +MCH +MCHC +RDW-CV +Platelet +7.6 +0.0 +5.42 +15.6 +47.8 +88.2 +4.3-11.1 +4.46-5.78 +13.6-17.6 +40.2-51.4 +82.5-96.5 +27.1-34.9 +33.0-37.0 +12.0-14.0 +130-374 +L=Low LI-Low Critical H-High Hl=High Critical A=Abnormal Al =Abnormal Critical + +K/uL +% +M/uL +g/dL +% +28.8 +L +32.6 +12.8 +338 +Pg +g/dL +% +K/UL + + +Federal +Prisons +Name EPSTEIN, JEFFREY +Reg # 76318-054 +DOB 01/20/1953 +Sex +M +Facility MCC New York +Order Unit E06-547U +** Sensitive But Unclassified *** +Collected 07/09/2019 13:34 +LIS ID + +HEMATOLOGY +MPV +10.4 +Neutrophils % +58.7 +Therapeutic decision making should be based on absolute values, rather than percentages +Lymphocytes % +25.0 +Monocytes % +11.1 +Eosinophils % +4.1 +Basophils % +0.8 +Immature Granulocytes % +0.3 +Neutrophils # +4.4 +Lymphocytes # +1.9 +Monocytes # +0.8 +Eosinophils # +0.3 +Basophils # +Immature Granulocytes # +0.1 +0.02 +HEMOGLOBIN A1C +H +6.3 +6.9-10.5 +0.0-5.0 +1.9-6.7 +1.3-3.7 +0.3-1.1 +0.0-0.5 +0.0-0.1 +0.00-0.50 +Hemoglobin A1C +.7 - 6.4 Increased Risi +• 6.4 Diabete: +<5.7 +SEROLOGY +RPR +Non-Reactive +Results may be affected in patients with severely advanced immunosuppression. +Non-Reactive +% +% +% +% +KJuL +KJUL +K/UL +K/ul +KUL +10^3/UL +% +L=Low LI=Low Critical H=High HI=High Critical A=Abnormal Al =Abnormal Critical +Page 20f3 + + +ederal +Bureau c +Prisons +Name EPSTEIN, JEFFREY +Reg # 76318-054 +DOB 01/20/1953 +Sex +M +Facility MCC New York +Order Unit E06-547U +" Sensitive But Unclassified *** +Collected 07/09/2019 13:34 + +HIV +HIV 1/2 +Screening test- See confirmatory testing for Reactive results +L=Low LI=Low Critical H=High HI=High Critical A=Abnormal Al =Abnormal Critical + + + +Encounter Date: 07/10/2019 16:58 +Cosigned by +Cosign/Review +Provider: Lab Result Receive +on 07/14/2019 18:12. +Reg#: +Race: + + +U.S. DEPARTMENT OF JUSTICE. +MEDICAL TREATMENT REFUSAL +CDFRM +FEDERAL BUREAU OF PRISONS +1-24-2019 +1, JEFFREY EPSTEIN +6318-054, refuse treatment recommended by the Feder +ureau of Prisons Medical staff for the following condition(s +DESCRIBE CONDITION IN LAYMAN'S TERMINOLOGY: +EYE DOCTOR EVALUATION. +The following treatments) was/were recommended: +EYE DOCTOR EVALUATION. +INABILITY TO DIAGNOSE CURRENT OPTHALMOLOGIC DISEASES. +I understand the possible consequences and/or complications, listed above, and still refuse +recommended treatment. I hereby assume ail responsibility for my physical and/or mental condition, and +release the Bureau of Prisons and Its employees from any and all liabllity for respecting and following my +Counseled by +7-24-2019 +Datone Sonale + + +A&O DENTAL EXAMINATION +(Initial Clinical Dental Findings) +FEDERAL BUREAU OF PRISONS +Occlusion: +Oral Hyglene: +Good +Fair +Poor +CPITNE +3 +3 +2 +2 +3 +Head & Neck / Soft Tissue: +F14 +Classification: +CL. +Pain Scale: +31 +9 1011 1213 +16 m +30 29 28 27 26 25 24 23 22 21 20 19 - 18 +Gold +33880a00a0880 +800 +Dental Prostheses st intake: +No +Yes +Type: +Age: +Condition: +Intra-oral Photos Taken: +Yes +No +Instructed how to obtaln urgent and non-urgent dental care: +Treatment Prioritias: +None: +Radiographs authorized: +PAS: +BWE: +Рапогех: +Patient Name:, +estein, Jeftrey E +gister Number. +Institution: +MCC NEW YORK +PDF +/10. +advanced +mod to modersate. +recession observe ding val +Lover an feror Crowding obserted +Radiographs Taken: (Document findings on A8O encounter) +Yes +No +Yes: +No: +Non-urgent: +Urgent Referred to Sick Call: +non-urgent +Prophylaxis authorized: +Yes / +No +(Approval valid 18 months from examination date) +Dental alancticed +Date: +7-26-19. +Signature Block/Stamp: +Chief Dental Officer +MCC New York +Prescribed by P6400 +• Replaces BP-A0018 of JUN 10 + + +Encounter Date: 07/28/2019 20:25 +Sex: +Provider: +Race: WHITE +Reg#: 76318-054 +Unit: +H01 +Nursing - Follow up encounter performed at Health Services. +SUBJECTIVE: +COMPLAINT 1 +Provider: +Chief Complaint: Neuropathy - Tingling/Numbness of Extremity(ies) +ubjective: Inmate seen for F/U after returing from attorney conference offers no new complaints o +orsening S/S stats " My R hand still has pins and needles sometimes" No change i +appearance from previous exam. +OBJECTIVE: +Pulse: +Ilme +Rate Per Minute +Lecation +07/28/2019 20:28 +Respirations: +07/28/2019 +Time +20:28 NYM +Rate Per Minute Provider +14 +Blood Pressure: +Rate +Time +Value +Lecation +Position +07/28/2019 20:28 NYM +: 157/91 +Sa02: +Rate +07/28/2019 +Time +20:28 NYM +Value(%) Alr +98 +Exam: +General +Affect +Yes: Cooperative +Appearance +Yes: Appears Well, Alert and Oriented × 3 +Nutrition +Yes: Within Normal Limits +Bhythm +Cuff Size +Skin +General +Yes: Within Normal Limits, Dry, Skin Intact +ASSESSMENT: +No Significant Findings/No Apparent Distress +PLAN: +To be Evaluated by Provider +Generated 07/28/2019 20:30 by + + + +Encounter Date: 07/28/2019 20:25 +Follow-up in 12-24 Hours +Patient Education Topics: +Rate Initiated Format +07/28/2019 +Counseling +Sex: +Provider: +Handout/Topic +Plan of Care +Copay Required: No +Cosign Required: Yes +Telephone/Verbal Order: No +Completed by +on 07/28/2019 20:30 +Requested to be cosigned by +Cosign documentation will be displayed on the following page. +Bace: WHITE +Unit: +H01 +Outcome +Verbalizes +Generated 07/28/2019 20:30 by + + + +Encounter Date: 07128/2019 20:25 +Cosigned by +Cosign/Review +Sex: +Provider: +on 07/28/2019 20:50. +Reg #: +Race: +Facility: + + +Sex: +Encounter Date: 07/28/2019 06:51 +Provider: +Bai WHITE +Reg#: 76318-054 +Unit: +H01 +Nursing - Triage Note encounter performed at Health Services. +SUBJECTIVE: +COMPLAINT 1 +Provider: +Chief Complaint: Neuropathy - Tingling/Numbness of Extremity(ies) +Subjective: * I woke up and I had no control over my Right arm for a few minutes it was just doing what it +OBJECTIVE: +Pulse: +Rate +Time +07/28/2019 06:57 +Bate Per Minute +82 +Lecation +Respirations: +07/28/2019 +Time +06:57 NYM +Bate Per Minute Provider +14 +Blood Pressure: +Time +Yalue +Location +Position +07/28/2019 06:57 NYM 138/80 +Sa02: +Pate +07/28/2019 +Time +06:57 NYM +Value(%) Air +98 +Exam: +Goneral +Affect +Yes: Cooperative +Appearance +Yes: Appears Well, Alert and Oriented × 3 +Bhythm +Cuff Size +Skin +General +Yes: Within Normal Limits, Dry, Skin Intact +General +Yes: Symmetry of Motor Function, Atraumalic/Normocephalic +No: Facial Asymmetry, Batlle's Sign, Raccoon Eyes, Deformity +Eyes +General +Yes: PERRLA, Extraocular Movements Intact +Face +General +Yes: Symmetric +Generated 07/28/2019 07:22 by + + + +Sex: +Encounter Date: 07/28/2019 06:51 +Provider: +Exam: +M +Race: WHITE +Unit: +H01 +No: Ecchymosis, Numbness, Swelling, Periorbital Edema +Neck +General +Yes: Abrasion(s) +Pulmonary +Observation/Inspection +Yes: Within Normal Limits +No: Respiratory Distress, Tachypnea, Hyperventilation +Cardiovascular +Observation +Yes: Normal Rate +Musculoskeletal +Shoulder +Yes: Full Range of Motion R, Symmetric R +No: Swelling R, Inflammation R +Humerus +Yes: Within Normal Limits R +Elbow +Yes: Normal Exam R, Full Range of Motion R, Non-Tender on Palpation R +Radius / Ulna +Yes: Normal Exam R, Full Range of Motion R +Wrist/Hand/Fingers +Yes: Full Range of Motion R, Non-Tender on Palpation R, Swelling R +No: Inflammation R, Ecchymosis R, Erythema R, Tenderness R, Laceration(s) R, Abrasion(s) R, +Contusion(s) R +ROS Comments +Received inmate AAOX3 in no acute distress, speaking in full sentenced ambulating independently C/O Right arm +numbness after waking up from "sleeping on my side" that has since subsided. inmate interviewed in psyc obs through +the slot. V/S noted WL, RR even and unlabored, no neurological deficits noted, no facial droop slurred speech or +dysphagia, Inmate with Full ROM to all extremities with 4/4 strength bilaterally, slight swelling noted to right phalanges +when compared to left, no edema, erythema or ecchymosis noted. Denies any pain numbness or tingling at this time. +Denies any Chest pain, Headache, Dizziness, SOB or Blurred vision. Eyes PERRLA. MD on Call notified, Re-evaluate +ASSESSMENT: +Alteration in comfort +PLAN: +Follow-up at Sick Call as Needed +Notify Medical Duty Officer +Patient Education Topics: +Rate Initiated Eormat +07/28/2019 Counseling +Generalad 07/28/2019 07:22 by l +Handout/ToRic +Plan of Care +Outcome +Verbalizes + + + +Encounter Date: 07/28/2019 06:51 +Date Initiated Eormat +Copay Required: No +Sex: +Provider: +Handout/ToRic +Cosign Required: Yes +Telephone/Verbal Order: No +Completed by +on 07/28/2019 07:22 +Requested to be cosigned by +Cosign documentation will be displayed on the following page. +Race: WHITE +Unit: +HO1 +Qutcome +Generaled 07/28/2019 07:22 by + + + +Encounter Date: 07/28/2019 06:51 +Cosigned byl +Cosign/Review +Sex: +Provider: +/ on 07/28/2019 20:51. +Reg #: +Race: + + +Note Date: +07/26/2019 08:57 +Provider: +Race:WHITE +Reg #: +Faility: +HOM +Cosign Note - Clinical Encounter Cosign encounter performed at Health Services. +Administrative Notes: +ADMINISTRATIVE NOTE 1 +Provider: ( +THE MLP NOTIFIED THE OP LT OF THE INMATE STATEMENT REGARDING WHAT HAPPENED TO HIM +2 NIGHTS AGO. +Now Medication Orders: +Bx# +Medication +Docusate Sodium Capsule +Order Date +07/26/2019 08:57 +Prescriber Order +TAKE ONE 100 MG CAP Orally +- Two Times a Day × 180 day(s) +Indication: Constipation, unspecified +Copay Required: No +Cosign Required: No +Telephone/Verbal Order: No +Completed by +on 07/26/2019 08:58 +Generated 07/26/2019 08:58 by + + + +Note Date: +07/24/2019 16:10 +Srovider: +Bara WHITE +Reg #: +Facility: NOM +H01 +Cosign Note - Clinical Encounter Cosign encounter performed at Health Services. +Administrative Notes: +ADMINISTRATIVE NOTE 1 +Provider: +THE MLP NOTIFIED THE OP LT OF THE INMATE STATEMENT REGARDING WHAT HAPPENED TO HIM +2 NIGHTS AGO.1 +Copay Required: No +Telephone/Verbal Order: +Completed by +Cosign Required: No +on 07/24/2019 16:12 +Amendment + +Generated 07/24/2019 16:12 by L + + +Note Date: +07/24/2019 16:10 +Stovider: +Bace: WHITE +Reg#: +Unity: +H01 +Cosign Note - Clinical Encounter Cosign encounter performed at Health Services. +Administrative Notes: +ADMINISTRATIVE NOTE 1 +Provider: I +THE MLP NOTIFIED THE OP LT OF THE INMATE STATEMENT REGARDING WHAT HAPPENED TO HIM +2 NIGHTS AGO. +Copay Required: No +Telephone/Verbal Order: +No +Completed by +Cosign Required: No +on-07/24/2019 16:12 +Amendment +Generated 07/24/2019 16:12 by + + + +Encounter Date: 07/26/2019 08:57 +Amendment made to this note byl +See Amendment +Sex: +M +on 07/26/2019 08:58. +Reg #: +Race: +Facility: + + +ate of Birth +lote Date: +07/24/2019 15:10 +Soder: +Race: WHITE +Reg #: +Fility: +H01 +Admin Note - General Administrative Note encounter performed at Health Services. +Administrative Notes: +ADMINISTRATIVE NOTE 1 +Provider: +PATIENT WAS OFFERED TO HAVE AN OPTOMETRIST EVALUATION. HE REFUSED. REFUSAL FORM +SIGNED. +Copay Required: No +Telephone/Verbal Order: No +Completed by| +Cosign Required: No +on 07/24/2019 15:17 +Generated 07/24/2019 15:17 by + + + +Encounter Date: 07/24/2019 13:08 +Provider: I BaGPi MUTE +Unit: +H01 +Mid Level Provider - Follow up Visit encounter performed at Receiving & Discharge. +SUBJECTIVE: +COMPLAINT 1 +Provider: +Chief Complaint: Other Problem +Subjective: I still do not want to talk about. But, between you and me. I think my room mate had to do with +what happened to me. Do not ask me. I am not going to say anything. +Pain: +OBJECTIVE: +Temporature: +07/24/2019 +Ilme +13:12 NYM +Eabrenhelt Celsius Lecatien +97.8 +36.6 Oral +Pulse: +Rate +Ilme +07/24/2019 13:12 +Rate Per Minute +83 +becation +Via Machine +Bhythm +Regular +Blood Pressure: +Ilme +Yalue +07124/2019 13:12 NYM 132/89 +Lecatien +Right Arm +Position +Sitting +Suff Size +Adult-regular. +Provide +SaO2: +07/24/2019 +Ilme +13:12 NYM +Value(%) Alr +96 Room Air +Exam: +General +Affect +Yes: Cooperative +Appearance +Yes: Appears Well, Alert and Oriented × 3 +No: Appears Distressed, Appears in Pain +Exam Comments +Follow up evaluation done for inmate Epstein. +He does not look in any pain or distress. +He still has the erythema around his neck. Central part of this erythema has some abrasion. Patient does not complaint +of any respiratory problem or distress. He still does not want to explain how the skin injury on his neck happed. he +insinuates that injuries on his neck have to do with his room mate. But does not want to talk about it. +ASSESSMENT: +Injury, unspecified, T1490 - Current +PLAN: +Generaled 07/24/2019 13:24 by | + + + +Encounter Date: 07/24/2019 13:08 +Follow-up at Sick Call as Needed +Patient Education Topics: +Date Initiated Eormat +07/24/2019 +Counseling +07/24/2019 +Counseling +Sex: +Provider: +Handout/ToRic +Access to Care +Preventive Health +Copay Required: No +Cosign Required: Yes +Telephone/Verbal Order: No +Completed by +on 07/24/2019 13:24 +Requested to be cosigned by +Cosign documentation will be displayed on the following page. +Race: WHITE +Unit: +H01 +Outcome +Verbalizes +Verbalizes +Generaled 07/24/2019 13:24 by + + + +Encounter Date: 07124/2019 13:08 +Cosigned with New Encounter Note by i +Cosign/Review +Sex: +Provider: +Reg #: +Race: +Facility: +Ion 07/24/2019 16:10. + + +Sex: +Encounter Date: 07/23/2019 06:20 +Provider: +Race: WHITE +Unit: +H01 +Injury Assessment - Non-work related encounter performed at Health Services. +SUBJECTIVE: +INJURY 1 +Date of Injury: +Work Rolated: +Provider: +07/23/2019 01:27 +No +Date Roported for Treatment: +Work Assignment: UNASSG +Pain Location: +Pain Scale: 0 +Pain Qualities: +Where Did Injury Happen (Be specific as to location): +Special Housing Unit Z05-Cell 124 L +Cause of Injury (Inmate's Statement of how injury occurred): +"I do not know. Just went to drink a little water and wake up snorting". +Symptoms (as reported by inmate): +None +07/23/2019 08:25 +OBJECTIVE: +Temperature: +07/23/2019 +Time +06:30 NYM +Eahrenheit Celsius Location +97.5 +36.4 Oral +Pulse: +Ilme +07/23/2019 06:30 +Rate Per Minute +92 +Lecation +Via Machine +Bhythm +Regular +Respirations: +07/23/2019 +Time +06:30 NYM +Bate Per Minute Provider +16 | +Blood Pressure: +Time +Value +07/23/2019 06:30 NYM 140/85 +Location +Right Arm +Position +Sitting +Cuff Size Provider +Adult-regular +Sa02: +07/23/2019 +Time +06:30 NYM +Value(%) Air +96 Room Air +Exam: +General +Affect +Yes: Cooperative +Appearance +Yes: Appears Well, Alert and Oriented × 3 +No: Appears Distressed, Lethargic, Dyspneic, Appears in Pain, Pallor, Cyanolic, Diaphoretic, Disheveled, +Generated 07/23/2019 09:05 by lI + + + +Encounter Date: 07/23/2019 06:20 +Exam: +Sex: +Provider: 1 +Race: WHITE +Unit: +H01 +Acutely III +Pulmonary +Auscultation +Yes: Clear to Auscultation, Vesicular Breath Sounds Bilaterally +No: Crackles, Rhonchi, Wheezing +Exam Comments +Inmate for injury report as requested by Operational Lt. +He is ambulatory, oriented × 3. In not apparent distress, smiling during this clinical encounter. Alleges, that he does not +know what happened. Can not explain the marks on his neck. Responded: "I don't know". +He does not want to talk of the events leading to the marks on his neck. +He does not look in any distress or pain. +Has an circular line of erythema at the base of the neck. Reaching 2/3 of the neck circumference, 2 inches wide, sparing +the back of the neck. Has one section of this erythema in the front with marks of friction. +No inflammation, no deformities, no hematomas, no lacerations, no tenderness. Patient moving his neck without any +restriction. Denies having any pain or discomfort. Denies any respiratory problem. +Has another small erythema on left knee about 2cm in diameter(mild). +As per information from custody staff inmate Epstein was found in his cell with a rope around his neck and sitting on the +floor. +Inmate is currently placed on suicide watch. +ASSESSMENT: +Injury, unspecified, T1490 - Current - R/O self inflicted injuries. +PLAN: +Follow-up at Sick Call as Needed +Placed on Suicide Watch +Follow-up in 2-4 Hours +Other: +For follow up with psychology service. +Patient Education Topics: +Date Initiated Format +07/23/2019 +Counseling +07/23/2019 +Counseling +Handout/Topic +Access to Care +Plan of Care +Proxies +Outcome +Verbalizes +Verbalizes +Copay Required: No +Cosign Required: Yes +Telephone/Verbal Order: No +Completed by +on 07/23/2019 09:05 +Requested to be cosigned by +Cosign documentation will be displayed on the following page. +Generated 07/23/2019 09:05 by + + + +Encounter Date: 07/23/2019 06:20 +Cosigned by d +Cosign/Review +Provider: +on 07/23/2019 15:44. +Reg #: +Race: + + +Sex: +Encounter Date: 07/14/2019 17:36 +Provider: +M +Race: WHITE +Unit: +Z05 +Chronic Care - 14 Day Physician Eval encounter performed at Health Services. +SUBJECTIVE: +COMPLAINT 1 +Provider: +Chief Complaint: ENDO/LIPID +Sublective: 66 YR OLD WHITE MALE WITH HX OF +HYPERTRIGLYCERIDEMIA X 5 YEARS ON VASCEPA FOR 1 YEAR. STATES TRIGL WAS +800 , NOW 431. STATES HE COULD NOT TOLERATE OTHER ANTI-TRIGLYCERIDE +HX OF OBSTRUCTUVE SLEEP APNEA X 5 YEARS FOR WHICH HE USED A CPAP +MACHINE. STATES HE HAD HIS CPAP MACHINE WITH HIM WHEN HE ARRESTED. +L4 - L5 SEVERE STENOSIS CASUING NUMBNESS AND SHOOTING PAIN IN THE +LOWER EXTREMITIES. +SURGICAL HX: NONE +MENTAL HEALTH HX: NONE +Pain: +Yes +Pain Assessment +Date: +Location: +Quality of Pain: +Pain Scale: +Intervention: +07/12/2019 13:25 +Back-Middle +Shooting +5 +MEDROL DOSE PACK +Trauma Date/Year: +Injury: +Mechanism: +Onset: +5+ Years +Duration: +5+ Years +Exacerbating Factors: NO EXERCISE +Relieving Factors: +MEDROL DOSE PACK +• Reason Not Done: +Comments: +Seen for clinic(s): Orthopedic/Rheumatology, Pulmonary/Respiratory, Endocrine/Lipid +Added to clinic(s): Orthopedic/Rheumatology, Pulmonary/Respiratory, Endocrine/Lipid +OBJECTIVE: +Exam: +General +Appearance +Yes: Appears Weil, Alert and Oriented × 3 +No: Appears Distressed, Dyspneic, Appears in Pain, Writhing in Pain, Pale, Pallor, Cyanotic, Diaphoretic, +Disheveled, Unkempt, Acutely III +Nutrition +Generaled 07/14/2019 18:11 by + + + +Encounter Date: 07/14/2019 17:36 +Exam: +Eyes +Sex: +Provider: +Race: WHITE +General +Yes: PERRLA, Extraocular Movements Intact +Pulmonary +Auscultation +Yes: Clear to Auscultation +Cardiovascular +Auscultation +Yes: Regular Rate and Rhythm (RRR), Normal S1 and S2 +No: M/R/G +Abdomen +Auscultation +Yes: Normo-Active Bowel Sounds +Palpation +Yes: Within Normal Limits +Musculoskeletal +Tibia / Fibula +No: Edema +Back +Yes: Tenderness +Neurologic +Cranial Nerves (CN) +Yes: Within Normal Limits +Motor System-General +Yes: Normal Exam +ASSESSMENT: +Constipation, unspecified, K5900 - Current +Hyperlipidemia, unspecified, E785 - Current +Low back pain, M545 - Current +Neuralgia and neuritis, unspecified, M792 - Current +Sleep apnea, G4730 - Current +PLAN: +New Medication Orders: +Bx#t +Medication +Omega 3 (Vascepa) 1 GM Capsule +Order Date +07/14/2019 17:36 +Indication: Hyperlipidemia, unspecified +New Laboratory Requests: +Details +Lab Tests pid Probin A10 +Erequensy +One Time +Additional Information: +Generated 07/14/2019 18:11 by +Unit: +Z05 +Prescriber Order +TAKE 2 CAPS Orally - Two +Times a Day × 180 days) - +TAKE WITH FOOD. +Que Date +10/10/2019 00:00 +Priority +Routine + + + +Reg #: +Sex: +Encounter Date: 07/14/2019 17:36 +Provider: +M Race: WHITE +Unit: +Z05 +FASTING. +Lab Tests-H-Hep B surface Ab +One Time +08/08/2019 00:00 +Routine +Lab Tests-H-Hep B surface Ag +Lab Tests-H-Hep C Ab +Lab Tests-H-Hepatic Profile +Schedule: +Activity +Date Scheduled Scheduled Provider +07/24/2019 00:00 Optometrist +66YR OLD MALE FOR ROUTINE SCREENING. +Chronic Care Visit +01/07/2020 00:00 Mid-Level Provider +6 MONTH F/U. +Chronic Care Visit +07/01/2020 00:00 Physician 01 +Other: +PENDING EKG AND FOBT. CXR WAS REFUSED. +Patient Education Topics: +Date Initiated Format +Handout/Topic +Provider. +07/14/2019 +Counseling +Diagnosis +Copay Required: No +Telephone/Verbal Order: No +Completed by +Cosign Required: No +| on 07/14/2019 18:11 +Outcome +Verbalizes +Generated 07/14/2019 18:11 by + + + +.' +BP-$358.060 +MEDICAL TREATMENT REFUSAL +CORM +FEDERAL BUREAU OF PRISONS +1-24-2019 +1, JEFFREY EPSTEIN +76318-054, refuse treatment recommended by the Federal +Bureau of Prisons Medical staff for the following condition(s): +DESCRIBE CONDITION IN LAYMAN'S TERMINOLOGY: +EYE DOCTOR EVALUATION. +: +The following treatments) was/were recommended: +EYE DOCTOR EVALUATION. +Federal Bureau of Prisons Medical staff members have carefully explained to me that the following +possible consequences and/or complications may result because of my refusal to accépt treatment: +INABILITY TO DIAGNOSÉ CURRENT OPTHALMOLOGIC DISEASES. +I understand the possible consequences and/or complications, listed above, and still refuse +recommended treatment. I hereby assume all responsibility for my physical and/or mental condition, and +release the Bureau of Prisons and its employees from any and all liability for respecting and following my +expressed wishes and directions. +Counseled by +7-24-2019 + + +BP-S358.C60 +MEDICAL TREATMENT REFUSAL +CDFRM +FEDERAL BUREAU OF PRISONS +7-10-2019 +I, JEFFREY EPSTEIN +76318-054, refuse treatment recommended by the Federal +Bureau of Prisons Medical staff for the following condition(s): +DESCRIBE CONDITION IN LAYMAN'S TERMINOLOGY: +66 YR OLD MALE WITH NO PMHX, REFERRED FOR ROUITNE CXR. +The following treatments) was/were recommended: +CHEST X-RAY +WORSENING THE CONDITION IF THERE IS ANY FINDINGS +I understand the possible consequences and/or complications, listed above, and still refuse +recommended treatment. I hereby assume all responsibility for my physical and/or mental condition, and +release the Bureau of Prisons and its employees from any and all lability for respecting and following my +Counseled by +7-10-2019 +Patients Signature +7-10-19 + + +MEDICAL TREATMENT REFUSAL +FEDERAL BUREAU OF PRISONS +1-24-2019 +1, JEFFREY EPSTEIN +76318-054, refuse treatment recommended by the Federa +Sureau of Prisons Medical staff for the following condition(s): +DESCRIBE CONDITION IN LAYMAN'S TERMINOLOGY: +EYE DOCTOR EVALUATION. +The following treatments) was/were recommended: +EYE DOCTOR EVALUATION. +Federal Bureau of Prisons Medical staff members have carefully explained to me that the following +possible consequences and/or complications may result because of my refusal to accept treatment: +INABILITY TO DIAGNOSE CURRENT OPTHALMOLOGIC DISEASES. +I understand the possible consequences and/or complications, listed above, and still refuse +Counseled by +7-24-2019 +Pater sales +e7ta/9 +NYM--NEW YORK MCC + + +A&O DENTAL EXAMINATION +(Initial Clinical Dental Findings) +FEDERAL BUREAU OF PRISONS +Occlusion: +Oral Hyglene: +Good +Falr +L Poor +CPITNE + +3 +3 +2 +2 +3 +3 +Head & Neck / Soft Tissue: +4 +32 +31 +5 6 7 8 +10 11 12 13 +14. 15 +16 +El +28 27 26 25 24 23 22 21 20 +19 - 18 +Gold + +F:14 +Classification: +CLI +Pain Scale: +110 +Dental Prostheses at Intake: +Yes +Type: +Age: +Condition: +Intra-oral Photos Taken: +Yes +man to marge ging ia +ecession observed +lover anteror crowding obserted +Radiographs Taken: (Document findings on A8O encounter) +Yes +No +Instructed how to obtain urgent and non-urgent dental care: +Treatment Priorities: +None: +Yes: +No: +Non-urgent: +Urgent Referred to Sick Call: +non-urgent +Radiographs authorized: +Prophylaxis authorized: Yes / +No +PAS: +(Approval valid 18 months from examination date) +BWE: +Ралогех: +Patient Name: +Denfst Sianature: +Epstein, JeFFrey E +Institution: +MCC NEW YORK +Date: +7-26-19. +Signature Block/Stamp: +Chief Dental Officer +MCC New York +PDF +Prescribed by P$400 +• Replaces BP-ACB18 of JUN 10 + + +A&O DENTAL EXAMINATION +(Initial Clinical Dental Findings) +FEDERAL BUREAU OF PRISONS +Occlusion: +Oral Hygiene: +Good +Fair +Poor +CPITN: +3 +3 +2 +2 +• RIGHT +5 6 7 +0 1011 1213 +14. 15 +30 29 +1 28 27 28 25 24 23 22 21 20 +19. 18 +Gold +1 +Classification: +CLI +Pain Scale: +110. +3 +Head & Neck / Soft Tissue: +Dental Prostheses at intake: +Yes +Туре: +Age: +Condition: +Intra-oral Photos Taken: +Yes +Instructed how to obtain urgent and non-urgent dental care: +Treatment Priorties: +None: +Radiographs authorized: +PAs: +BWs: +Рапогех: +Patient Name: +Fister Numba +astein, Jeftrey d +Institution: +MCC NEW YORK +PDF +Radiographs Taken: (Document findings on ASO encounter) +Yes +Yes: +No: +Non-urgent: +non-urgent +Prophylaxis authorized: Yes / +No +(Approval valid 18 months from examination dato) +Urgent Referred to Sick Call: +Dentist Sianature: +Date: +7-26-19. +Signature Block/Stamp: +Prescribed by P6400 +Chief Dental Officer +MCC New York +• Replaces BP-A0B18 of JUN 10 + + +MEDICAL TREATMENT REFUSAL +CDFRM +FEDERAL BUREAU OF PRISONS +1-24-2019 +1, JEFFREY EPSTEIN +76318-054, refuse treatment recommended by the Federal +Bureau of Prisons Medical staff for the following condition(s): +DESCRIBE CONDITION IN LAYMAN'S TERMINOLOGY: +EYE DOCTOR EVALUATION. +The following treatments) was/were recommended: +EYE DOCTOR EVALUATION. +'ederal Bureau of Prisons Medical staff members have carefully explained to me that the following +ossible consequences and/or complications may result because of my refusal to accept treatment +INABILITY TO DIAGNOSE CURRENT OPTHALMOLOGIC DISEASES. +I understand the possible consequences and/or complications, listed above, and still refuse +recommended treatment. I hereby assume all responsibility for my physical and/or mental condition, anc +release the Bureau of Prisons and its employees from any and all liability for respecting and following my +expressed wishes and directions. +Counseled by +7-24-2019 + + +Federal +Prisons +Name EPSTEIN, JEFFREY +Reg # 76318-054 +DOB 01/20/1953 +Sex M +Facility MCC New York +Order Unit E06-547U +Provider | +*'Sensitive But Unclassified** +Collected 07/09/2019 13:34 +LuS Inted 0781004 1:46 + +HIV +HIV 1/2 +Screening test - See confirmatory testing for Reactive results +L-Low LI-Low Critical HaHigh HI=High Critical A=Abnormal Al =Abnormal Critical + + + +Cosign/Review +Inmale Name: EPSTEIN, JEFFREY EDWARD +Encounter Date: 07/10/2019 16:58 +Preorder: Lab Rosit Recivo +Cosigned by | +lon 07/14/2019 18:12. +Reg #: +Race: +Facility: + + +MEDICAL TREATMENT REFUSAL +CDFRM +FEDERAL BUREAU OF PRISONS +1-24-2019 +Bureau oF Prisons Medical stafor the rising conditions reatment recommended by the federal +DESCRIBE CONDITION IN LAYMAN'S TERMINOLOGY: +EYE DOCTOR EVALUATION. +The following treatments) was/were recommended: +EYE DOCTOR EVALUATION. +Federal Bureau of Prisons Medical staff members have carefully explained to me that the following +possible consequences and/or complications may result because of my refusal to accept treatment: +INABILITY TO DIAGNOSE CURRENT OPTHALMOLOGIC DISEASES. +Counseled by +7-24-2019 +Paters sonater + + +100m + +1 +10 11 +12 13 +14. 15 +15 m +32 31 30 2Đ 28 27 26 25 24 23 22 21 20 19 • 18 +Gold +Gold +Dental Prostheses at Intake: +Yes +Type: +NO +Age: +Condition: +Intra-crad Photos Taken: +Yes +Instructed how to obtain urgent and non-urgent dental care: +Treatment Priories: +None: +Radiographs authorized: +PAS: +Ралогех. +Patient Name: +Epstein, JefFrey E +Institution: +MCC NEW YORK +PDF +A&O DENTAL EXAMINATION +(Initial Clinical Dental Findings) +FEDERAL BUREAU OF PRISONS +Occlusion: +Oral Hyglene: +Good +Fair +Poor +CPITN: +3 +3 +2 +2 +3 +Head & Neck / Soft Tissue: +D: +° +1 +F/4 +Classification: +CLI +Pain Scale: +/10 +advanced +mod to materage singival +recession observed. +Lover antenor crowding obserted +Radiographs Taken: (Document findings on ASO ericounter) +Yes +No +Yes: / +No: +Non-urgent +Urgent Referred to Sick Call: +non-urgent +Prophylaxis aulhorized: Yes / +No +(Approval valid 18 months from examination date) +Dentist Sinnature: +Date: +7-26-19. +Signature Block/Stamp: +Prescribed by P6400 +Chief Dental Officer +MCC New York +• Replaces BP-A0G18 of JUN 10 + + +MEDICAL TREATMENT REFUSAL +CARM +FEDERAL BUREAU OF PRISONS +1-24-2019 +Bureau oF Prisons Medical staf for the rolowing concrete treatment recommended by the federal +DESCRIBE CONDITION IN LAYMAN'S TERMINOLOGY: +EYE DOCTOR EVALUATION. +The following treatments) was/were recommended: +EYE DOCTOR EVALUATION. +Federal Bureau of Prisons Medical staff members have carefully explained to me that the following +possible consequences and/or complications may result because of my refusal to accept treatment: +INABILITY TO DIAGNOSE CURRENT OPTHALMOLOGIC DISEASES. +I understand the possible consequences and/or complications, listed above, and still refuse +recommended treatment. I hereby assume all responsibility for my physical and/or mental condition, and +release the Bureau of Prisons and its employees from any and all liability for respecting and following my +Counseled by +7-24-2019 + + +BP.S358.060 +MEDICAL TREATMENT REFUSAL +CDFRM +FEDERAL BUREAU OF PRISONS +2-10-2012 +1, JEFFREY EPSTEIN +76318-054, refuse treatment recommended by the Foderal +Bureau of Prisons Medical staff for the following condition(s): +DESCRIBE CONDITION IN LAYMAN'S TERMINOLOGY: +66 YR OLD MALE WITH NO PMHX, REFERRED FOR ROUITNE CXR. +The following treatments) wastwere recommended: +CHEST X-RAY +Federal Bureau of Prisons Medical staff members have carefully explained to me that the following +possible consequences and/or complications may result because of my refusal to accept treatment: +WORSENING THE CONDITION IF THERE IS ANY FINDINGS +I understand the possible consequences and/or complications, listed above, and still refuse +recommended treatment. I hereby assume all responsibility for my physical and/or mental condition, and +release the Bureau of Prisons and its employees from any and all lability for respecting and following my +Counseled by +7-10-2019 +Patients Signature +7-10-19 + + +A&O DENTAL EXAMINATION +(Initial Clinical Dental Findings) +FEDERAL BUREAU OF PRISONS +Occlusion: +Oral Hygiene: +Good +Fair +Poor +CPITN: +3 +3 +2 +2 +3 +Head & Neck / Soft Tissue: +RIGHT +7 +10 11 1213 +14. +15 16 +El +31 +30 +29 28 27 26 25 24 23 22 21 20 +19 • 18 +FT +Goe +cold +Classification: +D: +L +CLI +F14 +Pain Scale: +/10. +Dental Prostheses at intake: +one to mange gingives +Yes +No +Type: +ecession observed. +Age: +Loser antonor Crowding deserted +Condilian: +Intra-oral Photos Taken: +Radiographs Taken: (Document findings on ABO encounter) +Yes +Yes +No +instructed how to obtain urgent and non-urgent dental care: +Yes: +No: +Treatment Priontes: +None: +Non-urgent: +Urgent: Referred to Sick Call: +non-urgent +Radiographs authorized: +Prophylaxis authorized: +Yes / +No +PAS: +(Approval valid 18 months from examination date) +BWS! +Раполех: +Pattent Name: +Dentist Sianature: +Epstein, JeFFrey E +Institution: +Date: +Signature Block/Stamp: +MCC NEW YORK +7-26-19. +Chief Dental Officer +MCC New York +PDF +Prescribed by P8400 +• Replaces BP-A0618 of JUN 10 + + +Sex: +M +Encounter Date: 08/10/2019 07:25 +Provider: +Race: WHITE +Reg#: 76318-054 +Unit: +Z04 +Emergency Code - Resuscitation Event encounter performed at Special Housing Unit. +SUBJECTIVE: +Emergency Note Provider: +Team Members: +Role +Team/Code Leader +Code Events: +IxeR +CPR +EKG/Monitor +Value +Compressions +Lifepak +08/10/2019 06:35 +08/10/2019 06:39 +No shock advised +CPR +Oxygen +IV Access +Compressions +15 L +Peripheral IV +08/10/2019 06:40 +08/10/2019 06:47 +08/10/2019 06:48 +18 g Left AC +Airway +Endotracheal Tube +08/10/2019 07:08 +ET Tube 7.5 24CM to L Lip line Placed by Paramedics +Medications +Epinephrine 1mg IV +08/10/2019 07:10 +Epinephrine 3 doses and Sodium bicarb 2 doses administered by paramedics +CPR +Compressions +08/10/2019 07:11 +Medications +Sodium Bicarbonate 1 mEa/kg IV +08/10/2019 07:11 +IV Fluids +Normal Saline 0.9% 1000 ml +08/10/2019 07:12 +Medications +Epinephrine 1mg IV +08/10/2019 07:13 +CPR +Compressions +08/10/2019 07:14 +Medications +Sodium Bicarbonate 1 mEa/kg V +08/10/2019 07:14 +Medications +Epinephrine 1mg IV +08/10/2019 07:16 +CPR +Compressions +08/10/2019 07:17 +Comments: +Responded to a body alarm at 0635 for medical emergency on 9S, Upon arrival Inmate was received on the floor of his +cell unresponsive with CPR in progress by correctional officers, Inmate was Cold, with circumferential Bruising around the +neck and posterior mottling, Pupils Fixed and dilated, No Palpable pulses, Call place for EMS, CPR Continued, AED +OBJECTIVE: +Exam: +General +Appearance +Yes: Unconscious +Generated 08/10/2019 08:10 by| +Bureau of Prisong - NYM + + + +Encounter Date: 08/10/2019 07:25 +Exam: +ASSESSMENT: +Cardiac Arrest +PLAN: +New Consultation Requests: +Consultation/Procedure +Emergency Room +Subtype: +AMBULANCE +Reason for Request: +•Cardiac arrest with CPR in progress +Provider: +Copay Required: No +Cosign Required: Yes +Telephone/Verbal Order: No +Completed byl +Lon 08/10/2019 08:10 +Requested to be cosigned by +Cosign documentation will be displayed on the following page. +Base: WHITE +Unit: +Z04 +Target Date Scheduled Target Date Priority +08/10/2019 08/10/2019 +Emergent +Iranslater Language +No +Generated 08/10/2019 08: 10 by + + + +mate Name: EPSTEIN, JEFFREY EDWAR +ate of Birth +Encounter Date: 07/30/2019 15:58 +Sex: +Provider. +Z01 +Chronic Care - Chronic Care Clinic encounter performed at Health Services. +SUBJECTIVE: +COMPLAINT 1 +Provider: +Chief Complaint: Other Problem +Subjective: PATIENT WAS REFERRED BY THE WARDEN FOR EVALUATION. +PATIENT REPORTS HE HAS BEEN WITHOUT HIS MEDS FOR ABOUT 1 WEEK. HE +ALSO REPORTS NUMBNESS IN HIS RIGHT ARM FOR A FEW MINUTES 3 DAYS AGO. +STATES THE NUMBNESS WENT AWAY ON ITS OWN, BUT WAS VERY CONCERNING. +HE DENIES RIGHT SIDED WEAKNESS, DIPLOPIA, FACIAL DROOP, DIFFICULTY +SPEAKING OR SWALLOWING. +HE REPORTS NOCTURIA OF ABOUT 5 TIMES,, HE DENIES DYSURIA. +HE REPORTS H OF KIDNEY STONES, HX OF HTN FOR WHICH HE WAS TAKING +TOPROL. +HE AHS A HX OF SLEEP APNEA AND STATED HE HAS NOT SLEPT FOR 3 WEEKS +ISNCE HE HASB EEN HERE SINCE HE DIE NOT HAVE ACCESS T HI CPAP MACHINE. I +INFORME DHIM THAT WE RECEIVED HIS CPAP MACHINE AND IT WILL BE GIVEN TO +HIM TONIGHT.. +HE REPORT OTHER NON-MEDICAL ISSUES. +STATES HE FEELS OTHERWISE FINE. +Pain: +Not Applicable +Seen for clinics): Pulmonary/Respiratory, Orthopedic/Rheumatology, Endocrine/Lipid +OBJECTIVE: +Exam: +General +Affect +Yes: Cooperative +Appearance +Yes: Appears Well, Alert and Oriented × 3 +No: Appears Distressed, Dyspneic, Appears in Pain, Writhing in Pain, Pale, Pallor, Cyanotic, Diaphoretic, +Disheveled, Unkempt, Acutely III +Nutrition +Pulmonary +Auscultation +Yes: Clear to Auscultation +Cardiovascular +Auscultation +Yes: Regular Rate and Rhythm (RRR), Normal S1 and S2 +No: M/R/G +Musculoskeletal +Tibla / Fibula +No: Edema +• Neurologic +Generated 07/30/2019 18:12 b| +Bureau of Priscns - NYM + + + +Encounter Date: 07/30/2019 15:58 +Exam: +Cranial Nerves (CN) +Yes: Within Normal Limits +Motor System-General +Yes: Normal Exam +Motor System-Strength +Yes: Normal Muscular Strength +ASSESSMENT: +Body mass index (BMI) 27.0-27.9, adult, Z6827 - Current +Constipation, unspecified, K5900 - Current +Essential (primary) hypertension, 110 - Current - BY HX. +Hyperlipidemia, unspecified, E785 - Current +Low back pain, M545 - Current +Neuralgia and neuritis, unspecified, M792 - Current +Prediabetes, R7303 - Current +Sleep apnea, G4730 - Current +PLAN: +New Medication Orders: +Rx#l +Medication +INsulin REG - Human +Indication: Prediabetes +Discontinued Medication Orders: +Medication +122148-NYM +Insulin Reg (10 ML) 100 UNITS/ML Inj +Prouder: M3 B WHITE +Order Rate +07/30/2019 15:58 +Order Date +07/30/2019 15:58 +Discontinue Type: When Pharmacy Procosses +Discontinue Reason:new order written +Indication: +Copay Required: No +Telephone/Verbal Order: No +Completed by +Cosign Required: No +on 07/30/2019 16:12 +Generated 07/30/2019 18:12 by +Unit: +Z01 +Prescriber Order +SLIDING SCALE +Subcutaneously each morning x +7 day(s) Pill Line Only +Prescriber Order +Inject regular insulin +subcutaneously per sliding scale: +twice daily ***pill line*** for 7 +days + + + +Encounter Date: 07/30/2019 11:12 +Sex: +Provider: +Race: WHITE +Unit: Z01| +Chronic Care - Chronic Care Clinic encounter performed at Health Services. +SUBJECTIVE: +COMPLAINT 1 +Provider: +Chief Complaint: Other Problem +Subjective: +PATIENT WAS REFERRED BY THE WARDEN FOR EVALUATION. +PATIENT REPORTS HE HAS BEEN WITHOUT HIS MEDS FOR ABOUT 1 WEEK. HE +ALSO RERORTS NUMBNESS IN HIS RIGHT ARM FOR A FEW MINUTES 3 DAYS AGO. +STATES THE NUMBNESS WENT AWAY ON ITS OWN, BUT WAS VERY CONCERNING. +HE DENIES RIGHT SIDED WEAKNESS, DIPLOPIA, FACIAL DROOP, DIFFICULTY +SPEAKING OR SWALLOWING. +HE REPORTS NOCTURIA OF ABOUT 5 TIMES,. HE DENIES DYSURIA. +HE REPORTS H OF KIDNEY STONES, HX OF HTN FOR WHICH HE WAS TAKING +TOPROL. +HE AHS A HX OF SLEEP APNEA AND STATED HE HAS NOT SLEPT FOR 3 WEEKS +ISNCE HE HASB EEN HERE SINCE HE DIE NOT HAVE ACCESS T HI CPAP MACHINE. I +INFORME DHIM THAT WE RECEIVED HIS CPAP MACHINE AND IT WILL BE GIVEN TO +HIM TONIGHT.. +HE REPORT OTHER NON-MEDICAL ISSUES. +STATES HE FEELS OTHERWISE FINE, +Pain: +Not Applicable +Seen for clinic(s): Endocrine/Lipid, Orthopedic/Rheumatology, Ralmonary/Respiratory +OBJECTIVE: +Pulse: +Time +07/30/2019 13:02 +07/30/2019 09:40 +07/30/2019 09:30 +Respirations: +07/30/2019 +Time +09:30 NYM +Blood Pressure: +Time +Value +07/30/2019 13:02 NYM 114/84 +07/30/2019 09:40 NYM 125/60 +07/30/2019 09:30 NYM 108/86 +SaO2: +07/30/2019 +Time +09:30 NYM +Weight: +Time +Rate Per Minute +Location +Rhyfhm +94 +88 +87 +Via Machine +Via Machine +Rate Per Minute Provider +12| +Location +Left Arm +Right Arm +Left Arm +Position +Standing +Standing +Sitting +Cuff Size +Value(%) Air +98 Room Air +Lbs. +Kg Waist Circum. Provider + + + +Sex: +M +Race: WHITE +Encounter Date: 07/30/2019 11:12 +Provider: +Unit: +201 +Time +Lbs +Kg Waist Circum. Provider +07/30/2019 +09:30 NYM +194.2 +88.1 +Exam: +General +Affect +Yes: Cooperative +Appearance +Yes: Appears Well, Alert and Oriented × 3 +No: Appears Distressed, Dyspneic, Appears in Pain, Writhing in Pain, Pale, Pallor, Cyanotic, Diaphoretic, +Disheveled, Unkempt, Acutely III +Nutrition +Pulmonary +Musculoskeletal +in Amendment +Tibia / Fibula +No: Edema +Neurologic +Cranial Nerves (CN) +Yes: Within Normal Limits +Motor System-General +Yes: Normal Exam +Motor System-Strength +Yes: Normal Muscular Strength +ASSESSMENT: +Body mass index (BMI) 27.0-27.9, adult, Z6827 - Current +Constipation, unspecified, K5900 - Current +Essential (primary) hypertension, 110 - Current - BY HX. +Hyperlipidemia, unspecified, E785 - Current +Low back pain, M545 - Current +Neuralgia and neuritis, unspecified, M792 - Current +Prediabetes, R7303 - Current +Sleep apnea, G4730 - Current +PLAN: +New Medication Orders: +Rx# +Medication +Order Date +Prescriber Order +Generated 07/30/2019 14:05 by| + + + +Encounter Date: 07/30/2019 11:12 +Sex: +Provider: M +New Medication Orders: +Rx#l +Medication +Magnesium Hydroxide Susp conc 800 +MG/5ML +Indication: Constipation, unspecified +INsulin REG - Human +Unit: +Z01 +Order Date +07/30/2019 11:12 +Prescriber Order +10 CC Orally - Two Times a +Day PRN × 90 day(s) +07/30/2019 11:12 +SLIDING SCALE +Subcutaneously - Two Times a +Day x 7 day(s) Pill Line Only +Indication: Prediabetes +Renew Medication Orders: +Rx#l +121836-NYM +Medication +Order Date +methy|PRÊON/Solone 4 MG Tab ( 21 count 07/30/2019 11:12 +Prescriber Order +ake the tablet by mouth a +irected × 6 day(si +Pack) +Indication: Neuralgia and neuritis, unspecified +New Laboratory Requests: +Details +Lab Tests - Short List-General-CBC w/diff +Frequency +One Time +Due Date +08/01/2019 00:00 +Priority +Routine +Lab Tests-P-PSA, Total +Lab Tests-U-Uric Acid +Lab Tests - Short List-General-Comprehensive +Metabolic Profile (CMP) +Lab Tests-U-Urinalysis w/Reflex to Microscopic +New Radiology Request Orders: +Details +End Date +General Radiology-Spine / Cervical- +Frequency. +One Time +Due Date +08/29/2019 +Priority +- Routine +General +Specific reason(s) for request (Complaints and findings): +66 YR OLD MALE WITH COMPLAIN OF RIGHT ARM NUMBNESS FOR 2-3 MINUTES 3 DAYS AGO. +PLEASE PERFORM C SPINE SERIES +Follow-up at Sick Call as Needed +Patient Education Topics: +Date Initiated Format +07/30/2019 +Counseling +Handout/Topic +Access to Care +nen +Provider A2 +07/30/2019 Counseling +Plan of Care +Outcome +Verbalizes +Verbalizes +Copay Required:No +Telephone/Verbal Order: No +Completed byl +Cosign Required: No +on 07/30/2019 14:05 + + + +Encounter Date: 07/30/2019 11:12 +Sex: +Provider: +BareiWHITE +Jnit: 201 +Chronic Care - Chronic Care Clinic encounter performed at Health Services. +SUBJECTIVE: +COMPLAINT 1 +Provider: +Chief Complaint: Other Problem +Subjective: +PATIENT WAS REFERRED BY THE WARDEN FOR EVALUATION. +PATIENT REPORTS HE HAS BEEN WITHOUT HIS MEDS FOR ABOUT 1 WEEK. HE +ALSO REPORTS NUMBNESS IN HIS RIGHT ARM FOR A FEW MINUTES 3 DAYS AGO. +STATES THE NUMBNESS WENT AWAY ON ITS OWN, BUT WAS VERY CONCERNING. +HE DENIES RIGHT SIDED WEAKNESS, DIPLOPIA, FACIAL DROOP, DIFFICULTY +SPEAKING OR SWALLOWING. +HE REPORTS NO TURIA OF ABOUT 5 TIMES.. HE DENIES DYSURIA. +HE REPORTS H'OF KIDNEY STONES, HX OF HTN FOR WHICH HE WAS TAKING +TOPROL. +HE AHS A HX OF SLEEP APNEA AND STATED HE HAS NOT SLEPT FOR 3 WEEKS +ISNCE HE HASB EEN HERE SINCE HE DIE NOT HAVE ACCESS T HI CPAP MACHINE. I +INFORME DHIM THAT WE RECEIVED HIS CPAP MACHINE AND IT WILL BE GIVEN TO +HIM TONIGHT.. +HE REPORT OTHER NON-MEDICAL ISSUES. +STATES HE FEELS OTHERWISE FINE +Pain: +Not Applicable +Seen for clinic(s): Endocrine/Lipid, Orthopedic/Rheumatology, Palmonary/Respiratory +OBJECTIVE: +Pulse: +Time +07/30/2019 13:02 +07/30/2019 09:40 +07/30/2019 09:30 +Respirations: +07/30/2019 +Time +09:30 NYM +Blood Pressure: +Time +Value +07/30/2019 13:02 NYM 114/84 +07/30/2019 09:40 NYM 125/60 +07/30/2019 09:30 NYM 108/86 +SaO2: +07/30/2019 +Time +09:30 NYM +Weight: +Rate Per Minute +Location +Rhythm +94 +88 +Via Machine +87 +Via Machine +Rate Per Minute Provider +12| +Location +Left Arm +Right Arm +Left Arm +Position +Standing +Standing +Sitting +Cuff Size +Value(%) Air +98 Room Air +Time +Generaled 07/30/2019 14:05 by l +Lbs. +Kg Waist Circum. Provider + + + +Encounter Date: 07/30/2019 11:12 +Time +07/30/2019 +09:30 NYM +Lbs +194.2 +Provider: M Bai E +Kg Waist Circum. Provider +88.1 +Unit: +Z01 +Exam: +General +Affect +Yes: Cooperative +Appearance +Yes: Appears Well, Alert and Oriented × 3 +No: Appears Distressed, Dyspneic, Appears in Pain, Writhing in Pain, Pale, Pallor, Cyanotic, Diaphoretic, +Disheveled, Unkempt, Acutely III +Nutrition +Pulmonary +Musculoskeletal +in Amendment +Tibia / Fibula +No: Edema +Neurologic +Cranial Nerves (CN) +Yes: Within Normal Limits +Motor System-General +Yes: Normal Exam +Motor System-Strength +Yes: Normal Muscular Strength +ASSESSMENT: +Body mass index (BMI) 27.0-27.9, adult, Z6827 - Current +Constipation, unspecified, K5900 - Current +Essential (primary) hypertension, 110 - Current - BY HX. +Hyperlipidemia, unspecified, E785 - Current +Low back pain, M545 - Current +Neuralgia and neuritis, unspecified, M792 - Current +Prediabetes, R7303 - Current +Sleep apnea, G4730 - Current +PLAN: +New Medication Orders: +Rx# +Medication +Order Date +Prescriber Order + + + +Encounter Date: 07/30/2019 11:12 +Sex: +Provider: +New Medication Orders: +Rx#l +Medication +Magnesium Hydroxide Susp conc 800 +MG/5ML +Indication: Constipation, unspecified +INsulin REG - Human +M +Race: WHITE +Unit: +Z01 +Order Date +07/30/2019 11:12 +Prescriber Order +10 CC Orally - Two Times a +Day PRN x 90 day(s) +07/30/2019 11:12 +SLIDING SCALE +Subcutaneously - Two Times a +Day x 7 days) Pill Line Only +Indication: Prediabetes +Renew Medication Orders: +Rxit +121836-NYM +Medication +Order Date +methy/PRÊDNISolone 4 MG Tab (21 count 07/30/2019 11:12 +Prescriber Order +Take the tablet by mouth as +directed x 6 day(s) +Pack) +Indication: Neuralgia and neuritis, unspecified +New Laboratory Requests: +Details +Lab Tests - Short List-General-CBC w/diff +Erequency. +One Time +Due Date +08/01/2019 00:00 +Priority +Routine +Lab Tests-P-PSA, Total +Lab Tests-U-Uric Acid +Lab Tests - Short List-General-Comprehensive +Metabolic Profile (CMP) +Lab Tests-U-Urinalysis w/Reflex to Microscopic +New Radiology Request Orders: +Details +General Radiology-Spine / Cervical- +Frequency +One Time +End Date +Due Date +08/29/2019 +Priority +Routine +General +Specific reason(s) for request (Complaints and findings): +66 YR OLD MALE WITH COMPLAIN OF RIGHT ARM NUMBNESS FOR 2-3 MINUTES 3 DAYS AGO. +PLEASE PERFORM C SPINE SERIES +Follow-up at Sick Call as Needed +Patient Education Topics: +Date Initiated Format +07/30/2019 +Counseling +Handout/Topic +Access to Care +nen +07/30/2019 +Counseling +Plan of Care +Outcome +Verbalizes +Verbalizes +Copay Required: No +Telephone/Verbal Order: No +Completed byl +Cosign Required: No +on 07/30/2019 14:05 + + + +Encounter Date: 07/30/2019 15:58 +Amendment made to this note by +See Amendment +Sex: +M +on 07/30/2019 16:12. +Reg #: +Race: +Facility: \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/016f8302234a4c76ac6528b382a9f0fc7d938ba72347381233bec5a19c8184b2.receipt.json b/vision-fixhub/ds9-parsed-01/016f8302234a4c76ac6528b382a9f0fc7d938ba72347381233bec5a19c8184b2.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..a64d110e0168210ccdca5d9c1f387afa1a48f463 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/016f8302234a4c76ac6528b382a9f0fc7d938ba72347381233bec5a19c8184b2.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -15513, + "dataset": "marble-joined", + "doc_id": "016f8302234a4c76ac6528b382a9f0fc7d938ba72347381233bec5a19c8184b2", + "engine": "marble-apple-vision", + "event_count": 184, + "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "8a719346f2b86de4f748d7aa50c1fe6a341fef4407248660dfbe20308f00c424", + "output_sha256": "0062e6f0fbe9c3fbd93c3991d04dc80696a8c7fdb7c01560b8e2f823d86b02a2", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/016fca06ec755f378e2bc29d66cf90e97b073ca1ba53e81bac28319e2576863f.md b/vision-fixhub/ds9-parsed-01/016fca06ec755f378e2bc29d66cf90e97b073ca1ba53e81bac28319e2576863f.md new file mode 100644 index 0000000000000000000000000000000000000000..fa35a0330694291ce80776adb43aaad994513ce8 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/016fca06ec755f378e2bc29d66cf90e97b073ca1ba53e81bac28319e2576863f.md @@ -0,0 +1,181 @@ +From: " +To: " +Cc: " +(USANYS) [Contractor]". +(NY) (FBI)" ≤ +Subject: RE: [EXTERNAL EMAIL] - RE: Maxwell To-dos +Date: Tue, 06 Jul 2021 20:19:30 +0000 +(USANYS)" +That works for me. +From: +Sent: Tuesday, July 6, 2021 4:18 PM +To: +(USANYS) [Contractor] < +Cc: +(USANYS) < +Subject: [EXTERNAL EMAIL] - RE: Maxwell To-dos +I can bring them over now if that still works. +Special Agent +FBI New York Field Office +On Jul 6, 2021 2:35 PM, " +I have not. +files off. +(USANYS) [Contractor]" < +> wrote: +I'll be around the rest of the day today and the whole week. Let me know when you're free to drop the +From: +Sent: Tuesday, July 6, 2021 2:06 PM +To: +(USANYS) [Contractor] < +P: +(NY) (FBI) +Cc: +(USANYS) < +Subject: RE: Maxwell To-dos +Checking in on this- +, were you able to get these files from | +From: | +(USANYS) [Contractor] < +Sent: Friday, July 2, 2021 10:03 AM +To: | +P: +(NY) (FBI) < +Cc: +(USANYS) < +Subject: RE: Maxwell To-dos +Sure thing! +- I'll be around until 230 today if you're available to drop them off. +From: +Sent: Friday, July 2, 2021 9:55 AM +To: +(NY) (FBI) < +(USANYS) [Contractor] +Cc: +(USANYS) < +Subject: RE: Maxwell To-dos + + +Thanks +would you please coordinate getting these from +From: +Sent: Thursday, July 1, 2021 3:23 PM +To: +Cc: +Subject: RE: Maxwell To-dos +We have the files from CART. +• let me know a good time to coordinate to turn them over to you. +I then circle up with me to discuss prepping for production? +(USANYS) [Contractor] +(USANYS) < +Special Agent | +FBI New York Field Office +Child Exploitation/Human Trafficking +Desk: +From: +Sent: Friday, June 4, 2021 12:47 PM +To: L +I (NYPD) < +Cc:| +(NY) (FBI) 4| +• (USANYS) < +Subject: [EXTERNAL EMAIL] - RE: Maxwell To-dos +Thanks! +From: +Sent: Friday, June 4, 2021 10:12 AM +To: +Cc: +(NY) (FBI) < +(USANYS) < +Subject: Re: Maxwell To-dos +Sure let me check on that today when I'm in. +On Jun 3, 2021, at 21:57, +> wrote: +Hi +Checking in again on the avi files from CART. Any update? +Thanks, + + +From: +Sent: Monday, April 19, 2021 2:40 PM +To: I +Cci +Subject: RE: Maxwell To-dos +Hi +Thanks, +(NY) (FBI) < +| (USANYS) < +Any update from CART regarding the avi files, please? And any luck with the review of images for +From: | +Sent: Thursday, February 4, 2021 1:24 PM +To: | +Cc:| +I. (NY) (FBI) < +(USANYS) <| +Subject: Re: Maxwell To-dos +Hey guys, +To answer your questions: +you should have +: These photos are stil under review. +1 302's from I by now. +• We have not forgotten about the lavi files they are also still being processed. +• Palm Beach PD Captain +I is the POC for this task. His phone number is +(office) and email is +(cell) +We • let you know as soon as the photo and video tasks are completed. Let us know if there's anything +else. +Detective +NYPD / FBI +Child Exploitation Human Trafficking Task Force +Office: | +Cell: +Fax: 212-384-8289 +From: | +Sent: Tuesday, February 2, 2021 4:03 PM +To: I +|. (NY) (FBI) 4 + + +Cc:_ +P:0 +(USANYS) < +Subject: Maxwell To-dos +and +Just wanted to check in on a few tasks for Maxwell. Not a huge rush, but wanted to make sure these stay on your radar: +• Please send me the draft 302s from the 1/20 and 1/21 interviews of +for review +• Review of images in FBI office for photos of +• The .avi files from Reiter ( +, I know CART has been under water with the Capitol investigation, but wanted to +ping on this to make sure we don't forget it) +• Finding PBPD witness who can authenticate the message pads and other items that were seized from Epstein's +Palm Beach residence. On this, I've gone through the reports, and below are the PBPD personnel who I think +might be able to provide this testimony. If you could please get me contact information for a point of contact at +PBPD, I'm happy to hound them for contact info for these individuals (ranked in order of how likely they are to +be useful witnesses for these purposes): +• Evidence Specialist +(inventory return, documentation of property receipts, and collection +and bagging of evidence - ideally we could just call her to authenticate everything that was seized from +the property) +(searched garage, towel closet and pantry off the kitchen, kitchen phone message +book, office room, green bathroom on first floor, closet by green bathroom, two bedrooms on second +floor with sex toys, pool cabana, +| living quarters) +(searched garage, towel closet and pantry off the kitchen, kitchen phone message book, +officer room, green bathroom on first floor, closet by green bathroom, two bedrooms on second floor +with sex toys, pool cabana, +living quarters) +(read warrant, video scene) +CSI +(photographer) +| (pantry next to kitchen, yellow and blue room with photos, main entrance, blue +room with photos, sliding glass door room, cars) +• Detective +(pantry next to kitchen, yellow and blue room with photos, main entrance, blue +room with photos, sliding glass door room, cars) +(electronic devices) +Thanks very much, +Assistant United States Attorney +Southern District of New York +1 St. Andrew's Plaza +New York, NY 10007 diff --git a/vision-fixhub/ds9-parsed-01/016fca06ec755f378e2bc29d66cf90e97b073ca1ba53e81bac28319e2576863f.receipt.json b/vision-fixhub/ds9-parsed-01/016fca06ec755f378e2bc29d66cf90e97b073ca1ba53e81bac28319e2576863f.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..500e6b97c2af30a89a1da0e41b924c3e1b0bb6b9 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/016fca06ec755f378e2bc29d66cf90e97b073ca1ba53e81bac28319e2576863f.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -48, + "dataset": "marble-joined", + "doc_id": "016fca06ec755f378e2bc29d66cf90e97b073ca1ba53e81bac28319e2576863f", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "8a538d91ade7a5f221e8ef6e073e9e9a4e112b2175187440c25a01ba2886b21c", + "output_sha256": "2740ba9a741515d698cd0140eb1cf1ebb0074f46eab600224a6cae423c85c4be", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0196097882f5fd1f88b261726f81227607e4071b80554baaff41e64e5fef03f3.md b/vision-fixhub/ds9-parsed-01/0196097882f5fd1f88b261726f81227607e4071b80554baaff41e64e5fef03f3.md new file mode 100644 index 0000000000000000000000000000000000000000..40d2855f246451683e2a346d47c2b0d40ea9a106 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0196097882f5fd1f88b261726f81227607e4071b80554baaff41e64e5fef03f3.md @@ -0,0 +1,32 @@ +12/02/2009 +ALFREDO RODRIGUEZ, date of birth +social +security number +I, of | +was interviewed, after waiving his Miranda Rights, at +•. After being advised of the identity of +the interviewing agents and the purpose of the interview, he +provided the following information: +RODRIGUEZ worked for JEFFREY EPSTEIN as a house manager +for approximately six months between 2004 and 2005. +During his +employment he obtained a copy of a black book and other papers that +had the contact information for numerous individuals. +claimed that many of the individuals in the book were underage +(minor) females. RODRIGUEZ stated that he forgot that he had these +items until the past couple of months. +RODRIGUEZ wanted to sell +these items for $50, 000.00 to attorney BRADLEY EDWARDS because he +had been unable to work +since losing his job with EPSTEIN. +RODRIGUEZ' employment with EPSTEIN he (RODRIGUEZ) saw naked minor +females sunbathing at EPSTEIN's pool, he saw images of naked minor +emales on EPSTEIN's computer, and he knew that EPSTEIN was having +sexual contact with minor females at his house. +occasionally tasked with cleaning sex toys after the minor females +had departed the residence. +RODRIGUEZ did not tell the FBI nor any +other law enforcement agency about this information, even though he +knew there was an investigation, because he was scared of EPSTEIN. +RODRIGUEZ claimed that he did give the Palm Beach Police Department +some information related to the EPSTEIN investigation. diff --git a/vision-fixhub/ds9-parsed-01/0196097882f5fd1f88b261726f81227607e4071b80554baaff41e64e5fef03f3.receipt.json b/vision-fixhub/ds9-parsed-01/0196097882f5fd1f88b261726f81227607e4071b80554baaff41e64e5fef03f3.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..58f2c2be053a8f009efa6a9cfaedbdcfcf69889b --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0196097882f5fd1f88b261726f81227607e4071b80554baaff41e64e5fef03f3.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "0196097882f5fd1f88b261726f81227607e4071b80554baaff41e64e5fef03f3", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "2bb4c9d2d94374987f51c10566488d995f47f1a82f18e3113a085e8811e76408", + "output_sha256": "b9460a1beb3372ea1f1de659f28368ceffeb9361abd1da0a4a03dc26f0b3807e", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/01b302297a486688d645427cabaa2f043bd2e22a2a77bdca1b4aa0c603d777c3.md b/vision-fixhub/ds9-parsed-01/01b302297a486688d645427cabaa2f043bd2e22a2a77bdca1b4aa0c603d777c3.md new file mode 100644 index 0000000000000000000000000000000000000000..8cab76b15d6a93f937f62ff09cf15dce64b24622 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/01b302297a486688d645427cabaa2f043bd2e22a2a77bdca1b4aa0c603d777c3.md @@ -0,0 +1,439 @@ +LAST WILL AND TESTAMENT +OF +JEFFREY E. EPSTEIN +I, JEFFREY E. EPSTEIN, a resident and domiciliary of St. Thomas, United States Virgin Islands, +do make, publish and declare this to be my Will hereby revoking all prior Wills and Codicils made +by me. +I direct my Executor to pay from my estate all expenses of +my my til duly proven and d lourial expinses e administration expenses of my estate and all +I direct my Executor to pay from my estate, as compensation +to each Executor for serving as Executor hereunder, the sum of Two Hundred Fifty Thousand +Dollars ($250,000) to each Executor upon the completion of probate of my estate. No Executor +shall receive any other compensation for serving as Executor hereunder; provided, however, that +my Executor shall be reimbursed from my estate for all reasonable costs, expenses, charges, and +liabilities incurred or paid in respect thereto, including fees and expenses of counsel or any other +agents hired by my Executor, and my Executor shall not be liable therefor individually. +C +I direct my Executor to pay from my estate the federal and +state transfer taxes described in Paragraph B(1) of Article SEVENTH. +I direct my Executor to pay from my estate all expenses of +storing, insuring, packing, shipping and delivering my tangible personal property in accordance +with the provisions of Article SECOND. +SECOND: +I give all of my property, real and personal, wherever situated, after +the payments and distributions provided in Article FIRST, to the then acting Trustees of The +Jetfrey E. Epstein 2019 Trust (Trust") created under that certain Trust Agreement of The Jeffrey +E. Epstein 2019 Trust (the "Trust Agreement") dated January 18, 2019, as the same may be +amended from time to time, to be held in accordance with the provisions comprising the Trust +Agreement at the time of my death +I appoint DARREN K. INDYKE and RICHARD D. KAHN +o serve as the Executors of this Will. If any one or more of my Executors fails to quality, is unabl +or unwilling to serve or ceases to act, I appoint KATHRYN H. RUEMMLER, as successo +Executor. If any successor Executor fails to qualify, is unable or unwilling to serve or ceases to +act, I authorize the last acting Executor to designate his or her successor. Such designation shall +be made by written instrument delivered to such designated successor Executor. +B. +If my estate must be administered in whole or in part in any +jurisdiction other than the state or territory of my domicile at the date of my death, and if my +GJ_000188 + + + +Executor is unable or unwilling to serve in such jurisdiction, then I appoint the successor Executor +of my estate designated in Paragraph A of Article THIRD as successor Executor in such +jurisdiction only, provided that he or she is able and willing to serve in such jurisdiction. If no +Executor or successor Executor is able and willing to serve in such jurisdiction, my Executor shall +designate a successor Executor to serve in such jurisdiction. Such designation shall be made by +written instrument delivered to such successor Executor. +C. No bond or other security shall be required of any Executor +in any jurisdiction. +D. Any Executor may resign in the manner provided for by the +governing statutes of the state or territory having jurisdiction of the administration of my estate or +in the absence of such statutory guidance, by filing a written notice of resignation with the Court +having jurisdiction of the administration of my estate. Any Executor who resigns shall not be +entitled to any compensation hereunder for any services rendered as Executor prior to his or her +resignation. +My Executor shall not be accountable or responsible to any +person interested in my estate for the manner in which my Executor in good faith exercises or +declines to exercise any discretionary authority or power of my Executor. My Executor shall not +be liable for any loss or depreciation in value occasioned by reason of any negligence, error or +mistake of judgment in entering into any transaction, in making any sale or investment, in +continuing to hold any property or by reason of any action or omission, whether by my Executor +or any other fiduciary, unless my Executor has acted in bad faith. In the absence of proof by +affirmative evidence to the contrary, each Executor shall be deemed to have acted within the scope +of my Executor's authority, to have exercised reasonable care, diligence and prudence and to have +acted impartially as to all interested persons. An Executor shall not be liable for the acts or defaults +of another Executor. +FOURTH: +The following provisions shall apply to my estate and to my +Executor, except as is otherwise specifically provided in this Will: +A. +My Executor has the entire care and custody of all assets of +my estate. My Executor has the power to do everything my Executor in good faith deems advisable +without necessity of any judicial authorization or approval, even though but for this power it +would not be authorized or appropriate for fiduciaries under any statutory or other rule of law. My +Executor shall exercise my Executor's best judgment and discretion for what my Executor +believes to be in the best interests of the beneficiaries hereunder. Except as otherwise specifically +provided in this Will, if two Executors are empowered to participate in the decision to exercise or +not to exercise any fiduciary power granted by this Will or by law, such decision shall be made +by such Executors acting unanimously. If more than two Executors are empowered to participate +in the decision to exercise or not exercise any fiduciary power granted by this Will or by law, a +majority of such Executors shall be empowered to make such decision. +B. +Except as otherwise provided herein, my Executor shall +have the power: +2 +GJ_000189 + + + +(1) to enter upon and take possession of the +assets of my estate and collect the income and profits from such assets, and to invest and reinvest +such assets in real, personal or mixed assets (including the common trust funds of a corporate +fiduciary) or in undivided interests therein without being limited by any present or future +investment laws; +(2) +to retain all or any part of the assets of my +estate (without regard to the proportion that any one asset or class of assets may bear to the whole) +in the form in which such assets were received or acquired by my Executor; +(3) to sell or dispose of, exchange, transfer, +invest or loan all or any part of the assets of my estate which may, at any time, be held by my +Executor for such sums or upon such terms as to payment, security or otherwise as my Executor +determines, either by public or private transactions; +to buy and sell options, warrants, puts, calls +or other rights to purchase or sell (collectively "options") relating to any security or securities, +regardless of whether such security or securities are then held by my Executor, and whether such +options are purchased or sold on a national securities exchange, and to exercise with respect to +such options all powers which an individual owner thereof could exercise, including, without +limitation, the right to allow the same to expire; +(5) with respect to oil, natural gas, minerals, and +all other natural resources and rights to and interests therein (together with all equipment +pertaining thereto), including, without limiting the generality of the foregoing, oil and gas +royalties, leases, or other oil and gas interests of any character, whether owned in fee, as lessee, +lessor, licensee, concessionaire or otherwise, or alone or jointly with others as partner, joint tenant, +or joint venture in any other noncorporate manner, (a) to make oil, gas and mineral leases or +subleases; (b) to pay delay rentals, lease bonuses, royalties, overriding royalties, taxes, +assessments, and all other charges; (c) to sell, lease, exchange, mortgage, pledge or otherwise +hypothecate any or all of such rights and interests; (d) to surrender or abandon, with or without +consideration, any or all of such rights and interests; (e) to make farm-out, pooling, and unitization +agreements; (f) to make reservations or impose conditions on the transfer of any such rights or +interests; (g) to employ the most advantageous business form in which properly to exploit such +rights and interests, whether as corporations, partnerships, limited partnerships, mining +partnerships, limited liability companies, joint ventures, co-tenancies, or otherwise exploit any +and all such rights and interests; (h) to produce, process, sell or exchange all products recovered +through the exploitation of such rights and interests, and to enter into contracts and agreements +for or in respect of the installation or operation of absorption, reprocessing or other processing +plants; (i) to carry any or all such interests in the name or names of a nominee or nominees; (i) to +delegate, to the extent permitted by law, any or all of the powers set forth herein to the operator +of such property; and (k) to employ personnel, rent office space, buy or lease office equipment, +contract and pay for geological surveys and studies, procure appraisals, and generally to conduct +and engage in any and all activities incident to the foregoing powers, with full power to borrow +and pledge in order to finance such activities; together with the power to allocate between +principal and income any net proceeds received as consideration, whether as royalties or +3 +GJ_000190 + + + +otherwise, for the permanent severance from lands of oil, natural gas, minerals, and all other +natural resources; +estate in cash or in bank accounts without the necessity of i all ing the sant of the acts of my +(7) +to improve, repair, partition, plat or +subdivide all or any part of the assets of my estate; +to litigate, defend, compromise, settle, +abandon or submit to arbitration on such terms and conditions as my Executor determines any +claims in favor of or against my estate or the assets of my estate; +(9) +to loan or borrow money in such amounts +and upon such terms and conditions as my Executor determines, assume such obligations or give +such guarantees as my Executor determines, for the purpose of the acquisition, improvement, +protection, retention or preservation of the assets of my estate, or for the welfare of the +beneficiaries of my estate; +(10) to carry on for as long and in such manner as +my Executor determines any business enterprise in which I owned any interest at my death, either +individually, or as a partner, member, joint venture, stockholder or trust beneficiary; to sell such +business enterprise as an ongoing business; to consolidate, merge, encumber, dissolve, liquidate +or undertake any other extraordinary corporate transaction relating to such business enterprise; +(11) to vote in person or by proxy any and all +stock or securities and to become a party to any voting trusts, reorganization, consolidation or +other capital or debt readjustment of any corporation, association, partnership, limited liability +partnership, limited liability company or individual with respect to stocks, securities or debts held +by my estate; +(12) except as provided for in Sections (20) and +(21) of this Article Fourth, to enter into any good faith transactions with any Executor individually +or with any corporation, partnership or other entity in which any Executor has an ownership +interest; +(13) To purchase from my estate any stocks, +bonds, securities, real or personal property, or other assets, or make loans to my estate even though +the same person or persons occupy the office of my Trustee and the office of the Executor of my +estate; +(14) to lease, mortgage, pledge, grant a security +interest in or otherwise encumber all or any part of the assets of my estate for any term of years +whether or not beyond the duration of my estate (including, without limitation, any such action +for the benefit of any of the beneficiaries of my estate; +(15) to abandon any property of my estate, real or +personal, which my Executor may deem worthless or not of sufficient value to warrant keeping +4 +GJ_000191 + + + +or protecting; to abstain from the payment of taxes, water rents or assessments and to forego +making repairs, maintaining or keeping up any such property; and to permit such property to be +lost by tax sale or other proceedings or to convey any such property for a nominal consideration +or without consideration so as to prevent the imposition of any liability by reason of the continued +ownership thereof; +(16) +to elect the mode of distribution of the +proceeds payable to my estate from any profit-sharing plan, pension plan, employee benefit plan, +individual retirement plan, insurance contract or annuity contract pursuant to the terms of such +plan; +(17) to allocate, in my Executors discretion, any +adjustment to basis provided to my estate under the provisions of Federal and State law with +respect to property comprising my estate, without any obligation to make a compensatory +adjustment among the beneficiaries hereunder on account of such allocation; +(18) to conduct any audit, assessment or +investigation with respect to any asset of my estate regarding compliance with any law or +regulation having as its object protection of public health, natural resources or the environment +("Environmental Laws"); to pay from the assets of my estate to remedy any failure to comply with +any Environmental Law (even to the exhaustion of all of the assets of my estate); and, as may be +required in my Executor's judgment by any Environmental Law, to notify any governmental +authority of any past, present or future non-compliance with any Environmental Law; and +(19) to sell to the Trustee under the Trust +Agreement any stocks, bonds, securities, real or personal property or other assets or borrow from +the Trustee under the Trust Agreement even though the same person or persons occupy the office +of the Executor of my estate and the Trustee under the Trust Agreement. +(20) No executor shall directly or indirectly buy or +sell any property for the estate from or to himself, or from or to his relative, employer, employee, +partner, or other business associate. +(21) No executor shall lend estate funds to +himself, or to his relative, employer, employee, partner, or other business associate. +C. +Except as otherwise provided herein, my Executor shall +have the power: +attorneys-at-law, +administration of my Executor's duties; to delegate to such persons, or to one or more of my +Executors, the custody, control or management of any part of my estate as my Executor determines +and to pay for such services from the assets of my estate, without obtaining judicial authorization +or approval; +5 +GJ_000192 + + + +(2) to delegate, in whole or in part, to any person +or persons the authority and power to (a) sign checks, drafts or orders for the payment or +withdrawal of funds, securities and other assets from any bank, brokerage, custody or other +account in which funds, securities or other assets of my estate shall be deposited, (b) endorse for +sale, transfer or delivery, or sell, transfer or deliver, or purchase or otherwise acquire, any and all +property, stocks, stock warrants, stock rights, options, bonds or other securities whatsoever, (c) +gain access to any safe deposit box or boxes in which my assets or assets of my estate may be +located or which may be in the name of my Executor and remove part or all of the contents of any +such safe deposit box or boxes and release and surrender the same, and (d) take any other action +that my Executor may have the power to take with respect to my estate and the property thereof; +no person or corporation acting in reliance on any such delegation shall be charged with notice of +any revocation or change of such delegation unless such person or corporation receives actual +notice thereof; +(3) +to pay any property distributable to a +beneficiary under a legal disability or who has not attained the age of 21, without liability to my +Executor, by paying such property (a) to such beneficiary, (b) for the use of such beneficiary, (c) +to a legal representative of such beneficiary appointed by a court or if none, to a relative for the +use of such beneficiary, or (d) to a custodian for such beneficiary designated by my Executor, to +hold until age 21 or such earlier age as shall be the maximum permitted under applicable law; +(4) +to distribute to any of the beneficiaries of my +estate in kind or in cash, or partly in kind and partly in cash, and to allocate different kinds or +disproportionate shares of assets or undivided interests in assets among all of such beneficiaries; +(5) to have evidence of ownership of any +security maintained in the records of a Federal Reserve Bank under the Federal Reserve Book +Entry System; to deposit funds in any bank or trust company; to carry in the name of my Executor +or the nominee or nominees of my Executor and with or without designation of fiduciary +capacity, or to hold in bearer form, securities or other property requiring or permitting of +registration; and to cause any securities to be held by a depository corporation of which an +Executor is a member or by an agent under a safekeeping contract; provided, however, that the +books and records of my Executor shall at all times show that such investments are part of my +estate; +(6) +to renounce and disclaim, in whole or in part, +and in accordance with applicable law, any assets, interests, rights or powers (including any power +of appointment) which are payable to (or exercisable by) me or my estate, which are includible in +my estate or Gross Estate or over which I have any right, title, interest or power; and +(7) to make, execute and deliver any and all such +instruments in writing as shall be necessary or proper to carry out any power, right, duty or +obligation of my Executor or any disposition whatsoever of my estate or any asset of my estate +and to exercise any and all other powers incidental or necessary to carry out or to fulfill the terms, +provisions and purposes of my estate. +D. +In connection with any insurance policy or annuity on the +6 +GJ_000193 + + + +life of an Executor which is included in my estate, such Executor shall not participate in the +decision to exercise or not exercise any fiduciary power in connection with any incidents of +ownership for such policy or annuity, including, without limitation, any decision to continue, +assign, terminate or convert such policy or annuity or to name the beneficiary of such policy or +annuity. +E. +An Executor hereunder may by a written notice delivered to +the other Executor decline to participate in the decision to exercise or not exercise any fiduciary +power granted by this Will or by law. +F. +If an Executor is not empowered (because of a conflict of +interest, declination to act or otherwise) to participate in the decision to exercise or not exercise +any fiduciary power granted by this Will or by law, then the remaining Executor shall be +empowered to make such decision. If no Executor is empowered to participate in such decision, +then the successor Executor of my estate designated in Paragraph A of Article THIRD and able +and willing to act shall be empowered to make such decision. If no Executor or successor Executor +is empowered to participate in such decision, my Executor may designate a successor Executor to +serve as Executor of my estate who shall be empowered to make such decision but shall have no +other power or authority of my Executor. Such designation shall be by written notice delivered to +such successor Executor. +G. +(1) +Except as otherwise specifically provided in this +Paragraph G(1) of this Article, and except as provided in Paragraph G(2) of this Article, my +Executor shall allocate receipts and disbursements in accordance with sound trust accounting +principles and shall have discretion to allocate receipts and disbursements when the treatment is +uncertain under applicable laws or generally accepted accounting principles in the judgment of +my Executor. +(2) +Except as otherwise specifically provided in this +Will, my Executor shall not treat any part of the principal amount of the proceeds of sale of any +asset of my estate as income distributable to or for the benefit of any beneficiary entitled to +distributions of income; provided, however, that my Executor shall treat a portion of any proceeds +of sale of any financial instrument originally issued or acquired at a discount equal to the amount +which (a) has previously been characterized as ordinary income for income tax purposes or (b) +will be characterized as ordinary income for income tax purposes in the year of such sale, as +income for trust accounting purposes. +FIFTH: +Where a party to any proceeding with respect to my estate has the +same interest as a person under a disability, it shall not be necessary to serve legal process on the +person under a disability. +SIXTH: +If any beneficiary under the Trust shall in any way directly or +indirectly (a) contest or object to the probate of my Will or to the validity of any disposition or +provision of my Will or of the Trust or (b) institute or prosecute, or be in any way directly or +indirectly instrumental in the institution or prosecution of, any action, proceeding, contest, +objection or claim for the purpose of setting aside or invalidating my Will or the Trust or any +disposition therein or provision thereof, then I direct that (a) any and all provisions in the Trust +7 +GJ_000194 + + + +for such beneficiary and his issue in any degree shall be null and void and (b) my estate, whether +passing under my Will or the Trust or pursuant to the laws of intestacy, shall be disposed of as if +such beneficiary and his issue in any degree had all failed to survive me. +SEVENTH: A. +As used herein: +(I) The term "Executor" of a person's estate +means all persons or entities who occupy the office of executor, administrator, personal +representative, or ancillary administrator while such persons or entities occupy such office, +whether one or more persons or entities occupy such office at the same time or times, and includes +any successor or successors to that office. The term "Trustee" means all persons or entities who +occupy the office of Trustee under the Trust Agreement while such persons or entities occupy +such office, whether one or more persons or entities occupy the office of Trustee at the same time +or times, and includes any successor Trustee or Trustees. A reference to a person's estate or +probate estate means that person's estate which is subject to probate administration. A reference +to a person's Will means such person's Last Will and Testament and any Codicil or Codicils +thereto. +(2) +The term "IRC section" means a section of +the Internal Revenue Code of 1986, as amended, or the corresponding provision of any successor +Internal Revenue law, as in effect as of the date of my death. +(3) A reference to any tax also includes any +interest or penalties thereon. A reference to a person's "Gross Estate" means such person's gross +estate as finally determined for purposes of computing such person's federal estate tax. +(4) Whenever the singular number is used, the +same shall include the plural, and the masculine gender shall include the feminine and neuter +genders. +B. +(1) The federal and state transfer taxes which my +Executor shall be obligated to pay pursuant to Paragraph B of Article FIRST shall consist of all +federal and state estate, inheritance, succession, and similar taxes (including any federal or state +generation-skipping transfer tax) imposed upon my probate estate or by reason of my death in +respect to all assets which pass under this Will or the Trust Agreement. Subject to Paragraph B(2) +of this Article, all federal estate taxes with respect to assets not passing under this Will or the Trust +Agreement (such assets are referred to as the "Apportionment Assets") and any applicable state +estate taxes with respect to the Apportionment Assets shall be apportioned among all persons +interested in the Apportionment Assets. My Executor shall make reasonable efforts to collect all +federal estate taxes and state estate, inheritance, succession and similar taxes allocable to the +Apportionment Assets from the recipients of the Apportionment Assets. Without changing the +apportionment of taxes in this Paragraph B(1), my Executor has discretion, but is not required, to +pay all or part of such taxes allocable to the Apportionment Assets. To the extent my Executor +pay such are all there te of tine Appose en Assetstory l set or but nor e +8 +GJ_000195 + + + +personally liable for any of such taxes if my Executor is unable, with reasonable efforts, to collect +payment (or reimbursement) from any recipient of any Apportionment Assets for any or all of +such taxes allocable to such assets. +(2) My Executor has discretion to direct the +Trustee of the Trust Agreement to pay all or any portion of the taxes which my Executor is directed +or obligated to pay pursuant to Paragraph B of Article FIRST and this Paragraph B pursuant to a +written direction delivered to the Trustee under the Trust Agreement. Any taxes which my +Executor directs the Trustee under the Trust Agreement to pay shall be allocated and paid from +the trusts under the Trust Agreement as provided under the Trust Agreement. +C. +Except as otherwise specifically provided in this Will, a +bequest or devise to an individual who does not survive me shall lapse notwithstanding any law +to the contrary. +D. +To the extent that the distribution to the Trustee under the +Trust Agreement pursuant to Article SECOND shall not be effective, I give all the rest of my +property, real and personal, wherever situated, after the payments and distributions provided in +Article FIRST, to the person or persons named as Trustee or Trustees under the Trust Agreement, +be to held in trust under this Will in accordance with the provisions comprising the Trust +Agreement at the time of my death, which provisions are incorporated in this Will by reference. +IN WITNESS WHEREOF, I have duly executed this Will this 18 day of January, +2019. +JEFFREY E. EPSTEIN +The foregoing written instrument was, on the date thereof, signed, published and +declared by the Testator therein named as the Testator's Will in the presence of us and of each +of us, who, at the Testator's request, in the Testator's presence, and in the presence of each other +have subscribed our names as witnesses thereto. +residing at +residing at +579 HUHHAeK Cn. +VERO BEAN, 71.32962 +AFFIDAVIT +We, +JEFFREY E. EPSTEIN, +and CARLL PYLDine Testator +and the witnesses, respectively, whose names are signed to the foregoing instrument, having been +9 +GJ_000196 + + + +sworn, declared to the undersigned officer that the Testator, in the presence of the witnesses, +signed the instrument as his Will, that he signed, and that each of the witnesses, in the presence +of the Testator and in the presence of each other, signed the Will as a witness. +STATE OF NEW YORK Florida +) +)ss: +COUNTY OF NEW YORK Palm Beach) +Subscribed and sworn to before me by JEFFREY E. EPSTEIN, the Testator, who is personally +known to me or who has produced +_ as identification, and by +a witness who is personally known to me or who has produced. +as identification, +and Carluiz Toylo +_, a witness who is personally known to me or who has produced +as identification, on January 18, 2019. +Sworn to before me this 18th day of January, 2019. +amanda serine. +Notary Public +AMANDA DEVINE +Notary Public - State of Fiorida +Commission # GG 268365 +My Comm. Expires Oct 16, 2022 +Bonded through Nationa: Notary Assr. +10 +GJ_000197 \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/01b302297a486688d645427cabaa2f043bd2e22a2a77bdca1b4aa0c603d777c3.receipt.json b/vision-fixhub/ds9-parsed-01/01b302297a486688d645427cabaa2f043bd2e22a2a77bdca1b4aa0c603d777c3.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..78a08dba6ecdc5596274a7f1ec6e6da558444edb --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/01b302297a486688d645427cabaa2f043bd2e22a2a77bdca1b4aa0c603d777c3.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -626, + "dataset": "marble-joined", + "doc_id": "01b302297a486688d645427cabaa2f043bd2e22a2a77bdca1b4aa0c603d777c3", + "engine": "marble-apple-vision", + "event_count": 20, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "5156dbf9da6d1195cb920be677491023015632645950406f44af449dab3a2502", + "output_sha256": "6733e7804b72711a9cb887142acb4def615ba774e74d65d3fd38dd82cb15f4ad", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/01c83f8a3601307fbe106e7839fa2bc803675bdfa9e2eb8ff2c30cb6dd5cde63.md b/vision-fixhub/ds9-parsed-01/01c83f8a3601307fbe106e7839fa2bc803675bdfa9e2eb8ff2c30cb6dd5cde63.md new file mode 100644 index 0000000000000000000000000000000000000000..996abcbcf2c281827969ccbfeaef18aeecf56d39 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/01c83f8a3601307fbe106e7839fa2bc803675bdfa9e2eb8ff2c30cb6dd5cde63.md @@ -0,0 +1,23 @@ +ANIXTER TP120240 & SIGNET TECH TP120150 +From +• +Date +Subject: +Attachments: +2019/04/01 14:11 +ANIXTER TP120240 & SIGNET TECH TP120150 +TEXT.htm +Good afternoon, +Ms. +after reviewing my CORS report for the Central Office Samples; I went ahead and asked +our Comp. Tech on the status of these particular POs and he advised me that they haven't been able to +receive the Fiber Cable and without the cable they can't proceed with the Camera Systems. He mentioned +that the company is requiring some sort of documentation and he should be able to provide you with the +details. +Sincerely, +United States Department of Justice +Federal Bureau of Prisons +Metropolitan Correctional CTR +150 Park Row New York, NY 10007 +SENSITIVE PRIVILEGED COMMUNICATION +intended recipient of this infomation, any disclosuns, copying, distrbution, ur the taking of any action in relance on this information is strictly prohibited. diff --git a/vision-fixhub/ds9-parsed-01/01c83f8a3601307fbe106e7839fa2bc803675bdfa9e2eb8ff2c30cb6dd5cde63.receipt.json b/vision-fixhub/ds9-parsed-01/01c83f8a3601307fbe106e7839fa2bc803675bdfa9e2eb8ff2c30cb6dd5cde63.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..6d41829b154d146cb49592ee2d6eaea57a893e6d --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/01c83f8a3601307fbe106e7839fa2bc803675bdfa9e2eb8ff2c30cb6dd5cde63.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "01c83f8a3601307fbe106e7839fa2bc803675bdfa9e2eb8ff2c30cb6dd5cde63", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "62cf505d6f33188a96bc9a636bc364740cfbe43e30c09cd6f5be66bd32d48a0e", + "output_sha256": "e094710b68d7c1fd48219f88bc2ad4e6c28ce82d6af223f5fc15aaf9dd67ea95", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/01d04ebf019cbb17f611857bdb83843b8e1345a29d15d2dfb2f7561aa7a79536.md b/vision-fixhub/ds9-parsed-01/01d04ebf019cbb17f611857bdb83843b8e1345a29d15d2dfb2f7561aa7a79536.md new file mode 100644 index 0000000000000000000000000000000000000000..4874ffabfbea2f95e286f5894e98e113f0510891 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/01d04ebf019cbb17f611857bdb83843b8e1345a29d15d2dfb2f7561aa7a79536.md @@ -0,0 +1,106 @@ +Grand Jury Subpoena +United States District Gnurt +SoUTHeRN DISTRICT OF NEW YorK +TO: +Equifax +Custodian of Records +1550 Peachtree Street, NW +Atlanta, GA 30309 +Fax: +GREETINGS: +Appearance Date: +September 13, 2019 +Appearance Time: 9:00 a.m. +to testify and give evidence in regard to alleged violation of: +18 U.S.C. $$ 1791, 201. +and not to depart the Grand Jury without leave thereof, or of the United States Attorney, and that you +bring with you and produce at the above time and place the following: +Please sellereum bed rilk, Personal apachane is potresuired rule renues record are l moduced om +or before the return date to AUSA +accompanied by an executed copy of the attached Declaration of Custodian of Records. +Failure to attend and produce any items hereby demanded will constitute contempt of court and will +subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law. +DATED: New York, New York +August 30, 2019 +SEE BERNAN +S. Bernar +United States Attorney +Assistant United States Attorney +One St. Andrew's Plaza +New York, New York 10007 +Telephone: +Email: +rev. 02.01.12 + + +(Grand Jury Subpoena to Equilax, dated August 30,2019: USAO 2019R01059) +REQUEST: +Please provide all financial account information, including credit reports, relating to the following +individuals: +- +, DOB +Tova A. Noel, DOB | +Michael A. Thomas, DOB +ISSN +, SSN +In lieu of an appearance you may comply with this subpoena by providing the requested information, +along with a business records certification pursuant to Fed. R. Evid. 803(6) to AUSA + + +Declaration of Custodian of Records +Pursuant to 28 U.S.C. § 1746, I, the undersigned, hereby declare: +My name is +(name of declarant) +I am a United States citizen and I am over eighteen years of age. I am the custodian of records of the +business named below, or I am otherwise qualified as a result of my position with the business named below to +make this declaration. +I am in receipt of a Grand Jury Subpoena, dated August 30, 2019, and signed by Assistant United States +Attorney +,. requesting specified records of the business named below. Pursuant to Rules 902(11) +and 803(6) of the Federal Rules of Evidence, I hereby certify that the records provided herewith and in response to +the Subpoena: +(1) were made at or near the time of the occurrence of the matters set forth in the records, by, or from +information transmitted by, a person with knowledge of those matters; +(2) were kept in the course of regularly conducted business activity; and +(3) were made by the regularly conducted business activity as a regular practice. +I declare under penalty of perjury that the foregoing is true and correct. +Executed on +(date) +(signature of declarant) +(name and title of declarant) +(name of business) +(business address) +Definitions of terms used above: +As defined in Fed. R. Evid. 803(6), "record" includes a memorandum, report, record, or data compilation, in any form, of acts, +events, conditions, opinions, or diagnoses. The term "business" +neudes business, opinion, a socinoises, Thesim "business", a ud d in Fed. every did, (%) her the above delted tor +profit. + + +U.S. Department of Justice +United States Attorney +Southern District of New York +The Silvia J. Mello Building +One Saint Andrew's Plaza +New York. New York 10007 +August 30, 2019 +Equifax +Custodian of Records +1550 Peachtree Street, NW +Atlanta. GA 30309 +Fax: +Re: Grand Jury Subpoena: +Please be advised that the accompanying grand jury subpoena has been issued in connection with +an official criminal investigation of a suspected felony being conducted by a federal grand jury. Th +sovernment hereby requests that you voluntarily refrain from disclosing the existence of the subpoena to +any third party. While you are under no obligation to comply with our request, we are requesting you not +to make any disclosure in order to preserve the confidentiality of the investigation and because disclosure +of the existence of this investigation might interfere with and impede the investigation. +If you intend to disclose the existence of this Grand Jury Subpoena request to a third party, please +let me know before making any such disclosure. +Thank you for your cooperation in this matter. +Very truly yours, +GEOFFREY S. BERMAN +United States Attorney +By: +Assistant United States Attorney diff --git a/vision-fixhub/ds9-parsed-01/01d04ebf019cbb17f611857bdb83843b8e1345a29d15d2dfb2f7561aa7a79536.receipt.json b/vision-fixhub/ds9-parsed-01/01d04ebf019cbb17f611857bdb83843b8e1345a29d15d2dfb2f7561aa7a79536.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..a00b86aa4476b90895db6ca4e459aa6772725d8a --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/01d04ebf019cbb17f611857bdb83843b8e1345a29d15d2dfb2f7561aa7a79536.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -48, + "dataset": "marble-joined", + "doc_id": "01d04ebf019cbb17f611857bdb83843b8e1345a29d15d2dfb2f7561aa7a79536", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "296a5ee43017316b871682d50024c94d22a1717d7741ed0f98aeca39931caf7c", + "output_sha256": "bb3b76a7a1481c28272fec3e60049284b212cdd0d7db01b046e6c8714f3b9262", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/01fd1ffd2a5c624f56116ec3c2b4e37d916c6acb96931a520dc271595614a659.md b/vision-fixhub/ds9-parsed-01/01fd1ffd2a5c624f56116ec3c2b4e37d916c6acb96931a520dc271595614a659.md new file mode 100644 index 0000000000000000000000000000000000000000..03af30aeafa208f468f061ce56d37936c0d08c8f --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/01fd1ffd2a5c624f56116ec3c2b4e37d916c6acb96931a520dc271595614a659.md @@ -0,0 +1,85 @@ +Suicide Timeline re: Epstein, Jeffrey Edward, Reg. No. 73618-054 +Friday, August 9, 2019 +8:00 am inmate +1 Reg. No. +departs for +court (WAB-USMS-SDNY) . +is Epstein's cellmate. +8:30 am inmate Epstein arrives in Attorney Conference. He is +visited by several attorneys throughout the day. +6:45 pm inmate Epstein departs attorney conference and returns +7:00 pm inmate Epstein provided a social call by IDO. IDO +reports inmate Epstein was in good spirits, nothing unusual. +7:32 am PIO notified of incident by the Warden +***Inmate +is released from court and does not return to +the institution. +Saturday, August 10, 2019 +6:33 am body alarm activated in SHU. Staff found inmate Epstein +unresponsive in cell. Staff reported to bedside of inmate and +attempted to wake him. Control announced medical emergency. CPR +initiated +6:35 am medical staff (on duty PA) on site, CPR already in +progress medical staff continues CPR and AED applied +on inmate. Control called for ambulance +6:40 am +• AW notified +6:45 am EMS arrives, paramedics continue CPR. Inmate Epstein +remains unresponsive. Inmate Epstein is intubated, given three +rounds of Epinephrine, IV access started, I0 initiated. No pulse +found, no shock advised, inmate prepared for transport to local +hospital. +7:10 am EMS departs institution enroute to Beekman Hospital. +7:19 am USMS notified of incident. +7:20 am SIS It notified. +7:30 am +, Warden arrives at institution. +| AN +notified. +7:36 am official time of death reported by ER physician. +7:40 am Acting Chief Psychologist notified. +8:00 am +and Captain +arrive at institution. +8:10 am SIS It arrives at institution. +8:10 am CMC and SCSS notified. +8:34 am FBI notified. +9:00 am AUSA notified. +9:00 am +1. +arrives at institution. +9:00 am SIS It. reports to SHU. Interviews will be conducted +with inmates assigned to tier. + + +9:15 am CMC arrives at institution. +9:30 am Acting Chief Psychologist arrived to the institution. +9:50 am SCSS arrives at institution. +9:55 am CMC and IDO depart institution enroute to Beekman +Hospital. +10:00 am CMC and IDO arrive at Beekman Hospital, fingerprints +and photographs taken of inmate Epstein. Inmate +clothing secured +and brought back to institution. +10:00 am Judge Berman notified. +10:15 am CMC return to institution. +10:45 am PIO arrived to the institution. +Coordinator. +11:12 am press release is released to media. +11:15 am press release provided to Judge Berman. +11:15 am CST activated. +12:15 pm body release to Medical Examiner (ME) for autopsy +12:19 pm FBI arrives. +1:35 pm FBI arrives in Special Housing Unit. +1:40 pm OIG notified by the Warden and they will be sending an +Agent to NYM. +2:15 pm CST debrief conducted. +2:45 pm OIG arrived in Special Housing Unit (SHU). +3:45 pm OIG and FBI depart SHU. +5:05 pm OIG/FBI depart institution +9:10 pm Computer Services Manager (CSM) notified to report to +institution to remove desktop from SHU. +10:15 pm CSM arrives at institution. +11:00 pm desktop removed from SHU and secured in SIS office. OIG +will retrieve desktop tomorrow morning. +12:15 pm CSM departs institution. diff --git a/vision-fixhub/ds9-parsed-01/01fd1ffd2a5c624f56116ec3c2b4e37d916c6acb96931a520dc271595614a659.receipt.json b/vision-fixhub/ds9-parsed-01/01fd1ffd2a5c624f56116ec3c2b4e37d916c6acb96931a520dc271595614a659.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..8805a415cd62d9f8689cb7c74caf99913e6b571c --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/01fd1ffd2a5c624f56116ec3c2b4e37d916c6acb96931a520dc271595614a659.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "01fd1ffd2a5c624f56116ec3c2b4e37d916c6acb96931a520dc271595614a659", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "cbb1e9bdadbd0617fbf899d54f97b87dbe2f33dfd900c44a5814c732744d2bb5", + "output_sha256": "0c4b68e87b4153c2c462c05aa3f11539b1a676e989343cf7afa6c6b82b1dff54", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0225653fa640e6c8f2ce28ccffb9df8aa79201854e7e053324f66f1bd15e857d.md b/vision-fixhub/ds9-parsed-01/0225653fa640e6c8f2ce28ccffb9df8aa79201854e7e053324f66f1bd15e857d.md new file mode 100644 index 0000000000000000000000000000000000000000..1d1aee578eb8c8690db9794469a27ee7d8303bef --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0225653fa640e6c8f2ce28ccffb9df8aa79201854e7e053324f66f1bd15e857d.md @@ -0,0 +1,391 @@ +CWT +SatoTravel +Your Itinerary +Trip on Feb 03, 2020 +Traveler +ATTN- +DOJEZ +US +USA +ALL MCO‡S MUST BE MAILED TO. +EOUSA +Customer Number +Agent +THIS IS AN ITINERARY ONLY +AND NOT A VALID TICKET OR RECEIPT +643SR7F +SH +*TICKET PURCHASE WITH CA......0426* +Monday, February 03, 2020 +Flight AMERICAN AIRLINES 6137 +DEPARTURE +NEW YORK JFK, NY +8:15 PM, Feb 03, 2020 +Status +Class +Duration +al Senice +Notes +Locator: HEZZTD +Date: Jan 24, 2020 +Confirmation HEZZTD +ARRIVAL +LONDON HEATHROW, UNITED KINGDOM +8:10 AM, Feb 04, 2020 +Confirmed +Coach Class - K +06:55 (Non-stop) +aing777 et +DEP-TERMINAL 7 +ARR-TERMINAL 5 +*JFK-LHR OPERATED BY BRITISH AIRWAYS +ONEWORLD +CABIN-ECONOMY +Tuesday, February 04, 2020 +Confirmation LNLVLB +* Flight BRITISH AIRWAYS 778 +DEPARTURE +LONDON HEATHROW, UNITED KINGDOM +10:50 AM, Feb 04, 2020 +ARRIVAl +STOCKHOLM ARLANDA, SWEDER +2:25 PM, Feb 04, 2020 +Status +Class +Duration +Equipment +Meal Service +Notes +Confirmed +Coach Class - Y +02:35 (Non-stop) +irbus Industrie 32 +ood and Be For Purchas +DEP-TERMINAL S +ARR-TERMINAL Z +ONEWORLD +CABIN-ECONOMY +Tuesday, February 04, 2020 +Confirmation 96152174 + + +# Hotel SHERATON STOCKHOLM HOTEL +LOCATION +TEGELBACKEN 6-BOX 195 +STOCKHOLM SE 10123 +, SE +Reserved For +Status +Check-In +Check-Out +Confirmed +Feb 04, 2020 +eb 06, 2020 +Number of Rooms +Rate +Cancellation Policy +SEK 2,795.00/night +Cancel 1 day prior +Thursday, February 06, 2020 +Flight BRITISH AIRWAYS 777 +DEPARTURE +STOCKHOLM ARLANDA, SWEDEN +11:40 AM, Feb 06, 2020 +Status +Class +Duration +Equipment +Meal Service +Notes +CONTACT +Tel 46-8-4123400 +Fax 46-8-4123405 +Confirmation LNLVLB +ARRIVAL +LONDON HEATHROW, UNITED KINGDON +1:30 PM, Feb 06, 2020 +Confirmed +Coach Class - Y +02:50 (Non-stop) +Airbus Industrie 320 +Food and Bev For Purchase +DEP-TERMINAL 2 +ARR-TERMINAL 5 +ONEWORLD +CABIN-ECONOMY +Thursday, February 06, 2020 +Flight AMERICAN AIRLINES 6134 +DEPARTURE +LONDON HEATHROW, UNITED KINGDOM +4:20 PM, Feb 06, 2020 +Status +Class +Duration +Equipment +Meal Service +Notes +Confirmation HEZZTD +ARRIVAL +NEW YORK JFK, NY +7:30 PM, Feb 06, 2020 +Confirmed +Coach Class - N +08:10 (Non-stop) +Boeing 747 +Meal +DEP-TERMINAL 5 +ARR-TERMINAL 7 +*LHR-JFK OPERATED BY BRITISH AIRWAYS +ONEWORLD +CABIN-ECONOMY +Name +Invoice / Ticket / Date +Tax 1 +Tax 2 +Tax 3 +Base +USD 587.00 +USD 1,074.00 +Total Amount +Total +937.35 +1,137.20 +2,074.55 +Form of Payment: +GENERAL INFORMATION +****************************************************** +*******TO BOOK RESERVATIONS ONLINE PLEASE VISIT******* +********************WOD 13^10151M***************** +INTERNATIONAL RESERVATIONS REQUIRE CHECK-IN AT LEAST +2 HOURS PRIOR TO DEPARTURE AND RE-CONFIRMATION WITH +THE AIRLINES AT LEAST 72 HOURS BEFORE YOUR SCHEDULED + + +U.S. DEPARTMENT OF STATE +This certificate is awarded to +in recognition of successful completion of +High Threat Security Overseas Seminar +(HTSOS) +on +September 3, 2019 +POC DEALS Team + + +Questionnaire for Official Foreign Travel +United States Attorneys' Offices and the Executive Office for United States Attorneys +Last Revised: April 28, 2016 +A separate questionnaire is required for each EOUSA/USAO employee who is traveling. +Part I. Traveler Information and Scope of Travel +Full Name +Office (e.g.., EOUSA, USAO-ALN, etc.) +USAO-SDNY +E-mail Address +Position Title +AUSA +Telephone Number +Departure Date (from Home or Office) +02/03/2020 +Country of Birth +Foreign Locations +Destination 1 +City +Stockholm +Departure Address (City and State) +New York, New York +Return Date (to Home or Office) +02/06/2020 +Place of Birth +Province (if applicable) +Country +Sweden +Destination 2 +Destination 3 +Destination 4 +Q1: Are you traveling to more than four destinations? If yes, +attach an additional sheet listing the additional destinations. +Q2: Have you completed your travel reservations? If yes, please +attach a detailed flight itinerary, your lodging information, and +any other transportation reservations. If no, please STOP and +make your travel reservations before proceeding. +Q3: Have you already obtained OIA's approval? If yes, please +attach OIA's approval e-mail. If you are traveling for civil +purposes, you do not need OIA's approval to travel. For others, +submit a completed questionnaire to OIA to obtain approval. +Q4: Do you have an official passport that is valid for at least six +months from the date you will arrive in the foreign country? +Q5: Have you submitted a request for an official passport to +EOUSA and is the request currently pending? +Q6: Has the Department of State granted you a waiver of the +requirement for an official passport? If yes, please attach the +State Department's e-mail granting a waiver. +YES +YES +YES +YES +YES +YES + + +Q7: Do any of your destinations require a visa for travel under +an official passport? If applicable, submit the required materials +YES +to EOUSA to obtain visas prior to departure. +Q8: For the passport under which you will be traveling, please provide the following data: +Passport Type (e.g.. +Tourist, Official) +Passport Issuing +Country +Passport Number +(note pending, if +applicable) +Passport Expiration +Date (note pending, if +applicable) +Official +USA +Q9: Are you traveling to a high-threat area? +Q10: Have you completed HTSOS training in the last five +years? If yes, please attach the training certificate if you are +traveling to a high-threat area. +Q11: Have you completed FACT training in the last five years? +If yes, please attach the training certificate, if you are traveling +to a high-threat area. +Q12: What is your security clearance level? If you have access +to TS-SCI, you must complete a DOJ-504 and provide it to your +DOSM and receive a security briefing prior to departure. +Q13: Do you plan to take any government-furnished equipment +(including "bring your own device" equipment) out of U.S. +territory? If yes, submit a request to your IT Systems Manager. +Q14: Will any travel expenses be paid for, or reimbursed, by a +source external to the EOUSA/USAO community? If yes, seek +advance approval from GCO or RMP, as necessary. +Q15: Do your travel arrangements include actual lodging +expenses (i.e., lodging expenses in excess of OCONUS rates)? +YES +YES +YES +Secret +• TS-SCI +YES +YES +YES +Q16: Do your travel arrangements include premium class travel +(e.g., travel accommodations above coach class)? +Q17: Have you already received country clearance from the +State Department through the eCC system? If yes, please attach +the eCC notification that provides country clearance. +Q18: EOUSA requests eCC country clearance for nearly all +EOUSA and USAO travelers. The clearance is required prior to +departure. Shall EOUSA request eCC clearance for you? +Q19: If you do not have eCC authorization to travel, and you +do not want EOUSA to request eCC clearance for you, what +office is requesting eCC clearance on your behalf? Note that +federal investigative agencies are not authorized to obtain eCC +clearance on behalf of EOUSA or USAO attorneys. +YES +YES +YES +) Top Secret +Other + + +Part II. General Questions Applicable to All Foreign Travel +Q20: Who is paying for the travel? +USAO-SDNY +Q21: If foreign embassy personnel or consular or diplomatic officials have been consulted +regarding travel, please provide their names, titles, organizations and contact information. +N/A +Q22: If U.S. Embassy or consular personnel have been involved, please provide their names, +titles, section, and contact information. +N/A +Q23: If assistance from U.S. Embassy or consular personnel is required (e.g., a consular official +to administer an oath) or if office space at an Embassy or consulate is required, please specify. Il +the Embassy is coordinating lodging, please include your credit card information +N/A +Q24: If the assistance of a stenographer, court reporter, interpreter, or other service provider is +required in the foreign country, please provide specific details about when and where services +are required. EOUSA will relay the request to the State Department in the eCC system. +N/A +Q25: Please include any other comments or details that would help the Department of State +ensure that difficulties do not arise. +N/A +Q26: 1 am traveling... +Abroad to Attend a Conference or Training Event (Complete Part III) +• To a Country Other Than Canada on a Judicial Assistance Matter (Complete Part IV) +• To Canada on a Judicial Assistance Matter (Complete Part V) + + +Part III. Additional Questions for Conferences and Training Events +Q27: What is the name of the conference event or training program? +Q28: What is the purpose of the conference event or training program? +Q29: What is the specific venue name and address for the conference event or training program? +Q30: Who are the primary points of contact for the conference event or training program? Please +include contact information (e.g., organizations, telephone numbers, and email addresses). +Part IV. Additional Questions for Travel to Countries Other Than Canada on Judicial +Assistance Matters +intend to travel, as well as service providers who will be traveling with you (if applicable). +AUSA +AUSA +AUSA +FBI SA +NYPD Det. +Q32: Please provide the case name, USAO number, and court docket number. +In re Jeffrey Epstein, USAO # 2018R01618 +Q33: What is the nature of the case (explain briefly in lay terms)? In what stage is the case? +How sensitive is the case in your estimation? +Investigation is ongoing and very sensitive. + + +Q34: What is the purpose of travel? In particular, specify what will be accomplished during +travel (e.g., interviewing witnesses, taking depositions, etc.). +Interviewing and debriefing a witness. +Q35: Please list the names and nationalities of persons to be interviewed or deposed, including +addresses and telephone numbers if available. +Jane Doe, Swedish +Q36: Is the prosecution of a foreign national foreseen? If so, provide name and nationality. +A subject of the investigation is Ghislaine Maxwell, who is believed to be a citizen of the United States, the United +Kingdom, and France. +Q37: Is a host country government official to be deposed or interviewed? Please provide name, +title, and whether the person has been contacted and has agreed to participate. +No. +Q38: Have foreign authorities (e.g., INTERPOL, foreign police) cleared the visit and are foreign +authorities prepared to cooperate? Please explain in detail and reference the names, titles, and +telephone numbers of the foreign contacts. +Yes. + + +Part V. Additional Questions for Travel to Canada on Judicial Assistance Matters +Q39: Please provide the names, titles, offices, districts, telephone numbers, and email addresses +of the individuals traveling abroad with you for purposes of conducting investigations. +interviews, depositions, inspections, etc. Include all federal, state or local U.S. officials who +intend to travel, as well as service providers who will be traveling with you (if applicable). +Q40: Please provide the case name, USAO number, and court docket number. +Q41: Briefly explain the background of the case (including the nature of the case, stage of the +case, special sensitivities associated with the case, and how much money is involved). +Q42: What is the purpose of travel? In particular, specity what will be accomplished during +travel (e.g., interviewing witnesses, taking depositions, etc.). Include the dates and times of the +interviewing, investigating or other activities. Why is travel to Canada necessary? + + +Q43: Names of persons to be interviewed or deposed, including dates of birth, nationality and +citizenship, phone numbers, and home or business address for each witness and any other +pertinent information that may assist in locating them. If this information is unavailable, +DFAIT will not grant clearance. +Q44: Provide confirmation that the interviews or depositions are voluntary and provide the +contact information for the persons who have contacted the witnesses/suspects (e.g., Royal +Canadian Mounted Police). +Q45: Provide the name and contact information for any legal representative(s) who may take part +in the proceedings, as well as that of their firm/organization. +Q46: If the prosecution of a foreign national is foreseen, please provide name and nationality. +Q47: If a Canadian government official is to be deposed or interviewed, provide name, title, and +whether the person has been contacted and has agreed to participate. +Q48: If INTERPOL, Canadian law enforcement, or another Canadian authority has cleared the +visit or if Canadian authorities are otherwise prepared to cooperate, explain in detail including +names, titles, and telephone numbers of the Canadian contacts). +The completed questionnaire and attachments (e.g., itinerary, training certificate), should be: +• Emailed to OIA to obtain OIA's approval for foreign travel (unless OTA approval has already been +obtained or unless travel is for civil purposes only) +• Emailed to EOUSA (using the USAEO-Foreign Travel Mailbox) +Included as an attachment to the foreign travel authorization in E2 Solution +f you have any questions about foreign travel, please contact the EOUSA RMP Travel Unit by emailing USAEO +Foreign Travel or by calling \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/0225653fa640e6c8f2ce28ccffb9df8aa79201854e7e053324f66f1bd15e857d.receipt.json b/vision-fixhub/ds9-parsed-01/0225653fa640e6c8f2ce28ccffb9df8aa79201854e7e053324f66f1bd15e857d.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..6cf3d35fa0ad9ab06c7067d0407f108191da71b9 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0225653fa640e6c8f2ce28ccffb9df8aa79201854e7e053324f66f1bd15e857d.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -169, + "dataset": "marble-joined", + "doc_id": "0225653fa640e6c8f2ce28ccffb9df8aa79201854e7e053324f66f1bd15e857d", + "engine": "marble-apple-vision", + "event_count": 11, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "893a55e718bb22cc1162eb3052141a930f2282e0b6c0f790c5a8301fdaafd9a8", + "output_sha256": "4bfc3876383f8dea01deb4611ecb004f6a2d42334e160c62ebc0450fe0177968", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/023a8c2910efbabb1ef158735960bb83b9ede0d4e2fa0c5fbd8918fdc69d102b.md b/vision-fixhub/ds9-parsed-01/023a8c2910efbabb1ef158735960bb83b9ede0d4e2fa0c5fbd8918fdc69d102b.md new file mode 100644 index 0000000000000000000000000000000000000000..4e97e0e60d92f126ee9683b4e94242de3b5c6aeb --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/023a8c2910efbabb1ef158735960bb83b9ede0d4e2fa0c5fbd8918fdc69d102b.md @@ -0,0 +1,15 @@ +From: +To: +Subject: +Date: +.. (OIG) +[EXTERNAL] FW: JE 1 +Wednesday, September 22, 2021 2:24:46 PM +From: | +[mailto: +Sent: Wednesday, September 22, 2021 1:48 PM +To: 'STACEY RICHMAN' < +P: +Subject: JE 1 +Photos show electric cord on Outside and inside of door. It was handled. +Top bunk show no one jumped off of bunk. Items on bunk would have been disturbed. diff --git a/vision-fixhub/ds9-parsed-01/023a8c2910efbabb1ef158735960bb83b9ede0d4e2fa0c5fbd8918fdc69d102b.receipt.json b/vision-fixhub/ds9-parsed-01/023a8c2910efbabb1ef158735960bb83b9ede0d4e2fa0c5fbd8918fdc69d102b.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..6929643e489a6872aa292bcf54d1b459004ec528 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/023a8c2910efbabb1ef158735960bb83b9ede0d4e2fa0c5fbd8918fdc69d102b.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "023a8c2910efbabb1ef158735960bb83b9ede0d4e2fa0c5fbd8918fdc69d102b", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "63c49486cc8e849c4979f3f9ae76a54afeed69cc4172dac5c561182624bdf088", + "output_sha256": "91f86345aa83d9435ccb4e3d3d4a2fbbee147c9e58a2efbf871d19d18b638214", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/024e618fbebabeeacca0e1ceebdb82a69f8f95f162b078823be8545f16aac223.md b/vision-fixhub/ds9-parsed-01/024e618fbebabeeacca0e1ceebdb82a69f8f95f162b078823be8545f16aac223.md new file mode 100644 index 0000000000000000000000000000000000000000..5b216ed1fce924fca03b695c0dac75737a9a21f3 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/024e618fbebabeeacca0e1ceebdb82a69f8f95f162b078823be8545f16aac223.md @@ -0,0 +1,100 @@ +1 0f4 +INMATE +RD. Мн, кт +8/19/19 +- got to SHU ~ 7122 - went to L-tier first few days, +ten o tier, then He-tier +- was in fat el on the right in L-tier-alone in cell. +- at re he band to a man angre +nas going to pay him +shenevent ere ted du first one to the right next to +there 9-10 days +- then to th-tier. +sack mojica-latuking, +cel 107, second on right -IN= +- moved from L-tier bc It. +lid they need that cel +ale box is so full so moved to o-tier which is obsenata +bald, short, fat and one co moved win. +they come avond is 6:30 breakfast. tave clock on radio. +sloan toast thettor flights at 930 count. if they +canse guards perfectly fam ter all on the right +- heard from othertamates at SHU -guards dont do anything guards +dant to count, leave the unit for hours at atome, +to stop kz +cout do austens +SDNY_00007765 + + + +20F4 +frot cel onight +repeated it to unit - echoes in there +said y'all heard that-he's on the gate at all times +une what officer said +She said to male officer but d/n thank +meant to pe overheard +- Junk there's afternoon count not aware or any ofer counts +unna maht - +4:30 Weakfast ef a yere dang count between +ever hears +after his death thay're tong an the counts; theyre astrally +omg theyno jobs: +outs. oster stands as gate, the other walks unit and bangs to +lake sure they more. Then they switch. Always two officers. +remale who got fine was lazy. When you ask for paper/en velope +one she not ignores yor. She winit de it. +he cuosint oven ice to ome orm wre to do count- M +attitude-she slums annoyer +"("(hispanic); +Tazy but vies jub), +try to catch people smoking fisking-d/udo 30-mn +ands disas day. +usually work at night. +SDNY_00007766 +EFTA_00000890> + + +30f4 +haduit seen until Epstandied +- morning he was tond - sounded like female voice yelled +"Oh shit oh tick" i then heard whunguy feus, called +for backup- people start yelling "He's dead, they ticked p +saying its all temale officer s tault. mumates were +- Kept caling out when agents were there that I guard farit +- MCC compared to other jails- +- +told +that he was beat upt out in hen pop +and guards nevent on whit people smoking out in gen +- officers here seemto be too comfrtable w/ mater +- seems like offers dont cave+ desit do jols +is known tor beating peode up -call nim dirty lt. +nas a case on them bic +broke his boat +"miss Black" has rex wichmate in her house +-Arabic counselor-heard she was haung sex w/ mmate +-te they states gerything right +womy 30 win rounds. +=-semont+Ltier-when people said i'm hauna suicidal +- thoughts -quards torothy but that changed after it died. +→- everyone knew sEwanted to kill himself on sHura + + +of4 +- Wandthat re runted to the and offered his bunkie it to +in um. when we had marks on neck, +he did it. → Weand hom guys of t the demed that +- Hin heard that "Viller cop" on sth +- does not happen that get legal calls in SHI. Dont get stamps. +meats at mee - +- on H-ter-other Bloods said (moved to v-ter bur in +nt we catch you we +hat +- peopen o tier can ven to nter +- happened a week age +- "b" said its cary simebody has to pass away to +make someone do their job +- guards have come done Call clamp-food is better, enough +SDNY_00007768 + diff --git a/vision-fixhub/ds9-parsed-01/024e618fbebabeeacca0e1ceebdb82a69f8f95f162b078823be8545f16aac223.receipt.json b/vision-fixhub/ds9-parsed-01/024e618fbebabeeacca0e1ceebdb82a69f8f95f162b078823be8545f16aac223.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..5c7916b5f137d798ac855333220738db16a9d6f8 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/024e618fbebabeeacca0e1ceebdb82a69f8f95f162b078823be8545f16aac223.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -74, + "dataset": "marble-joined", + "doc_id": "024e618fbebabeeacca0e1ceebdb82a69f8f95f162b078823be8545f16aac223", + "engine": "marble-apple-vision", + "event_count": 6, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "73b9e95c4f50ca3ff811e07a8f3d6ec93cd4f14c2ebb68082ef36c0c631c7676", + "output_sha256": "431c37c261be587ada545de7f984fe42b9c8ae86ef20349ccf2742d353524324", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0262f8b6405d70e6e7ce99c0333088a06556c23790367e1d4bd66be3b66605d7.md b/vision-fixhub/ds9-parsed-01/0262f8b6405d70e6e7ce99c0333088a06556c23790367e1d4bd66be3b66605d7.md new file mode 100644 index 0000000000000000000000000000000000000000..0e13e8ff419a631c5813961947a5398c713a2047 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0262f8b6405d70e6e7ce99c0333088a06556c23790367e1d4bd66be3b66605d7.md @@ -0,0 +1,14 @@ +From: +To: +Subject: +Date: +Mark Epstein +[EXTERNAL] FW: JE5 +Wednesday, September 22, 2021 8:31:51 PM +From: Mark Epstein +Sent: Wednesday, September 22, 2021 2:01 PM +To: 'STACEY RICHMAN' ‹ +Subject: JE5 +Blood vessel in eye like a strangulation +Bruises to mouth +Bruise to back of neck diff --git a/vision-fixhub/ds9-parsed-01/0262f8b6405d70e6e7ce99c0333088a06556c23790367e1d4bd66be3b66605d7.receipt.json b/vision-fixhub/ds9-parsed-01/0262f8b6405d70e6e7ce99c0333088a06556c23790367e1d4bd66be3b66605d7.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..0ae9d00d2ff9e8529c836d729365e3a30032bfd9 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0262f8b6405d70e6e7ce99c0333088a06556c23790367e1d4bd66be3b66605d7.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "0262f8b6405d70e6e7ce99c0333088a06556c23790367e1d4bd66be3b66605d7", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "3417ef114fc7a0472aec906e68a79430e7f2ae1d644b06bce7f8e9911c6ce3cd", + "output_sha256": "03f825d703c20b6c38e70c05ee5571478cd8ba0a3241727311dd7d3a1aed6a60", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/027871741f850e97f55eaaf02599bd2a0672d820de7ec64fff57a41e438b5f4c.md b/vision-fixhub/ds9-parsed-01/027871741f850e97f55eaaf02599bd2a0672d820de7ec64fff57a41e438b5f4c.md new file mode 100644 index 0000000000000000000000000000000000000000..c8cd647a41177a7fd22b898b9b253f1fcd6f9b86 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/027871741f850e97f55eaaf02599bd2a0672d820de7ec64fff57a41e438b5f4c.md @@ -0,0 +1,83 @@ +FD-302 (Rev. 5-x-10) +- 1 of 2- +FEDERAL BUREAU OF INVESTIGATION +OFFICIAL RECORD +Date of entry +03/31/2020 +STEVE SCULLY, date of birth +was interviewed at the Federal +Bureau of Investigation St. Thomas | +Resident Agency in the Virgin Islands by +Detective +and Special Agent +After being advised of +the identities of the interviewing Agents ano +the nature of the interview, +SCULLY was shown a photobook containing +85 +persons associated with this +investigation. +SCULLY recognized the following persons by making these +statements while viewing each individual page: +Page 2: looks like an older version of one of the girls on the wall +Page 5: Looks like GHISLAINE MAXWELL +Page 9: looks like a girl I saw on the island / dock with other girls +Page 18: Looks like a younger MILES ALEXANDER +Page 30: She 1ooks older in picture, I think she was there on the island +Page 52: I think she was on the island +Page 62: I think she was in a picture on the island, a topless photo, I +think one of the girls might have been in picture with +Page 67: Kind of what girl looked like, brunette on boat when he took me +back to St. Thomas +Page 34: Think one of the pictures in his bedroom, maybe a topless at least +Page 76: Looks familiar +Page 12: Looks like a guy that had an apartment below MILES cottage which +meant he would have been an employee and only employees stay in that +Investigation on 08/13/2019 +St. Thomas, Virgin Islands, United States (In Person) +File # 50D-NY-3027571 +Date drafted 03/24/2020 +by +This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your agency; it and its contents are not +to be distributed outside your agency. + + +FD-302a (Rev. 5-8-10) +50D-NY-3027571 +Continuation of FD-302 of (U) Interview of STEVE SCULLY +On 08/13/2019 +, Page 2 of 2 +apartment. +Page 22: Just looks like a guy that stayed in the guest room, don't know if +that is him +SCULLY then makes the following statements: +SCULLY states that EPSTEIN had a type. He liked blonde girls. He didn't +seem to like Asian girls. +He had a bed in his office. +EPSTEIN had workers rebuild his cabana completely because they did not +use stainless steel screws. He thinks this was post 9/11. +On one occasion SCULLY arrived on the island and there were five girls on +the dock. SCULLY was told they were all Victoria's Secret models. +BOSCOE told SCULLY that +only saw +did special projects for EPSTEIN. SCULLY +on the island one time and BOSCOE told him her name. +SCULLY has seen ALAN DERSHOWITZ and ANDREW (his bodyguard) in the kitchen +at one point. +SCULLY went up to the kitchen while talking with MILES and +in. He said, "not right now +I gotta deal with this". +walked +The news showed SCULLY a picture of +immediately. It was an older version of her. +wall there was a young picture of +•. She had +i he recognized her +He recalled on the office +BOSCOE told SCULLY that she was +There was another picture in the bedroom +bedroom but they were both clothed. +and EPSTEIN in the +The blue and white building was not there when SCULLY was there. +The checks came from out of the New York office. They were sent to the +American Yacht Harbor office. diff --git a/vision-fixhub/ds9-parsed-01/027871741f850e97f55eaaf02599bd2a0672d820de7ec64fff57a41e438b5f4c.receipt.json b/vision-fixhub/ds9-parsed-01/027871741f850e97f55eaaf02599bd2a0672d820de7ec64fff57a41e438b5f4c.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..aa5cb1e823dadef071ec319c220e76c0637dec57 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/027871741f850e97f55eaaf02599bd2a0672d820de7ec64fff57a41e438b5f4c.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "027871741f850e97f55eaaf02599bd2a0672d820de7ec64fff57a41e438b5f4c", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "16ed262b9281f167f6a3b272067cd2723224478978c4956ef3d9d92e106917db", + "output_sha256": "9bf7318dba6aff6ebf35a0549043d7b0dab1637e17d0a18e2967d0dd2f2e8d62", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/027f424e50203a7dea479399683c7afad5d0b7337241a04a493c42e72dd7223f.md b/vision-fixhub/ds9-parsed-01/027f424e50203a7dea479399683c7afad5d0b7337241a04a493c42e72dd7223f.md new file mode 100644 index 0000000000000000000000000000000000000000..02bea4f0ed15064b6bd29bb6b80a0b3186c38b0f --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/027f424e50203a7dea479399683c7afad5d0b7337241a04a493c42e72dd7223f.md @@ -0,0 +1,154 @@ +From: +To: +Subject: FW: Reference materials further to our call +Date: Tue, 01 Sep 2020 17:35:30 +0000 +Inline-Images: image001 jpg; image002.jpg +Our response (for now) below. +From: +Sent: Tuesday, September 1, 20201535 PM +To: Gary Bloxsome & +¡ Daniel Cundy 1 +Cc: +(USANYS) +Subject: RE: Reference materials further to our call +Gary, +We have received the below communication, and we will revert back as appropriate. +thank you, +*; Jennifer Richardson +Assistant U.S. Attorney +Southern District of New York +From: Gary Bloxsome & +Sent: Tuesday, September 01, 2020 13:04 +To: +Cundy +P; Daniel ++; Jennifer Richardson +Subject: Re: Reference materials further to our call +Dear +We have found our recent conferences with you and your team (on 27 July, 3, 11 and 20 August 2020) helpful and +informative and again I extend my thanks for your taking the time to discuss these matters at length. +In the UK the provision of a signed witness statement - bearing a statement attesting as to its truth - is a commonly used +approach when a witness provides evidence. Whilst we appreciate that such an approach differs from what is standard in +the US, we do not consider such an approach would be unhelpful, or of no utility, to your case. Our client is willing to +provide you with a witness statement, addressing any issues that he may be able to, in relation to Ghislaine Maxwell and +Jeffrey Epstein, his association with them and his knowledge of them such as may be relevant to the prosecution of +Ghislaine Maxwell. In addition - should you make written requests for clarification arising from that witness statement - +our client could provide written answers by way of a supplementary/addendum statement. Such an interaction could take +place more than once if necessary. Providing written answers to either written questions or to questions previously put, is +again a common practice in the UK. + + +You have invited us to identify any areas or subject topics which we would consider to be inappropriate or irrelevant to be +put to our client; we consider that questions put/topics raised should rightfully be limited to the indictment period in the +current proceedings (i.e. US v Ghislaine Maxwell), being 1994-1997. +We are of course aware that you have requested a witness interview in your request to the UKCA and to ourselves; you +have confirmed to us however (in January this year, through your liaison officer immediately prior to our recent +conferences, and then during our conferences) that you regard our client not as a witness but as a subject. We have +ventilated at some length our concerns regarding our client being interviewed in those circumstances and we consider a +witness statement and the offer of further engagement with written questioning to be a fair compromise and one which +would be acceptable in the UK. +To move forward with the above approach, we would continue to require your assurance that the content of any such +witness statement and supplementary written responses be treated with the utmost confidentiality, not used for any +purpose other than in relation to the criminal proceedings against Ms Maxwell, and not be shared with any parties +outside of your department, including complainants and their representatives in your investigation and in civil matters +outside of it. +Kind regards +Gary +Gary Bloxsome | Partner +Blackfords LLP | 15 Old Bailey | London | EC4M 7EF +DX 161400 Old Bailey 5 | 020 3427 3343 | www.blackfords.com +RANKED IN +Chambers +UK +•+2020+ +Leading Firm +500 +UNITED KINSPOR +TOP TIER +2020 +COVID-19 - Please see our website here for our updated position in relation to Coronavirus. +In the meantime if you need to speak to one of our lawyers, please leave a voicemail by dialling 020 +8686 6232 where we will respond to the messages in the order they are received or by emailing your +enquiry to covid@blackfords.com +Blackfords LLP is a limited liability partnership registered in England & Wales with registered number OC325398 at Hill House, 1 Mint Walk, +Croydon, CRO 1EA. A list of members' names is available at this address. +GDPR: details of how we handle personal data can be found in our Privacy Statement +Authorised and regulated by the Solicitors Regulation Authority under number 462078. +On 19 Aug 2020, at 18:19, +wrote: +External email: is it safe to open attachments and links? +Received, thank you. We'll speak with you then. + + +From: Gary Bloxsome +Sent: Wednesday, August 19, 2020 12:39 +To +Cc: +Richardson +¡ Daniel Cundy +Subject: Re: Reference materials further to our call +Yes +Same dial in details as before. +Regards +P; Jennifer +Gary Bloxsome | Partner +== +Blackfords LLP T 15 Old Bailey | London T EC4M 7EF +DX 161400 Old Bailey 5 | 020 3427 3343 | www.blackfords.com +COVID-19 - Please see our website here for our updated position in relation to Coronavirus. +In the meantime if you need to speak to one of our lawyers, please leave a voicemail by dialling 020 +8686 6232 where we will respond to the messages in the order they are received or by emailing your +enquiry to covid@blackfords.com +Blackfords LLP is a limited liability partnership registered in England & Wales with registered number OC325398 at Hill House, 1 Mint Walk, +Croydon, CRO 1EA. A list of members' names is available at this address. +GDPR: details of how we handle personal data can be found in our Privacy Statement +Authorised and regulated by the Solicitors Regulation Authority under number 462078. +On 19 Aug 2020, at 17:36, +wrote: +External email: is it safe to open attachments and links? +Gary, +Are we still planning to speak via phone tomorrow at 2:30 London time? +Regards, +From: Daniel Cundy 4 +Sent: Sunday, August 09, 2020 12:30 +Tol +P; +* Jennifer Richardson +Subject: Reference materials further to our call +Dear +>; Gary Bloxsome + + +Apologies for the slight delay. +Please find attached an extract from The Decision Procedure and Penalties manual (DEPP 7) from the Financial +Conduct Authority handbook - drawing attention to 7.2.14. This practice and approach resonates with the law as set +out in United States v. Allen, 864 F.3d (2d Cir.2017). We also attach an extract from the publication 'Montgomery and +Ormerod on Fraud: Criminal Law and Procedure' (2008) which summarises the approach taken by the Serious Fraud +Office (see A7-327) to the limitations and protections on use when their compulsory powers are used in MLAT +requests, an approach which reflects such cases as Kastigar v. United States, 406 U.S. 441 (1972) as well as decisions in +UK domestic law. We reiterate the protection at Article 7(2) of the MLAT treaty although there is no need to attach it. +Kind regards +Daniel Cundy | Partner +=- +Blackfords LLP | 15 Old Bailey | London | EC4M 7EF +DX 161400 Old Bailey 5 | 020 3427 3343 | www.blackfords.com +COVID-19 - Please see our website here for our updated position in relation to Coronavirus. +In the meantime if you need to speak to one of our lawyers, please leave a voicemail by dialling 020 +8686 6232 where we will respond to the messages in the order they are received or by emailing your +enquiry to covid@blackfords.com +Blackfords LLP is a limited liability partnership registered in England & Wales with registered number OC325398 at Hill House, 1 Mint Walk, +Croydon, CRO 1EA. A list of members' names is available at this address. +GDPR: details of how we handle personal data can be found in our Privacy Statement +Authorised and regulated by the Solicitors Regulation Authority under number 462078. +Daniel Cundy Partner +-- +Blackfords LLP T 15 Old Bailey | London ГЕC4М 7EF +DX 161400 Old Bailey 5 | 020 3427 3343 | www.blackfords.com +COVID-19 - Please see our website here for our updated position in relation to Coronavirus. +In the meantime if you need to speak to one of our lawyers, please leave a voicemail by dialling 020 +8686 6232 where we will respond to the messages in the order they are received or by emailing your +enquiry to covid@blackfords.com +Blackfords LLP is a limited liability partnership registered in England & Wales with registered number OC325398 at Hill House, 1 Mint Walk, +Croydon, CRO 1EA. A list of members' names is available at this address. +GDPR: details of how we handle personal data can be found in our Privacy Statement +Authorised and regulated by the Solicitors Regulation Authority under number 462078. diff --git a/vision-fixhub/ds9-parsed-01/027f424e50203a7dea479399683c7afad5d0b7337241a04a493c42e72dd7223f.receipt.json b/vision-fixhub/ds9-parsed-01/027f424e50203a7dea479399683c7afad5d0b7337241a04a493c42e72dd7223f.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..a5030bd8a135cc7bac30e6653b966a93c9ae07cd --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/027f424e50203a7dea479399683c7afad5d0b7337241a04a493c42e72dd7223f.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -48, + "dataset": "marble-joined", + "doc_id": "027f424e50203a7dea479399683c7afad5d0b7337241a04a493c42e72dd7223f", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "6ca253dc6ce41bcf6f8da0f4ac219e48e58bf99e37bf1deffbe1ae1c29e435ef", + "output_sha256": "bebcff809b3ccc244c9cf95a57531789659432dd20c100e1d0bcc9dfe2c65d0d", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/028713640e4e8c23c530a7af99f112a42ab40b76117b68e309dca22b774b6be3.md b/vision-fixhub/ds9-parsed-01/028713640e4e8c23c530a7af99f112a42ab40b76117b68e309dca22b774b6be3.md new file mode 100644 index 0000000000000000000000000000000000000000..eac8f52938c18f48adf95fa2d894f4dadf53b77e --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/028713640e4e8c23c530a7af99f112a42ab40b76117b68e309dca22b774b6be3.md @@ -0,0 +1,40 @@ +From: " +To: " +Subject: Re: grapes +Date: Wed, 24 Jul 2019 12:12:15 + 0000 +Importance: Normal +Attachments: TEXT.htm +D is so ridiculous lol. that's her job. that's why M asks whoever saw the person for the SRA or whatever to do the disciplinary +report. it seems like the reason he needs the report is because he received an incident report while on SW, or went to SW +right after. we always do them in those cases, even for people who are not high care levels or forensics. the issue is a matter +of the reported suicidality, all she needs to do is write what he said about the incident, and her opinion about it. if he shows +no signs of memory loss or cause for concern, he's competent. she's not making a judgment on whether he's guilty of the +infraction. she's just stating whether he's in his right mind to go through the process. isn't this part of her job as a +psychologist lol?? or, if she really feels like she doesn't know, then that's what she should say in the report. i feel like we just +enable her to skirt around her job and her clinical responsibilities, and i guess we're not going to change her at this point in +her career, but it's really a shame that it's gotten this far, and yes, totally ridiculous for M to even involve you. poor leadership, +again... +>>> +7/24/2019 8:05 AM >>> +not even just the ineffectiveness of not sending the e-mail herself, but she's obvi avoiding delegating this to +b/c she's +scared to tell her. +just declined to do it. saying she doesn't know if he was competent b/c he claims he doesn't recall the +incident. she said she will get torn up on the stand and lose her license if called in to testify about her SRA from yesterday +and a disciplinary report. so +then told me again to do it. anyway, looks like he would need it b/c he's not a CC3 or a +study so +said she just replied to It. +saying he's competent and that should be sufficient. smart move of K2 +>>> +7/24/2019 8:00 AM >>> +yeah, she does stuff like that all the time. it's so annoying. i just ignore her. she doesn't seem to get how inefficient it is to +send an email to someone to tell them to send an email to someone else lol. makes no sense. even K2 has noticed it, and +told me how M always sends her all these unnecessary emails, and how she has started to try to email her first, letting her +know she already received things or already knows things, so that M doesn't have to tell her again or forward her emails she +already has lol +>>> +7/24/2019 7:57 AM > > > +look what i just sent you about epstein - why does +tell me to send it to +? shouldn't this be her job as boss? diff --git a/vision-fixhub/ds9-parsed-01/028713640e4e8c23c530a7af99f112a42ab40b76117b68e309dca22b774b6be3.receipt.json b/vision-fixhub/ds9-parsed-01/028713640e4e8c23c530a7af99f112a42ab40b76117b68e309dca22b774b6be3.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..93bf1198f4328b0baecff6428d6e910613e18a42 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/028713640e4e8c23c530a7af99f112a42ab40b76117b68e309dca22b774b6be3.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "028713640e4e8c23c530a7af99f112a42ab40b76117b68e309dca22b774b6be3", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "3155a60602eca52ccca23afa1e25208ab7df1e9527df1edcf173ae4dc9282660", + "output_sha256": "f47bf5d6c08805ec42b6e24362361dfe4bf8e5b58f0f52b97bb3cbacc352cb93", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/02a556b2cb15d00ce6cbb65e5042127f8b804ee7c36d58439fac82fdfa03a2f5.md b/vision-fixhub/ds9-parsed-01/02a556b2cb15d00ce6cbb65e5042127f8b804ee7c36d58439fac82fdfa03a2f5.md new file mode 100644 index 0000000000000000000000000000000000000000..ab7848106178ba5dce5f0c8ea3eec3c94dcd449a --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/02a556b2cb15d00ce6cbb65e5042127f8b804ee7c36d58439fac82fdfa03a2f5.md @@ -0,0 +1,506 @@ +MC Truste +Truste +MUNICIPAL CREDIT UNION Growing +PO. BOX 3205, NEW YORK, NY 10007-3206 +212) 693-4900 OR (8001 323-6713 560-65345 ++ 0956847 000056462 OMCUOA 0630100 +MANHASSET NY 11030-3331 +Your Account Summary +Deposits +Primary Share +Checking +TOTAL DEPOSITS +$ +$ +$ +Loans +TOTAL LOANS +$ +Balance +5.50 +2,141.1' +2,146.6 +Balance +0.00 +PRIMARY SHARE +Transaction +Jan 01 +Previous Balance +Jan 25 +Deposit - ATM FEE REFUND +Jan 25 +ATM FEE REFUND +Jan 31 +New Balance +Totals For This Period: +Account Number: +Statement Period: +01/01/19 - 01/31/19 + +MCU News & Promotions +Because Time +is Money +Consolidate your bills with an +MCU Personal Loan +Apply today at nymcu.org/personal +Stron! +uh Trustai +Masooraora Growing +Monitor balances, +transactions and +account activity +through +NYMCU® +Online Banking. +Login and +select alerts. +° 0. +Sign up for +Account +Alerts +)) +Withdrawals +0.00 +Deposits +5.50 +5.50 +S 01 +Balance +0.00 +5.50 +5.50 +www.nymcu.org + + +Jan 01 +Jan 01 +Jan 01 +Jan 01 +Jan 02 +Jan 02 +Jan 02 +Jan 02 +Jan 02 +Jan 02 +Jan 03 +Jan 03 +Jan 04 +Jan 04 +Jan 05 +Jan 06 +Jan 06 +Jan 06 +Jan 07 +Jan 07 +Jan 07 +Jan 07 +Jan 08 +Jan 08 +Jan 09 +Jan 10 +Jan 10 +Transaction +Previous Balance +Withdrawal - 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VISA - Visa Purchase +01/23 DUNKIN #304361 Q35 BROOKLYN NY +Jan 25 +Withdrawal - VISA - Visa Purchase +01/23 KUNG FU JAPANESE & CHIN BROOKLYN NY +Jan 25 +Withdrawal - VISA - Visa Purchase +01/25 FAIRWAY MKT DG FAIRWAY NEW YORK NY +Jan 27 +Withdrawal - VISA - Visa Purchase +01/26 CERIELLO FINE FOODS WILLISTON PAR NY +Jan 28 +Withdrawal - POS #050360 +DEALS 2402 86TH ST BROOKLYN NY +Jan 28 +Withdrawal - VISA - Visa Purchase +01/28 AUTOZONE 5274 1455 86T BROOKLYN NY +Jan 28 +Withdrawal - POS #032167 +DOLLAR TREE 2847 W BTH ST BROOKLYN NY +Jan 29 +Withdrawal - VISA - Visa Purchase +01/29 BP#4836326MUKTI 49 PETR CORONA NY +Withdrawal - VISA - Visa Purchase +01/28 OUTBACK 3331 BROOKLYN NY +Jan 29 +Deposit - ACH - AGRI TREAS 310 +TYPE: FED SAL ID: 9101036009 AMT: 100.00 +CO: AGRI TREAS 310 +TYPE: FED SAL ID: 9101036009 AMT: 100.00 +CO: AGRI TREAS 310 +TYPE: FED SAL ID: 9101036009 +AMT: 2,318.95 CO: AGRI TREAS 310 +Jan 30 +Withdrawal - VISA - Visa Purchase +01/29 UMBERTOS OF NHP MANHASSET NY +Jan 30 +Withdrawal - POS #013746 +NST MODELL'S #61 430936 89-59 BAY PARKWAY +BROOKLYN NY +Jan 30 +Withdrawal - POS #061429 +TARGET T-1401 519 Gateway Dr Brooklyn NY +Jan 30 +Withdrawal - ACH - HONDA PMT +TYPE: 8004579929 ID: A953472715 +CO: HONDA PMT +Jan 31 +Withdrawal - VISA - Visa Purchase +01/30 OLIVE GARDEN 00015586 BROOKLYN NY +Jan 31 +New Balance +Totals For This Period: +Withdrawals +-3.69 +-40.00 +-78.19 +-37.76 +-43.27 +-38.28 +-21.89 +-25.00 +-67.38 +0956647 000056462 OMCUDA 0630100 + +(continued) +Deposits +$ 02 +Balance +549.10 +509.10 +430.91 +393.15 +349.88 +311.60 +289.71 +264.71 +197.33 +2,518.95 +2,716.28 +-45.32 +-64.57 +-38.08 +-375.00 +-52.20 +-3,502.40 +4,668.95 +2,670.96 +2,606.39 +2,568.31 +2,193.31 +2,141.11 +2,141.11 +YEAR TO DATE TOTALS +Total Dividends YTD +0.00 +IN CASE OF ERRORS OR QUESTIONS ABOUT YOUR ELECTRONIC TRANSFERS +Write to us at P.O. Box 3205, New York, NY 10007 or telephone us at (212)693-4900 (or (800)323-6713 if outside the five boroughs) if you think +your statement or receipt is wrong, or if you need more information about a transfer on your statement or receipt. Write to us as soon as possible. +We must hear from you no later than 60 days after we sent you the FIRST statement on which the error or problem appeared. Tell us the following: +• Your name and MCU account number (if any); +The amount of the suspected error or questioned transfer (and transaction date if known); +• A description of the error or the questioned transfer, and an explanation why you believe there is an error or need more information. +Ne will investigate your complaint and correct any error promptly. If we take more than 10 business days to do this, we will credit your account for +he amount you think is in error, so that you will have use of the money during the time it takes us to complete our investigation. + + +0956847 000056462 0MCU0A 0630100 + +USE THE FOLLOWING FORM TO ASSIST YOU IN BALANCING YOUR CHECKING ACCOUNT +LIST CHECKS OUTSTANDING +(NOT CHARGED TO YOUR CHECKING ACCOUNT YET) +PERIOD ENDING +CHECK NUMBER CHECK DATE +$ AMOUNT +1. SUBTRACT FROM YOUR REGISTER ANY CHARGES LISTED ON THIS +STATEMENT BUT NOT DEDUCTED FROM YOUR BALANCE +2. ENTER CHECKING BALANCE SHOWN $ +ON THIS STATEMENT. ++ +$ +3. ENTER DEPOSITS MADE +AFTER THE ENDING DATE OF +THIS STATEMENT. ++ +$ ++ +$ +4. TOTAL (2 PLUS 3): +$ +TOTAL: +5. CARRY OVER OUTSTANDING CHECK S +TOTAL. +6. REGISTER BALANCE (4 MINUS 5): +$ +SHARES ARE TRANSFERABLE ONLY TO QUALIFIED MEMBERS +and backed by the ful fats and redit of the United Slates Govemment +NCUA +National Credit Union Administration, a U.S. Government Agency \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/02a556b2cb15d00ce6cbb65e5042127f8b804ee7c36d58439fac82fdfa03a2f5.receipt.json b/vision-fixhub/ds9-parsed-01/02a556b2cb15d00ce6cbb65e5042127f8b804ee7c36d58439fac82fdfa03a2f5.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..34ce1c56959c1e1d60142583e67a878981124701 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/02a556b2cb15d00ce6cbb65e5042127f8b804ee7c36d58439fac82fdfa03a2f5.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -398, + "dataset": "marble-joined", + "doc_id": "02a556b2cb15d00ce6cbb65e5042127f8b804ee7c36d58439fac82fdfa03a2f5", + "engine": "marble-apple-vision", + "event_count": 11, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "8d9cdae39c20639905d9ae71f8fe6356b7f80ef8a67b8ad70d1f193373977ea9", + "output_sha256": "287721a6f142bf7bf92acca40aee5d7a45bf6dc600d8bc1864fa0c9a29a595da", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/02cadab498e672b5b3090a306120d64a4cf245b25bbb0d2e9dd1690b8d040efb.md b/vision-fixhub/ds9-parsed-01/02cadab498e672b5b3090a306120d64a4cf245b25bbb0d2e9dd1690b8d040efb.md new file mode 100644 index 0000000000000000000000000000000000000000..367d4e477f70cbd7b5a19999c36ff28e9b279a07 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/02cadab498e672b5b3090a306120d64a4cf245b25bbb0d2e9dd1690b8d040efb.md @@ -0,0 +1,168 @@ +From: " +To: " +(USANYS)" ≤ +(USANYS)" < +Cc: " +(USANYS)" < +Subject: RE: Epstein Estate Touhy Requests +Date: Tue, 20 Aug 2019 19:51:11 +0000 +I (USANYS)" +We are going to ask for everything back as soon as the nolle is entered. +From: | +(USANYS) < +Sent: Tuesday, August 20, 2019 3:44 PM +To: l +(USANYS) < +Cc: +I (USANYS) < +Subject: RE: Epstein Estate Touhy Requests +- (USANYS) C +Let me know what you end up deciding. Tx. +From: +To: +Cc: +(USANYS) < +Sent: Tuesday, August 20, 2019 2:42 PM +| (USANYS) < +(USANYS) < +Subject: RE: Epstein Estate Touhy Requests +(USANYS) < +We have not, but we've discussed doing so. Under the protective order, we are entitled to. +From: +To: +Cc: +| (USANYS) < +Sent: Tuesday, August 20, 2019 2:37 PM +(USANYS) < +(USANYS) < +Subject: RE: Epstein Estate Touhy Requests +(USANYS) < +De-looping +and +Maybe: +Your August 20, 2019, requests for disclosure under the Department of Justice's Touhy regulations +will be handled by AUSA +of our Civil Division, copied here. Please note that no +further discovery will occur in the context of the criminal case of US v. Epstein, 19 Cr. 0490. +Separately, will we be clawing back discovery already made in the Epstein case? +From: +To: +(USANYS) < +Sent: Tuesday, August 20, 2019 2:21 PM +(USANYS) < +(USANYS) < +Cc: +(USANYS) < +Subject: RE: Epstein Estate Touhy Requests +(USANYS) Y +(USANYS) < +Thanks, + + +In the interim, +I would propose having the crim team response as follows: +"Counsel - We are in receipt of your requests which do not appear to arise under Rule 16 or any other production +obligation associated with the criminal proceeding. Moreover, as you are aware, the Government has submitted a +proposed order of nolle prosequi which, once entered, will terminate that proceeding. We have forwarded your +correspondence to the Civil Division which will handle any further correspondence regarding these matters." We can also +have the point them directly to +if that makes sense. +From: +To: +Cc: +| (USANYS) < +Sent: Tuesday, August 20, 2019 2:16 PM +| (USANYS) | +(USANYS) < +(USANYS) < +Subject: RE: Epstein Estate Touhy Requests +(USANYS) < +(USANYS) < +All, +I will reach out to +on this, including for the letters from Steptoe. +, the matter number here is 2019V01791. +Thanks, +From: +(USANYS) < +Sent: Tuesday, August 20, 2019 1:32 PM +To: +(USANYS) < +Cc: +(USANYS) < +(USANYS) < +Subject: RE: Epstein Estate Touhy Requests +| (USANYS) < +(USANYS) < +Thanks. Would you open a new matter on this, it may end up being substantial. +From: +To: l +Cc: +(USANYS) < +Sent: Tuesday, August 20, 2019 1:26 PM +(USANYS) < +| (USANYS) < +(USANYS) < +P: +Subject: Re: Epstein Estate Touhy Requests +_(USANYS) < +(USANYS) <| +has been assigned. Thanks. +Jeff +On Aug 20, 2019, at 12:16 PM, +(USANYS) < +> wrote: +I: could you kindly assign an AUSA to be the point of contact on Epstein-related Touhy requests? +We can then discuss what the appropriate response may be. Thanks, as always, for your help on these issues. + + +From: +To: +Cc: +(USANYS) < +Sent: Tuesday, August 20, 2019 11:53 AM +| (USANYS) < +(USANYS) < +Subject: FW: United States v. Jeffrey Epstein, 19-CRIM-00490 (S.D.N.Y.) +- We continue to get document requests from Epstein's defense team related to his death. How would you like us +to handle? Should we refer them to someone at Civ Div? Ignore? There is, as best I can tell, no right to anything given +that there is no "proceeding" pending related to the death but, in any event, our crim AUSAs are presumably not the +appropriate point of contact. +From: +Sent: Tuesday, August 20, 2019 11:47 AM +To: +(USANYS) < +Cc: +(USANYS) < +Subject: FW: United States v. Jeffrey Epstein, 19-CRIM-00490 (S.D.N.Y.) +and +We received the attached document requests from Epstein's lawyers. Based on our previous conversations about this, it +sounds like these should be routed to the civil division, but I wasn't sure who in particular to contact, or whether you +would prefer to make the referral. +Thanks, +From: Miller, Michael < +Sent: Tuesday, August 20, 2019 11:42 AM +To: +Cc: +Reid < +P; +P; 'Martin G. Weinberg' +; Meade, Jason • +Subject: United States v. Jeffrey Epstein, 19-CRIM-00490 (S.D.N.Y.) +P; Weingarten, +Scavelli, Michael +Please find attached correspondence for your attention. We intend to serve these requests separately on the +VicC and the FBI, but are providing you with copies of all three letters as a courtesy. If you are willing to +accept service for all three, we will not otherwise serve them +Mike +Michael C. Miller +Partner +Steptoe +Steptoe & Johnson LLP +www.steptoe.com +notify the sender immediately by reply e-mail and then delete this message. + + +<8.20.19 Epstein Letter to SDNY-c2.pdf> +<8.20.19 Epstein Letter to MCC-c2.pdf> +<8.20.19 Epstein Letter to FBI-c2.pdt» diff --git a/vision-fixhub/ds9-parsed-01/02cadab498e672b5b3090a306120d64a4cf245b25bbb0d2e9dd1690b8d040efb.receipt.json b/vision-fixhub/ds9-parsed-01/02cadab498e672b5b3090a306120d64a4cf245b25bbb0d2e9dd1690b8d040efb.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..b4c26907ae84ea6eefc315c0f8686125dad72ae9 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/02cadab498e672b5b3090a306120d64a4cf245b25bbb0d2e9dd1690b8d040efb.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -48, + "dataset": "marble-joined", + "doc_id": "02cadab498e672b5b3090a306120d64a4cf245b25bbb0d2e9dd1690b8d040efb", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "ef1be8a1d690cab8d0bd9907b9cfde381f3829e90a9978ac1624ec046fbb113c", + "output_sha256": "2b6a2728745eada81d3017f4f0d5c0bf0ef5ee38596c291f422304771486a7ca", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/02ccb4926d725a2347a4d1c07dfc53efa2fe27ff20d350973626256e4faf070c.md b/vision-fixhub/ds9-parsed-01/02ccb4926d725a2347a4d1c07dfc53efa2fe27ff20d350973626256e4faf070c.md new file mode 100644 index 0000000000000000000000000000000000000000..d302cf050c34b684e2526cb2f93397f86e6a6d6a --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/02ccb4926d725a2347a4d1c07dfc53efa2fe27ff20d350973626256e4faf070c.md @@ -0,0 +1,114 @@ +U.S. Department of Justice +Office of the Inspector General +OFFICE +CASE # +2019-010614 +LOG # +EVIDENCE CUSTODY DOCUMENT +DATE AND TIME OF SEIZURE +8/22/19 +NYFO +PROPERTY SEIZED FROM +BOP MCC +3. +4. +5. +6. +12 +LOCATION OF SEIZURE +BOP MCC +DESCRIPTION OF THE PROPERTY SEIZED +Phone Log Print Outs for Ext.#6314 (in-out) +Phone Log Print Outs for Ext. #6313 (out-in) +333 Calls (in) +Phone Log Print Outs for Ext. #6468 (out-in) +Phone Log Print Outs for Ext. #6385 (out-in) +Phone Log Print Outs for Ext. #6317 (out) +NAME AND SIGNATURE OF WITNESS +NAME AND SIGNATURE OF SEIZING +SPECIAL AGENT +ITEM +1-6 +16 +1-6 +1-6 +DATE/TIME +8/22/19 +8bal11 + +12/6/21 +14:56 +12/1/22 +10:30 AM +12-19-24 +11:15am +12-19-24 +RELEASED BY +CHAIN OF CUSTODY +RECEIVED BY +PURPOSE +Evidence Storage +SPAY +Revio +received by Myto +12/10/19 +New Evidence +Rinali can +Final transle +to BOP + + +U.S. Department of Justice +Office of the Inspector General +[OFFICE +CASE # +2019-010614 +EVIDENCE CUSTODY DOCUMENT +LOG # +DATE AND TIME OF SEIZURE +8/22/19 +NYFO +PROPERTY SEIZED FROM +13 +LOCATION OF SEIZURE +BOP MCC +BOP MCC +ITEM +DESCRIPTION OF THE PROPERTY SEIZED +30 minute rounds 7/1/19 - 8/10/19 +NAME AND SIGNATURE OF WITNESS +NAME AND SIGNATURE OF SEIZING +SPECIAL AGENT +- +CHAIN OF CUSTODY +RELEASED BY +RECEIVED BY +ITEM +1-6 +1-6 +1 +DATE/TIME +8/22/19 +8laal11 + +12/6/21 +17:00 +1211/27 +Le :0 40 +2-19-2 +11:15am +17-19-24 +PURPOSE +Evidence Storage +TrAnsport +SONY +Arviev +received by NyFo +12/10/19 +Nel Enslence Custodian +Item 1:30 minute vonds +Return to case +agent +Find tonsks to +BaP +OIG FORM III - 234/1 (04/23/07) diff --git a/vision-fixhub/ds9-parsed-01/02ccb4926d725a2347a4d1c07dfc53efa2fe27ff20d350973626256e4faf070c.receipt.json b/vision-fixhub/ds9-parsed-01/02ccb4926d725a2347a4d1c07dfc53efa2fe27ff20d350973626256e4faf070c.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..2a96fd0acf0d937cbd4ee488beebf0a9741fad59 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/02ccb4926d725a2347a4d1c07dfc53efa2fe27ff20d350973626256e4faf070c.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -38, + "dataset": "marble-joined", + "doc_id": "02ccb4926d725a2347a4d1c07dfc53efa2fe27ff20d350973626256e4faf070c", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "1ebc02837bb6133fb2e44ffd8cdefb383b8bdc4b41905882718cd0680982faa3", + "output_sha256": "c3362e392ae064dfceb19e436c84e430f80deda916ac1143baed7c571e35543c", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/030486608bdda1d73e0bba939db9fb7e6470037a0a4d8705bb13a18fa2411816.md b/vision-fixhub/ds9-parsed-01/030486608bdda1d73e0bba939db9fb7e6470037a0a4d8705bb13a18fa2411816.md new file mode 100644 index 0000000000000000000000000000000000000000..8fb894047269ccae6a45132e8796bb6b4553525c --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/030486608bdda1d73e0bba939db9fb7e6470037a0a4d8705bb13a18fa2411816.md @@ -0,0 +1,17 @@ +BOBBI C. STERNHEIM, ESQ. +Law Offices of Bobbi C. Sternheim +33 West 19th Street - 4th Floor +New York, NY 10011 +Main: 212-243-1100 +Cell: 917-912-9698 +Fax: 888-587-4737 +bcsternheim@mac.com +**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely. +Please use email or fax, instead of regular mail, for all correspondence during this time. +We continue to work regular business hours throughout this situation. +Thank you for your consideration. Our best wishes for your good health and well being. +This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim +that may be confidential and/or privileged. +If you are not the intended recipient, you may not read, copy, distribute, or use this information. +If you have received this transmission in error, please notify the sender immediately by reply e-mail and +then delete this message. Thank you. diff --git a/vision-fixhub/ds9-parsed-01/030486608bdda1d73e0bba939db9fb7e6470037a0a4d8705bb13a18fa2411816.receipt.json b/vision-fixhub/ds9-parsed-01/030486608bdda1d73e0bba939db9fb7e6470037a0a4d8705bb13a18fa2411816.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..98ece1c7737c55ee39a52258ec7cf8a52965a0ed --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/030486608bdda1d73e0bba939db9fb7e6470037a0a4d8705bb13a18fa2411816.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "030486608bdda1d73e0bba939db9fb7e6470037a0a4d8705bb13a18fa2411816", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "d453fa6078b92233c0eff6e0a2d44c663e087bb24d793d4bfe7501e65b712db0", + "output_sha256": "cb76faf0034d1fa63cb15aa4cffb68db23a4f75d8b64f38748e3069204743c74", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/03296f92e3534ec461f5b2a0c22239271be9ba7294199e95ef06173f357238f2.md b/vision-fixhub/ds9-parsed-01/03296f92e3534ec461f5b2a0c22239271be9ba7294199e95ef06173f357238f2.md new file mode 100644 index 0000000000000000000000000000000000000000..beb861900a82095fe3239541367ae39cc00d83e9 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/03296f92e3534ec461f5b2a0c22239271be9ba7294199e95ef06173f357238f2.md @@ -0,0 +1,56 @@ +From: +To: "Sahni, Anjan" < +Cc: " +Subject: RE: JPMorgan Chase Production +Date: Tue, 29 Oct 2019 23:25:29 +0000 +I"< +"Stoddart, Allison" +Anjan, +Thank you for checking in, and we look forward to receiving the update later this week. Regarding the subpoenas, I think +there was one subpoena served by the FBI just a day or two before we were first in touch, dated September 3, 2019, +relating to +and then it appears we did inadvertently let the FBI serve one after we were in touch with +you, dated October 8, 2019, relating to L +I. If you've received any subpoenas addition to those (other than the +ones we've already previously discussed), please let us know, and otherwise we certainly will send any additional process +directly to you-apologies for any inconvenience or confusion caused by the separate service. +Thanks again, and talk soon. +From: Sahni, Anjan < +Sent: Monday, October 28, 2019 23:21 +To: +Cc: +P; Stoddart, Allison < +Subject: RE: JPMorgan Chase Production +Hope all is well. We expect to have an update for you later this week on the timing of the wire production and our other +ongoing collection efforts. On a related note, we learned from JPMorgan's National Subpoena Processing that they +received a couple subpoenas directly from the FBI, which I assume are related to the same investigation we've been +discussing. For any additional subpoenas in this investigation directed to JPMorgan, could you please direct them to us? +That will help us get them to the appropriate team more quickly. +Thanks, +Anjan +From: +Sent: Monday, September 30, 2019 5:25 PM +To: Stoddart, Allison < +Cc: Sahni, Anjan < +Subject: RE: JPMorgan Chase Production +EXTERNAL SENDER + + +Allison, +Received, thank you, and we were able to access the materials. +thanks again, +From: Stoddart, Allison < +Sent: Wednesday, September 25, 2019 20:12 +To: +Cc: Sahni, Anjan < +Subject: [Not Virus Scanned] [Not Virus Scanned] JPMorgan Chase Production +Attached is a letter on behalf of our client, JPMorgan Chase, along with an encrypted zip. I will send the password in a +separate email. Please let us know if you have any issues accessing the materials. +Thank you, +Allison +Allison Stoddart | WilmerHale +Please consider the environment before printing this email. +This email message and any attachments are being sent by Wilmer Cutler Pickering Hale and Dorr LLP, are confidential, and may be privileged. If you are not +the intended recipient, please notify us immediately—by replying to this message or by sending an email to postmaster@wilmerhale.com —and destroy all +copies of this message and any attachments. Thank you. +For more information about WilmerHale, please visit us at http://www.wilmerhale.com. diff --git a/vision-fixhub/ds9-parsed-01/03296f92e3534ec461f5b2a0c22239271be9ba7294199e95ef06173f357238f2.receipt.json b/vision-fixhub/ds9-parsed-01/03296f92e3534ec461f5b2a0c22239271be9ba7294199e95ef06173f357238f2.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..bf3961a881bbc8b8df10a8b53517cc03ff66faf6 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/03296f92e3534ec461f5b2a0c22239271be9ba7294199e95ef06173f357238f2.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "03296f92e3534ec461f5b2a0c22239271be9ba7294199e95ef06173f357238f2", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "53d6742c96b8f4f6e263031b4500c06b9ff6f6b39a8b62e779610cfc55f1ac86", + "output_sha256": "7ec2d44c31ff76989d51b5c90fe2026c07c8258659e37a2a227f4e75c4c5c874", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/032f58404d157375dbe1b25e958e561aa495a8476ef225099f3c2fe87d853e7f.md b/vision-fixhub/ds9-parsed-01/032f58404d157375dbe1b25e958e561aa495a8476ef225099f3c2fe87d853e7f.md new file mode 100644 index 0000000000000000000000000000000000000000..3f4360ba3ac68ac8cebfd5f1ac6e307b68bb47e9 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/032f58404d157375dbe1b25e958e561aa495a8476ef225099f3c2fe87d853e7f.md @@ -0,0 +1,15 @@ +From: +Subject: 20cr330, United States v. Maxwell +Date: Mon, 23 Aug 2021 19:49:35 +0000 +Attachments: 20cr330_Second_Ex_Parte_Mtn_Ex._I.pdf; 20cr330_Second _Ex_Parte_Mtn_Ex. _2.pdf; +20c330_Second_Ex_Parte_Mtn_Ex. _3.pdf; 20cr330_Second_Ex_Parte_Mtn_Ex._4.pdf; +20cr330_Temp._Sealed_Opinion_&_Order_8.13.21.pdf; +20cr330_Second_Ex _Parte_Mtn_for_Order +:_Auth_a_Sub_Pursnt_to_F.R.Crim.P_17(c) +(3)_3.19.21.pdf +Per this Court's Order at Dkt. No. 325, please see the attached August 13 Opinion & Order and related motions +Counsel: +papers. +Please confirm receipt. +Sincerely, +Chambers of Judge Alison J. Nathan diff --git a/vision-fixhub/ds9-parsed-01/032f58404d157375dbe1b25e958e561aa495a8476ef225099f3c2fe87d853e7f.receipt.json b/vision-fixhub/ds9-parsed-01/032f58404d157375dbe1b25e958e561aa495a8476ef225099f3c2fe87d853e7f.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..810b245eca2e48f9908366c7624b92f0be768ee5 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/032f58404d157375dbe1b25e958e561aa495a8476ef225099f3c2fe87d853e7f.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "032f58404d157375dbe1b25e958e561aa495a8476ef225099f3c2fe87d853e7f", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "eb48877ea142bfbc114c593dff96b7653e51a5073e02b057bd13bb2a85d57f43", + "output_sha256": "55008dc91a5b1f4b01d94a803de8e95ba0b1d2c40ba5efbf45628b7d88b30dd0", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/034910df0b77c625d79f6980ccbfe39303eb846aa11555e49b84720f96f30f23.md b/vision-fixhub/ds9-parsed-01/034910df0b77c625d79f6980ccbfe39303eb846aa11555e49b84720f96f30f23.md new file mode 100644 index 0000000000000000000000000000000000000000..cb6b42ee644438d8fbf4a81664974f1afbb7f848 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/034910df0b77c625d79f6980ccbfe39303eb846aa11555e49b84720f96f30f23.md @@ -0,0 +1,53 @@ +DRAFT +U.S. Department of Justice +Southern District of New York +One St. Andrews Plaza +New York, NY 10007 +Phone: +Fax: +August 01, 2019 +West Palm Beach, FL 33407 +Re: United States v. Defendants) Jeffrey Epstein +Case Number 2018R01618 and Court Docket Number 19-CR-00490 +Dear +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 during the +prosecution of this case. I am contacting you because you were identified by law enforcement as a victim or +potential victim during the investigation of the above criminal case. +Hearing Information +The case involving defendant, Jeffrey Epstein, has been scheduled for hearings on the following dates: +• An oral argument is scheduled for October 28, 2019 at 10:00 am; +• Another oral argument is scheduled for March 12, 2020 at 10:00 am; +• A status conference scheduled for June 8, 2020 at 9:00 am. +These hearings are before Judge Richard Berman in Courtroom 17B, 500 Pearl Street, New York, NY 10007. +If you plan on attending, please call me at +in case there are any last minute changes. +Because of the Court's schedule, hearing dates could change on very short notice. If you plan on attending, +you may want to call the VNS Call Center or check the website to confirm the date and time. Please note, +there is a 24-hour delay in information transfer to the website. +Information Regarding the Victim Notification System (VNS) +Through the Victim Notification System (VNS) we will continue to provide you with updated scheduling and +event intormation as the case proceeds through the criminal justice system. You may 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. VNS does not currently have an email +address for you. You can provide VNS an email address by accessing the VNS Internet Web page using the +login information provided below. By entering your email as part of the VNS registration process future +notifications will be delivered by email, except in rare circumstances when you might also receive a letter from +VNS. 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) '6017050' and Personal Identification Number (PIN) +7052' 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 +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, +Geoftrey S. Berman +United States Attorney +Victim Witness Coordinator diff --git a/vision-fixhub/ds9-parsed-01/034910df0b77c625d79f6980ccbfe39303eb846aa11555e49b84720f96f30f23.receipt.json b/vision-fixhub/ds9-parsed-01/034910df0b77c625d79f6980ccbfe39303eb846aa11555e49b84720f96f30f23.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..fef4d0e4e007b81562339e297f27403da8cd6426 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/034910df0b77c625d79f6980ccbfe39303eb846aa11555e49b84720f96f30f23.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "034910df0b77c625d79f6980ccbfe39303eb846aa11555e49b84720f96f30f23", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "e1c5b3d9343def1e7432685db952e1be879696735fbf53246cd11c9d94df0aad", + "output_sha256": "de0854f91e2d54cd55b49ffd26445e7c7e793bbd2e82c9ffda8f7e23d38d349f", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/036c3face65e21fc76e639b5d97240beb91a897e34ad0b5299aa9cb116f4eee1.md b/vision-fixhub/ds9-parsed-01/036c3face65e21fc76e639b5d97240beb91a897e34ad0b5299aa9cb116f4eee1.md new file mode 100644 index 0000000000000000000000000000000000000000..81f90fc45652fc10421146105393e2ca7670dee9 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/036c3face65e21fc76e639b5d97240beb91a897e34ad0b5299aa9cb116f4eee1.md @@ -0,0 +1,285 @@ +7|15/21 +NYMH3 +PAGE 001 +530.03 +QTRG EQ +BUREAU OF PRISONS COUNT SHEET +NEW YORK MCC +**** +OCTG +EO **** +U T +C +F +N +E +U +N +T +0 +P +E +40 4 2 H +I ON +23AP +08-09-2019 +21:33:35 +Z-A +Z-B +TOTAL +COUNT +VERIFY +CENSUS +26 +10 +83 +79 +78 +88 +4 +89 +137 +73 +5 +758 +N +VERIFY +COUNT +COUNT COUNT AREA +XXXXXXXXXXX +26 +B-A +10 C-A +83 +E-N +78 +78 +88 +4 +86 +88 +135 +K-S +0 +R-A +73 +Z-A +2-B +754 +OFFICIAL PREPARING COUNT: +OFFICIAL TAKING COUNT: +COUNT CLEARED TIME: +91 10pm + + +METROPOLITAN CORRECTIONAL CENTER +NEW YORK, NY +OFFICIAL OUT COUNT +DATE: +FROM: +APPROVED: +08-09-19 +thomos +(Staff Member Brenarine Out Count) +COUNT TIME: +LOCATION: +1000 pm +Hosp +(Operations Lieutenant) +REG # +NAME +UNIT +1, +2. +89673-053 Mersey Rs +91349-039 Noboa Ks +3. +4. +85317-054 Weber Ks +86272-054 Montas +KN +5. +6. +7. +8. +9. +10. +11. +12. +REG # +NAME +UNIT +13. +14 +15. +16. +17. +18. +19. +20. +- 21 +22. +23. +24. +B-A +I-N +C-A +K-N +E-N +K-s 2 +OUT-COUNT BY UNIT +E-S +R-A +G-N +ZA +G-S +Z-B +H-A +Total Out-Counted: +4 +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected count. +Prepare this form In ink. Group the inmates according to their respective housing units. This form is to be used only as an +Out-Count. No other form will be accepted in lieu of the Out-Count Form. + + +Metrupoltan Correctional Center +Ofcial Count 3ii +Call Ind +Couri: +Print Nasse +Spain: +Priat Mene: +Meirspultan Correctiosal Ceuter +Official Covet Slip +Time: YOu +Unti +Caunt: +Prime Name: +Signature: +Prist Name: +Signature: +Metrupulitan Correctional Cestro +Unit +KN +88 +Tate _ +18,9 +Qpm +Fring Has +Signahar +Trist Mane +Signalue +Metropoliton Correctional Center +New Vork, New Yerk +25+1 +Official Count Slip +Unit: +BED +Counti +Date: $/4/249 +Time: 1u.0of +1. Prise Name: +1. Siguature: +2. +Print Name: +2. +Signatire: +Netropoliss Corretticoul CeRt +Ofcial Coent Slip +Lalt: +Coaal: +Prine Name: +Signatum: +Frist Name +/ The +Signature: +Metropulites Correctional Center +Official Count Slip +_in 08-09349 +Thee +хоти ры +Unit: +Priet Mass: +Sipsaturer +Print Masse +Sigmalue +Metropolias Cerrectional Ceste +Ofcial Count Sip +U'nie: +Dair: 8.9-19 +Count: +da +Time: 109% +Print Name +Signatares _ +Print Name: +Signsiure: +Metropolitan Correctional Center +New Vork, New York +Official Count Slip +Unn: 2-3 +Hare 8-98. +Count +Time2 Dipm +1. Print Nam +1- Signature +2. Print Name. +7. Signatu +Metropolitas Correctional Cester +Official Count Stip +Dale... +20919 +L'ail: +Count: +Print Name +#grature: +Print Name +Signatume i + + +Metropalitan Cotectional Ceater +Chical Countin +Meirepulian Correcional Center +OMicial Coust Slip +Metropalilan Correctional Center +OMal Conne Slip +Date 319/19 +.. BA +2-6 +Count: +Prist Nawe: +Signatures +Print Name! +Signalure +Time: +2:00ph +Wet: 3 +Count: +Print Suae +Signature +Mot Need +Count +Priat Name: +• Signature: +Polal Name: +Signature +Mesropolitan Correctioeal Cenin +OMelel Chant Slip +Unit: +Cuesti +Prial Name: +Sigesture: +Prist Name: +Signature: +317/19 +Time swapm +Metropolites Correctional Cente +Official Count Sti +_ Dose, +8/9/29 +Ueit- +Count: . +TimE Nam +Signatare +Priat Man +Sipatee diff --git a/vision-fixhub/ds9-parsed-01/036c3face65e21fc76e639b5d97240beb91a897e34ad0b5299aa9cb116f4eee1.receipt.json b/vision-fixhub/ds9-parsed-01/036c3face65e21fc76e639b5d97240beb91a897e34ad0b5299aa9cb116f4eee1.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..76ce127cf53d7f9b0f07671d3e325a6e88dc0348 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/036c3face65e21fc76e639b5d97240beb91a897e34ad0b5299aa9cb116f4eee1.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -48, + "dataset": "marble-joined", + "doc_id": "036c3face65e21fc76e639b5d97240beb91a897e34ad0b5299aa9cb116f4eee1", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "157115fb5f3a5bab7ae9673444303b785e1c30420fab66832f935ffc7b165cee", + "output_sha256": "81b6fdd0b42d48cedb173dbdaefe9d50861df059868c5b1e264a402b3e10bdfe", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/03732aa9a1b844708c7f958d7a092e54b2650d749d447e4623130c958aecce7d.md b/vision-fixhub/ds9-parsed-01/03732aa9a1b844708c7f958d7a092e54b2650d749d447e4623130c958aecce7d.md new file mode 100644 index 0000000000000000000000000000000000000000..2d088a8254120793797b692048bd1b30f003ce03 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/03732aa9a1b844708c7f958d7a092e54b2650d749d447e4623130c958aecce7d.md @@ -0,0 +1,21 @@ +From: +To: " +Cc: ' +USANYS)" ≤ +(USANYS)". +(USANYS)" • +Subject: Re: Epstein +Date: Sun, 23 Jun 2019 17:24:31 +0000 +Importance: Normal +Yes —- I was aware of the need to meet this. Geoff was supposed to be out starting Monday afternoon, but now +he will be around through Tuesday, and he is happy to call into meetings later in the week as well. He was +planning to review +Sent from my iPad +> On Jun 23, 2019, at 11:51 AM, +(USANYS) ≤ +> wrote: +> +> Can we set a time to meet with brass on this to make sure evervone is comfortable proceeding and has their +questions answered? Mavbe Wednesday or Thursdav? +> +> Sent from my iPhone diff --git a/vision-fixhub/ds9-parsed-01/03732aa9a1b844708c7f958d7a092e54b2650d749d447e4623130c958aecce7d.receipt.json b/vision-fixhub/ds9-parsed-01/03732aa9a1b844708c7f958d7a092e54b2650d749d447e4623130c958aecce7d.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..fd11689c3b65a53422d3ebed51231e6151e23cbf --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/03732aa9a1b844708c7f958d7a092e54b2650d749d447e4623130c958aecce7d.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "03732aa9a1b844708c7f958d7a092e54b2650d749d447e4623130c958aecce7d", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "ce1a81fba6cdff848cc4935b1512b63063242ada1f3ad4c042f0973a47777707", + "output_sha256": "2ad902bf0fbe937dd881c652b85b3498e59e7f889247ca8d68fc02bfe85e58aa", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0373e8955161c75a2a6edbc4063bafbd2b7d0d52583d84fc5e28d0081eac7300.md b/vision-fixhub/ds9-parsed-01/0373e8955161c75a2a6edbc4063bafbd2b7d0d52583d84fc5e28d0081eac7300.md new file mode 100644 index 0000000000000000000000000000000000000000..01a9ff7ded0599a1b67fbf3cd8517763aa604cb0 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0373e8955161c75a2a6edbc4063bafbd2b7d0d52583d84fc5e28d0081eac7300.md @@ -0,0 +1,116 @@ +From: " +To: " +Cc: " +Subject: Re: USVIAG +Date: Wed, 02 Dec 2020 14:54:28 +0000 +Can you remind us - as part of your communications in October did you ask her who at USVI AG was +supervising this, and did you get an answer? Particularly if not, and while we're certainly happy to get involved, +I might suggest you start by reaching out again to (1) confirm that USVI has been issuing subpoenas (and +obviously try to gather any intel we can), and (2) express our concern about that at the line level. In the same +call, assuming (as we do) that it doesn't result in them immediately agreeing to stand down, I would tell her you +plan to elevate and ask her (again?) who the appropriate supervisor is at USVIAG. It will then be well teed up +to reach out later this week or next. +Sent from my iPhone +On Dec 1, 2020, at 6:05 PM. +wrote: +Hil +Following up on this, we spoke with counsel to the USVI in October and raised these concerns. The attorney said she +would consult with the USVI AG and get back to us. She did not get back to us, and we've learned today that the USVI +has been issuing a number of subpoenas to individuals-including to L +1. It seems clear to us they're not +willing to work with us at the line level on this issue. Would it be possible to elevate this? +Thanks, +From: +Sent: Wednesday, September 30, 2020 4:21 PM +To: +Cc: +Subject: RE: USVI AG +Okay, sounds good. +And that's great. Makes it somewhat easier for us to tell USVI AG, if we get there, that we are prepared to intervene to +seek a stay if we have to. +From: +Sent: Wednesday, September 30, 2020 4:19 PM +To: +Cc: +Subject: RE: USVI AG +Thanks - we can reach out at the line level for a call and let you know how it goes. +Land I agree this will likely +need to be elevated, but we're happy to start there. +Judge Freeman granted our motion for a stay, which is good. +From: +Sent: Wednesday, September 30, 2020 2:19 PM +To: +Cc: +Subject: RE: USVI AG + + +Got it. So couple thoughts for consideration: +One thing you could do is reach back out to her, tell her that you're hearing they may be trying to interview victims and +witnesses and that so doing poses concerns for the criminal case, and see if you can reach agreement that they will +either stand down or at least consult with us in the first instance before making contact, since l imagine there are some +victims and witnesses we may be less concerned with them attempting to interview at this point, right? +Based on what you've told me, I don't have high hopes that completely resolves things, but as a process point, it may be +helpful to have a record of at least trying. If it doesn't work, you could then ask her who at USVI AG is supervising her +work, because supervisors on this end are likely to reach out. Depending on the answer she gives you, we can then +decide who here should make the outreach. +Alternatively, we could just try to cold call supervisors at USVI AG (their website helpfully includes unit chief +names/phone numbers). Unless you happen to already know who at USVI AG is supervising the case/investigation, I'd +probably start with the head of their Special Investigations Division. +Also, on the issue of a stay, did Freeman rule of +and the civil suit? Apologies if I'm completely blanking on a +conversation we recently had, but this reminded me of our having to weigh in there... +Sent: Wednesday, September 30, 2020 1:40 PM +To: +Cc: +Subject: RE: USVI AG +You're exactly right, good memory. The USVI is represented by a private attorney. After they filed their suit (seemingly +based on no work on their part, and with obvious awareness of a pending criminal investigation), the attorney reached +out to us to boldly ask if we would give them information from our investigation. and I told them that we were +extremely surprised and frustrated that we were hearing from them only after the filed lawsuit suit, since they clearly +knew about our investigation and were making no efforts to avoid interfering with it. We told them we would not be +sharing information from our investigation and were disappointed in their lack of sensitivity towards an active federal +criminal investigation. We were professional, but it was not a friendly call. +The firm that represents the USVI is Linda Singer from Motley Rice: https://www.motleyrice.com/attorneys/linda-singer. +That same firm filed the motion to intervene in the l +| lawsuit. +It's hard to know who they've recently reached out to without canvassing all of our witnesses to ask. However, we +recently spoke with an attorney who represents one of Epstein's former chefs (who remembers • +_. but met her +after she turned 18, so it's unlikely we would call him), who told us that the USVI had reached out. There has been +public reporting about a leaked subpoena in their investigation seeking flight records, but the reporting is unclear as to +whether it was addressed to the pilots (who are witnesses in our case) or the estate. In either case, we would not want +those records to be made public in connection with a leaky civil case, because they will be trial exhibits for us (and they +include the names of trial witnesses). +From: +Sent: Wednesday, September 30, 2020 1:28 PM +To: +Cc: +Subject: RE: USVI AG +Thanks, | +• Very frustrating. Remind me, did we ever make contact with anyone at that Office? I have some memory +that they had actually hired a private attorney to handle the case and maybe we had talked with him? Am I making that +up? Mostly curious as to who we've talked to there and where we left things. +On the victim front, do you have a sense of who they have reached out to and whether those victims are folks we'd be +likely to call as trial witnesses? +From: +Sent: Wednesday, September 30, 2020 11:25 AM +To: +Cc: +Subject: USVI AG +Hi +We wanted to touch base about the USVI AG. As you know, they have a pending civil suit against Epstein's estate, +alleging very broad claims. At the time they filed, it seemed like their complaint was mostly based on articles they'd read + + +- it did not appear that they had actually done any investigating. Lately, their "investigation" has had broader reach - +they moved to intervene to unseal civil documents in the +_case, and at least one attorney for a witness we spoke +with has told us that the USVI reached out to ask for an interview. Subpoenas they have issued have also leaked. If USVI +is approaching witnesses (or asking for documents from them), we have concerns about a potential impact on our case. +We have been considering seeking a stay, or, in the alternative, were wondering if it would make sense for +someone else within the supervisory chain to reach out to the USVI to convey our concerns and ask them to stop +interfering. It would be helpful to get your thoughts on how you think we should proceed. +We'd be happy to have a call it's easier to discuss- +Assistant United States Attorney +Southern District of New York +New York, NY 10007 diff --git a/vision-fixhub/ds9-parsed-01/0373e8955161c75a2a6edbc4063bafbd2b7d0d52583d84fc5e28d0081eac7300.receipt.json b/vision-fixhub/ds9-parsed-01/0373e8955161c75a2a6edbc4063bafbd2b7d0d52583d84fc5e28d0081eac7300.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..2a4cc1056c733563cecf223f37c428a2b31e4708 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0373e8955161c75a2a6edbc4063bafbd2b7d0d52583d84fc5e28d0081eac7300.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -36, + "dataset": "marble-joined", + "doc_id": "0373e8955161c75a2a6edbc4063bafbd2b7d0d52583d84fc5e28d0081eac7300", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "03281338a1b24ce1d932fbc62004b45ac0c2e71cb2940bd6c26c4ee4b630b1e3", + "output_sha256": "509d3ed3ba957a10bcefda5467c9e60d0f1ff7301dea41557d55c48e99ba042b", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/03a967c61beec223c098b4d30265666645931359938fc8e7de946fbc0aa3f862.md b/vision-fixhub/ds9-parsed-01/03a967c61beec223c098b4d30265666645931359938fc8e7de946fbc0aa3f862.md new file mode 100644 index 0000000000000000000000000000000000000000..78d776823e32758e81be5ad40bedb8c8b41f80cd --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/03a967c61beec223c098b4d30265666645931359938fc8e7de946fbc0aa3f862.md @@ -0,0 +1,29 @@ +From: +Fwd: MCC Visit Thursday +Tuesday, August 13, 2019 3:28:21 PM +High +Importance: +Warden, +Per our discussion, please see the below request for a tour of the SHU and suicide watch areas by the US +ttorney and his staff Thursday, August 15. I will try to arrange it for 10 am, but we may be subject to the L +ttornev's schedule, Please let me know if you have any questions or concerr +Thank you, +Supervisory Staff Attorney +CLC New York +Metropolitan Correctional Center +150 Park Row +New York, New York 10007 +> 8/13/2019 2:05 PM > > > +The list of visitors from our office is below: +Geoffrey Berman +As discussed, we would like to see the 21d floor pscyh observation and suicide watch area; the gth +floor SHU, and Epstein's cell, which we understand to still be cordoned off. As discussed, we would +appreciate if only MCC legal would escort us, and we will not speak to any of the guards present given +the ongoing investigations. Please give me a call with any questions, and let us know what time and +where we should go, and if it would be easier for us to enter via the 3'° floor bridge. +Thanks, +Assistant United States Attorney +Southern District of New York + + +Tel: I diff --git a/vision-fixhub/ds9-parsed-01/03a967c61beec223c098b4d30265666645931359938fc8e7de946fbc0aa3f862.receipt.json b/vision-fixhub/ds9-parsed-01/03a967c61beec223c098b4d30265666645931359938fc8e7de946fbc0aa3f862.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..5dd6298dc0006ee7290b4c8231816ab725fb9775 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/03a967c61beec223c098b4d30265666645931359938fc8e7de946fbc0aa3f862.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "03a967c61beec223c098b4d30265666645931359938fc8e7de946fbc0aa3f862", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "88c99445ba6d440280d685e87e0c431d898e9bd3188b4c69f5bb8f8168d9b3d0", + "output_sha256": "6855e52e66b88704276f2951916543d62575923bdf3b6ace33a47530d086bc29", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/03b976d0c47f3abbe59990f98b440fb997f0d6f6e60ab6afb0be2d0bcf21cacb.md b/vision-fixhub/ds9-parsed-01/03b976d0c47f3abbe59990f98b440fb997f0d6f6e60ab6afb0be2d0bcf21cacb.md new file mode 100644 index 0000000000000000000000000000000000000000..32e8e7d3efb5fc1d77d2e630f2c2b8bd29626051 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/03b976d0c47f3abbe59990f98b440fb997f0d6f6e60ab6afb0be2d0bcf21cacb.md @@ -0,0 +1,47 @@ +From: +To: +Cc: +Subject: RE: US v. Jeffrey Epstein / 2018R01618 / Docket: 19-CR-00490 +Date: Fri, 12 Jul 2019 17:48:52 +0000 +Importance: Normal +I will call the ones that do not have lawyers. +Thank you, +From: [ +Sent: Friday, July 12, 2019 1:47 PM +To: +Cc: +Subject: RE: US v. Jeffrey Epstein / 2018R01618 / Docket: 19-CR-00490 +- I'm sorry that's what I was given from the Agents /AUSA's. My understanding is many have Legal Representation +and notification must go through them but I haven't been given that information. +I can try to call the ones that we can call and ask for their emails - would you like me to do that? +On Jul 12, 2019 1:34 PM, +(USANYS)" < +> wrote: +We are working hard to send out a letter. Do you have email addresses to any of these victims. The list of names that +we have only one person has an email address. +It would be great if you could provide email addresses so that notice will be sent to them today instead of snail mail. +Anything you have would be great. +From: +To: +Cc: +Sent: Friday, July 12, 2019 1:29 PM + + +Subject: US v. Jeffrey Epstein / 2018R01618 / Docket: 19-CR-00490 +- I have been working with I +I to ensure all victims are in VNS for you to provide notification. Some have +already asked when they would hear from your office. I told them they would hear soon especially since the +arraignment is scheduled for Monday. +Our office is also in the process of identifying new victims which we will add into VNS as soon as we have them. +Have a great weekend- +On Jul 12, 2019 1:23 PM, +USANYS)" ‹ +> wrote: +The above captioned case has been indicted by the USAO in SDNY and is pending in Federal District Court Southern +District of New York. All notifications will be going out to the victims from the USAO SDNY. If you require a copy of +the Attorney General Guidelines in which it specifically notes when the USAO sends out notifications I can provide it. +Regards, +United States Attorney's Office +Southern District of New York +1 St. Andrews Plaza +New York, New York 10007 diff --git a/vision-fixhub/ds9-parsed-01/03b976d0c47f3abbe59990f98b440fb997f0d6f6e60ab6afb0be2d0bcf21cacb.receipt.json b/vision-fixhub/ds9-parsed-01/03b976d0c47f3abbe59990f98b440fb997f0d6f6e60ab6afb0be2d0bcf21cacb.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..fdecdacf5bb883dd243ee44456e2f47d098de2ba --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/03b976d0c47f3abbe59990f98b440fb997f0d6f6e60ab6afb0be2d0bcf21cacb.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "03b976d0c47f3abbe59990f98b440fb997f0d6f6e60ab6afb0be2d0bcf21cacb", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "b2b19fbc7639546c927519d2b3d5399b1710170fd86b956182310480b09c86e0", + "output_sha256": "c744563f6e6e6293330bff92614c1b28855ea8884e76dbeac5c39e52b4cfe32d", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/03dc0d643a083884e98b63012c323dd994be02e0e100d3ab933655e90aaef0ee.md b/vision-fixhub/ds9-parsed-01/03dc0d643a083884e98b63012c323dd994be02e0e100d3ab933655e90aaef0ee.md new file mode 100644 index 0000000000000000000000000000000000000000..1e12c42cfa836ae941405a50f0eac0c7d0962f31 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/03dc0d643a083884e98b63012c323dd994be02e0e100d3ab933655e90aaef0ee.md @@ -0,0 +1,122 @@ +From: +lo: ' +Subject: RE: travel approval request +Date: Thu, 23 Jan 2020 22:54:23 +0000 +Hil +For this trip, could you please help with booking flights? If you could please book the following refundable ticket, that +would be very much appreciated: +• Monday, 2/3, 8:15 p.m. departure from JFK, landing at 2:25 p.m. in Stockholm on 2/4, with a layover in London +(American Airlines) +• Thursday, 2/6, 11:40 a.m. departure from Stockholm, landing at 7:30 p.m. at JFK, with a layover in London +(American Airlines) +• +Frequent flier #: +Thanks! +From: +Cc: +Sent: Tuesday, January 21, 2020 2:56 PM +Subject: RE: travel approval request +Approved +From: +Cc: +Sent: Tuesday, January 21, 2020 2:49 PM +Subject: RE: travel approval request +Similar to prior requests in connection with the Epstein investigation (2018R01618), but with an added international +element, we'd like to please request permission for the team to travel next week for an interview near Stockholm, +Sweden, next week on January 29th and/or 30th. We expect to be traveling, respectively, some combination of the 27th +(overnight) to the 31st, depending on when the interview ends up being scheduled, and we'll put final dates on our +formal applications. Also similar to prior trips, we'd like to request approval to get a conference room for one of those +days at a hotel for the interview itself. +Also based on our discussion earlier we'll be mindful of looking for domestic (or domestic-flagged) carrier flights, as well +as the costs of any alternatives, in looking at possible specific bookings. Thanks as always for your help and input on that. +thank you, + + +From: | +Sent: Wednesday, December 11, 2019 09:58 +Cc: +Subject: RE: travel approval request +Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request +permission for the team to travel next week for an interview (or possibly interviews) in Los Angeles on December 16 +and/or 17. We expect to be traveling, respectively, some combination of the 15th to the 18th. Also similar to prior trips, +we'd like to request approval to get a conference room for one of those days. +thank you, +From: +Sent: Tuesday, November 05, 2019 16:53 +To:1 +Cc: +Subject: RE: travel approval request +Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request +permission for the team to travel next week for an interview in Los Angeles on November 14. We expect to be traveling. +respectively, some combination of the 13th to the 15th (and no conference room necessary for this trip). +thanks, +From: +Sent: Tuesday, October 22, 2019 13:55 +To:| +Cc:| +P: +Subject: RE: travel approval request +Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request +permission to travel next week for an interview in West Palm Beach on November 4. It will just be me and | +and +we'll travel some combination of the 3rd to the 5th. And also same as last time, we'd like to ask permission to reserve a +conference room at the hotel on that Monday for the interview, please. +thanks very much, + + +From: +Cc: +Sent: Wednesday, June 12, 2019 14:51 +Subject: RE: travel approval request +Again in connection with the Epstein investigation (2018R01618), we'd like to please request permission to travel next +week for a victim interview in Los Angeles. As of now we tentatively expect to fly down Wednesday and return no later +than Friday (and will keep the timeframe as short as scheduling allows). The trip will be some combination of me, l +and/or_ +1, as previously. And also same as last time, we'd like to ask permission to reserve a conference room at +the hotel on Thursday for the interview, please. +thanks very much, +From: +Sent: Friday, May 24, 2019 14:57 +To: | +Cc: +Subject: RE: travel approval request +Again in connection with the Epstein investigation, we'd like to please request permission to travel for approximately +three days next week for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly +down Tuesday night and return on Wednesday or Thursday (and will keep the timeframe as short as scheduling allows). +Unfortunately we're still trying to pin down timing for interviewing the victims, so depending on the timing it will either +be me and +land +, but we wanted to ask for permission now either way so we weren't doing it +super last minute after the holiday on Tuesday. And also same as last time, we'd like to ask permission to reserve a +conference room at the hotel for the interviews, please. +thanks very much, +From: +Sent: Wednesday, April 03, 2019 20:57 +To: L +Subject: RE: travel approval request +Thank you +From: | +Sent: Wednesday, April 03, 2019 20:46 + + +Subject: Re: travel approval request +Approved +Sent from my iPad +On Apr 3, 2019, at 8:02 PM, L +> wrote: +For the same case as below, United States v. Epstein, 2018R01618, an investigation relating to enticement of minors for +and I would like to please request permission to travel for approximately three days next week for +sexual as aid interview West lalm to pacase ridas risin tere tree mate reader weak +return on Friday, though we will shorten the timeframe if scheduling allows. +Please let us know if any other information would be helpful, and thanks very much. +From: | +Sent: Thursday, March 14, 2019 18:32 +Cc:| +Subject: travel approval request +Land I would like to please request permission for travel for United States v. Epstein, 2018R01618, an +investigation relating to enticement of minors for sexual activity, for two days of meetings and interviews in West Palm +Beach and/or Fort Lauderdale, Florida. As of now we're hoping to fly down next Wednesday night and return on +Saturday. +Please let us know if any other information would be helpful, and thanks as always. +Assistant U.S. Attorney +Southern District of New York \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/03dc0d643a083884e98b63012c323dd994be02e0e100d3ab933655e90aaef0ee.receipt.json b/vision-fixhub/ds9-parsed-01/03dc0d643a083884e98b63012c323dd994be02e0e100d3ab933655e90aaef0ee.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..c2a562a7cca17bc87d6dd81ac58086fe44935b7b --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/03dc0d643a083884e98b63012c323dd994be02e0e100d3ab933655e90aaef0ee.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -69, + "dataset": "marble-joined", + "doc_id": "03dc0d643a083884e98b63012c323dd994be02e0e100d3ab933655e90aaef0ee", + "engine": "marble-apple-vision", + "event_count": 5, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "eb6069f5230ceb7a387dc579ef0b35f3242de048e07da80aac2586a056c0deeb", + "output_sha256": "b24d7458e3a608dcce9602f63b602984930f9f07b2b17d6529f8f0e617903de4", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/03f2532ee4fbf09c0874a7886f44f6a72d643f489481ac1dfb92c3974516a601.md b/vision-fixhub/ds9-parsed-01/03f2532ee4fbf09c0874a7886f44f6a72d643f489481ac1dfb92c3974516a601.md new file mode 100644 index 0000000000000000000000000000000000000000..d178a552f9b36f3a3568a1c5bfaffb96f576291e --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/03f2532ee4fbf09c0874a7886f44f6a72d643f489481ac1dfb92c3974516a601.md @@ -0,0 +1,8 @@ +NOTICE - This email and any attachments are solely for the intended recipient and may be confidential. If you have +received this email in error, please notify the sender and delete it from your system. Do not use, copy or disclose the +information contained in this email or in any attachment without the permission of the sender. Metropolitan Police Service +(MPS) communication systems are monitored to the extent permitted by law and any email and/or attachments may be read +by monitoring staff. Only specified personnel are authorised to conclude binding agreements on behalf of the MPS by email +and no responsibility is accepted for unauthorised agreements reached with other personnel. While reasonable precautions +have been taken to ensure no viruses are present in this email, its security and that of any attachments cannot be +guaranteed. diff --git a/vision-fixhub/ds9-parsed-01/03f2532ee4fbf09c0874a7886f44f6a72d643f489481ac1dfb92c3974516a601.receipt.json b/vision-fixhub/ds9-parsed-01/03f2532ee4fbf09c0874a7886f44f6a72d643f489481ac1dfb92c3974516a601.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..bd43560a9d774e7423be269d49ca05fe0e469ef7 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/03f2532ee4fbf09c0874a7886f44f6a72d643f489481ac1dfb92c3974516a601.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "03f2532ee4fbf09c0874a7886f44f6a72d643f489481ac1dfb92c3974516a601", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "eeb3105a29d905002115641e87c594c05bf1cc1815033919574da1157c843fc7", + "output_sha256": "aeade932af76a6d17b1ef238566d9caeb4af057216726c33a67df985e52166f0", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/040237c0ffc8b7af6540feec8e6e5c2316c0b13d33e954f0c26ebb15b4abf7ee.md b/vision-fixhub/ds9-parsed-01/040237c0ffc8b7af6540feec8e6e5c2316c0b13d33e954f0c26ebb15b4abf7ee.md new file mode 100644 index 0000000000000000000000000000000000000000..57ecd6800fdf3fedddbdab720faf83004773a592 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/040237c0ffc8b7af6540feec8e6e5c2316c0b13d33e954f0c26ebb15b4abf7ee.md @@ -0,0 +1,164 @@ +20-2413-cv +United States Court of Appeals +for the Second Circuit +VIRGINIA L. GIUFFRE, +—against— +GHISLAINE MAXWELL, +Plaintiff-Appellee, +Defendant-Appellant. +ON APPEAL FROM THE UNITED STATES DISTRICT COURT +FOR THE SOUTHERN DISTRICT OF NEW YORK +15-CV-7433 (LAP) +PLAINTIFF-APPELLEE'S RESPONSE TO AMICUS LETTER +BRIEF REGARDING APPELLANT'S MOTION TO +CONSOLIDATE +David Boies +BolEs SCHILLer FLEXNer LLP +333 Main Street +Armonk. New York 10504 +Sigrid S. McCawley +BOlES SCHILLER FLEXNER LLP +401 East Las Olas Boulevard, Suite 1200 +Fort Lauderdale, Florida 33301 +Attorneys for Plaintiff-Appellee + + +Plaintiff Virginia Giuffre submits this response pursuant to this Court's +September 11, 2020, order directing the parties to respond to the Government's +amicus letter brief filed on September 16, 2020. D.E. 113.' Ms. Giuffre agrees with +the Government's position and opposes Defendant's motion to consolidate this +appeal (the "civil appeal") with her appeal in United States v. Maxwell, No. 20-3061 +(the "criminal appeal"). +To the extent that Defendant's criminal appeal is not +dismissed, Defendant's motion to consolidate should be denied. +Courts "should consider both equity and judicial economy" in deciding +whether consolidation is appropriate. Devlin v. Transp. Commo'ns Int'l Union, 175 +F.3d 121, 130 (2d Cir. 1999). "However, under the applicable law, efficiency cannot +be permitted to prevail at the expense of justice—consolidation should be considered +when savings of expense and gains of efficiency can be accomplished without +sacrifice of justice." Id. (emphasis in original) (internal quotation marks omitted). +Here, consolidation would "sacrifice justice" because it would allow Defendant to +hold hostage this Court's mandated unsealing process by tying it to a criminal action +despite the core issues in the civil and criminal appeals bearing no relation to one +another. +First, the issues presented in the criminal appeal have no bearing on the civil +Citations to "D.E." refer to this Court's docket. Ghislaine Maxwell's Appendix is cited +as "App." Virginia Giuffre's Supplemental Appendix is cited as "SA." +1 + + +appeal, and vice versa. As the Government's letter sets forth, Defendant raises new +issues in her appeal papers, including a challenge to the process by which the +Government obtained certain materials that it intends to use against her at her +criminal trial. But Defendant ignores the fact that the only ripe issue before this +Court in the criminal matter is Judge Nathan's refusal to modify the protective order. +D.E. 113 (Gov't Affirmation) 9| 27. Further, contrary to Defendant's attempt to blur +the lines between two distinct district court proceedings, the only issue in the civil +appeal is whether Judge Preska abused her discretion in ordering certain judicial +documents unsealed pursuant to the public's right of access to such documents. +Whether the Government may use evidence against Maxwell during her criminal +trial bears absolutely no relation to whether the public has a right to access that same +evidence if it is a judicial document. The potential disputes between Defendant and +the Government in the criminal matter therefore do not impact Defendant's civil +appeal, or this Court's order on remand to conduct "a particularized review and +unseal all documents for which the presumption of public access outweighs any +countervailing privacy interests." Brown v. Maxwell, 929 F.3d 41, 51 (2d Cir. 2019). +Second, consolidation of the civil and criminal appeals would not further the +interests of equity or judicial economy, as any ruling by the Court in this civil appeal +would not prejudice Defendant's right to a fair trial in her criminal action. The fact +that a judicial document may become public by means of a ruling in the civil +2 + + +unsealing process does not necessarily mean that any such document will be +admissible evidence in Defendant's criminal trial. Defendant will still enjoy all of +the protections of the criminal justice system and the Federal Rules of Evidence, in +addition to having the opportunity to raise objections to the Government's evidencegathering process before Judge Nathan. D.E. 113 9|9l 2, 27. Defendant will also be +able to appeal any final judgment that may be entered against her in the criminal +case. Because the unsealing of the deposition materials at issue in this civil appeal +will not affect her criminal case, the interests of equity and judicial economy do not +favor consolidation of her civil and criminal appeals. +To the contrary, the interests of equity and judicial economy are best served +by denying Defendant's motion for consolidation and allowing the District Court's +unsealing process to proceed. Indeed, this Court sought "to avoid further delay," +and specifically remanded these materials because the District Court could "more +swiftly and thoroughly consider particular objections to unsealing specific +materials." Brown, 929 F.3d at 48, 51 (emphasis added). Defendant, on the other +hand, has sought to hinder the unsealing process at every opportunity, including by +filing "eleventh-hour" motions asserting broad arguments lacking in specificity. +App. 777 ("Ms. Maxwell's eleventh-hour request for reconsideration is denied." +(Preska, J.)); id. at 803-04 ("And, as Ms. Maxwell knows, her ipse dixit does not +provide compelling grounds for relief." (Preska, J.)); D.E. 102 at 3 ("But after +3 + + +fourteen single-spaced pages of heated rhetoric, the Defendant proffers no more than +vague, speculative, and conclusory assertions as to why that is the case." (Nathan, +J.)). For example, Defendant's delay tactics in the civil unsealing process include +raising arguments with the District Court only after rulings against her, App. 778 +n. 1; requesting stays based on "new information" without telling the District Court +what that information is, App. 803; filing generalized, conclusory objections to +unsealing each and every judicial document at issue despite this Court's order that +the District Court conduct a particularized, document-by-document review, App. +406-21; and even suggesting that the entire unsealing process should be stayed +pending resolution of Defendant's criminal trial next year, D.E. 68 at 13. +Defendant's motion to consolidate her civil appeal with her criminal proceedings is +merely her latest attempt to slow down the unsealing process that this Court ordered +over fourteen months ago by delaying a ruling by this Court that could result in the +public viewing judicial documents to which they have a presumptive right of access. +Consolidation of her criminal appeal with her civil appeal would only slow down +the thoughtful and rigorous unsealing process Judge Preska has implemented in the +civil action, which is well underway. SA-61-65, 84-116. +Finally, the equities weigh heavily against consolidation, as combining the +two appeals would only delay further the public's access to judicial documents for +which it has a strong interest in viewing. As this Court has held: "The common law +4 + + +right to public access to judicial documents is firmly rooted in our nation's history." +Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 119 (2d Cir. 2006). This Court +explained that this Circuit's "public access cases and those in other circuits +emphasize the importance of immediate access where a right of access is found." Id. +at 126 (emphasis added). This Court has thus emphasized the need for district courts +to move quickly. Id. ("We take this opportunity to emphasize that the district court +must make its finding quickly."); see also United States v. Erie Cty., N.Y.., 763 F.3d +235, 244 (2d Cir. 2014) ("recognizing the "importance of immediate access where a +right to access is found ....'"'); United States v. Graham, 257 F.3d 143, 147-48 (2d +Cir. 2001) (noting the importance of contemporaneous access). Indeed, Defendant +has argued that this Court should halt the District Court's unsealing process in its +entirety until her criminal trial is completed next year. See D.E. 68 at 13 (requesting +"a stay of the civil case until the resolution of the criminal case"). Any delay that +would result from consolidating Defendant's criminal appeal with the civil appeal, +an appeal of the very first unsealing decision in a review protocol mandated by this +Court over a year ago, would be contrary to the public right of access. +For the foregoing reasons, the Court should deny Defendant's motion to +consolidate. +5 + + +Dated: September 23, 2020 +Respectfully Submitted, +Is/ Sigrid S. McCawley +David Boies +Boies Schiller Flexner LLP +333 Main Street +Armonk, NY 10504 +Sigrid S. McCawley +Boies Schiller Flexner LLP +401 E. Las Olas Blvd., Suite 1200 +Ft. Lauderdale, FL 33301 +6 + + +Certificate of Compliance +Pursuant to Federal Rule of Appellate Procedure 32(g), the undersigned +counsel hereby certifies that this response complies with the type-volume limitation +of the Federal Rules of Appellate Procedure. As measured by the word processing +system used to prepare this response, there are 1,222 words in this response. +/s/ Sigrid S. McCawley +Certificate of Service +I certify that on September 23, 2020, I served a copy of Plaintiff-Appellee's +Response to Amicus Letter Brief Regarding Appellant's Motion to Consolidate via +CM/ECF, which will send notification of the filing to all counsel of record. +/s/ Sigrid S. McCawley +7 diff --git a/vision-fixhub/ds9-parsed-01/040237c0ffc8b7af6540feec8e6e5c2316c0b13d33e954f0c26ebb15b4abf7ee.receipt.json b/vision-fixhub/ds9-parsed-01/040237c0ffc8b7af6540feec8e6e5c2316c0b13d33e954f0c26ebb15b4abf7ee.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..1fc65cd8ed0b3710d57ebba6de5640acc7ffa1d6 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/040237c0ffc8b7af6540feec8e6e5c2316c0b13d33e954f0c26ebb15b4abf7ee.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -98, + "dataset": "marble-joined", + "doc_id": "040237c0ffc8b7af6540feec8e6e5c2316c0b13d33e954f0c26ebb15b4abf7ee", + "engine": "marble-apple-vision", + "event_count": 9, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "11a75eacd4f7eeb4e12bc92c8d50cab6f14a905ac440ebc6747c07b5eefc44ce", + "output_sha256": "8720f8a2727b6f687f2bf3d4f319693d7b8126c950e59cbde7a58f52a2e21ca9", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0411a6a509e095fa28c31b8bed57881bc1fefad775d3a6c088f6f352f574ae83.md b/vision-fixhub/ds9-parsed-01/0411a6a509e095fa28c31b8bed57881bc1fefad775d3a6c088f6f352f574ae83.md new file mode 100644 index 0000000000000000000000000000000000000000..d05e09df5ad07942b83e983219d161f8cfb74bcd --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0411a6a509e095fa28c31b8bed57881bc1fefad775d3a6c088f6f352f574ae83.md @@ -0,0 +1,31 @@ +From: " +To: " +Ce: " +(USANYS)" +Subject: RE: Epstein 6(e) Order Signed and Ready to Pick Up +Date: Mon, 03 Feb 2020 16:36:02 +0000 +Thanks, I believe Judge Nathan was the USDJ on Part 1 on Friday. +From: +To: +Cc: +Sent: Monday, February 3, 2020 11:34 AM +(USANYS) < +Subject: Re: Epstein 6(e) Order Signed and Ready to Pick Up +We can pick up ... only thing is, did this not need to go to Part 1? +order is sufficient, I just ask because I think the prior order was a district judge. +would know better than I whether a mag court +Sent from my iPhone +On Feb 3, 2020, at 11:25, +(USANYS) < +> wrote: +Were you guys able to pick this up? If not, can you send a paralegal over to do so today? Thanks. +From: +(USANYS) < +Sent: Friday, January 31, 2020 5:23 PM +To: +Cc: +(USANYS) < +P: +Subject: Epstein 6(e) Order Signed and Ready to Pick Up +I just got a call from Judge Nathan's clerk that she signed the order and it's ready to be picked up from her +chambers, if one of you want to engineer that right now. diff --git a/vision-fixhub/ds9-parsed-01/0411a6a509e095fa28c31b8bed57881bc1fefad775d3a6c088f6f352f574ae83.receipt.json b/vision-fixhub/ds9-parsed-01/0411a6a509e095fa28c31b8bed57881bc1fefad775d3a6c088f6f352f574ae83.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..e3d598458ec1c5069e0ff22faddcddf87399d159 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0411a6a509e095fa28c31b8bed57881bc1fefad775d3a6c088f6f352f574ae83.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "0411a6a509e095fa28c31b8bed57881bc1fefad775d3a6c088f6f352f574ae83", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "186c9d679a0397f7949a6ae4bc5f5dc46cb815974f1ed579af6ea742c2addad0", + "output_sha256": "4c4d89e068acce721e61e9ae885efdad1e9b6f82c0bd0529b4f7afa60dcc27fe", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0450cf3c8ccad421acb5d255a072ebdf87c83f975329e89f7166b32a190f48b6.md b/vision-fixhub/ds9-parsed-01/0450cf3c8ccad421acb5d255a072ebdf87c83f975329e89f7166b32a190f48b6.md new file mode 100644 index 0000000000000000000000000000000000000000..eed2792b43d17f08cf6544159e38743443e51581 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0450cf3c8ccad421acb5d255a072ebdf87c83f975329e89f7166b32a190f48b6.md @@ -0,0 +1,8 @@ +From: +To: +Subject: RE: Emailing: Y +Date: Wed, 01 Jul 2020 20:03:23 +0000 +0200701101236004_DRAFT.pdf +Thank you! + + diff --git a/vision-fixhub/ds9-parsed-01/0450cf3c8ccad421acb5d255a072ebdf87c83f975329e89f7166b32a190f48b6.receipt.json b/vision-fixhub/ds9-parsed-01/0450cf3c8ccad421acb5d255a072ebdf87c83f975329e89f7166b32a190f48b6.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..c03970c773da6a122461d81b925f1a0c1e66290b --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0450cf3c8ccad421acb5d255a072ebdf87c83f975329e89f7166b32a190f48b6.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "0450cf3c8ccad421acb5d255a072ebdf87c83f975329e89f7166b32a190f48b6", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "de0405d7484aaeac0ab046d7581268d7c9e74ce86f1fbcd615e84b76a427500d", + "output_sha256": "74b4e425f7905ea40e98b12eb914ca1257c8ca60b7ab3945a34aab5fe14064c2", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/04584bdddbf580b5fa254997b685a16c04b641121efb6344829189fe06668155.md b/vision-fixhub/ds9-parsed-01/04584bdddbf580b5fa254997b685a16c04b641121efb6344829189fe06668155.md new file mode 100644 index 0000000000000000000000000000000000000000..b4764fb5fde9efd7b8209febf5b46ffd94169f09 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/04584bdddbf580b5fa254997b685a16c04b641121efb6344829189fe06668155.md @@ -0,0 +1 @@ +No Images Produced diff --git a/vision-fixhub/ds9-parsed-01/04584bdddbf580b5fa254997b685a16c04b641121efb6344829189fe06668155.receipt.json b/vision-fixhub/ds9-parsed-01/04584bdddbf580b5fa254997b685a16c04b641121efb6344829189fe06668155.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..00981af2f72e12c5d82e49d5c92cc5c196ce9632 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/04584bdddbf580b5fa254997b685a16c04b641121efb6344829189fe06668155.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "04584bdddbf580b5fa254997b685a16c04b641121efb6344829189fe06668155", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "977688d2941677f752a0619c040cd6ec00b9957b63d5e99be0419bf71f575d17", + "output_sha256": "3874328764c818fba06683a6d5ddc2edc2d7850aaf4ba18646f81d3f8420a729", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/045fbb64ca945f6cf834c2d30824ba79417c5d632d32733d63eaae3bab92c9a7.md b/vision-fixhub/ds9-parsed-01/045fbb64ca945f6cf834c2d30824ba79417c5d632d32733d63eaae3bab92c9a7.md new file mode 100644 index 0000000000000000000000000000000000000000..fdd7b3af81f13b2970fcd9afb7c283bababb0e5b --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/045fbb64ca945f6cf834c2d30824ba79417c5d632d32733d63eaae3bab92c9a7.md @@ -0,0 +1,59 @@ +From: " +To: " +Ce: "l +(NY) (FBI)" < +Subject: Re: Application for corrected SW +Date: Mon, 26 Oct 2020 14:14:20 +0000 +P. +(USANYS)" +Do you guys have a date and time you would like to try? 12 noon works for us most days. Friday does not work +for us. +Detective +NYPD / FBI +Child Exploitation Human Trafficking Task Force +Office: +Cell: +Fax: +From: | +Sent: Monday, October 26, 2020 10:01 AM +Cc:| +| (NY) (FBI) < +(USANYS) < +Subject: Re: Application for corrected SW +I've canceled todays interview with him and awaiting a response on timing for him for the rest of the week. +Detective +NYPD / FBI +Child Exploitation Human Trafficking Task Force +Office: +Cell: +Fax: +From: +Sent: Sunday, October 25, 2020 1:38 PM +To: +Cc: +1. (NY) (FBI) < +(USANYS) < +Subject: RE: Application for corrected SW +Pi +Hi, +Following up on this, in order to make sure you can spend all day tomorrow focusing on the warrant, we would like to +reschedule the Mullen interview to a different day this week. Would you please reach out to Mullen to ask to reschedule? +Thanks very much, +From: +Sent: Thursday, October 22, 2020 8:44 PM + + +To: l +Cc:| +(NYPD) < +1. (NY) (FBI) < +(USANYS) < +Subject: Application for corrected SW +Paul, +As discussed earlier today, attached please find a draft affidavit in support of an amended warrant for three of the drives +seized from Epstein's NY residence. I'm also attaching the four exhibits referenced in the affidavit. +Please review this closely and let me know if you have any questions or revisions at all. I'll reach out to you on Monday to +talk about when it makes sense to schedule a time to swear this out. +Thanks, +Assistant United States Attorney +Southern District of New York diff --git a/vision-fixhub/ds9-parsed-01/045fbb64ca945f6cf834c2d30824ba79417c5d632d32733d63eaae3bab92c9a7.receipt.json b/vision-fixhub/ds9-parsed-01/045fbb64ca945f6cf834c2d30824ba79417c5d632d32733d63eaae3bab92c9a7.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..c30722b628e76776c9d25c2bd176bb986af3a50b --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/045fbb64ca945f6cf834c2d30824ba79417c5d632d32733d63eaae3bab92c9a7.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "045fbb64ca945f6cf834c2d30824ba79417c5d632d32733d63eaae3bab92c9a7", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "835947fe824ebb2c3ab513c45ac3dc47bfa2a2e73cc4bab1a1006a47c8fe8b19", + "output_sha256": "3913f4422ad95baf58516e4546ee6ae785cf76d7c247516aaaa7e92cb78a1945", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0468879fc2f5b35f1258da5edc5626f7cb0e08c0463a87677aa88e1aca218079.md b/vision-fixhub/ds9-parsed-01/0468879fc2f5b35f1258da5edc5626f7cb0e08c0463a87677aa88e1aca218079.md new file mode 100644 index 0000000000000000000000000000000000000000..d11f67826c53eaf618b115c8ddf6386f0b9633da --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0468879fc2f5b35f1258da5edc5626f7cb0e08c0463a87677aa88e1aca218079.md @@ -0,0 +1,47 @@ +MUNICIPAL CREDIT UNION +PO Box 3205 CSS +New York, NY 10007 +Tel: (212) 693-4900 +Fax: (212) 238-2700/2701 +BUSINESS RECORD CERTIFICATION +(Pursuant to C.P.L.R. 3122-a) +Our Reference: SUB9316-D.J, +State of New York +) +) S.s: +County of New York) +being duly sworn, deposes and says: +I am a duly authorized custodian of the attached records and am authorized to make the +within certification of behalf of Municipal Credit Union. +To the best of my knowledge, after reasonable inquiry, the records or copies thereof are +accurate versions of the documents described in the subpoena duces tecum (a copy of +which I annexed hereto) that are in the possession, custody, or control of Municipal +Credit Union, the recipient of the subpoena. +To the best of my knowledge, after reasonable inquiry, the records and copies produced: +represent all the documents described in the subpoena duces tecum +(or) +do not represent a complete set of the documents described in the subpoena duces +tecum. The missing documents, and the reason for their absence, are as follows: +Description of Missing Document +Reason for Absence +Checks +Not Applicable +Credit Cards Statements +Not Applicable +These records do not contain Suspicious Activity Reports or Currency Transaction +Reports. Municipal Credit Union's BSA Department will respond directly to any request +for Suspicious Activity Reports or Currency Transaction Reports. +make or maintain these records. +Signature/Date +U +9/4/19 +State of New York +County of NY +Sworn to before me this +NOTARY PUBSIC Y +4 +day or Sept. 2019 +Notary Public, State of New York +No.L +Qualified in queens County +erm Expires April 12, 202. diff --git a/vision-fixhub/ds9-parsed-01/0468879fc2f5b35f1258da5edc5626f7cb0e08c0463a87677aa88e1aca218079.receipt.json b/vision-fixhub/ds9-parsed-01/0468879fc2f5b35f1258da5edc5626f7cb0e08c0463a87677aa88e1aca218079.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..96e1d238c997dcd358018b03cc04de5e85c9d56e --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0468879fc2f5b35f1258da5edc5626f7cb0e08c0463a87677aa88e1aca218079.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "0468879fc2f5b35f1258da5edc5626f7cb0e08c0463a87677aa88e1aca218079", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "57ac2ec2ec89f5aa356f9de293894f3c0c26f445942e9c85c898bd65120843fc", + "output_sha256": "de460c89c7eead5525ca6f093672677bbfd8e603131fc6112794362524a20b94", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/04884812fa7b6090b21501cda607063d97bc576177c0c9217cadf00f45f2bb19.md b/vision-fixhub/ds9-parsed-01/04884812fa7b6090b21501cda607063d97bc576177c0c9217cadf00f45f2bb19.md new file mode 100644 index 0000000000000000000000000000000000000000..cd5b9228a811bd8afcd7f0b06515fa1b2561e232 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/04884812fa7b6090b21501cda607063d97bc576177c0c9217cadf00f45f2bb19.md @@ -0,0 +1,28 @@ +From: +To: +Subject: Fwd: Federal Criminal Practice Committee: Testimony of David Patton +Date: Wed, 16 Oct 2019 21:07:39 +0000 +Begin forwarded message: +From: +Date: October 16, 2019 at 1:37A14 PM EDT +To: +Cci +Subject: RE: Federal Criminal Practice Committee: Testimony of David Patton +Thanks, +This is actually really interesting. +From: +To: +Cc: +Sent: Wednesday, October 16, 2019 12:16 PM +Subject: Federal Criminal Practice Committee: Testimony of David Patton +Attached from yesterday's Federal Bar Council committee meeting is Congressional testimony that will be released +tomorrow by David Patton before the Judiciary Committee's Subcommittee on Crime, Terrorism and Homeland Security, +which is conducting an oversight hearing on the BOP and on the implementation of the First Step Act. +Patton's testimony, which runs twelve pages, discusses among other things conditions at the MCC and MDC, particularly +this winter's power outage at the MDC, and, briefly, suicide at the MCC, with mention of Jeffrey Epstein. At one point, +Patton's testimony is somewhat critical of the Office, contrasting out case against Rikers Island to his allegation that +"the office has never done anything about the MCC." (Page 5). Patton discusses the IG Report, which he says failed to +"discuss MDC's officials lies" concerning the MDC power outage. Patton says there has been "no real accountability" +and points out that Warden +I was promoted. +I will attempt to view David's testimony if it is available on C-Span. diff --git a/vision-fixhub/ds9-parsed-01/04884812fa7b6090b21501cda607063d97bc576177c0c9217cadf00f45f2bb19.receipt.json b/vision-fixhub/ds9-parsed-01/04884812fa7b6090b21501cda607063d97bc576177c0c9217cadf00f45f2bb19.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..7c6fb41135add09027f27556b4d7d0f9e9c8ed3e --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/04884812fa7b6090b21501cda607063d97bc576177c0c9217cadf00f45f2bb19.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "04884812fa7b6090b21501cda607063d97bc576177c0c9217cadf00f45f2bb19", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "945fcb652631681b5caf9e11a36d0cf707f9d11a6e4c297978b0de8a31345a96", + "output_sha256": "c459597afca913836bdea44c531084f1ae005bdac0968f4b8aab8ae2a325f049", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/04a44dde992d9fbfa6326290ccba763c96f9657bdae833c71498b1f93c7db845.md b/vision-fixhub/ds9-parsed-01/04a44dde992d9fbfa6326290ccba763c96f9657bdae833c71498b1f93c7db845.md new file mode 100644 index 0000000000000000000000000000000000000000..7e3057a2c5944424898e0b28c43f492a8e0c86e3 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/04a44dde992d9fbfa6326290ccba763c96f9657bdae833c71498b1f93c7db845.md @@ -0,0 +1,46 @@ +From: "l +To: "l +(USANYS)" < +(USANYS)" { +Cc: +(USANYS)" ‹ +Subject: RE: FBI shares Jeffrey Epstein findings with victims - including Prince Andrew info - Mirror +Online +Date: Thu, 12 Nov 2020 16:40:06 +0000 +Will do. Thanks, +•----Original Message-- +I (USANYS) + +Sent: Thursday, November 12, 2020 11:00 AM +To: +(USANYS) ≤ +(USANYS) +Subject: RE: FBI shares Jeffrey Epstein findings with victims - including Prince Andrew info - Mirror Online +I would refer this to Main. This is an ODAG meeting, not us. +-----Original Message--. +From: +(USANYS) < +Sent: Thursday, November 12, 2020 10:36 AM +To: +(USANYS) +(USANYS) < +Subject: Re: FBI shares Jeffrey Epstein findings with victims - including Prince Andrew info - Mirror Online +NBC has the letter to the victims. +Sent from my iPhone +> On Nov 12, 2020, at 10:32 AM, +P wrote: +> +> Thanks for letting us know. I defer to you and to our chiefs on what if anything should be communicated to the +Post about this, but the background is: the FBI and the Office of Professional Responsibility are meeting with +victims to discuss OPR's findings in connection with their investigation of the Southern District of Florida's +dealings with victims. This will largely deal with the Crime Victims' Rights Act and the manner in which the +NPA was negotiated. The meeting will not discuss the criminal investigation or anything dealing with our office. +> Sent from my iPhone +>> On Nov 12, 2020, at 9:57 AM, +> wrote: +>> +>> The N. Y. Post is asking what this is about/is it true. The Mirror story says the FBI will be sharing details with +Epstein victims. +>> + + +>> https://www.mirror.co.uk/news/us-news/fbi-release-findings-jeffrey-epstein-22995977 diff --git a/vision-fixhub/ds9-parsed-01/04a44dde992d9fbfa6326290ccba763c96f9657bdae833c71498b1f93c7db845.receipt.json b/vision-fixhub/ds9-parsed-01/04a44dde992d9fbfa6326290ccba763c96f9657bdae833c71498b1f93c7db845.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..1b987f6f2e1d9f0305bc3950081eb191422fbc45 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/04a44dde992d9fbfa6326290ccba763c96f9657bdae833c71498b1f93c7db845.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "04a44dde992d9fbfa6326290ccba763c96f9657bdae833c71498b1f93c7db845", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "b7ccdeec3086651b8750846fcf793f4e5b6ec9887fc5b759f71718b98a399f18", + "output_sha256": "bcb7f339105160c295d39ec12fb4037bfc8ea41b94b34213668b2311f02d401e", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/04ab2a1146746834ebb39393c36844cb3ab482663f39dd60ff6580228596100e.md b/vision-fixhub/ds9-parsed-01/04ab2a1146746834ebb39393c36844cb3ab482663f39dd60ff6580228596100e.md new file mode 100644 index 0000000000000000000000000000000000000000..69bebe65eb41f5d93b56349672738a3fb3487191 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/04ab2a1146746834ebb39393c36844cb3ab482663f39dd60ff6580228596100e.md @@ -0,0 +1,104 @@ +From: +To: ' +Subject: RE: Grand Jury Materials for Federal Investigation +Date: Mon, 26 Oct 2020 22:40:49 +0000 +Apologies, I was tied up in court and on calls all day. I will give you a call tomorrow. +Thank you, +From: +To: +Sent: Monday, October 26, 2020 4:23 PM +Subject: RE: Grand Jury Materials for Federal Investigation +Please give me a call when you get a chance so we can discuss transfer of documents. Thank you, I +From: +To: +Cc: +Sent: Friday, October 23, 2020 5:51 PM +Subject: RE: Grand Jury Materials for Federal Investigation +****** Note: This email was sent from a source external to Palm Beach County. Links or attachments should +not be accessed unless expected from a trusted source. ****** +Good evening, +Attached please find a signed unsealing order. +Thank you, + + +From: +To: " +Cc: +Sent: Thursday, October 15, 2020 9:28 PM +Subject: RE: Grand Jury Materials for Federal Investigation +Thank you very much. I will send you the unsealing order as soon as it is signed. +From: +To: +Cci +Sent: Thursday, October 15, 2020 9:25 PM +> +Subject: Re: Grand Jury Materials for Federal Investigation +Case No. 50-2006-CF-009454 AXX in 15th Judicial Circuit , Palm Beach County, Florida. +On Oct 15, 2020, at 4:59 PM, +> wrote: +****** Note: This email was sent from a source external to Palm Beach County, Links or attachments should +not be accessed unless expected from a trusted source. ****** +Hi +Following up on my original email to | +below, we would be very grateful for any guidance regarding how we might +obtain copies of the grand jury materials related to Jeffrey Epstein. We are happy to have a call to discuss if that would +be useful. +Thank you, + + +From: +To: +Cc: +Sent: Thursday, October 15, 2020 4:49 PM +Subject: RE: Grand Jury Materials for Federal Investigation +Hi +I'm not exactly the right person to ask -I handle communications for the office. However, I can connect you with the +person who can walk you through the process here: +1, our Chief Operating Officer for Courts and Legal +Records and our Acting General Counsel. +I've copied her on this email so you have her contact information. +Thank you, +Chief Communications Officer +Executive +Clerk & Comptroller Palm Beach County +Serving the Citizens of Palm Beach County +301 N. Olive Ave., 9th Floor +West Palm Beach, FL 33401 +Direct +www.mypalmbeachclerk.com_[protect2.fireeye.com] +Tell us how we're doing at www.mypalmbeachclerk.com/survey_[protect2.fireeye.com]l +_image001 jpg=[protect2.fireeye.com| +[twitter.com].[protect2.fireeye.com|l[protect2.fireeye.com] +Simage001.ipg2|protect2.fireeye.com|| +[facebook.com|_[protect2.fireeye.com||[protect2.fireeye.com] +Kimage001.jpg>[protec12.fireeye.com] +Please be advised that Florida has a broad public records law, and all correspondence to me may be subject to +disclosure. Under Florida public records laws email addresses are public records. If you do not want your email address +released in response to a public records request, do not send electronic mail to this entity. Instead, contact this office by +phone or in writing. +From: +To: +Cc: +[mailto: +Sent: Thursday, October 15, 2020 4:25 PM +(USANYS) < +Subject: Grand Jury Materials for Federal Investigation +****** Note: This email was sent from a source external to Palm Beach County. Links or attachments should +not be accessed unless expected from a trusted source. ****** + + +Good afternoon, +The Office of the State Attorney for the 15th Judicial Circuit provided me with your contact information and suggested +you may be able to assist my office with a request for records. Together with my colleagues AUSA L +and AUSA +I (both cc'd), I am one of the federal prosecutors handling the ongoing investigation regarding Jeffrey +Epstein and prosecution of Ghislaine Maxwell. +We understand that evidence, including witness testimony, relevant to our investigation may have been presented to a +grand jury in your courthouse in connection with the prosecution of Jeffrey Epstein. How might our office obtain a copy +of any transcripts, records, and related materials from those grand jury presentations? When seeking such items from +state courts in New York, we regularly obtain unsealing orders from a federal judge in our district. Would such an order +suffice for your court, or are there other procedures you would like us to follow? +We are happy to have a phone call to discuss this request if that would be useful. I can be reached by email or at the +phone number below. +Thank you very much for your assistance. +Best, \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/04ab2a1146746834ebb39393c36844cb3ab482663f39dd60ff6580228596100e.receipt.json b/vision-fixhub/ds9-parsed-01/04ab2a1146746834ebb39393c36844cb3ab482663f39dd60ff6580228596100e.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..e5f779ff288b1e8fa3e8925b0b37e96182c0df6d --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/04ab2a1146746834ebb39393c36844cb3ab482663f39dd60ff6580228596100e.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -377, + "dataset": "marble-joined", + "doc_id": "04ab2a1146746834ebb39393c36844cb3ab482663f39dd60ff6580228596100e", + "engine": "marble-apple-vision", + "event_count": 5, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "d4a9887dea2a1373782c17be3b351d4a6f773b15be6fe13bbe42bba58b2246eb", + "output_sha256": "13f4de258d035c76c971110b73981e862df5d088dec33d97d7e1db632edd3160", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/04be0d9d9e21dbc4efd7b341d4739a1560592a7c78933889ca687be8689ef796.md b/vision-fixhub/ds9-parsed-01/04be0d9d9e21dbc4efd7b341d4739a1560592a7c78933889ca687be8689ef796.md new file mode 100644 index 0000000000000000000000000000000000000000..31ee6c7455f6d15bef7321cdbbe9b63e762444d3 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/04be0d9d9e21dbc4efd7b341d4739a1560592a7c78933889ca687be8689ef796.md @@ -0,0 +1,41 @@ +NITED STATES DISTRICT COUR +OUTHERN DISTRICT OF NEW YORK +- X +UNITED STATES OF AMERICA, +V. +GHISLAINE MAXWELL, +20 Cr. 330 (AJN) +NOTICE OF MOTION +ORAL ARGUMENT REQUESTED +Defendant. +- x +DEFENDANT GHISLAINE MAXWELL'S NOTICE OF MOTION TO DISMISS +COUNTS FIVE AND SIX OF THE SUPERSEDING INDICTMENT BECAUSE THE +ALLEGED MISSTATEMENTS ARE NOT PERJURIOUS AS A MATTER OF LAW +(Pretrial Motion # 4) +PLEASE TAKE NOTICE that, upon the accompanying memorandum of law and +exhibits, Defendant Ghislaine Maxwell, through counsel, hereby moves to dismiss Counts Five +and Six of the Superseding Indictment because the alleged misstatements are not perjurious as a +matter of law. +Dated: January 25, 2021 +New York, New York + + +Respectfully submitted, +s/ Jeffrey S. Pagliuca +Jeffrey S. Pagliuca +Laura A. Menninger +HADDON, MORGAN & FOREMAN P.C. +150 East 10th Avenue +Phonet: CO 80203 +Mark S. Cohen +Christian R. Everdell +COHEN & GRESSER LLP +800 Third Avenue +New York, NY 10022 +Phone: +Bobbi C. Sternheim +Law Offices of Bobbi C. Sternheim +33 West 19th Street - 4th Floor +New York. NY 10011 +Attorneys for Ghislaine Maxwell diff --git a/vision-fixhub/ds9-parsed-01/04be0d9d9e21dbc4efd7b341d4739a1560592a7c78933889ca687be8689ef796.receipt.json b/vision-fixhub/ds9-parsed-01/04be0d9d9e21dbc4efd7b341d4739a1560592a7c78933889ca687be8689ef796.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..8032cbb951c852246b69869aad3b9e922514b7b2 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/04be0d9d9e21dbc4efd7b341d4739a1560592a7c78933889ca687be8689ef796.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "04be0d9d9e21dbc4efd7b341d4739a1560592a7c78933889ca687be8689ef796", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "83aa7a7cd501587f259154190d10afbdcc0e1de2cd5bf5fc30283246df5fa1fa", + "output_sha256": "77316a7606516a3dfbd07e0856f145c5b3f8e7fe9b99336a145e1eb5b23e916d", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/04ed92bccb7ad9dd2ca82c09a356bd950f7bdceab910cb79857685aca3f379af.md b/vision-fixhub/ds9-parsed-01/04ed92bccb7ad9dd2ca82c09a356bd950f7bdceab910cb79857685aca3f379af.md new file mode 100644 index 0000000000000000000000000000000000000000..34a846736d96644e2f580d38e8446931168d969f --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/04ed92bccb7ad9dd2ca82c09a356bd950f7bdceab910cb79857685aca3f379af.md @@ -0,0 +1,113 @@ + + + +December 18, 2020, Paris. +Response to the government's memorandum in opposition to the defendant's renewed +motion for release. +I was asked to review the United States government's memorandum and notably pages 15 to +17 alongside the French Minister of Justice's letter dated 11 December 2020 produced as +Exhibit B to this memorandum. +The French Minister of Justice's letter (Exhibit B) +The letter of the French Minister of Justice, on which the US government relies to argue that +the French government does not extradite its citizens outside the European Union and thus to +the United States, quotes Article 696-2 of the French Code of Criminal Procedure, which +provides that France can extradite "any person not having French nationality" +It remains unclear whether the author of such letter had actually access to my opinion which is +not even quoted, and more generally it seems the letter responds to a question which +unexpectedly was not disclosed. +The letter fails to mention, however, that Article 696 of the same Code provides that provisions +of the French Code of Criminal Procedure on the conditions of extradition apply in the absence +of an international agreement providing otherwise (Article 696 of the French Code of +Criminal Procedure: "In the absence of an international agreement stipulating otherwise, the +conditions, procedure and effects of extradition shall be determined by the provisions of this +chapter'. These provisions shall also apply to matters which would not have been regulated by +international conventions"). The provisions of Article 696 of the French Code of Criminal +Procedure are a reminder that under Article 55 of the French Constitution, international +agreements prevail over national legislation (Article 55 of the French Constitution: "Treaties +or agreements that have been duly ratified or approved have, upon their publication, an +authority superior to that of laws, subject, for each agreement or treaty, to its application by +the other party"). It follows from these provisions that the key question is whether France may +extradite a French national under the Extradition Treaty between the USA and France and/or +under the Extradition Treaty between the European Union and the USA, not whether France +extradites its citizens under French legislation. +In accordance with this French constitutional rule, the administrative circular of 11 March 2004, +published by the French Ministry of Justice, which aims at specifying how the then recently +amended legal provisions regarding extradition should apply and be understood, states the +following: "Article 696 of the Code of Criminal Procedure reaffirms this principle of +1 The relevant chapter includes Articles 696-1 to Article 696-47-1 of the French Code of Criminal Procedure, +and thus includes Article 696-2. +51, RUE AMPÈRE - 75017 PARIS - TÉL. 01 88 33 51 80 - FAX. 01 88 33 51 81 + + +subsidiarity of domestic law in relation to international instruments as stated by the +aforementioned law of 10 March 1927: the legislative provisions on extradition are applicable +only in the silence or in the absence of international conventions."2 +It follows from the provisions of Article 696 of the French Code of Criminal Procedure that the +key question is whether France may extradite a French national under the Extradition Treaty +between the USA and France and/or under the Extradition Treaty between the European Union +and the USA, not whether France may extradite its citizens under French legislation. +As previously outlined, the Extradition Treaty between the USA and France does not preclude +the French government from extraditing a French national and must therefore be distinguished +from a number of other international agreements signed by France which contain a clear +prohibition to that extent. The Treaty between the USA and France gives the French +government discretion as to whether or not to extradite its own citizens to the USA. +It is noted that the letter of the French Minister does not provide any answer on this issue. +2 The DOJ Memorandum and the Peterson Case +In support of its argument that the French government would not extradite Ms Ghislaine +Maxwell to the USA, the government relies on the case of Mr Hans Peterson, a dual French +American citizen whose extradition to the US was denied by France in 2007. +The Peterson precedent should only be cited with great caution. First, I am not aware that this +case has given rise to a published judicial decision, therefore it should not be interpreted as the +support of any legal rule or principle. In addition, in regards to the documents that the DOJ has +referred to in its memorandum, I doubt that a judicial decision has ever occurred in this case: +as mentioned by the 2007 letter of US Senators Richard J. Durbin and Barack Obama to the +French Minister of Foreign Affairs, the French Minister of Justice communicated its decision +refusing extradition on August 22nd 2007, only a few days after the suspect was arrested (at the +beginning of August 2007). This decision is not a Court decision but a discretionary decision +from the French Ministry of Justice. It actually seems very unlikely that a court decision could +have been rendered in this timeframe. This indicates that the case must not have been handed +on to the court by the Ministry of Justice in the earliest stage of the extradition process. +A refusal to extradite may possibly be challenged by the requesting government before the +French Conseil d'Etat, which is the French Supreme Court for administrative matters, as for +example the United Kingdom and Hong Kong successfully challenged a decision from the +French authorities not to extradite an individual whose extradition they had requested (Conseil +d'Etat, 15 October 1993, no. 142578). In the Peterson case, the American government did not +" Circulaire Mandat d'arrêt européen et Extradition n° CRIM-04-2/CAB-11.03.2004 du 11 mars 2004 +51, RUE AMPÈRE - 75017 PARIS - TÉL. 01 88 33 51 80 - FAX. 01 88 33 51 81 + + +challenge the refusal before French courts, while such challenge could have led to a judicial +review of the request, in accordance with the ordinary extradition procedure. +Secondly, in the absence of a published judicial decision, it is impossible to determine what the +outcome of this case would have been if it had come before the courts. +Third, as was rightly pointed out by US Senators Richard J. Durbin and Barack Obama in their +aforementioned letter to the French Minister of Foreign Affairs, which the government cites in +its memorandum: +"Article 3 of the Extradition Treaty between the United States and France provides in +pertinent part that "There is no obligation upon the Requested State to grant the +extradition of a person who is a national of the Requested State". While this Article +does not require the extradition of a national to a requesting state, it also does not +appear to preclude extradition. To the extent there is discretion available in such +extradition decisions, we urge the French government to exercise that discretion in +favor of extradition". +I am satisfied that this is the right interpretation of Article 3, as this is exactly the conclusion I +came to in my first report. To the extent that there is a discretion, there can be no absolute rule +against the extradition of nationals under French law. A discretionary power is not a legal rule. +Indeed, there is no constitutional principle against the extradition of nationals. For these +reasons, the Peterson case does not alter my view that under the specific and unique facts of +this case, it is highly unlikely that the French government would refuse to issue and execute an +extradition decree against Ms. Maxwell, particularly if Ms. Maxwell has signed an irrevocable +waiver in the USA. +Finally, if an extradition request were to be issued against a French citizen today, the obligations +of the French government under the Extradition Treaty between the USA and France would +also need to be read in light of the Agreement on extradition between the European Union and +the United States of America, which came into force on February 1, 2010, several years after +the Peterson case. Article 1 of this Agreement, which enhances cooperation between +Contracting Parties, provides that: "The Contracting Parties undertake, in accordance with the +provisions of this Agreement, to provide for enhancements to cooperation in the context of +applicable extradition relations between the Member States and the United States of America +governing extradition of offenders". The existence of this Agreement would need to be taken +into account by the French government in the exercise of its discretion as to whether or not to +grant the extradition of a French national to the USA. +William JULIE +51, RUE AMPÈRE - 75017 PARIS - TÉL. 01 88 33 51 80 - FAX. 01 88 33 51 81 \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/04ed92bccb7ad9dd2ca82c09a356bd950f7bdceab910cb79857685aca3f379af.receipt.json b/vision-fixhub/ds9-parsed-01/04ed92bccb7ad9dd2ca82c09a356bd950f7bdceab910cb79857685aca3f379af.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..f341a15040f50f67020862eb60057bc8cee23071 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/04ed92bccb7ad9dd2ca82c09a356bd950f7bdceab910cb79857685aca3f379af.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -313, + "dataset": "marble-joined", + "doc_id": "04ed92bccb7ad9dd2ca82c09a356bd950f7bdceab910cb79857685aca3f379af", + "engine": "marble-apple-vision", + "event_count": 6, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "f16e744972df09ea3559a3f23f7a02254a79e56dc78342fe4263c8145fd8b1ef", + "output_sha256": "a8aac79b2b8ebc2d6c3b252981b3b344b35fc79b2702329649ff5f82a3adebdc", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/05075bbb9af006a455a8cc394c812fbd37a986e51e535be197f0a86aa1680159.md b/vision-fixhub/ds9-parsed-01/05075bbb9af006a455a8cc394c812fbd37a986e51e535be197f0a86aa1680159.md new file mode 100644 index 0000000000000000000000000000000000000000..c5aad53e65260db3eecbf339098e0c1ec53338b3 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/05075bbb9af006a455a8cc394c812fbd37a986e51e535be197f0a86aa1680159.md @@ -0,0 +1,27 @@ +From: " +To: +Subject: Re: Epstein #76318-054 +Date: Wed, 24 Jul 2019 15:34:28 +0000 +Importance: Normal +Attachments: TEXT.htm +Okay, thank you. Perhaps you can advise the Duty PA to ensure the inmate receives the medication while on Psychological +Observation? If not, I can do so. +>>> +Hello, +7/24/2019 11:32 AM > > > +Hm.. his docusate sodium 100mg (colace) was filled for a 30 day supply on 7/12.? +Thank You, +, PharmD, MS, BCACP +CAPT, U.S. Public Health Service +Chief Pharmacist +MCC New York +150 Park Row, +New York, NY 10007 +"This message is intended for official use and may contain SENSITIVE information. If this message contains SENSITIVE +information, it should be properly delivered, labeled, stored, and disposed of according to policy." +Commissioned Corps of the United States Public Health Service - +"Protecting, promoting, and advancing the health and safety of the +Nation" +>> +7/24/2019 10:57 AM > > > +This inmate, who is currently on Psychological Observation, said he has not been receiving his constipation medication. diff --git a/vision-fixhub/ds9-parsed-01/05075bbb9af006a455a8cc394c812fbd37a986e51e535be197f0a86aa1680159.receipt.json b/vision-fixhub/ds9-parsed-01/05075bbb9af006a455a8cc394c812fbd37a986e51e535be197f0a86aa1680159.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..f5bd955779d044562a83624a2780726b8c66dbd3 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/05075bbb9af006a455a8cc394c812fbd37a986e51e535be197f0a86aa1680159.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": 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"marble-apple-vision", + "event_count": 10, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "31026ec65b098ba2c160fc001fd0810898415f91271702d424c66267a40ac7f4", + "output_sha256": "3428927d98f9574cffbc37b6f976561cdf4d7be9a7f48ec874631fec584ea675", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0538ea4dc38583041d7b8a0c9f1d2177af714d072609ef2063e784b848674d74.md b/vision-fixhub/ds9-parsed-01/0538ea4dc38583041d7b8a0c9f1d2177af714d072609ef2063e784b848674d74.md new file mode 100644 index 0000000000000000000000000000000000000000..b356cd0e977d0dbfcb30d3d890ff274cdd8385ac --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0538ea4dc38583041d7b8a0c9f1d2177af714d072609ef2063e784b848674d74.md @@ -0,0 +1,113 @@ +U.S. Department of Justice +United States Attorney +Southern District of New York +The Silvin J. Mollo Building +One Saint Andrew's Plaz +New York, New York 1000 +July 11,2019 +Metropolitan Correctional Center +Attn: Legal Department +150 Park Row +New York, New York 10007 +Re: Grand Jury Subpoena +Please be advised that the accompanying grand jury subpoena has been issued in connection with +an official criminal investigation of a suspected felony being conducted by a federal grand jury. The +Government hereby requests that you voluntarily refrain from disclosing the existence of the subpoena to +any third party. While you are under no obligation to comply with our request, we are requesting you not +to make any disclosure in order to preserve the confidentiality of the investigation and because disclosure +of the existence of this investigation might interfere with and impede the investigation. +In addition to the materials requested in the enclosed subpoena, please accept this letter (in lieu of +a subpoena) as our written request for the e-mail correspondence of inmate Jeffrey Epstein (76318-054) +from July 6, 2019 through July 11, 2019 - excluding any correspondence between Epstein and the +following attorneys: Marc Fernich +_, Martin Weinberg +and +), and Reid Weingarten ( +Moreover, if you intend to disclose the existence of this subpoena to a third party, please let me +know before making any such disclosure. +Thank you for your cooperation in this matter. +Very truly yours, +GEOFFREY S. BERMAN +United States Attorney + + +Grand Jury Subpoena +United States District Onurt +SOUTHERN DISTRICT OF NEW YORK +TO: +Metropolitan Correctional Center +Attn: Legal Department +150 Park Row +New York, New York 10007 +GREETINGS: +WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend before +he GRAND JURY of the people of the United States for the Southern District of New York, at the United State +Courthouse, 40 Foley Square, Room 220, in the Borough of Manhattan, City of New York, New York, in th +Southern District of New York, at the following date, time and place: +Appearance Date: +July 12, 2019 +Appearance Time: 10:00 a.m. +to testify and give evidence in regard to an alleged violation of : +18 U.S.C. §§ 1591, 1594(c), 2422(b) +and not to depart the Grand Jury without leave thereof, or of the United States Attorney, and that you bring +with you and produce at the above time and place the following: +SEE ATTACHED RIDER. +Personal appearance is not required if the requested records are (1) produced by on or before the return +date to Special Agent Eric Blachman and/or Assistant U.S. Attorney +at: U.S. Attorney's +Office, Southern District of New York, 1 St. Andrew's Plaza, New York, NY 10007, telephone: +or via email at +and (2) accompanied by an executed copy of the +attacned Declaration of Custodian of Records. PLEASE PROVIDE IN ELECTRONIC FORMAT IF +POSSIBLE. +Failure to attend and produce any items hereby demanded will constitute contempt of court and will +subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law. +DATED: New York, New York +July 11, 2019 +GEOFFREY S. BERMAN +United States Attorney for the +Southern District of New York +STATES +rev. 02.01.12 + + +RIDER +(Grand Jury Subpoena to Metropolitan Correctional Center, dated July 11, 2019) +Please provide any and all available audio recordings and other records of, or relating to, +telephone calls to or from inmate Jeffrey Epstein (76318-054) for the period July 6, 2019 through July +11, 2019. +Except please EXCLUDE any communications with the following individuals and/or phone +numbers: +• Mare Fernicl +• Martin Weinber +Raid Mainmadon + + +Declaration of Custodian of Records +Pursuant to 28 U.S.C. § 1746, I, the undersigned, hereby declare: +My name is +(name of declarant) +I am a United States citizen and I am over eighteen years of age. I am the custodian of records of +the business named below, or 1 am otherwise qualified as a result of my position with the business named +below to make this declaration. +I am in receipt of a Grand Jury Subpoena, dated July 11, 2019, and signed by Assistant United +States Attorney +, requesting specified records of the business named below. Pursuant to +Rules 902(11) and 803(6) of the Federal Rules of Evidence, I hereby certify that the records provided +herewith and in response to the Subpoena: +(1) were made at or near the time of the occurrence of the matters set forth in the records, by, or +from information transmitted by, a person with knowledge of those matters; +(2) were kept in the course of regularly conducted business activity; and +(3) were made by the regularly conducted business activity as a regular practice. +I declare under penalty of perjury that the foregoing is true and correct. +Executed on +(date) +(signature of declarant) +(name and title of declarant) +(name of business) +(business address) +Definitions of terms used above: +As defined in Fed. R. Evid. 803(6), "record" includes a memorandum, report, record, or data compilation, +in any form, of acts, events, conditions, opinions, or diagnoses. The term, "business" as used in Fed. R. +Evid. 803(6) and the above declaration includes business, institution, association, profession, occupation, +and calling of every kind, whether or not conducted for profit. diff --git a/vision-fixhub/ds9-parsed-01/0538ea4dc38583041d7b8a0c9f1d2177af714d072609ef2063e784b848674d74.receipt.json b/vision-fixhub/ds9-parsed-01/0538ea4dc38583041d7b8a0c9f1d2177af714d072609ef2063e784b848674d74.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..c2599c6addca042ba8d583ad41904df61cec57d6 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0538ea4dc38583041d7b8a0c9f1d2177af714d072609ef2063e784b848674d74.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -48, + "dataset": "marble-joined", + "doc_id": "0538ea4dc38583041d7b8a0c9f1d2177af714d072609ef2063e784b848674d74", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "62b0be5b47f410bd5e2c6b4943599aa64cfe4a8105c9691e5851b548c561fba8", + "output_sha256": "7d9e15db0f1305e58de1bda287ce5c5f6b39fbe1b03acfef6520c385fc9484df", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0547d02ca8cf2d2a9d621d3bc546648b1337cb7d278766de02cfcf5af7c62f9f.md b/vision-fixhub/ds9-parsed-01/0547d02ca8cf2d2a9d621d3bc546648b1337cb7d278766de02cfcf5af7c62f9f.md new file mode 100644 index 0000000000000000000000000000000000000000..924b337dde846371cc154c0cc1946e58d2d39d69 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0547d02ca8cf2d2a9d621d3bc546648b1337cb7d278766de02cfcf5af7c62f9f.md @@ -0,0 +1,177 @@ +U.S. Department of Justice +United States Attorney +Southern District of New York +New York, New York 10007 +August 16, 2019 +JP Morgan Chase Bank N.A. And All Affiliates +National Subpoena Processing +7610 West Washing Street +Indianapolis, Indiana 46231-1335 +Fax Number: 317-757-7421 +Re: +Grand Jury Subpoena +Please be advised that the accompanying grand jury subpoena has been issued in +connection with an official criminal investigation of a suspected felony being conducted by a +federal grand jury. The Government hereby requests that you voluntarily refrain from disclosing +he existence of the subpoena to any third party. While you are under no obligation to comply +vith our request, we are requesting you not to make any disclosure in order to preserve th +confidentiality of the investigation and because disclosure of the existence of this investigation +might interfere with and impede the investigation. +Thank you for your cooperation in this matter. +Very truly yours, +GEOFFREY S. BERMAN +United States Attornev +By: +Assistant United States Attorney +Southern District of New York + + +Grand Jury Subpoena +United States District Court +SOUTHERN DISTRICT OF NEW YORK +TO: JP Morgan Chase Bank N.A. And All Affiliates +National Subpoena Processing +7610 West Washing Street +Indianapolis, Indiana 46231-1335 +Fax Number: 317-757-7421 +GREETINGS: +WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend +before the GRAND JURY of the people of the United States for the Southern District of New York, at +the United States Courthouse, 40 Foley Square, Room 220, in the Borough of Manhattan, City of New +York, New York, in the Southern District of New York, at the following date, time and place: +Appearance Date: +August 30, 2019 +Appearance Time: 10 a.m. +to testify and give evidence in regard to alleged violations of federal criminal law, including: +18 U.S.C. §§ 1591, 1594(c), 2422(b), 371 | +and not to depart the Grand Jury without leave thereof, or of the United States Attorney, and that you +bring with you and produce at the above time and place the following: +SEE ATTACHED RIDER. Personal appearance is not required if the requested records are (1) +produced by on or before the return date to Special Agent +Federal Bureau of +Investigation, 26 Federal Plaza, New York, NY 10278, telephone (212) 384-1000, +and (2) accompanied by an executed copy of the attached Declaration of Custodian of Records. Please +contact Forensic Accountant +at +or Special Agent +at +with any questions. +Failure to attend and produce any items hereby demanded will constitute contempt of court and will +subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law. +DATED: New York, New York +August 16, 2019 +GEOFFREY S. BERMAN +United States Attorney for the +Sauthorn District af Naw Varla +Assistant United States Attorney +One St. Andrew's Plaza +New York, New. Vork: 10007 +Telephone: + + +RIDER +(Grand Jury Subpoena to JP Morgan Chase, dated August 16, 2019) +Please provide from account inception to the present any and all records pertaining to the following +accounts(s)/organization(s)/individuals(s), whether held jointly or severally or as trustee or +fiduciary as well as custodian, executor, or guardian, to include all open and closed accounts. +Please provide all images of documents in Adobe PDF files on CDs. +A. Please use the following identifiers: +NAME +DOB +SSN +ADDRESS +PHONE +EMAIL +ACCT# +GHISLAINE MAXWELL +12/25/1961 +139A CHARLES ST APT 233, BOSTON, MA +116A E 65TH ST, NEW YORK, NY +(917) 520-3106 +(212) 535-6833 +(212) 327-0131 +(917) 573-9763 +(305) 588-1998 +(561) 655-4870 +(212) 737-7975 +GMAX1@ELLMAX.COM +(CHASE) +B. Records to be produced should include but are not limited to the items listed below: +1. Documents (checks, debit memos, cash in tickets, wires in, wires out, etc.) reflecting +additions and/or subtractions to the account and how the account balances are being satisfied +on a monthly basis; +2. Signature cards; +3. Proof of identification (including but not limited to copies of identification used to open the +account); +4. Location of withdrawals +5. Opening account(s) documents with attachments, including any and all applications, internal +documents generated to open accounts), and identification information or other +documentation provided by Customer; +6. "Know your customer" documentation; +7. Wire transfer records (incoming and outgoing, and any and all applications and instructions); +8. "Quick Pay" transaction detail including counterparty information; +9. Safe deposit records, including applications, signature cards, and sign-in records; +3 + + +10. Trust accounts; +11. Monthly statements; +12. Credit card statements; +13. Bank, travelers, or cashier checks drawn on account or purchased with an account check; +14. Prepaid debit cards, certified checks, cashiers' checks, money orders, and traveler's checks; +15. Loan, lease, and/or mortgage application files (whether granted or denied) including credit +reports, applications, and payments made on loans; +16. Any and all corporate resolutions, certifications of incorporation, business certificates and/or +partnership agreements; +17. Online banking information- All information regarding the electronic use of banking systems +to include the following: username, registration IP address, online account creation date, +online account status and IP logs/history, MAC addresses and online session times and +duration; and +18. Any and all correspondence, electronic or otherwise, including memoranda, emails and text +messages, that reference or concern items (1) through (17), above, and/or any financial +interests involving the individuals and/or entities identified in Section A. +N.B.: Personal appearance is not required if the requested records are (1) produced by on or +before the return date to Special Agen +Fodoral Bureau of Investigation, 26 +Federal Plaza, New York, NY 10278, terephone +l; and (2) +accompanied by an executed copy of the attached Declaration of Custodian of Records. +PLEASE PROVIDE IN ELECTRONIC FORMAT IF POSSIBLE. +Please contact Forensic Accountant +at +or Special Agen +with any questions. +IMPORTANT: REQUEST FOR NON-DISCLOSURE +Due to the ongoing nature of the investigation, it is requested that you do not +disclose any information relating to this Grand Jury subpoena request to any third party. +4 + + +Declaration of Custodian of Records +Pursuant to 28 U.S.C. § 1746, I, the undersigned, hereby declare: +My name is +(name of declarant) +I am a United States citizen and I am over eighteen years of age. I am the custodian of +records of the business named below, or I am otherwise qualified as a result of my position with +the business named below to make this declaration. +I am in receipt of a Grand Jury Subpoena, dated August 16, 2019, and signed by Assistant +United States Attorney +requesting specified records of the business name +elow. Pursuant to Rules 902(11) and 803(6) of the Federal Rules of Evidence, I hereby certif +that the records provided herewith and in response to the Subpoena: +(1) were made at or near the time of the occurrence of the matters set forth in the records, +by, or from information transmitted by, a person with knowledge of those matters; +(2) were kept in the course of regularly conducted business activity; and +(3) were made by the regularly conducted business activity as a regular practice. +I declare under penalty of perjury that the foregoing is true and correct. +Executed on +(date) +(signature of declarant) +(name and title of declarant) +(name of business) +(business address) +Definitions of terms used above: +As defined in Fed. R. Evid. 803(6), "record" includes a memorandum, report, record, or data +compilation, in any form, of acts, events, conditions, opinions, or diagnoses. The term, "business" +as used in Fed. R. Evid. 803(6) and the above declaration includes business, institution, +association, profession, occupation, and calling of every kind, whether or not conducted for profit. diff --git a/vision-fixhub/ds9-parsed-01/0547d02ca8cf2d2a9d621d3bc546648b1337cb7d278766de02cfcf5af7c62f9f.receipt.json b/vision-fixhub/ds9-parsed-01/0547d02ca8cf2d2a9d621d3bc546648b1337cb7d278766de02cfcf5af7c62f9f.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..802eadddb3a729c78d52fbd6a557e24e7430cf6e --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0547d02ca8cf2d2a9d621d3bc546648b1337cb7d278766de02cfcf5af7c62f9f.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -60, + "dataset": "marble-joined", + "doc_id": "0547d02ca8cf2d2a9d621d3bc546648b1337cb7d278766de02cfcf5af7c62f9f", + "engine": "marble-apple-vision", + "event_count": 5, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "25ae1208c8835c5e61e0d36f7450b699e5828360618f0efbf9004d98b102a3d3", + "output_sha256": "35ed9e06bb5b7c961fac3a6a4b3e995d3a17c65ed132fd15945485d147707f06", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0575a3f641b290dc4508b570b5ed41221e03ccd0c64ebc1e174cec04399c3cdb.md b/vision-fixhub/ds9-parsed-01/0575a3f641b290dc4508b570b5ed41221e03ccd0c64ebc1e174cec04399c3cdb.md new file mode 100644 index 0000000000000000000000000000000000000000..97ac258bc8bbbca4849f436f5f522d42cf1e580a --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0575a3f641b290dc4508b570b5ed41221e03ccd0c64ebc1e174cec04399c3cdb.md @@ -0,0 +1,420 @@ +From: " +To: " +Cc: " +(USANYS)". +>, Laura Menninger +I)" +LUSANYS)" +», Jeff Pagliuca +(USANYS) [Contractor]" +(USANYS) [Contractor?" < +Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] +Date: Sun, 22 Aug 2021 19:03:59 +0000 +Counsel, +We write to meet and confer about Judge Nathan's order (Dkt. No. 322) and some other issues. Please let us know if you +are free to speak by phone tomorrow before 3 pm or Tuesday after 2:30 pm. +Also, please let us know some dates and times that you would like to review the hard drives and boots in Colorado. +Best, +From: +Sent: Wednesday, August 4, 2021 5:25 PM +To: Laura Menninger +Cc: +P; +P; Jeff Pagliuca +(USANYS) [Contractor < +[Contractor] < +P: +• (USANYS) [Contractor] < +Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] +(USANYS) +Laura, +Thank you for your email and for your patience as I track down answers for you. +By the end of this week, I expect to have a production ready for you, which will contain two categories of images +responsive to the discussions we have been having: +• First, the production will include several thousand images that the FBI has de-designated from Highly Confidential +down to Confidential. These will be produced in a format that should provide you with all available metadata +together with each image. This production is the culmination of the de-designation review process that the FBI has +completed over the past few months. +• Second, the production will include all of the approximately 40,000 images previously produced to you, which were +extracted from CDs seized from Epstein's New York residence. This production will be in a new format that should +provide you with all available metadata together with each image. +For this production, we will need two 500GB hard drives (one for counsel's copy and one for Ms. Maxwell's copy) on +which to load the materials. +I have also discussed your request that the FBI relocate certain items to the field office in Colorado to facilitate your +review. The FBI is able to make such a transfer of two of the items you requested: + + +• The FBI will send hard drives containing the remaining highly confidential image and video files seized from +Epstein's devices and CDs to Colorado, where you may review them. As was the case in New York, these will need +to be reviewed on a government laptop in the presence of an FBI employee and cannot be copied, photographed, +or removed from FBI property. +• The FBI will also send the boots that were recently taken into evidence at 1B items to Colorado, where you may +review them. You may examine and photograph the boots in the presence of an FBI employee, but they may not +be removed from FBI property. +• The photographs provided by l +A cannot be shipped out of the New York office because they are +logged as 1A items and must remain with the case file in New York. We are happy to arrange a time for the defense +to examine those photographs in person in New York. You may examine and photograph the photos in the +presence of an FBI employee, with the understanding that any photographs of these materials must be treated as +Confidential under the Protective Order in this case. There are relatively few photographs, so any review of these +should not be time-intensive. +Both of the case agents on our team are out of the office this week and next week, but we are working to find other +agents who can help us coordinate shipping the drives and the boots to Colorado. My hope is that they will get to +Colorado by next week. Please let me know what date(s) you would like to review those items later this month, and I will +coordinate with the FBI to schedule your review. +Best, +Assistant United States Attorney +Southern District of New York +1 St. • +Plaza +New York, NY 10007 +From: Laura Menninger +Sent: Wednesday, July 21, 2021 7:37 PM +To:/ +(USANYS) < +P; Jeff Pagliuca +| (USANYS) [Contractor< +[Contractor] < +• (USANYS) [Contractor] ‹ +Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] +(USANYS) +I am writing to inquire regarding the status of the HC material review and de-designation (highlighted #2 below, from May +14) and also to discuss how we may go about reviewing the additional 30,000 HC materials that we were not made +available to us when we traveled to NY for that purpose. +Do you know when the de-designation process will be complete? And when do you expect the de-designated documents +will be disclosed? +Also, regarding the remaining HC materials (highlighted #1 below), we would propose that they be made available for our +review at the FBI office here in Colorado within the next 30 days. We also would like to inspect at the same time and +place (a) the originals of the VRG photos that you located after our evidence review and (b) the boots that you recently +took possession of. + + +I am happy to schedule a time to discuss logistics if that would be easier. +Thanks, +Laura +Laura A. Menninger | Partner +Haddon, Morgan & Foreman, P.C. +150 . 10th Avenue | Denver, CO 80203 +From: +Sent: Thursday, May 20, 2021 6:15 PM +To: Laura Menninger +Cci +(USANTS)S +P; +P; Jeff Pagliuca • +'Bobbi Sternhein +(USANYS) [Contractor] < +Pi +(USANYS) [Contractor] +P: +(USANYS) [Contractor] < +Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] +Laura, +Thank you for your email. Below please find updates regarding these outstanding issues: +1. I have confirmed with the FBI that the larger number contained in the 302 is accurate. I have not been able to +figure out where the disconnect arose between the actual number and the number that was verbally conveyed to +me, which I then conveyed to you. I apologize for the mistake, which was unintentional. +2. The FBI's review of the Highly Confidential material and de-designation remains ongoing. I have reached out to the +case agent for an update on timing and will let you know when I have an estimate of when that process will be +complete. +3. My office did not create the empty Excel spreadsheet. It was included on a hard drive provided to our vendor by +the FBI containing the images from CDs seized from Epstein's residence and spreadsheets created by the FBI during +its review of those CDs. I do not know the origins of that third blank spreadsheet, and the FBI has informed me +that it only created two spreadsheets in connection with its review of the CDs. My best guess is that the blank +document was a temporary file that was automatically created when the spreadsheets were copied onto the drive, +but I do not know that for certain. To the best of my knowledge, there are no blank files that my office created. +4. Our paralegals have been working to look into the thousands of Bates numbers you listed as unviewable at the +MDC. Attached please find a spreadsheet our paralegals created providing the status of each document. You will +see that the spreadsheet is divided into separate tabs for each category of problem you identified. Next to each +identified Bates number, the paralegals have noted the status of each image and/or document. Below please find a +key explaining each of these different status entries: +• Blanks +• "Confirmed Blank" means the document has no content. +• "Not Blank" means there is content to the document. For documents in this category, please let us know if +you are requesting that we reproduce these documents to Ms. Maxwell at the MDC. +• "No Native" means there is no corresponding native with the image. +• "N/A - Not PAE Export" means the document was not produced by our vendor. +• Not Supported +• "raf files " means we are unable to open these files on our system and are asking our vendor and IT for +assistance. We will reach back out once we have obtained that assistance. + + +• "txt file (blank)" means the document has no content. +• Can't Read - Won't Open +• "Image Opens" means there is content to the image. Please let us know if you are requesting that we +reproduce these documents to Ms. Maxwell at the MDC. +• "Image Opens - Black Box(es)" means these images contained redactions of nudity. Please let us know if +you are requesting that we reproduce these documents to Ms. Maxwell at the MDC. +• "Native Opens" means there is content to the native. Please let us know if you are requesting that we +reproduce these documents to Ms. Maxwell at the MDC. +• "No native" means there is no corresponding native with the image. +• "Document Produced Natively" means that a cover sheet was produced instead of an image for this +document. +• "Corrupt" means the document has no viewable content. +• "Native Password Protected" means we are unable to open this document and are asking our vendor for +assistance. We will reach back out once we have obtained that assistance. +• "N/A - Not PAE Export" means the document was not produced by our vendor. +• "Image Opens" means there is content to the image. Please let us know if you are requesting that we +reproduce these documents to Ms. Maxwell at the MDC. +• "No native" means there is no corresponding native with the image. We are conferring with our vendor +regarding certain documents for which the image cover sheet indicates the document was produced natively +but for which we do not have a corresponding native. We will reach back out once we have obtained that +assistance. +• "Document Produced Natively" means that a cover sheet was produced instead of an image for this +• "Not Missing - Opens" means there is content to the native. Please let us know if you are requesting that +we reproduce these documents to Ms. Maxwell at the MDC. +• "Image for this document is not exported" means that we do not have these images. We are conferring with +our vendor regarding these documents and will reach back out once we have obtained assistance. +• "Blank" means the image file is blank. +• "Not Missing - Corrupt" means the document has no viewable content. +• Corrupt +• "Document Produced Natively" means that a cover sheet was produced instead of an image for this +• "Not Corrupt" means there is content to the document. Please let us know if you are requesting that we +reproduce these documents to Ms. Maxwell at the MDC. +• "Password Locked" means we are unable to open this document and are asking our vendor for assistance. +We will reach back out once we have obtained that assistance. +• "Blank File" means the native file we have is blank. We are checking with our vendor for assistance with +such files and will reach back out once we have obtained that assistance. +• "Blank" means the image file is blank. +• "Corrupt" means the document has no viewable content. +• "No Native File" means there is no corresponding native with the image. +• "'N/A - Not PAE Export" means the document was not produced by our vendor. +• "Lazer Scan" means that the file is part of the 3D scan of Epstein's private island. As you may recall, there +were difficulties producing the 3D scan to counsel in a viewable format, and we reproduced these +documents to counsel on multiple occasions. Within the lazer scan production there are pdf files that +should be viewable and should reflect the substance of the 3D scan. +Best, +From: Laura Menninger +Sent: Tuesday, May 18, 2021 12:21 PM + + +To: +Cc: +(USANYS) < +P: Jeff Pagliuca +'Bobbi Sternheim +subject: RE: U5 V. Maxwell - [conferral re photo and other discovery deficiencies] +Following up on the below, as I believe these are the outstanding issues from this email chain. +1. When do you expect to have clarification from the FBI regarding the discrepancy in highly confidential material +count? +2. Same for the de-designated HC materials? +3. Your answer regarding Bates-stamped but content-less files only addressed those that you took off of Epstein +devices. I asked about a file that your office created - an Excel spreadsheet - that did not have content yet you +Bates-stamped and produced it. Are there others? +4. When do you expect to have answers to the list of documents that our client is unable to view at the MDC? It is a +few days shy of a month since | forwarded that list to you and l am hoping that you will have answers in the next +few days. +1 will wait for answer to 1 and 2 above before I can adequately address your position on the HC materials. It may be that +we need to go back to the Court to address your definition of highly confidential which is unlike I have seen on even child +pornography cases. +Thanks for your prompt attention to these matters. +-Laura +Laura A. Menninger | Partner +Haddon, Morgan & Foreman, P.C. +150 10th Amenue I Denter CO 80203 +From: I +Sent: Tuesday, May 11, 2021 9:01 PM +To: Laura Menninger • +Cc: +PiL +P; Jeff Pagliuca +Bobbi Sternheim +Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] +Laura, +I have responded to your comments below in red. +I am working with the FBI to understand the discrepancy you pointed out, which I did not appreciate until receiving your +May 7, 2021 email. The 2,100 estimate was the amount of files that the FBI verbally informed me had been loaded onto +the second hard drive when I was arranging for your review of evidence at 500 Pearl. At the time, I did not recall that the +302 had a different number, and I did not check the number the FBI provided verbally against the 302. As soon as I +receive clarification from the FBI, I will reach back out to you. + + +As for your request to have access to Highly Confidential images and videos, paragraph 12 of the Protective Order in this +case defines Highly Confidential information as discovery material that "contains nude, partially-nude, or otherwise +sexualized images, videos, or other depictions of individuals." That definition does not limit this category to child +pornography. Paragraph 14 of the Protective Order further provides that any Highly Confidential materials "Shall be made +available for inspection by Defense Counsel and the Defendant, under protection of law enforcement officers or +employees." Given those provisions, as well as the importance of maintaining the security of nude images of third parties, +including victims, we are not prepared to provide you with copies of nude or partially-nude images from the hard drives. +However, we appreciate your concern that images that do not contain nudity appear to have been designated as Highly +Confidential. Accordingly, I am working with the FBI to de-designate any images that do not depict genitals, breasts, or +buttocks. Once those images have been de-designated, our office will produce them to you. +Best, +From: Laura Menninger • +Sent: Friday, May 7, 2021 4:43 PM +To: +Cc: +(USANYS) < +(CIV) < +P; Jeff Pagliuca +I; 'Bobbi Sternheim +Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] +Thank you for your response of April 23. I haven't heard back from you last week as promised on this or my April 28 +request, so I'm writing to follow up. I have responses to specific questions of yours below in blue. +Additionally, I have more questions regarding your production of "highly confidential" ('H") images and videos. When +we met the week of April 13 in NY, during which time I requested to view all evidence in the government's possession, +including all highly confidential material, you described for me two hard-drives that contained all of the HC images and +videos from this case. +• First, one of those hard-drives you said contained all of the materials extracted from the disks contained in the +black binders. There were approximately 40,000 or so images (Excel spreadsheet SDNY_GM_00467567) of which +3,400 images were deemed HC and tagged "#nudity" by your team (SDNY_GM _00467568). (I still await a response +regarding the problems with your metadata overlay). +• Second, the other hard-drive contained images extracted from Epstein's devices which were searched pursuant to a +warrant. You said the responsive image/video files were contained on that second hard-drive, and there were +approximately 2,100 "nude" or HC images on that hard-drive. You did not produce the metadata for those images +because it was still present on the files which had been digitally extracted. +As I understood it then, there were approximately 5,500 HC images that you made available for review. However, the FBI +Report dated January 27, 2021 (produced at SDNY_GM_02742399) indicates there are approximately 33,747 HC images +and 895 HC videos that were identified by a digital review of CART-processed evidence; I presume based on the CART +numbers that this list is the same as the images extracted from Epstein's devices, or as I understood it, the content on +your hard-drive #2 above. +I am completely unclear as to why you informed me that there were 2,100 nude images from Epstein's devices, but this +report seems to indicate there were approximately 34,000 HC images and videos. Please let me know if I am +misunderstanding what you told me and if so, what the correct information is. +I reiterate my request that you provide to us hard-drives with all of the HC material minus any child pornography. + + +I am available to discuss if that would be more convenient. +Thanks, +Laura +Laura A. Menninger | Partner +Haddon, Morgan & Foreman, P.C. +150 . 10th Avenue | Denver, CO 80203 +From: +Sent: Friday, April 23, 2021 10:13 AM +To: Laura Menninger +(USANTeT- +P; +P; Jeff Pagliuca +Bobbi Sternheim +Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] +Laura, +I am working with our team as quickly as we can to address the issues you raised in the below email. In particular: +• I have asked our vendor to look into the issues with SDNY_GM _00467566. When I attempt to access that +document on our Relativity database, I also receive an error message saying that the document is corrupt. I am not +sure what this spreadsheet is because the only two spreadsheets that I'm aware of that correspond with the +SDNY_PROD011 contained in the November 9, 2020 production are the two other Excel spreadsheets you +referenced. In any event, I am looking into the issue. +I understand from your subsequent email that the Excel spreadsheet at 467566 does not have any content. Are +there any other "Bates-stamped" documents without content? +It is possible that there are additional items that were recovered from electronic devices and storage media that +do not have content. For example, as Chris and I discussed in a separate email exchange, certain attachments to emails +on Epstein's devices were only partially recovered. Because they were attached to responsive emails, we produced those +partially recovered attachments, even though many did not have content. +• Iam similarly working with our vendor to understand how to best identify for you which Bates number corresponds +with the metadata in the index contained in the Excel spreadsheets. +We received your overlay on April 27. On April 28, I wrote you back with the persistent problems despite the +overlay. I do not see that you have responded to those concerns. Can you please advise? +I have been working with our vendor and paralegals to look into this issue and will respond to your April 28 email shortly. +• Can you please provide me with a list of the photos that you are unable to view? Once I have that list, I will check +to see whether we are able to open them on our end. +I am not able to provide you a list of the photos I am unable to view, for a number of reasons including my workproduct protections. I can highlight the file types that are contained on the disk and perhaps your vendor can tell +us which reader will work with those file types: +apmaster +apversion + + +attr +avi +omp +bup +dat +data +db +db-journal +doc +ds_store +f catalog +ifo +images #1 +images 2 +iphoto +ivc +JPg +tropez +txt +XISX +xml +I will forward this response to the vendor and see what, if any, assistance we can provide. +• Can you be more specific in identifying photographs that you believe should have been produced but have been +omitted, please? We have endeavored with the FBI to produce copies of all non-nude photographs recovered from +searches of Epstein's residence to the defense, and I am not aware of any intentional omissions. +See above. +Without specifics, I cannot address this issue further. +• I am discussing with the FBI your request that we produce all Highly Confidential images to you. I will respond to +that request next week. +I do not believe I received a response to this last week as indicated. Can you please update me? +Please see above. +• Once we have a firm trial date, I will let you know by what date I expect to be able to provide you with a list of the +Highly Confidential photographs we may introduce at trial. + + +Please advise. +We will discuss this request as a team now that we have a trial date of November 29, 2021. +• I am working with our paralegals to assess the list of files that your client is unable to review at the MDC. As soon +as we have finished looking into those issues, I will let you know. +Is there any update on this project? +As I mentioned above, our paralegals are still working through this list of documents. As soon as I have information to +provide on this score, I will reach out. +Best, +From: Laura Menninge +Sent: Wednesday, April 21, 2021 1:42 PM +To: +Cc: +(USANYS) < +P; Jeff Pagliuca +Bobbi Sternheim +Subject: US v. Maxwell - [conferral re photo and otner discovery dencienciest +I'm writing to follow-up on our discussion last Thursday regarding the photo evidence and to address a number of other +critical problems with the discovery provided to date. +Unfortunately, both in the production to defense counsel and on the hard-drive supplied by your office to our client at +MDC, there are thousands, if not hundreds of thousands, of photos that are still unreadable. We have spent countless +hours, and a chunk of our client's resources, trying to rectify a number of these problems ourselves, to no avail. Our +ability, and our client's ability, to review all of the discovery in this case is absolutely critical and is constitutionally +guaranteed. Unless you can quickly propose a solution, we believe we need to raise this with the Court. +• We do not have a functional copy the Excel spreadsheet located at SDNY_GM_00467566. I have confirmed that +the original spreadsheet provided to us is corrupt and the vendor and I-discovery provider cannot open it. +• The other two Excel spreadsheets from the production (and presumably the one we cannot open) are insufficiently +detailed to tell us which photo goes with which meta-data. +• The index contains multiple instances of the same "file name" with different hash values. +• The index does not match any particular file with a Bates stamp. +• The index does not indicate which files were withheld as "highly confidential." +• Many of the photo files that were provided in discovery ( +., SDNY011) do not have a discernible reader. I cannot +open them. Ms. Maxwell does not have a reader on her MDC laptop that can read them. If the government is able +to view them, then we should be provided the means to view them as well. +• A number of photo files appear to be missing from the MDC laptop and are not highly confidential, based on my +review of documents last week. Because we do not have a list of what was/was not produced, however, we cannot +confirm. +• As you know, the 2 x "highly confidential hard-drives" in NY did not work until Thursday once an appropriate reader +was added to the laptop. I did not have enough time to view all of the files. I do not have the reader that you +ultimately added to that laptop. + + +• The discs that | attempted to view in NY (from various binders) would not load on the government laptop. I was +unable to match up disks with potential files on the hard-drives. Because I did not have a functioning Excel +spreadsheet, I also was not able to match any highly confidential photos from the hard-drives with the associated +I am requesting that you produce to defense counsel replicas of the two hard-drives that you made available for review +last week, subject to all of the strictures of the protective order. +I recognize that you have designated as "highly confidential" photos that you contend contain "nude, partially-nude, or +otherwise sexualized images, videos, or other depictions of individuals." Among the photos on the hard-drive that I was +able to view, there were a lot of "nude" and "partially-nude" photos of adults, but I did not see anything that would +qualify as child pornography under the statute. Some of the photos only showed a woman's back or shoulder. If you have +reason to believe that there is child pornography contained on the two hard-drives, then certainly defense counsel is not +asking to possess that material; you can designate it as such and we can view it at an acceptable location as occurs in any +Otherwise, I think the burden of reviewing adult nudity only in the government's office or courthouse imposes an +extraordinary cost on our client and prevents us from analyzing the metadata, having our experts review the file +structures, keeps us from preparing photos for use at trial, and generally impedes our defense. +In a similar vein, can you let me know when you are willing to disclose any photos that you intend to introduce at trial? As +to any of those, I will need sufficient information and time to analyze them for foundation and admissibility purposes with +an appropriate expert. +Finally, I am attaching an incomplete list of the documents that our client still cannot read at MDC. It is a small sample, as +she has had to spend hours of her "review" time communicating to our staff which files she cannot read. Also, the +manner in which the discovery was provided to her (load file format) precludes her from comparing the "image" and the +"native" files (they do not, for example, have clearly labeled bates-stamps). +I would appreciate as prompt a response as you can provide so that we can address any issues with the Court on Friday. +Thanks, +Laura +Laura A. Menninger | Partner +Haddon, Morgan & Foreman, P.C. +150 |. 10th Avenue | Denver, CO 80203 diff --git a/vision-fixhub/ds9-parsed-01/0575a3f641b290dc4508b570b5ed41221e03ccd0c64ebc1e174cec04399c3cdb.receipt.json b/vision-fixhub/ds9-parsed-01/0575a3f641b290dc4508b570b5ed41221e03ccd0c64ebc1e174cec04399c3cdb.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..1e3d8ad720e2f4f1081be9befc29e815b5c40142 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0575a3f641b290dc4508b570b5ed41221e03ccd0c64ebc1e174cec04399c3cdb.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -122, + "dataset": "marble-joined", + "doc_id": "0575a3f641b290dc4508b570b5ed41221e03ccd0c64ebc1e174cec04399c3cdb", + "engine": "marble-apple-vision", + "event_count": 11, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "2d769c2a08f42a22d80c72f5c70dd9cfca60cdb3e3ab708c11a3e29c6763679e", + "output_sha256": "b137487373333ef7e0b9e244fb518b9b03b97e9ce17defb9a82bcb1d8672041f", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/05852d1bfbb9d2a3e1805ec0671290970fdc61079e06bb9515f396a650da6231.md b/vision-fixhub/ds9-parsed-01/05852d1bfbb9d2a3e1805ec0671290970fdc61079e06bb9515f396a650da6231.md new file mode 100644 index 0000000000000000000000000000000000000000..b3906db78a45c8d9e82c747254aad15ec6580fca --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/05852d1bfbb9d2a3e1805ec0671290970fdc61079e06bb9515f396a650da6231.md @@ -0,0 +1,39 @@ +From: +To: +Subject: t/c with DB counsel +Date: Sun, 14 Jul 2019 04:13:19 +0000 +Importance: Normal +Andrew Stemmer, head of litigation for the Americas at +some press about his relationship with Deutsche +try to understand the relationship, privacy issues +suggesting a subpoena +DB AG, NY branch, DB Securities Inc (US broker dealer) - send it all, and to him +- +any and all accounts +There's a trust account +some of the beneficiaries we may be familiar +Relationship largely terminated several months ago +just haven't closed them yet +2019, the movement looks like attempts to close out the accounts +Names of recipients of the trust +HAVE RECEIVED PAYMENTS from the trust: +(married to +Luella Rabuyo (accused as co-conspirator in Florida) +Beneficiaries (receiving payments): +Ghislaine Maxwell +Address: +HOW MANY ACCTS? Summary? +- total of 65 accounts (60 closed) +Top-line: +total assets +where did he go to +• destination? +- total number of accounts +significant amount payees +- designated beneficiaries +- KYC - know your client +• when did the relationship start? + + +Assistant U.S. Attorney +Southern District of New York diff --git a/vision-fixhub/ds9-parsed-01/05852d1bfbb9d2a3e1805ec0671290970fdc61079e06bb9515f396a650da6231.receipt.json b/vision-fixhub/ds9-parsed-01/05852d1bfbb9d2a3e1805ec0671290970fdc61079e06bb9515f396a650da6231.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..5685a3ce3fe9ddd1182959667d723d31215524ed --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/05852d1bfbb9d2a3e1805ec0671290970fdc61079e06bb9515f396a650da6231.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "05852d1bfbb9d2a3e1805ec0671290970fdc61079e06bb9515f396a650da6231", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "47c658df3c6ee53199e291d14f12552329373841dfd1b7c7a0d4b65bbe5ff848", + "output_sha256": "4e592adc43401ba3ffba70968287a2200a360b95a3a7626f45a2568c0d6f130c", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0595cdd97d52581e743710a8401bef624139ae690ff19fc0927aa9cb67a9887b.md b/vision-fixhub/ds9-parsed-01/0595cdd97d52581e743710a8401bef624139ae690ff19fc0927aa9cb67a9887b.md new file mode 100644 index 0000000000000000000000000000000000000000..53cdbe6abcf9666d7c0b5942d941e34c5787d2de --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0595cdd97d52581e743710a8401bef624139ae690ff19fc0927aa9cb67a9887b.md @@ -0,0 +1,347 @@ +From: "McGorty, Glen" { +To: " +Ce: "l +Subject: Re: Meeting with +Date: Fri, 24 Jul 2020 18:25:37 +0000 +D' 4 +→, "Giffini, Danielle: 1 +Got it. We will get back to you ASAP. +Glen G. McGorty | Crowell & Moring LLP +Managing Partner, New York Office +Privileged and Confidential • Attorney-Client Communication • Attorney Work Product +This message contains privileged and confidential information. IF IT WAS SENT TO YOU BY MISTAKE, DO +NOT READ IT. Instead, please notify the sender (or postmaster@crowell.com) by reply e-mail, and delete this e- +mall, Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited. +On Jul 24, 2020, at 2:14 PM, +> wrote: +External Email +Glen, +thanks, +From: McGorty, Glen 4 +Sent: Wednesday, July 22, 2020 17:30 +Cc: +Giffuni, Danielle < +Yes, that works. We will send a calendar invite with a dial-in. + + +Thanks, +Glen +Glen G. McGorty | Crowell & Moring LLP +Managing Partner, New York Office +Privileged and Confidential • Attorney-Client Communication • Attorney Work Produet +This message contains privileged and confidential information. IF IT WAS SENT TO YOU BY MISTAKE, DO +NOT READ IT. +Instead, please notify the sender (or postmaster@crowell.com) by reply e- +mail, and delete this e-mail. +Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited. +COVID-19 Questions or Concerns? See Crowell & Moring's COVID-19 Resource +Center> +P>; Giffuni, Danielle +*mailto: +External Email +Glen, +No problem. Would tomorrow at 2:00 p.m. work for you? Or if not, we should be pretty flexible, if you want to +suggest an alternate time. +thanks, + + +From: McGorty, Glen < +Sent: Wednesday, July 22, 2020 09:53 +Cc: +; Giffuni, Danielle +P>; +Sorry for the delay. We've spoken to +couple days. +Best, +Glen +Glen G. McGorty | Crowell & Moring LLP +Managing Partner, New York Office +Let us know when might be a good time for a call over the next +Privileged and Confidential • Attorney-Client Communication • Attorney Work Produet +This message contains privileged and confidential information. IF IT WAS SENT TO YOU BY MISTAKE, DO +NOT READ IT. +Instead, please notify the sender (or postmaster@crowell.com) by reply e- +mail, and delete this e-mail. +Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited. +COVID-19 Questions or Concerns? See Crowell & Moring's COVID-19 Resource +Center +From: +; Giffuni, Danielle +External Email +Glen, +Thanks again for following up with us on this issue previously, and we wanted to circle back to take you up on +the offer to convey some additional information to your client to see if it causes him to recall anything additional. +If you could please advise Mr. +of the following additional information? And then we can have a call +similar to our last one to check in. +The individual whose photo we sent is named +is an employee of the U.S. +Customs and Border Protection agency and worked in Saint Thomas for a number of years, and may have had a +friendship with Jeffrey Epstein during that time. In particular, +Thas been to Epstein's home in the Virgin +Islands and has accompanied Epstein on boat, helicopter, and/or plane trips. +Mr. +to +was listed as a contact in +phone, and +may have introduced one or more individuals +at a bar or other location in the Virgin Islands. +Please let us know when you've had an opportunity to provide this additional information? And we hope you're +well and look forward to being in touch. +thanks, +From: McGorty, Glen < +Sent: Monday, June 22, 2020 14:27 +To: l +Cc: Zelenko, Daniel < +; Giffuni, Danielle + + +Would you all be available for a call on Wednesday morning? I think we could do any time before noon. +We will let you know if Mr. +Best, +Glen +recognizes the individual in the photo. +Glen G. McGorty | Crowell & Moring LLP +Managing Partner, New York Office +Privileged and Confidential • Attorney-Client Communication • Attorney Work Product +This message contains privileged and confidential information. IF IT WAS SENT TO YOU BY MISTAKE, DO +NOT READ IT. +Instead, please notify the sender (or postmaster@crowell.com) by reply e- +mail, and delete this e-mail. +Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited. +COVID-19 Questions or Concerns? See Crowell & Moring's COVID-19 Resource +Center +From: + +Sent: Monday, June 22, 2020 12:49 PM +To: McGorty, Glen < +Cc: Zelenko, Daniel < +‹mailto: +‹mailto: +External Email +Glen, +It was indeed quite a weekend, but we continue to do our work as always, and the kind words are appreciated. +hanks also for getting back to us, and we're available for a call this week if that would be helpful, and/or if ye +ant to let us know in the first instance about the photo in particular, we can also just go from there. Let 1 +know, and we're around. +thanks, +From: McGorty, Glen < +Sent: Saturday, June 20, 2020 17:28 +To: +Cc: Zelenko, Daniel < + +Privileged and Confidential • Attorney-Client Communication • Attorney Work Produet +This message contains privileged and confidential information. IF IT WAS SENT TO YOU BY MISTAKE, DO +NOT READ IT. +Instead, please notify the sender (or postmaster@crowell.com) by reply e- +mail, and delete this e-mail. +Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited. +COVID-19 Questions or Concerns? See Crowell & Moring's COVID-19 Resource +Center +From: +> +Sent: Friday, June 19, 2020 3:07 PM +To: McGorty, Glen < +Ce: Zelenko, Daniel < +‹mailto: +> +Subject: FW: Meeting with +External Email +Glen, +Per my previous email, please see the below. +thanks, +From: +Sent: Wednesday, June 17, 2020 18:29 +To: Donnie Murrell < +Cc: +> +It's been a while since we've been in touch, and obviously our world changed substantially very shortly after the +would be willing to ask Mr. + + +still hope to schedule, once health and safety permits but given all of the current circumstances, we'd like to +make the request through you. +The initial question is whether Mr. +recognizes the individual in the attached photo, and if so, generally +how he knows the individual. And if Mr. +does know the individual, we may ask you to please convey +limited follow-up questions, or to schedule a brief call. If it would be at all useful to discuss this request, please +let us know; if that is helpful we can chat at your convenience. +Thank you, and hope this finds you well. +Assistant U.S. Attorney +Southern District of New York +From: +Sent: Friday, August 09, 2019 15:20 +To: Donnie Murrell < +Cc: +»> +>> +P>; +, "Benjamin, James" +1)" < +Subject: Deutsche Bank Production +Date: Thu, 22 Aug 2019 02:22:48 +0000 +Attachments: 2019.08.21_DB_Submission_to_SDNY.pdf; 2019.8.21_- +_SDNY_Prod007_Updated_Production_Index.xlsx; Attachments.html +On behalf of our client, Deutsche Bank, the link below contains an additional production of documents in response to +your July 11, 2019 subpoena. Also attached is the accompanying cover letter for today's production, as well as an +updated version of the production index we previously provided. The password to access these materials is the same as it +was for the previous submissions. For your convenience, I will recirculate it momentarily under separate cover. +Please do not hesitate to reach out if you have any questions. +Regards, +Tom +Citrix Attachments +DB-SDNY-PROD007.zip +Expires February 17, 2020 +2.3 GB +Download Attachments +Thomas Moyer uses Citrix Files to share documents securely. +Tom Moyer +AKIN GUMP STRAUSS HAUER & FELD LLp +2001 K Street N.W.| Washington, DC 20006| USA | Direct: +Fax: +akingump.com | Bio +The information contained in this e-mail message is intended only for the personal and confidential use of the +recipients) named above. If you have received this communication in error, please notify us immediately by e- +mail, and delete the original message. diff --git a/vision-fixhub/ds9-parsed-01/07876d923288d992b13fbbe2f356ca5fe0b5cc383248c5ca0a30345365b503ae.receipt.json b/vision-fixhub/ds9-parsed-01/07876d923288d992b13fbbe2f356ca5fe0b5cc383248c5ca0a30345365b503ae.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..dfc9f1c932ae57b1fc60630fe450c6b3172c13e2 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/07876d923288d992b13fbbe2f356ca5fe0b5cc383248c5ca0a30345365b503ae.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "07876d923288d992b13fbbe2f356ca5fe0b5cc383248c5ca0a30345365b503ae", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "810b50380ae2a1e8414f152aa1beca313fe5799704be96118b69f267abb27457", + "output_sha256": "077a80f20c63a6e56d3bc2ffe6c4175f7d2fa73b548a3b888731f6e46f60d04f", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/07c9dd420bbf477b7300da75cf2aefe4c9b72062b9afb9743855d7fa907280cd.md b/vision-fixhub/ds9-parsed-01/07c9dd420bbf477b7300da75cf2aefe4c9b72062b9afb9743855d7fa907280cd.md new file mode 100644 index 0000000000000000000000000000000000000000..5581148c3a1d7b71779b7581021dc0ba61051080 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/07c9dd420bbf477b7300da75cf2aefe4c9b72062b9afb9743855d7fa907280cd.md @@ -0,0 +1,90 @@ +From: " +To: ' +(NY) (FBI)" < +Ce: +"Young, Amanda N. (NY) (FBI)" +Subject: RE: GM investigation +Date: Thu, 05 Mar 2020 17:16:54 +0000 +I have reviewed the financial productions for Maxwell and Epstein as well as FinCEN filings regarding Maxwell. +Highlights are as follows: +1. On 6/15/07, a $7,400,000 wire transfer was made from Epstein's account at Bear Stearns account +Maxwell's JP Morgan Chase Account +to +2. On 1/4/11, a $3,000,000 transfer was made from Epstein's JP Morgan Chase account +to Maxwell's +JP Morgan Chase Account #739116312. On the same day, those proceeds were transferred to Epstein's JP Morgan +Chase account +3. On 7/28/11, $10,900,773.48 was wired from FSL LLC's account at Firstbank Pueto Rico to Maxwell's JP Morgan +• On the same day, the following transfers totaling $10,895,644.29 were made from +Chase Account +Maxwell's JP Morgan Chase Account/ +a. $722,802.88 transfer to Epstein's JP Morgan Chase account +b. $9,768,791.41 transfer to Epstein's JP Morgan Chase account +c. $339,050 transfer to Asset Account I +• (I do not know the owner of that account) +d. $65,000 wire transfer to George V. Delson Associates' account at Signature Bank +4. During the period of 9/10/09 through 7/20/10, three direct deposits and a check deposit totaling $22,206.52 +were made from NES LLC to Maxwell's JP Morgan Chase Account L +. Additionally, during the period of +12/22/09 thru 3/2/10, three checks totaling $7,399.08 were written from Maxwell's JP Morgan Chase Account +to NES LLC. (Please note that the first statement that was available for account Maxwell's JP Morgan +Chase Account +was September 2009. Previous payments from NES LLC may have been made to +Maxwell.) +Other than accounts held at financial institutions, I have not identified any assets. +Best +From: +To: +Cc: +[mailto: +Sent: Monday, February 24, 2020 12:55 PM +Subject: Re: GM investigation +Pi +(NY) (FBI) < +(NY) (FBI) + + +No problem, we will start working on what we can today. I've CC'd +for assistance with some of these +requests. +Mark, would you be able to give us a hand with items 2-3 on this list as requested by the AUSA's. I've +performed an updated Accurint check on Maxwell search for any properties she owns with negative results. +Hoping maybe you can come up with something in your searches. Thanks! +Detective +NYPD / FBI +Child Exploitation Human Trafficking Task Force +Office: +Cell: +Fax: +From: | +Sent: Monday, February 24, 2020 12:27 PM +To: +Cc: +(NY) (FBI) < +Subject: GM investigation +Hi +In connection with the Maxwell investigation, I know this is a travel week, but if at all possible, are you able to assist with +the following? It would be great to get some of these in motion this week: +Are you able to spend some time reviewing the message pads seized from Epstein's residence, to search for any +messages left by (or regarding) any of the individuals relating to the GM case? In particular, it would be helpful to +know if there are messages relating to: +2) +I recognize that we do not have a complete picture of Maxwell's current finances. I don't think it makes sense to +request additional financial information, but it would be helpful to have a snapshot of what we already know +about her current assets. In addition, it would be helpful to know if there are any significant transfers from +Epstein's account to Maxwell since 2005. Along the same line, a check for more recent alerts in FinCEN would be +helpful. +3) On the topic of assets, can you tell us what properties Maxwell currently owns? +Could you please send us the current tracking document for the hotline? It would be helpful for us to check +through the leads regarding Maxwell. +5)I think we emailed about this last month, but can you let us know how you know that she has UK and French +citizenship? +6) Could you please send us the notes from the +interview? +Thanks in advance, and sorry to pile on, I know everyone is busy. +Assistant United States Attorney +Southern District of New York +One Saint Andrew's Plaza +New York, NY 10007 + + diff --git a/vision-fixhub/ds9-parsed-01/07c9dd420bbf477b7300da75cf2aefe4c9b72062b9afb9743855d7fa907280cd.receipt.json b/vision-fixhub/ds9-parsed-01/07c9dd420bbf477b7300da75cf2aefe4c9b72062b9afb9743855d7fa907280cd.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..bb07c7bc361c35b338660abd0c73c7f293d6812a --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/07c9dd420bbf477b7300da75cf2aefe4c9b72062b9afb9743855d7fa907280cd.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -36, + "dataset": "marble-joined", + "doc_id": "07c9dd420bbf477b7300da75cf2aefe4c9b72062b9afb9743855d7fa907280cd", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "6876d29414be36335ada89cf2b22971e8948696086eca32331e44180555599c8", + "output_sha256": "585c4d2ca39fd170ea9a27ec0ce9a80a694eaec3cf238adecc11b28cea604f90", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/08085257796b05b7a06ea27b6b56c1e1b2b1e08803e173c5bad600e348624037.md b/vision-fixhub/ds9-parsed-01/08085257796b05b7a06ea27b6b56c1e1b2b1e08803e173c5bad600e348624037.md new file mode 100644 index 0000000000000000000000000000000000000000..d4b4f7397c653a552761a49cf1b08aca378a55dc --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/08085257796b05b7a06ea27b6b56c1e1b2b1e08803e173c5bad600e348624037.md @@ -0,0 +1,139 @@ +U.S. Department of Justice +United States Attorney +Southern District of New York +The Silvio J. Mollo Building +New Start New or P/0027 +September 3, 2019 +PayPal/Venmo +Re: +Grand Jury Subpoena +connection with an official criminal investigation of a suspected felony being conducted by +ederal grand jury. The Government hereby requests that you voluntarily refrain from disclosing +the existence of the subpoena to any third party. While you are under no obligation to comply +with our request, we are requesting you not to make any disclosure in order to preserve the +confidentiality of the investigation and because disclosure of the existence of this investigation +might interfere with and impede the investigation. +Thank you for your cooperation in this matter. +Very truly yours, +GEOFFREY S. BERMAN +United States Attorney +By: +Assistant United States Attorney +Southern District of New York + + +Grand Jury Subpoena +United States District Curt +SOUTHERN DISTRICT OF NEW YORK +TO: PayPal/Venmo +GREETINGS: +WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend +before the GRAND JURY of the people of the United States for the Southern District of New York, at +the United States Courthouse, 40 Foley Square, Room 220, in the Borough of Manhattan, City of New +York, New York, in the Southern District of New York, at the following date, time and place: +Appearance Date: +September 17, 2019 +Appearance Time: 10 a.m. +to testify and give evidence in regard to alleged violations of federal criminal law, including: +18 U.S.C. §§ 1591, 1594(c), 2422(b), 371 | +and not to depart the Grand Jury without leave thereof, or of the United States Attorney, and that you +bring with you and produce at the above time and place the following: +SEE ATTACHED RIDER. Personal appearance is not required if the requested records are (1) +produced by on or before the return date to Forensic Accountant +_Federal Bureau of +Investigation, 26 Federal Plaza, New York, NY 10278, telephone +and (2) accompanied by an executed copy of the attached Declaration of Custodian of Records. +. Please +contact Forensic Accountant +pr Special Agent +at +with any questions. +Failure to attend and produce any items hereby demanded will constitute contempt of court and will +subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law. +DATED: New York, New York +September 3, 2019 +GEOFFREY S. BERMAN +United States Attorney for the +Southern District of New York +Assistant United States Attorney +One St. Andrew's Plaza +New York. New York 10007 + + +RIDER +(Grand Jury Subpoena to PayPal/Venmo, dated September 3, 2019) +For the time period of account inception to the present, please provide any and all +records, including but not limited to account holder information and transaction records, relating +to the following emails: +@YAHOO.COM +@YAHOO.COM +@YAHOO.COM +Account holder and transaction information to include: +• User ID History +• Name +• Phone Number +• Address +• Billing Address +• Shipping Address +• E-mail Address +• IP Address +• Transaction details +• Bank account information +• Credit card account information +• Debit card account information +• Money sent +• Money received +• Checks requested +• Venmo account information and transactions +• PayPal Credit account information and transactions +• PayPal Working Capital account information and transactions +• PayPal MyCash account information and transactions +• PayPal Cash account information and transactions +• Xoom account information and transactions +• Braintree account information and transactions +N.B.: Personal appearance is not required if the requested records are (1) produced by on or +before the return date to Forensic Accountant +_Federal Bureau of Investigation, +26 Federal Plaza, New York, NY 10278, telephone +(2) accompanied by an executed copy of the attached Declaration of Custodian of Record +PLEASE PROVIDE IN NATIVE, ELECTRONIC FORMAT IF POSSIBLE. +Please contact Forensic Accountant | +or Special Agent +with any questions. +3 + + +IMPORTANT: REQUEST FOR NON-DISCLOSURE +Due to the ongoing nature of the investigation, it is requested that you do not +disclose any information relating to this Grand Jury subpoena request to any third party. +4 + + +Declaration of Custodian of Records +Pursuant to 28 U.S.C. § 1746, I, the undersigned, hereby declare: +My name is +(name of declarant) +I am a United States citizen and I am over eighteen years of age. I am the custodian of +records of the business named below, or I am otherwise qualified as a result of my position with +the business named below to make this declaration. +I am in receipt of a Grand Jury Subpoena, dated September 3, 2019, and signed by Assistant +United States Attorney +requesting specified records of the business named +below. Pursuant to Rules 902(11) and 803(6) of the Federal Rules of Evidence, I hereby certify +that the records provided herewith and in response to the Subpoena: +(1) were made at or near the time of the occurrence of the matters set forth in the records, +by, or from information transmitted by, a person with knowledge of those matters; +(2) were kept in the course of regularly conducted business activity; and +(3) were made by the regularly conducted business activity as a regular practice. +I declare under penalty of perjury that the foregoing is true and correct. +Executed on +(date) +(signature of declarant) +(name and title of declarant) +(name of business) +(business address) +Definitions of terms used above: +As defined in Fed. R. Evid. 803(6), "record" includes a memorandum, report, record, or data +compilation, in any form, of acts, events, conditions, opinions, or diagnoses. The term, "business" +as used in Fed. R. Evid. 803(6) and the above declaration includes business, institution, +association, profession, occupation, and calling of every kind, whether or not conducted for profit. diff --git a/vision-fixhub/ds9-parsed-01/08085257796b05b7a06ea27b6b56c1e1b2b1e08803e173c5bad600e348624037.receipt.json b/vision-fixhub/ds9-parsed-01/08085257796b05b7a06ea27b6b56c1e1b2b1e08803e173c5bad600e348624037.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..1927c4f861d559e619b2f172908701d49af524f9 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/08085257796b05b7a06ea27b6b56c1e1b2b1e08803e173c5bad600e348624037.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -60, + "dataset": "marble-joined", + "doc_id": "08085257796b05b7a06ea27b6b56c1e1b2b1e08803e173c5bad600e348624037", + "engine": "marble-apple-vision", + "event_count": 5, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "03b39d8e06933e93a3cf9751016c86355630d36d5d831381f20f5c0c71638b07", + "output_sha256": "97fb9eb1827acf2337165000f74c46590b67e33d29ac8726e3f1887ae3642e1a", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/080f2c3174721f4acc28bf855d641ccedefd68509e515419b6468decfaf25879.md b/vision-fixhub/ds9-parsed-01/080f2c3174721f4acc28bf855d641ccedefd68509e515419b6468decfaf25879.md new file mode 100644 index 0000000000000000000000000000000000000000..6b797ce11dbba8f664de39797aae9710091f0743 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/080f2c3174721f4acc28bf855d641ccedefd68509e515419b6468decfaf25879.md @@ -0,0 +1,38 @@ +From: +(USANYS)" < +To: " +Ce: "l +Subject: Re: Important question re USA V Ghislaine Maxwell +Date: Sun, 05 Jul 2020 01:47:26 +0000 +Sent from my iPhone +On Jul 4, 2020, at 9:23 PM, +No worries at all — we just forward all these to you! +Sent from my iPhone +On Jul 4, 2020, at 20:36, +USANYS) 4 +TIl respond and also let them know not to contact you anymore. +Sent from my iPhone +On Jul 4, 2020, at 7:15 PM, +FYI +Sent from my iPhone +Begin forwarded message: +From: kathryn milofsky < +Date: July 4, 2020 at 19:08:45 EDT +To: " +Subject: Important question re USA V Ghislaine Maxwell +Reply-To: kathryn milofsky < +• wrote: +> wrote: +> wrote: +Dear Mr +I am Kathryn Milofsky a producer for ITV News in the UK, based in NY.We are the largest commercial +broadcaster in the UK, similar in style stature to NBC. +We are trying to establish when the bail hearing is in your case USA V Maxwell. +Could you be so kind as to let me know. + + +Have a wonderful safe July 4th. +Best +Kathryn Milofsky +Producer +ITV News diff --git a/vision-fixhub/ds9-parsed-01/080f2c3174721f4acc28bf855d641ccedefd68509e515419b6468decfaf25879.receipt.json b/vision-fixhub/ds9-parsed-01/080f2c3174721f4acc28bf855d641ccedefd68509e515419b6468decfaf25879.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..8f8f48cb999a204e45c1bdcd8a5e0263871e6011 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/080f2c3174721f4acc28bf855d641ccedefd68509e515419b6468decfaf25879.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "080f2c3174721f4acc28bf855d641ccedefd68509e515419b6468decfaf25879", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "0765382400d8fb52eddde558fb8ce526f78eb545f8311c0031856c79e7fc8ba4", + "output_sha256": "25988bd0d2f82169de1a3a4ac1acd7fc3aec7ff56623063a2c9d95e64a1c1090", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/085b3b4a9de1fd148771363f5e7e03c899dcfeb83718c22a60bd59764e61dae7.md b/vision-fixhub/ds9-parsed-01/085b3b4a9de1fd148771363f5e7e03c899dcfeb83718c22a60bd59764e61dae7.md new file mode 100644 index 0000000000000000000000000000000000000000..94bdcc080a4c76a532b827c560cb98f6520e001d --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/085b3b4a9de1fd148771363f5e7e03c899dcfeb83718c22a60bd59764e61dae7.md @@ -0,0 +1,36 @@ +From: " +(USANYS)" { +To: " +(USANYS)" < +Subject: Re: Epstein FOIA Update +Date: Fri, 09 Apr 2021 23:53:45 +0000 +Thanks, +I will review the transcript and then we can discuss. I'll give Audrey a heads up that you will +be conveying to her. +Sent from my iPhone +On Apr 9, 2021, at 7:21 PM, +(USANYS) < +• wrote: +All, +I'm writing to bring everyone up to speed in the Epstein FOIA. We had a pretty rough, approximately 2 hour oral +argument today before Judge Engelmayer. It may be easier to share the transcript (which I have same-day ordered and +will circulate once received) and/or to talk things through on a call. In sum, the Court is very skeptical of the breadth of +the 7(A) withholdings here and will enter an Order on Monday directing that the withheld documents be produced to +the Court for in camera review. In connection with that, the Court will direct that any material withheld under 7(A) in +connection with the Tartaglione case be specifically marked out as such (as compared to the broader set of material +withheld on account of its likelihood of interference with Noel). Basically, the Court has concerns that too much has +been withheld on the theory of interference with the criminal cases and will undertake its own assessment of the +withholding of the documents. +The Court was also interested in exactly how much of the withheld materials have been produced to the Noel +defendants under Rule 16, and it sounds like it will ask us to make specific representations about precisely which +documents have been produced in Noel. +Also, as you will see from the transcript, the Court directed that I communicate to Audrey that he wants her to consider +this case and to evaluate whether it is necessary to confer with Main Justice on the FOIA response here (specifically +whether more documents might be produced on reconsideration). In particular, the Court perceived a possibility that +the recent change in administration could have some bearing on this. I plan to communicate this to Audrey as soon as +we have the transcript (I've asked for that piece of it tonight). +As noted I will follow up once I have the transcript and will also circulate the Court's Order when it comes out on +Monday. I think it would probably make sense to have a call thereafter and will circulate an invite for early next week. I +am also available to speak over the weekend if anyone would like to talk sooner. +Thanks, +Assistant United States Attorney diff --git a/vision-fixhub/ds9-parsed-01/085b3b4a9de1fd148771363f5e7e03c899dcfeb83718c22a60bd59764e61dae7.receipt.json b/vision-fixhub/ds9-parsed-01/085b3b4a9de1fd148771363f5e7e03c899dcfeb83718c22a60bd59764e61dae7.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..e622df8de4954abb412678abcf544655ac9fcab8 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/085b3b4a9de1fd148771363f5e7e03c899dcfeb83718c22a60bd59764e61dae7.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "085b3b4a9de1fd148771363f5e7e03c899dcfeb83718c22a60bd59764e61dae7", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "0c66e8729707b6bbbbe0f7511ffb2df50df3de568bba622ff7e11af4f249e45e", + "output_sha256": "6360939c240c8e625419c8d32aec850a4c0231ada12d593f323029f973cbc8bd", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/08628cd86effe395918d048b597579c22bad7401714d48922e30050d83aae541.md b/vision-fixhub/ds9-parsed-01/08628cd86effe395918d048b597579c22bad7401714d48922e30050d83aae541.md new file mode 100644 index 0000000000000000000000000000000000000000..2800685cdb037cbfd2d0d3917db9f77a6faf4764 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/08628cd86effe395918d048b597579c22bad7401714d48922e30050d83aae541.md @@ -0,0 +1,418 @@ +1 +2 +3 +4 +5 +6 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +UNITED STATES GRAND JURY +SOUTHERN DISTRICT OF NEW YORK +- +UNITED STATES OF AMERICA +-V- +GHISLAINE MAXWELL +(2018R01618) +- - X +: +: +-X +: November 19, 2019 Additional +United States Courthouse +300 Quaroppas Street +White Plains, New York +July 8, 2020 +10:05 a.m. +APPEARANCE S: +Assistant United States Attorney +Acting Grand Jury Reporter +FREE STATE REPORTING, +INC. +D.C. Area l + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +United States v. Ghislaine Maxwell +PROCEEDINGS +07/08/20 +2 +(10:05 a.m.) +MS. +Let the record reflect that there are +17 grand jurors present and that the foreperson is present. +Good morning, ladies and gentlemen. My name is +and I am an Assistant United States Attorney +here in the Southern District of New York. +Can everyone hear me okay? All right. I see +everybody's heads nodding. Thank you. +I am here today to present for your consideration +a proposed superseding +indictment charging Ghislaine Maxwell +in six counts. This indictment is virtually identical to +the indictment that you returned last week charging Maxwell +in those same six counts except that it corrects two +clerical errors, or two typographical errors that were +contained in Counts Five and Six which are the perjury +charges. +As a result, +I will not be presenting any new +evidence or new witnesses today. Instead, I will identify +for you those two clerical errors in the indictment. I will +point out the portion of the exhibits that you saw last week +that provide the correct information. Then I will identify +the corrected portion of the superseding indictment in the +proposed superseding indictment. +Before I do that though, I must ask you all the +FREE STATE REPORTING, INC. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +United States v. Ghislaine Maxwell +07/08/20 +same preliminary questions that we went over last week. +First, do any of you believe that you personally know or +have met the proposed defendant, Ghislaine Maxwell? I see +no hands. +Next, have you any heard or read about, or learned +anything Ghislaine Maxwell, Jeffrey Epstein or anyone else +related to this case, if you could just raise your hand? I +see a number of hands. Virtually every hand is in the air. +You can all put your hands down. Thank you. +As you know, you must make your determination as a +grand jury based on the evidence presented before you in the +grand jury, in this room alone. Accordingly, you must set +aside any other knowledge you may have about this case or +the people involved in it, and base your decision solely on +the evidence presented to this grand jury to determine +whether there is probable cause to believe that the charges +in the proposed indictment were committed. +Is there any grand juror here today who cannot +follow these instructions? +I see no hands. Just to be +sure, is there any grand juror here who would have any +difficulty setting aside the outside information you may +have about the defendant or the facts of this case? I see +no hands. +Finally, do any of you believe you know me in +anything other than my professional capacity? I see no +FREE STATE REPORTING, INC. +Balt. & Annap. I + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +United States v. Ghislaine Maxwell +07/08/20 +4 +hands. +Now, as I mentioned, I will not be calling any +witnesses today. Instead I will present you with the +exhibits from last week, the transcript of the testimony you +heard from last week and the proposed superseding +indictment. I will then walk you through the error that the +superseding indictment seeks to correct. +Please keep in mind though that what I say is not +evidence. Only the testimony of the witnesses and the +exhibits are evidence. +So as I'm walking you through these +exhibits, your understanding of them and your understanding +of the evidence controls. I am just trying to provide you +with an overview. +With that instruction in mind, I am going to put +up onto the Elmo what was previously received and marked as +Grand Jury Exhibit 1. That is the proposed six-count +indictment that you voted to return last week. A copy of it +will be available for review when you deliberate. +You also received what has been marked as Grand +Jury Exhibit 2, which I will not put up on the Elmo. That +was a PowerPoint presentation containing photographs and +excerpts of certain documents that was shown to you during +the testimony last week. You also heard testimony from FBI +Special Agentl +Today I am marking, as Grand Jury Exhibit 3, a +FREE STATE REPORTING, INC. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +United States v. Ghislaine Maxwell +07/08/20 5 +copy of the transcript of that testimony. It is up on the +Elmo now and it will be available for you to review if you +would like as you deliberate. I will not read it back to +you now, but you can read through it as you deliberate. +Finally, I am marking, as Grand Jury Exhibit 4, +the proposed superseding indictment, which I have now placed +up on the Elmo. As I mentioned, this proposed superseding +indictment corrects two clerical errors and is otherwise +identical to the original indictment, Grand Jury Exhibit 1. +I'm now going to walk you through the errors that +we're going to correct starting on Grand Jury Exhibit 1. +Page 15 contains the beginning of Count Five which charges +Maxwell with perjury. Paragraph 21 on that page refers to +the civil case in which Maxwell gave deposition testimony on +April 22nd, 2016, as 15 Civ. 7344. That is the error we are +going to correct. +Similarly, page 16 contains the beginning of Count +Six which charges another count of perjury. Paragraph 23 on +that page refers to the civil case in which Maxwell gave +deposition testimony on July 22nd, 2016, under the same +number, 15 Civ. 7344. +Turning now to Grand Jury Exhibit 2. Slide 22 of +that exhibit contains the first page of the deposition +transcript from the testimony that Maxwell gave on +April 22nd, 2016. As you can see here, the docket number +FREE STATE REPORTING, INC. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +United States v. Ghislaine Maxwell +07/08/20 +6 +for that case is in fact 15 Civ. 7433 not 7344. +Similarly, slide 25 contains the first page of the +transcript from the July 22nd, 2016 deposition that Maxwell +gave. As you can see here, again, the docket number for +that case is 15 Civ. 7433 not 7344. +Finally, I will turn to the proposed indictment, +Grand Jury Exhibit 4. On page 15, you have again the same +perjury count with one change. Paragraph 21 corrects the +docket number for the civil case to be 15 Civ. 7433. +Similarly, on page 16, which contains the second +per jury count for the July 22nd, 2016 deposition, the docket +number is corrected to 15 Civ. 7433. There are otherwise no +changes to the substance of this indictment. +That is my presentation. Before I leave you to +deliberate, would anyone like me to read the full proposed +superseding indictment out loud? I see no hands. +I must advise you that you must independently find +probable cause, again, +for each count in the superseding +indictment. The evidence before you in support of the +charges in the superseding +I indictment is the same evidence +that was before you when you considered the indictment last +week. +Does anyone have any questions about that +evidence? I see no hands. +The legal instructions that you received before +FREE STATE REPORTING, INC. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +United States v. Ghislaine Maxwell +07/08/20 +7 +voting on the indictment last week are the same instructions +that apply to your consideration of the proposed superseding +indictment. Would anyone like me to read those instructions +out loud for you again? +I see no hands. +Does anyone have any questions about the legal +instructions? I see no hands. +I will leave you now with the exhibits to +deliberate. As always, if you have any questions or +concerns about the proposed indictment, please let me know +before you vote so that I may answer any questions you may +have on the law, or bring any additional evidence before you +to consider. Thank you, all. +(Matter concluded) +(Time Noted: 10:14 a.m.) +FREE STATE REPORTING, +INC. +D.C. Area I + + +1 +2 +3 +4 +5 +6 +CERT +'IFICATE +I hereby certify that the foregoing is a true and +accurate transcription, to the best of my skill and ability, +from my electronic notes of this proceeding. +July 22, 2020 +Date +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Acting Grand Jury Reporter +Free State Reporting, Inc. +FREE STATE REPORTING, +D.C. Area I \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/08628cd86effe395918d048b597579c22bad7401714d48922e30050d83aae541.receipt.json b/vision-fixhub/ds9-parsed-01/08628cd86effe395918d048b597579c22bad7401714d48922e30050d83aae541.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..7741c02b2879416ad277e3db7abbc02ec11247be --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/08628cd86effe395918d048b597579c22bad7401714d48922e30050d83aae541.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -504, + "dataset": "marble-joined", + "doc_id": "08628cd86effe395918d048b597579c22bad7401714d48922e30050d83aae541", + "engine": "marble-apple-vision", + "event_count": 9, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "d85b0223a09e6d847b4395d66627ebbc31ce54bbc44aec668c449237db2d88f1", + "output_sha256": "58b36b454e90c4072813fe0c65159afefe0806364075e0acb83992a9d9755bad", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/086853c51ec205c997421f20c90cecf1072ae9c65cbfcf2a533ab80b75880e84.md b/vision-fixhub/ds9-parsed-01/086853c51ec205c997421f20c90cecf1072ae9c65cbfcf2a533ab80b75880e84.md new file mode 100644 index 0000000000000000000000000000000000000000..18f8c35029221ac474c17e821b4c0051cf6b3038 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/086853c51ec205c997421f20c90cecf1072ae9c65cbfcf2a533ab80b75880e84.md @@ -0,0 +1,18 @@ +From: +To: +Ce: +Subject: Subpoena Log and Subpoena Records +Date: Sat, 17 Aug 2019 20:27:24 +0000 +Attachments: Updated_Subpoena_Log.xlsx +Hi, +Attached is a log of all the subpoenas we've served and what has come back. I've posted the actual subpoenas and +returns on the USAO's FTP site, called USAFX. +already have access to USAX. For everyone else, +you'll need an account which is very easy. Will can help you get an account - I think he'll just need your cellphone +number. +Let us know if you have any questions. +Assistant United States Attorney +United States Attorney's Office +Southern District of New York +One St. Andrew's Plaza +New York, New York 10007 diff --git a/vision-fixhub/ds9-parsed-01/086853c51ec205c997421f20c90cecf1072ae9c65cbfcf2a533ab80b75880e84.receipt.json b/vision-fixhub/ds9-parsed-01/086853c51ec205c997421f20c90cecf1072ae9c65cbfcf2a533ab80b75880e84.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..fe97d622ab426766aecd5c8ac6427620bf0d2b26 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/086853c51ec205c997421f20c90cecf1072ae9c65cbfcf2a533ab80b75880e84.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "086853c51ec205c997421f20c90cecf1072ae9c65cbfcf2a533ab80b75880e84", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "fcfbeefe9c2dd539afc5886f0d13e19eb18ac87349a572c895499d9401a17fc6", + "output_sha256": "f815c0ce0f12f84208ed3329e0075c1cf0b07cbeead94d2d7679d58945041249", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0887671e65d20abda0bbefa5406b31c095469d5e3e7d04e2df62eaa8b5334af7.md b/vision-fixhub/ds9-parsed-01/0887671e65d20abda0bbefa5406b31c095469d5e3e7d04e2df62eaa8b5334af7.md new file mode 100644 index 0000000000000000000000000000000000000000..e807f203216a3c67fe1f0864edca982ae1ca559b --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0887671e65d20abda0bbefa5406b31c095469d5e3e7d04e2df62eaa8b5334af7.md @@ -0,0 +1,81 @@ +From: +To: +Cc: +Subject: +Date: +Attachments: +Echert Nanle +Alison Leukefeld; Bobert Nagle +Psychological Reconstruction +Monday, August 12, 2019 8:59:09 AM +TEXT. htm +Beconstruction Documentation Ust Request. doc +Nagle, Robert-vot +Warden N'Diaye, +Thank wou for supporting our scheduling of the Psuchological Reconstruction for inmate Epstein. I will be joined +by +I am attaching a list of materials we will use to complete the reconstruction. We routinely take these documents +with us so please ensure you have a copy of any documents you also need. Your assistance in gathering these +documents is appreciated and will be helpful. +Organizing and facilitating staff interviews often takes the most time and l am requesting the assistance of an +assigned staff member. In the past, wardens commonly have someone from the SIS department or a lieutenant +available throughout the reconstruction for this purpose and to track down additional documents as needed. +As discussed we will be staying at the Sheraton Tribeca on 370 Canal Street and appreciate your arranging travel +to the institution. We will be ready for pickup at 0715 on Tuesday morning and expect to complete the +reconstruction by close of business on Thursday. +Please feel free to contact me with any questions. +Thanks, +Rob +Robert W. Nagle, Psy D +National Suicide Prevention Coordinator +Federal Bureau of Prisons +Psycholony Services Branch +Psychological Reconstucti + + +NATIONAL SUICIDE PREVENTION PROGRAM +SUICIDE RECONSTRUCTION MATERIALS +(5-30-2015) +The following is a list of requirements, resources and documentation needed to conduct a thorough +reconstruction. It is also important to have one person identified who will coordinate documentation collection, +interview scheduling, and serve as a contact person for the reconstruction team. Typically, this person would be +the SIA. Having the following items collected in a tabulated binder will expedite the review process and ensure +that relevant data is examined. Please remember that not all items will be available or applicable to every case. +A copy of this binder will be a permanent record that leaves with the reconstruction team. +Cell/Location of Suicide is secured until the arrival of the Reconstruction Team when feasible +TRU-INTEL Download Report of Incident (583), 586, & Global Report +TRUVIEW Report - Money Received/Sent; Phone Lists; Calls; Email Lists; Messages; Visitor Lists; Visits; Timeline +Memorandums From Staff (List of All Staff Involved) +Photographs of Scene, Deceased and Autopsy - Saved to a CD/DVD - Please do not print. +All Video Showing Scene and Staff Response - If none, documentation noting why not - Saved to a CD/DVD +Video of the Scene for the Eight Hours Preceding Incident - Saved to a CD/DVD +Police Report when appropriate +FBI Referral including acceptance or declination +Inmate Mass Interviews (if applicable) +Last Staff Member to See Inmate Alive +Last Inmate to See Inmate Alive +Sentry Documentation: PP44 Inmate Profile, PP37 Inmate History, 41 Inmate Load Data, 10 CMC Clearance and Separtee +Data, GO Security/Designation Data, J8 Assignment History, 15 Chronological Disciplinary Record, PSCD Sentence Data +SIS Case File Index +Receipt of Property Form +• Evidence Recovery Log (if applicable) +• Chain of Custody +• Photograph Logs +• Coroner's Receipt +Psychology File (PDS-BEMR) +Medical Information/Records (BEMR) +BOP Twenty-Four Hour Death Report +Multi-Level Mortality Review Report +Judgment & Commitment Order +Any Note(s) Left Behind by Deceased +Most Recent Screening For Risk of Victimization & Abusiveness +Detailed Time Line (Minute by Minute Breakdown of What Occurred) +30 minute SHU rounds for one week prior to suicide if in SHU or secure unit +Staff Sign-In Log 1 Week Prior to Suicide (SHU) +Secured Personal Property - Please do not send property home until team arrives and reviews. +Notification of Death +Autopsy Request & Report +BP 292's & 295's - (SHU Program) +Available for Review Only - Please de not make copies: +• Hard Medical File (when one exists) +• Inmate Central File diff --git a/vision-fixhub/ds9-parsed-01/0887671e65d20abda0bbefa5406b31c095469d5e3e7d04e2df62eaa8b5334af7.receipt.json b/vision-fixhub/ds9-parsed-01/0887671e65d20abda0bbefa5406b31c095469d5e3e7d04e2df62eaa8b5334af7.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..3ea16a1a2a6c47b174ff8117baad989fa7d2560c --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0887671e65d20abda0bbefa5406b31c095469d5e3e7d04e2df62eaa8b5334af7.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "0887671e65d20abda0bbefa5406b31c095469d5e3e7d04e2df62eaa8b5334af7", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "ed54e8ddc3c48a680617b6a843a93e90e90f71a2d160c35ce553caa9f05b5d62", + "output_sha256": "15a4b29d89f22c1ea82b0353103dbc015646034d058795e11f792df42f6718a7", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/08a61cc5868bbeb526beb6ffa4aef0e509487e80fe2063935367d32477686689.md b/vision-fixhub/ds9-parsed-01/08a61cc5868bbeb526beb6ffa4aef0e509487e80fe2063935367d32477686689.md new file mode 100644 index 0000000000000000000000000000000000000000..5ed786a8574492df49fc9f1ee8db1affc14395da --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/08a61cc5868bbeb526beb6ffa4aef0e509487e80fe2063935367d32477686689.md @@ -0,0 +1,460 @@ + + + +AO 89B (07/16) Subpoena to Produce Documents, Information, or Objects in a Criminal Case +UNITED STATES DISTRICT COURT +for the +Southern District of New York +United States of America +Ghislaine Maxwell +Defendant +Case No. 20CR330 (AJN) +SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR +OBJECTS IN A CRIMINAL CASE +To: +(Name of person to whom this subpoena is directed) +YOU ARE COMMANDED to produce at the time, date, and place set forth below the following books, papers, +documents, data, or other objects: +See Attachment A +Place: United States District Court +Date and Time: +Southern District of New York, Courtroom 318 +40 Foley Square, New York, NY 10007 +Certain provisions of Fed. R. Crim. P. 17 are attached, including Rule 17(c)(2), relating to your ability to file a +motion to quash or modify the subpoena; Rule 17(d) and (e), which govern service of subpoenas; and Rule 17(g), +relating to your duty to respond to this subpoena and the potential consequences of not doing so. +(SEAL) +Date: +CLERK OF COURT +Signature of Clerk or Deputy Clerk +The name, address, e-mail, and telephone number of the attorney representing (name of party) +Ghislaine Maxwell +, who requests this subpoena, are: +Jeffrey S. Pagliuca, Haddon, Morgan & Foreman P.C., 150 East 10th Ave., Denver, Colorado 80203, +Notice to those who use this form to request a subpoena +Before requesting and serving a subpoena pursuant to Fed. R. Crim. P. 17(c), the party seeking the subpoena is advised to +consult the rules of practice of the court in which the criminal proceeding is pending to determine whether any local rules +or orders establish requirements in connection with the issuance of such a subpoena. If no local rules or orders govern +practice under Rule 17(c), counsel should ask the assigned judge whether the court regulates practice under Rule 17(c) to +1) require prior judicial approval for the issuance of the subpoena, either on notice or ex parte; 2) specify where the +documents must be returned (e.g., to the court clerk, the chambers of the assigned judge, or counsel's office); and 3) +require that counsel who receives produced documents provide them to opposing counsel absent a disclosure obligation +under Fed. R. Crim. P. 16. +Please note that Rule 17(c) (attached) provides that a subpoena for the production of certain information about a victim +may not be issued unless first approved by separate court order. + + +AO 89B (07/16) Subpoena to Produce Documents, Information, or Objects in a Criminal Case (Page 2) +Case No. +20CR330 (AJN) +PROOF OF SERVICE +This subpoena for (name of individual and title, if any) +was received by me on (dase) +• I served the subpoena by delivering a copy to the named person as follows: +on (date) +; or +• I returned the subpoena unexecuted because: +Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also +tendered to the witness fees for one day's attendance, and the mileage allowed by law, in the amount of +$ +My fees are $ +for travel and S +for services, for a total of $ +0.00 +I declare under penalty of perjury that this information is true. +Date: +Server's signature +Printed name and title +Server's address +Additional information regarding attempted service, etc.: +Print +Save As... +Add Attachment +Reset + + +AO 89B (07/16) Subpoena to Produce Documents, Information, or Objects in a Criminal Case (Page 3) +Federal Rule of Criminal Procedure 17 (c), (d), (e), and (g) (Effective 12/1/08) +(c) Producing Documents and Objects. +(1) In General. A subpoena may order the witness to produce any books, papers, documents, data, or other objects the subpoena +designates. The court may direct the witness to produce the designated items in court before trial or before they are to be offered in +evidence. When the items arrive, the court may permit the parties and their attorneys to inspect all or part of them. +(2) Quashing or Modifying the Subpoena. On motion made promptly, the court may quash or modify the subpoena if compliance +would be unreasonable or oppressive. +(3) Subpoena for Personal or Confidential Information About a Victim. After a complaint, indictment, or information is filed, a +subpoena requiring the production of personal or confidential information about a victim may be served on a third party only by court +order. Before entering the order and unless there are exceptional circumstances, the court must require giving notice to the victim so that +the victim can move to quash or modify the subpoena or otherwise object. +(d) Service. A marshal, a deputy marshal, or any nonparty who is at least 18 years old may serve a subpoena. The server must deliver a copy +of the subpoena to the witness and must tender to the witness one day's witness-attendance fee and the legal mileage allowance. The server +need not tender the attendance fee or mileage allowance when the United States, a federal officer, or a federal agency has requested the +subpoena. +(e) Place of Service. +(1) In the United States. A subpoena requiring a witness to attend a hearing or trial may be served at any place within the United +(2) In a Foreign Country. If the witness is in a foreign country, 28 U.S.C. $ 1783 governs the subpoena's service. +(g) Contempt. The court (other than a magistrate judge) may hold in contempt a witness who, without adequate excuse, disobeys a subpoena +issued by a federal court in that district. A magistrate judge may hold in contempt a witness who, without adequate excuse, disobeys a +subpoena issued by that magistrate judge as provided in 28 U.S.C. § 636(e). + + +ATTACHMENT A +DEFINITIONS +1. "You" or "Your" means any owner, shareholder, partner or employee of the Epstein Victim's +Compensation Program ("EVCP"), and any former owner, shareholder, partner or employee +of the EVCP +2. +"Accusers" or "Accuser" means +3. Attorneys means legal counsel for any Accuser or the EVCP. +4. "Communication" means all forms of correspondence, including regular mail, email, text +message, memorandum, or other written communication of information of any kind. +5. "EVCP Material" refers to any submission to the Epstein Victim's Compensation Program +made by an Accuser, including any claims on behalf of persons who have accused Jeffrey +Epstein or Ghislaine Maxwell of any misconduct, any releases signed by an Accuser or their +Attorneys, and any compensation received by an Accuser. +INSTRUCTIONS +1. Production of documents and items requested herein shall be made in person to United States +District Court, Southern District of New York, 40 Foley Square, New York, NY 10007, +Courtroom 318. +2. This Request calls for the production of all responsive Documents in Your possession, +custody or control without regard to the physical location of such documents. +3. If any Document was in your possession or control, but is no longer, state what disposition +was made of said Document, the reason for the disposition, and the date of such disposition. +4. In producing Documents, if the original of any Document cannot be located, a copy shall be +produced in lieu thereof, and shall be legible and bound or stapled in the same manner as the +original. +5. Any copy of a Document that is not identical shall be considered a separate document. +6. All Documents shall be produced in the same order as they are kept or maintained by You in +the ordinary course of business. +7. Responsive electronically stored information (ESI) shall be produced in its native form; that +is, in the form in which the information was customarily created, used and stored by the +native application employed by the producing party in the ordinary course of business. +8. Defendant does not seek and does not require the production of multiple copies of identical +Documents. +9. This Request is deemed to be continuing. If, after producing these Documents, you obtain or + + +become aware of any further information, Documents, things, or information responsive to +this Request, you are required to so state by supplementing your responses and producing +such additional Documents to Defendant. +DOCUMENTS OR THINGS TO BE PRODUCED +1. Any and all EVCP Material submitted by each Accuser, not limited to Claim Forms and +supporting submissions made by each Accuser; +2. Communications between the EVCP to each of the Accusers and/ or their Attorneys; +3. Copies of any payments to the Accusers and their Attorneys; +4. Any and All Releases executed by the Accusers. + + + + + +Independent +Epstein Victims' Compensation Program +PROTOCOL +May 29, 2020 +I. +PURPOSE AND OVERVIEW +The Epstein Victims' Compensation Program (the "Program") is a voluntary, independent Program that +has been established to compensate and resolve the claims of victims-survivors of sexual abuse by +Jeffrey Epstein ("Epstein"). +The Estate of Jeffrey Epstein (the "Estate") has retained the services of nationally recognized claims +to design the +"). This +Program. Ms. +will also serve as +Protocol reflects input from victims-survivors, their lawyers, other potentially interested parties, and +representatives of the Estate. +Through the Program, the Estate wishes to acknowledge the wrongs endured by victims-survivors and +offer them an opportunity to voluntarily resolve their individual claims for such sexual abuse. +The Program is governed by the following non-exclusive guiding principles: +• The Program is purely voluntary. It does not affect any rights a Claimant may have +unless and until the Claimant accepts the offered compensation and executes a +Release. A Claimant may reject the offer of compensation and may stop +participating in the Program and withdraw the claim at any time prior to execution +of the Release. +• The Program is independent and will in no way be administered, controlled or +overseen by the Estate. The Administrator is responsible for all decisions relating to +the review, processing and evaluation of individual claims submitted to the +Program. The Administrator will have final, binding and exclusive authority to +determine Claimant eligibility and the valuation of each eligible individual claim. +Decisions of the Administrator made pursuant to this Protocol are not subject to +review or modification in any way by the Estate or any other party or entity. +• There is no cap or limitation on the aggregate amount of funds available to +compensate all eligible Claimants or on the amount of compensation to be made to +each individual Claimant. Each individual claim will be evaluated separately by the +Administrator. The Administrator will determine, in her sole and exclusive +discretion, issues of eligibility and the amount of compensation and the Estate will +pay all eligible claims based on the Administrator's determination. +1 | Page + + +• All Claimants will be treated with respect, dignity and fairness without regard to +race, color, sexual orientation, national origin, religion, gender or disability. To +ensure claims will be adjudicated fairly, the Administrator will manage the process +so that all Claimants can equally access the Program's claim process. Individuals +with disabilities will be given the opportunity to effectively communicate their +claims and to request special process accommodations. +The Program is available to all victims-survivors regardless of where they were harmed, when they were +harmed, whether the claim is time-barred by the applicable statute of limitations, and whether they +have previously filed a lawsuit against or settled with Epstein and/or the Estate. +The exclusive claims period for filing a claim pursuant to this Protocol shall commence on the to-bedetermined Effective Date and shall conclude nine (9) months after that date ("Filing Deadline"). All +individual claims filed with the Program must be filed within this period +To complement the Program's resources, the Administrator will, at her discretion and with the consent +of the Claimant, consult with Professor Marci A. Hamilton, a nationally recognized sexual abuse expert, +leading legal academic and advocate of victims' rights. Ms. Hamilton's role will be to further inform the +Administrator and her staff about the dynamics of sexual abuse, common responses to sexual abuse, +and the impact of sexual abuse on victims; to serve as a resource for the Administrator in developing or +updating policies and procedures; to advise the Administrator regarding sensitivities involved in +interactions with victims; and to serve as a referral source for the Administrator in providing postdetermination information to claimants who seek guidance, counseling or other services. The +Administrator may, at her discretion and with the Claimant's prior written consent, request that Ms. +Hamilton review an individual claimant file. The Administrator will determine on a case-by-case basis, in +her discretion, the need to anonymize individual claimants' files before sharing them with Ms. Hamilton. +As set forth above, the Administrator is solely responsible for all decisions relating to the administration +of the Program, including the review, processing, evaluation, and determination of individual claims +submitted to the Program. +During the term of the Program, Ms. Hamilton will not meet or speak with a Claimant or her +representatives concerning any aspect of the Program without the Administrator present. Ms. Hamilton +will maintain in strict confidence and will not disclose outside the Program any information she obtains +through her participation in the Program, including individual Claimants' submissions. +2| Page + + +Il. +ELIGIBILITY REQUIREMENTS +A. Eligibility Criteria +The persons eligible to participate in this Program are individuals who allege they were sexually abused +by Epstein. In addition, the following criteria apply: +• The claim of sexual abuse must be directed against Epstein. +• An individual whose claim is time-barred by the applicable statute of limitations may +participate in the Program provided that other eligibility criteria are met. +• An individual who previously entered into a settlement agreement resolving a claim of sexual +abuse against Epstein may participate in the Program provided that other eligibility criteria are +met. +• An individual who allegedly assisted Epstein in procuring other victims-survivors may +participate in the Program where there is a credible basis to determine that the individual +acted under duress as a result of her own sexual abuse by Epstein, provided that other +eligibility criteria are met. +• If the Claimant chooses to accept the offered compensation, the Claimant must dismiss with +prejudice any existing lawsuits, legal actions or claims filed against the Estate or related entities +and/or related individuals. The Claimant must provide proof of such dismissal along with or +prior to the signed acceptance of the compensation determination offer letter and executed +Release in order to receive payment. +B. Legal Representatives of Claimants +An individual may file a claim on a victim's behalf where that individual has been granted legal authority +to act in a representative capacity pursuant to appropriate law. The "Legal Representative" of an +individual Claimant shall mean: (1) in the case of a Claimant who is currently a minor, a parent or legal +guardian authorized by law to serve as the minor's legal representative; (2) in the case of an +incompetent or legally incapacitated Claimant, a person who has been duly appointed as the Claimant's +legal representative in accordance with applicable law; (3) in the case of a deceased Claimant, a person +who has been duly appointed to act as the personal representative of the Claimant's estate by a court of +competent jurisdiction and is authorized to file and compromise a claim; or (4) an attorney authorized to +represent the Claimant for purposes of pursuing a claim through this Program. +Legal Representatives must provide proper documentation demonstrating representative capacity. Such +proof may include a power of attorney; documentation showing the individual's appointment as +guardian or guardian ad litem; documentation showing the individual's appointment as personal +representative of the Claimant's estate (such as letters of administration); a copy of a retainer +3 | Page + + +agreement showing legal representation signed by both the Claimant and the attorney or a signed +statement by an adult Claimant and the attorney that a licensed/admitted attorney is acting on her +behalf. +III. CLAIMS ADMINISTRATION - SUBMISSION, EVALUATION AND DETERMINATION +A. Claims Submission Process +Individuals who have filed a lawsuit, legal action or claim against Epstein and/or the Estate or have +otherwise been identified as a victim of Epstein by their attorney to the Administrator on or before the +Effective Date will be sent a Claim Form and other relevant Program information, including Instructions +for completion and submission of the Claim Form and a copy of this Protocol. Individuals who have filed +a lawsuit need not agree to a stay of litigation or make any other concession in any pending litigation to +be eligible to participate in the Program. Likewise, individuals who have not yet filed a lawsuit remain +free to file a lawsuit and engage in litigation concurrently with participation in the Program. Individuals +must, however, dismiss with prejudice any and all existing lawsuits, legal actions and claims prior to or at +the time of acceptance of a compensation determination offer in order to receive payment. +Individuals who have not filed a lawsuit, legal action or claim against Epstein and/or the Estate or have +not otherwise been identified as a victim of Epstein by their attorney to the Administrator on or before +the Effective Date may register to participate in this Program on the Program's website at +www.EpsteinVCP.com. To register, such individuals must complete a questionnaire setting forth their +name, contact information, a summary description of the nature of the claim and other requested +information. Upon registration, the Administrator will perform a preliminary review to consider if the +individual is eligible to participate in the Program. If the Administrator deems that the individual is +eligible to participate in the Program, she will then send that individual a Claim Form and other relevant +Program information. +Note: The fact that an individual is sent a Claim Form and other relevant Program information indicates +that the Administrator has determined that such individual is eligible to participate in the Program. It +does not indicate that the Administrator has determined that such individual is eligible to receive +compensation. That determination is made only after a Claim Form and all required documentation has +been submitted and evaluated by the Administrator. +Registrations for individuals who have not filed a lawsuit, legal action or claim against Epstein and/or the +Estate or have not otherwise been identified as a victim of Jeffrey Epstein by their attorney to the +Administrator on or before the Effective Date will be accepted by the Administrator from the Effective +Date through a date that is 45 days prior to the Filing Deadline ("Registration Deadline"). It is important +to note that the Registration Deadline is separate from, and precedes, the Filing Deadline. As explained +above, all claims must be filed by the Filing Deadline. +4 | Page + + +All Claim Forms must be completed to the best of a Claimant's ability and filed no later than the Filing +Deadline. Claim Forms should be uploaded to the Program website at www.EpsteinVCP.com, or mailed +via overnight courier (a pre-paid courier voucher will be included with each packet) to the Administrator +at the following address: +Epstein Victims' Compensation Program +Attn: +1050 Connecticut Ave., NW +#65488 +Washington, D.C. 20035 +Claimants are invited to provide documentation identified in the Claim Form, and any other +corroborating or supporting information sufficient to substantiate the claim, satisfy eligibility +requirements, and allow the Administrator to review, process and evaluate the claim. If the claim is +being presented by a Legal Representative, then the Legal Representative will be responsible for +submitting the necessary documentation relating to the represented Claimant. +Additional documentation may be requested at the discretion of the Administrator. Both the Claimant +and the Estate will be afforded the opportunity to submit to the Administrator any information deemed +relevant to the Administrator's evaluation and determination of the claim before the Administrator's +final disposition of the claim. +If a Claimant submits an incomplete or deficient claim, the Administrator will notify the Claimant, +explain the additional information that is needed, and work with the Claimant or the Claimant's Legal +Representative (where applicable) to assist in submitting a complete claim. +B. Claims Evaluation and Determination +Claims will be evaluated in the order in which they are received, with the Administrator evaluating each +submitted individual claim in a prompt and fair manner. Claims will only be determined once all +required documentation has been submitted to the Administrator, with due consideration granted to +Claimant's good faith explanations for delays and/or absence of documentation. +1. Factors Considered in Evaluating Claims +As to each individual claim, the Administrator will determine, in her sole discretion based upon all of the +information available, whether the allegations of sexual abuse are credible. The Administrator will +consider appropriate factors and corroborative support, including but not limited to: +• The level of documentation, corroboration or other circumstantial evidence regarding the +nature and extent of the abuse, the frequency, location and other details of the abuse, and the +age of the victim at the time of the abuse. Non-exhaustive examples of such evidence include +(i) medical or psychiatric counseling/therapy records relevant to the abuse, and +(ii) contemporaneous written notification or other correspondence (e.g., letters, emails) of the +abuse by the Claimant to law enforcement authorities, parents, friends or others. The +5 | Page + + +Administrator acknowledges that some Claimants may not be able to provide any +documentation to corroborate their Claim based on the nature and circumstances of Epstein's +conduct. If a Claimant's written and oral presentation is deemed to be credible by the +Administrator, the Claimant may still be eligible for compensation under the Program. +• Whether there exists any information and/or pertinent findings offered by the appropriate +Office of the District Attorney, United States Attorney's Office, or other law enforcement +agency. +• Whether the Administrator finds the claims of the individual to be credible after complete +review of all relevant documentation and other evidence provided by the Claimant and the +Estate. +As to each individual claim, the Administrator will determine, in her sole discretion based upon all of the +information available, the amount of compensation that should be offered to each eligible Claimant. +The Administrator will consider appropriate factors and corroborative support, including but not limited +to: +• The nature, duration and extent of the sexual abuse suffered by the Claimant. +• The age of the Claimant at the time of the sexual abuse. +• The nature and extent of the Claimant's physical or psychological damage resulting from the +sexual abuse, and the effect of the sexual abuse on the Claimant. +• The credibility of the claim based upon all of the facts and circumstances, supporting +documentation and corroborating evidence. +• Whether the Claimant previously entered into a settlement agreement with Epstein and +received a payment pursuant to such agreement. +The Administrator will confidentially send the Claimant a compensation determination offer letter +including the following: (1) the Administrator's eligibility decision regarding the claim; (2) the amount of +compensation offered; (3) a Release to be signed by the Claimant if the Claimant accepts the offered +compensation; and (4) a Payment Option Form. The Administrator's offer shall be valid for 60 days from +the date of the compensation determination offer letter. +The Administrator's determinations in this Program will not be binding on any potential criminal +investigation involving Claimant's claims. +2. Opportunities to be Heard +The Claimant will be afforded an opportunity to be heard, either before or after the Administrator +renders her determination. Upon request by the Claimant, the Administrator will be available to meet in +person (as practicable in light of the COVID-19 pandemic), by video conference, or by teleconference to +6| Page + + +further discuss the claim. These meetings are completely optional and voluntary. Requests to meet +with the Administrator should be sent by email to ClaimantServices@EpsteinVCP.com and will be +scheduled at a mutually convenient time and location. The Administrator may also request a meeting +with a Claimant or her Legal Representative at a reasonable mutually convenient time and location, +though the Claimant is not obligated to attend any such meeting. +3. Release +By submitting a claim to the Program, a Claimant is seeking to resolve all claims relating to allegations +of sexual abuse against Epstein and/or the Estate, and related entities and individuals as set forth in the +Release. If a Claimant chooses to accept the offer of compensation pursuant to the Program, the +Claimant will be required to sign and execute a full Release, in a form satisfactory to the Estate, of all +past and future claims (including lis pendens, writs of attachment, etc.) relating to such allegations of +sexual abuse against the Estate, related entities and/or related individuals. A Claimant may reject the +offer of compensation and may stop participating in the Program and withdraw the claim at any time +prior to the execution of the Release. +The Release will waive any rights the Claimant and her heirs, descendants, legatees or beneficiaries +may have to assert any claims relating to allegations of sexual abuse against the Estate, related +entities and/or related individuals, to file an individual legal action relating to such allegations, or to +participate in any civil legal action associated with such allegations, except as a witness. However, +the Release will not operate to preclude or limit the Claimant's ability to report and discuss +allegations of sexual abuse with law enforcement officials or anyone else. In other words, the +Release will not impose any rules of confidentiality on claimants, who are expressly permitted to +discuss their allegations without restriction, should they choose. +Before signing a Release, the Claimant must consult with an attorney selected by the Claimant. If the +Claimant is not represented by an attorney, the Program will provide an attorney to provide free legal +counseling to the Claimant for the sole purpose of advising the Claimant concerning the language and +binding nature of the Release. +No one affiliated with the Program will provide tax or legal advice to those receiving payments under +the Program. Claimants are urged to consult with a tax advisor concerning any questions regarding +tax liability for payments pursuant to the Program. +4. Payments +Upon the Claimant's acceptance of the Administrator's determination, the Administrator's receipt of +the Claimant's executed Release and, where applicable, dismissal with prejudice of any existing +lawsuit, legal actions or claims against the Estate or related entities and/or related individuals, the +Administrator will initiate payment by check or electronic funds transfer to each eligible Claimant as +directed by the Claimant. Checks will be sent to Claimants via overnight courier service. All +7| Page + + +payments made under the Program shall be for a Claimant's physical injuries, physical sickness and +resulting emotional distress within the meaning of Section 104(a) of the Internal Revenue Code. +C. Program Integrity +For the purpose of protecting both the integrity of the Program and financial resources for eligible +Claimants, the Administrator will institute all necessary measures to prevent payment of fraudulent +claims, including taking steps to verify claims and analyze submissions for inconsistencies, +irregularities or duplication. +Each Claimant who signs the Claim Form at the time of submission certifies that the information +provided in the Claim Form is true and accurate to the best of the Claimant's knowledge, and that the +Claimant understands that false statements or claims made in connection with such submission may +result in fines, imprisonment and/or any other remedy available by law. Claims that appear to be +potentially fraudulent or to contain information known by the Claimant to be false when made will be +forwarded to federal, state or local law enforcement agencies and/or the appropriate Office of the +District Attorney and/or United States Attorney's Office for possible investigation and prosecution. +D. Confidentiality/Privacy +The Program is confidential. By filing a claim with the Program, the Claimant or her Legal +Representative (where applicable) agrees that information submitted by the Claimant pursuant to +the Program will be used and/or disclosed by the Administrator and her designees only for the +following purposes: +1) Processing and evaluating the Claimant's claim; +2) Administering the Program and other Program-related work; and +3) Reports to law enforcement where appropriate, related to potentially fraudulent claims. +When documents or other information maintained or submitted by the Estate become part of a +Claimant's file for purposes of the Program, such materials will be reviewed by the Administrator to +assist in processing and evaluating the claim, but will otherwise remain confidential. No information +provided by Claimants will be provided to the Estate except for the Claimant's name and the date(s) +and location(s) of the alleged abuse, for the sole purpose of processing and evaluating the claim and, +for purposes of the Release, the names of any other individual(s) to whom or by whom the Claimant +alleges she was trafficked or sexually abused. The Estate has agreed that no information obtained +solely through the Program will be disclosed publicly or used by the Estate in defending itself from any +claim, regardless of forum. The Program's files are not available for inspection, review or copying by +the Estate or the Claimant or her representatives during or after the Program, and all pertinent +1 All parties agree that they are using the services of a third-party administrator to help reach a resolution of individual claims +of sexual abuse, and that this Program is entitled to confidentiality, privileges (mediation, settlement and all other pertinent +privileges), and protection from disclosure under applicable law. +8 | Page + + +mediation privileges, settlement privileges and other privileges apply. +To protect the privacy of Claimants participating in the Program, all personal information provided by +the Claimant during this process will be returned or destroyed within one year after the conclusion of +the Program. +Individual Claimants are not bound through the Program by any rules of confidentiality. Claimants may, +at their sole and voluntary option, disclose information in their possession regarding their claim, their +compensation and their experience with the Program. +All confidentiality requirements are subject to law, regulation and judicial process. +E. Reporting +The Administrator shall, on a monthly basis, confidentially provide reports regarding the number and +total value of claims paid each month to the Probate Court of the United States Virgin Islands and the +Attorney General of the United States Virgin Islands. Such reports will report on an aggregate level +only. No individual Claimant information will be published or disclosed in a way that compromises +Claimant confidentiality. +9 | Page diff --git a/vision-fixhub/ds9-parsed-01/08a61cc5868bbeb526beb6ffa4aef0e509487e80fe2063935367d32477686689.receipt.json b/vision-fixhub/ds9-parsed-01/08a61cc5868bbeb526beb6ffa4aef0e509487e80fe2063935367d32477686689.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..cb7649f8d8200e465c248a5d5126d970e2a36968 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/08a61cc5868bbeb526beb6ffa4aef0e509487e80fe2063935367d32477686689.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -214, + "dataset": "marble-joined", + "doc_id": "08a61cc5868bbeb526beb6ffa4aef0e509487e80fe2063935367d32477686689", + "engine": "marble-apple-vision", + "event_count": 20, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "0cf6d7368d6503ac4415646e2469ce20486911b3909b1e9f9150af57603286ee", + "output_sha256": "da5a0e1374a9d656bcb8340de63a2bf0b6f09a24e1e9db956c14f98fc45a3b93", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/08ae0d9a85adb177aabe31fcf24f91a67b0b753cc53e7cf1b45632fa6995040e.md b/vision-fixhub/ds9-parsed-01/08ae0d9a85adb177aabe31fcf24f91a67b0b753cc53e7cf1b45632fa6995040e.md new file mode 100644 index 0000000000000000000000000000000000000000..571a20b25c05bfb6ecbf745bba33fd30d720672e --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/08ae0d9a85adb177aabe31fcf24f91a67b0b753cc53e7cf1b45632fa6995040e.md @@ -0,0 +1,44 @@ +From: " +To: +Subject: FW: SDNY investigation (re: Epstein) +Date: Tue, 16 Jul 2019 17:17:15 +0000 +Importance: Normal +Inline-Images: image001.png; image002.jpg +Should we do this at 5:00? Or +if you want, +and I can do it at 4:30 - totally happy to wait until you can join if +you want, but if you don't care, likely won't be super exciting and we can cover. Your call. +From: Christian Everdell < +Sent: Monday, July 15, 2019 22:33 +To: +Cc: +P; Mark S. Cohen < +Subject: RE: SDNY investigation (re: Epstein) +Thanks for the email, +We appreciate your willingness to meet with us. If you can make the time, I think it would be +useful to have an introductory meeting tomorrow. Let us know what time works best for you. +Regards, +Chris +Christian Everdell +COHEN & GRESSER LLP +New York | Seoul | Paris | Washington DC | London +CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only +the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient, you are hereby notified that any +review, dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error, please immediately notify +the sender by telephone and permanently delete this e-mail. Thank you. +PRIVACY:A complete copy of our privacy policy can be viewed all +From: +Sent: Monday, July 15, 2019 7:57 PM +To: Christian Everdell; Mark S. Cohen +Cc:_ +Subject: RE: SDNY investigation (re: Epstein) + + +Chris, Mark, +Following up on my very brief conversation with Chris earlier this afternoon, and the voicemail you left earlier, thanks for +getting in touch regarding your representation of Ms. Maxwell. I understand you'll be in our neighborhood tomorrow +afternoon; we can make ourselves available to meet, but will that have been enough time for you to speak with your +client? Let us know what you think would be best to proceed, and we'll figure out next steps. +thanks, +Assistant U.S. Attorney +Southern District of New York diff --git a/vision-fixhub/ds9-parsed-01/08ae0d9a85adb177aabe31fcf24f91a67b0b753cc53e7cf1b45632fa6995040e.receipt.json b/vision-fixhub/ds9-parsed-01/08ae0d9a85adb177aabe31fcf24f91a67b0b753cc53e7cf1b45632fa6995040e.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..a8789e2d2a85b550bf142abc1ad198313e0a2d8c --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/08ae0d9a85adb177aabe31fcf24f91a67b0b753cc53e7cf1b45632fa6995040e.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "08ae0d9a85adb177aabe31fcf24f91a67b0b753cc53e7cf1b45632fa6995040e", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "21d27a5efd8c72dc911993c8770f41426286b9bb3706dabd7ed0aae0f4a84c3d", + "output_sha256": "0231908d3bf50069e2a0fa90afc20485e3622e1a86200a07ec945a0aaaee5f03", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/08b64850a14adb7aa0ebe7311b028a9c34d3201d0d752eef307b90fda86cec8a.md b/vision-fixhub/ds9-parsed-01/08b64850a14adb7aa0ebe7311b028a9c34d3201d0d752eef307b90fda86cec8a.md new file mode 100644 index 0000000000000000000000000000000000000000..06e97675bc3198529e7704f7784cdb3b552ae994 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/08b64850a14adb7aa0ebe7311b028a9c34d3201d0d752eef307b90fda86cec8a.md @@ -0,0 +1,35 @@ +From: "Jestin, Katya"l +Subject: Re: Epstein question +Date: Sat, 08 May 2021 12:33:35 +0000 +Hi there - sorry I missed this. I am around. Let me know when might be an ok time. +Katya +> On May 7, 2021, at 7:02 PM, +wrote: +> +> +> External Email — Exercise Caution +> Hi Katya, +> Can you give me a call when you have a chance? I'm free this evening if you want to call my cell at +V +> Thanks, +> --Original Message +> From: Jestin, Katya < +> Sent: Thursday. May 6. 2021 6:22 PM +> To: +> Subjech Epstem question +> +> Hi there - I know you are busy. I was just following up on the question I asked about. +> Katya +> +> +> Katya Jestin +> Co-Managing Partner +> +> Jenner & Block LLP +> Pronouns: She / Her +> +> CONFIDENTIALITY WARNING: This email may contain privileged or confidential information and is for +your system. +> + + diff --git a/vision-fixhub/ds9-parsed-01/08b64850a14adb7aa0ebe7311b028a9c34d3201d0d752eef307b90fda86cec8a.receipt.json b/vision-fixhub/ds9-parsed-01/08b64850a14adb7aa0ebe7311b028a9c34d3201d0d752eef307b90fda86cec8a.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..c15de25e0f8fc575762786a2884c4e5eeb06d038 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/08b64850a14adb7aa0ebe7311b028a9c34d3201d0d752eef307b90fda86cec8a.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "08b64850a14adb7aa0ebe7311b028a9c34d3201d0d752eef307b90fda86cec8a", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "14fede100471cc88b53e794dd3656213470456a4d4e0678c98f2c57c167e21ed", + "output_sha256": "876d19cb42d47d7816ca7f13c305850d5cd742323dff0fa0f358548eb71f52f9", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/08bd3abdb337ab1b405db7f3dfbcffd130d209ed66ba55b8f0814d6b812ffd7a.md b/vision-fixhub/ds9-parsed-01/08bd3abdb337ab1b405db7f3dfbcffd130d209ed66ba55b8f0814d6b812ffd7a.md new file mode 100644 index 0000000000000000000000000000000000000000..8c1419d2a77cd928edda2490ade7b331d317c834 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/08bd3abdb337ab1b405db7f3dfbcffd130d209ed66ba55b8f0814d6b812ffd7a.md @@ -0,0 +1,696 @@ +NYMA3 +530.03 +PAGE 001 +A +Y +QTRG EQ +BUREAU OF PRISONS COUNT SHEET +NEW YORK MCC +**** +OCTG EQ **** +OUTCOUNT SECTION +I Z' +J +F +F +N +E +S +TR V +H 0 H +** +08-03-2019 +09:46:09 +oc +UO +TU +N +T +COUNT +AREA +B-A +C-A +E-N +E-S +G-N +G-S +H-A +I-N +K-N +K-S +R-A +Z-A +Z-B +TOTAL +COUNT +VERIFY +CENSUS +26 +10 +87 +78 +78 +82 +87 +88 +142 +77 +5 +761 +1 +2 +3 +1 +1 +2 +13 +VERIFY +COUNT +COUNT COUNT AREA +26 B-A +10 C-A +87 E-N +75 E-S +78 G-N +82 G-S +1 H-A +87 +I-N +87 +K-N +128 +K-S +0 +R-A +76 +Z-A +5 +Z-B +742 +14 +1 +2 +19 +X. +OFFICIAL PREPARING COUNT +OFFICIAL TAKING COUNT +COUNT CLEARED TIME: 10149A m +Good Verbal: 10:43Am + + +DATE: +FROM: +8/3/2019 +METROPOLITAN CORRECTIONAL CENTER l +NEW YORK NY +OFFICIAL OUT-COUNT FORM +TIME:_10:00AM +LOCATION:_F/S +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +Number +61876-054 +86024-054 +15657-179 +01558-112 +23789-057 +85771-054 +86074-054 +76149-054 +06303-082 +85571-054 +11714-052 +79752-054 +01735-007 +79196-054 +Name +Unit +Number +Name +Unit +KS +KS +ES +IKS +KS +KS +KS +KS +KS +KS +KS +KS +KS +KS +21 +22 +23 +24 +25 +26 +27 +28 +29 +30 +31 +32 +33 +34 +35 +36 +37 +38 +39 +40 +OUT-COUNTS +BY UNIT: +B-A +C-A +E-N +E-S +TOTAL ON OUT COUNT: +14- +G-N +G-S +I-N +K-$_13 - +K-N +Z-A +Z-B +H-A +Approving Operations Lieutenant +ut-counts will be submitted at a minimum of two (2) hours prior to the count. Out-counts WILL be submitted in ink, and legible. Out-coun +lould list inmates alphabetically by unit with the inmate's name, register number, and quarters assignment. Please verify all informatio + + +NYMH4 530*05* +INMATE ROSTER + +ASSIGNMENT: ES +OPER CATG ASSIGNMENT +OPER +CATG ASSIGNMENT +NUM ASSIGNMENT REG NO +0001 FS +23789-057 +0002 +15657-179 +0003 +61876-054 +0004 +79196-054 +0005 +01558-112 +0006 +85771-054 +0007 +86024-054 +0008 +86074-054 +0009 +76149-054 +0010 +06303-082 +0011 +79752-054 +0012 +85571-054 +0013 +01735-007 +0014 +11714-052 +NAME +* +08-03-2019 +09:26:32 +GROUP CODE: +FACILITY: NYM +OPER CATG ASSIGNMENT +OCT DATE +OTR +08-03-2019 K07-008U +08-03-2019 E10-579L +08-03-2019 K11-053U +08-03-2019 K07-008L +08-03-2019 KOB-016L. +08-03-2019 K11-054L +08-03-2019 K08-074L +08-03-2019 KOB-020L +08-03-2019 K08-014L +08-03-2019 K11-055U +08-03-2019 K08-019U +08-03-2019 K08-020U +08-03-2019 K07-001L +08-03-2019 K11-052L +WRK +UNASSG +WAREHOUSE +ES AM +ES AM +ES AM +ES AM +SUICIDE OR +FS AM +ES AM +FS AM +ES AM +ES AM +FS AM +FS AM +FS AM + + +METROPOLITAN CORRECTIONAL CENTER +NEW YORK, NY +OFFICIAL OUT COUNT +DATE: +FROM: +APPROVED: +8-3-19 +COUNT TIME: +LOCATION: +10:00Am +Hosp. +(Staff Merber Preparing Out Count) +(Sporations Lieutenant) +AIVID +REG # +I. 53634-424 +2. +3. +4. +5. +6. +7. +8. +9. +10. +11. +12. +UNIT +KN +REG # +NAME +UNIT +13. +14. +15. +16 +17. +18 +19. +20. +21. +22. +23. +24. +B-A +I-N +C-A +K-N +E-N +K-S +OUT-COUNT BY UNIT +E-S +G-N +_ R-A +- Z-A +G-S +Z-B +H-A +Total Out-Counted: +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected count. +Prepare this form in ink. Group the inmates according to their respective housing units. This form is to be used only as an +Out-Count, No other form will be accepted in lieu of the Out-Count Form. + + +NYMA3 530*05* + +ASSIGNMENT: HOSP +OPER CATG +ASSIGNMENT +OPER +NUM ASSIGNMENT REG NO +0001 HOSP +53634-424 +NAME +INMATE ROSTER +CATG ASSIGNMENT +* +08-03-2019 +09: 04:28 +GROUP CODE: +FACILITY: NYM +OPER CATG ASSIGNMENT +OCT DATE +OTR +08-03-2019 K03-122L +WRK +SUICIDE OR +UNASSG + + +Date: 08/03/2019 +VISIT +OFFICIAL OUT-COUNT FORM +Metropolitan Correctional Center +New York, New York 10007 +Time 10:00 Am +Staff supervising count :- +Operations Lieutenant'S Approval +REG. NO. +24263-052 +85382-054 +NAME +UNIT +ES +E-S +REG. NO. +NAME +UNIT +Total Count For Department: +- **This form must be submitted to the Counts and Assignments Officer FORTY FIVE MINUTES PRIOR to the +affected count. Prepare this form in ink and group the inmates by respective floors. This is not a count slip, but an +out-count form. + + +NYMA3 530*05 * +INMATE ROSTER + +ASSIGNMENT: VISIT +OPER +CATG +ASSIGNMENT +OPER CATG +ASSIGNMENT +NUM ASSIGNMENT REG NO +0001 VISIT +24263-052 +0002 +85382-054 +NAME +* +08-03-2019 +09:29:25 +GROUP CODE: +FACILITY: NYM +OPER CATG ASSIGNMENT +OCT DATE +QTR +08-03-2019 E07-553L +08-03-2019 E07-552U +WRK +CMS CLERK +CMS CLERK +GO000 + + +METROPOLITAN CORRECTIONAL CENTER +NEW YORK, NY +OFFICIAL OUT COUNT +DATE: +FROM: +APPROVED: +8-3-19 +COUNT TIME: +LOCATION: +0° +10 Am +Atty. Conf. +aring Out Count) +(Operations Lieutenant) +NAME +Epstein +UNIT +KS +2A +REG # +1. 86407-054 +276318-054 +3. +4. +5. +6. +7. +8. +9. +10. +11. +12. +B-A +I-N +REG # +NAME +UNIT +13. +14. +15. +16. +17. +18. +19. +20. +21. +22. +23. +24. +OUT-COUNT BY UNIT +E-S +G-N +R-A +_ Z-A +C-A +K-N +E-N +K-S +G-S +Z-B +H-A +Total Out-Counted: +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected count. +Prepare this form in ink. Group the inmates according to their respective housing units. This form is to be used only as an +Out-Count. No other form will be accepted in lieu of the Out-Count Form. + + +NYMA3 530*05 * + +ASSIGNMENT: ATTY +OPER CATG +ASSIGNMENT +OPER +NUM ASSIGNMENT REG NO +NAME +0001 ATTY +76318-054 EPSTEIN +0002 +86407-054 +INMATE ROSTER +CATG ASSIGNMENT +* +08-03-2019 +09:30:02 +GROUP CODE: +FACILITY: NYM +OPER CATG ASSIGNMENT +OCT DATE +QTR +WRK +08-03-2019 Z04-206LAD UNASSG +08-03-2019 K12-069L +UNASSG + + +Metropolitan Correctional Center +Official Count Slip +Date.., +8/3/2019 +Time: 10:00au +Unit: +KS +Count. +Print Name: +Print Name: +Signature +Unit: +Count: +Metropolitan Correctional Center +Official Count Slip +ZA +76 +_ Date _ +8/3/19 +Timer +10Am +Print Name: +Print Name: +Signature. +Metropolitan Correctional Center +New York, New Xork +Official Count Slip +Unit: FS +Date: 8/3/19 +Count:_ +14 +Time: 10 Am +1. Print Name +1. Signature: +2. Print Name +2. Signature:. +Metropolitan Correctional Center +Official Count Slip +Date: +8-3-2019 +Metropolitan Correctional Center +New York, New York +Official Count Slip +Unil: VISIT +Date: 08/03/2019 +Count: +/Timc: 10:00Am +1. Print Name +1. Signature: 6 +2. Print Name +2. Signature: +Metropolitan Correctional Center +Official Count Slip +Unit: +GN +_Date 08/03/19 +An +Count: +78 +Time: 10:00 +Print Name: +Print Name: +Signature _ +Metropolitan Correctional Center +Official Count Slip +Unit: +I-N +Date ... +8. 3. 14 +Count: +887 +Time: 10:00 Am +Print Name: +Print Name: _ +Signature. +Unit: +Count: +8 +Print Name: +Print Name: +Unit: +Metropolitan Correctional Center +Official Count Slip +Atty Conf. +Date: +Count: +8. 3•19 +Time: +10 Am +Print Name: +Print Name: +Metropolitan Correctional Center +Official Count Slip +Unit: +KN +Date: +8/3/19 +Count: +81 +Time: +10 A.M +Print Name: +Print Name: + + +Metropolitan Correctional Center +Official Count Slip +Unit: +ES +Date _ +8-3-2019. +Count: +75 +Time: 10:00A +Print Name: +Print Name +Signature +Unit: +Count: +CA +10 +Metropolitan Correctional Center +Official Count Slip +_ Date. +8-3-19 +Time: +DAu +Print Name: +Print Name: +Signature_ +Unit: +Count: +Print Name: +Signatur +Print Na +Signatur +Metropolitan Correctional Center +Official Count Slip +HosP +Date: +Time: +8.03-19 +10m +E Olivares +Unit: +Metropolitan Correctional Center +Official Count Slip +Date: +Count: +BA +26 +Print Name: +Print Names +Time: +8.03.19 +10am +Metropolitan Correctional Center +Official Count Slip +Date: +8-03-19 +1 +Time: +100% m +Unit: +Count: +Print Name: +Print Name: +Metropolitan Correctional Center +Official Count Slip +Date _ +8-3: 19 +Time: 1000 AM +Unit: _ +Count: +Print Name: +Print Name: +Signature \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/08bd3abdb337ab1b405db7f3dfbcffd130d209ed66ba55b8f0814d6b812ffd7a.receipt.json b/vision-fixhub/ds9-parsed-01/08bd3abdb337ab1b405db7f3dfbcffd130d209ed66ba55b8f0814d6b812ffd7a.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..fe46e7a7159fc8969cf7addb8e983e63d6888de9 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/08bd3abdb337ab1b405db7f3dfbcffd130d209ed66ba55b8f0814d6b812ffd7a.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -594, + "dataset": "marble-joined", + "doc_id": "08bd3abdb337ab1b405db7f3dfbcffd130d209ed66ba55b8f0814d6b812ffd7a", + "engine": "marble-apple-vision", + "event_count": 16, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "f9cd02e827963f3a293bbc9ecb616e18efe1e8ea82542b2864818b51378e71ee", + "output_sha256": "f5f8e660408c7cf073e6b1f17b2cb6a2a1e926f6d2bfc59c684b56bb8923379e", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/08c3e2f909eae738f125572e0d21a48273feb2231792306c68d9cbdfce8f8a1c.md b/vision-fixhub/ds9-parsed-01/08c3e2f909eae738f125572e0d21a48273feb2231792306c68d9cbdfce8f8a1c.md new file mode 100644 index 0000000000000000000000000000000000000000..d9f1b7797df2b5d621279250b40a573473bb0f07 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/08c3e2f909eae738f125572e0d21a48273feb2231792306c68d9cbdfce8f8a1c.md @@ -0,0 +1,18 @@ +From: +To: "Todd Wallace Blanche ( +Buckley Esq. ( +Cronan Esq. ( +Subject: Ballsy! +Date: Fri, 12 Jul 2019 16:26:34 +0000 +Importance: Normal +Attachments: Epstein_bail_letter.pdf +I" < +D" < +. "Sean S. +≥. "John Peter +I' < +Have you read Reid Weingarten's bail letter for Epstein? +It is very impressive, until page 10, when he actually argues that refusing to allow a rich defendant to hire private guards +and live in his mansion implicates equal protection concerns because the decision not to allow defendants to buy their +own cages discriminates against them "based largely on socioeconomic status." +Also, in how many other bail applications do defendants offer to "deregister or otherwise ground his private jet"? diff --git a/vision-fixhub/ds9-parsed-01/08c3e2f909eae738f125572e0d21a48273feb2231792306c68d9cbdfce8f8a1c.receipt.json b/vision-fixhub/ds9-parsed-01/08c3e2f909eae738f125572e0d21a48273feb2231792306c68d9cbdfce8f8a1c.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..2cca44a01365054cedfc6e0c0d4861636d8bc820 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/08c3e2f909eae738f125572e0d21a48273feb2231792306c68d9cbdfce8f8a1c.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "08c3e2f909eae738f125572e0d21a48273feb2231792306c68d9cbdfce8f8a1c", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "ca5cd16528aa8ebe3f58fc71cf06e1972822fd4931c5263ed8fd376b6d455306", + "output_sha256": "f838c940e9b63082beb316612aec5ad2c8b99381405851fb938be8f163411803", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/08cc86f89071d7648fbbcad6e9b0aaa6e357626cb5974bd4643faf3561118bf7.md b/vision-fixhub/ds9-parsed-01/08cc86f89071d7648fbbcad6e9b0aaa6e357626cb5974bd4643faf3561118bf7.md new file mode 100644 index 0000000000000000000000000000000000000000..c10026b24407d25b2fad24f3faca4adf3d88f14a --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/08cc86f89071d7648fbbcad6e9b0aaa6e357626cb5974bd4643faf3561118bf7.md @@ -0,0 +1,169 @@ +Date: Wed, 22 Jul 2020 22:40:20 +0000 +Inline-Images: image001.jpg +Sent: Wednesday, July 22, 2020 18:37 +Sorry guys, today turned into a complete technological nightmare, so 1 just had to save the Word doc locally and do my +best to look stuff up on my phone. Hopefully it's passable. I'm around this evening it it'd be useful to chat. +Sent: Wednesday, July 22, 2020 6:08 PM +Of course, let's plan to touch base at 1:45. +Sent: Wednesday, July 22, 2020 18:07 +On this call in particular - promise it'll be quick. Perhaps we could talk just a few minutes before the call? +Sent: Wednesday, July 22, 2020 5:50 PM + + +Of course - on this call in particular, or just generally? I'm around literally anytime between now and the call tomorrow. +Sent: Wednesday, July 22, 2020 17:32 +Subject: FW: Meeting with +Can we talk for like 5 minutes at some point before this call tomorrow? +From: McGorty, Glen < +Sent: Wednesday, July 22, 2020 5:30 PM +Cc: +Yes, that works. We will send a calendar invite with a dial-in. +Thanks, +Glen +Glen G. McGorty | Crowell & Moring LLP +Managing Partner, New York Office +www.crowell.com +Privileged and Confidential • Attorney-Client Communication • Attorney Work Product +This message contains privileged and confidential information. IF IT WAS SENT TO YOU BY MISTAKE, DO NOT READ IT. +Instead, please notify the sender (or postmaster@crowell.com) by reply e-mail, and delete this e-mail. +Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited. +COVID-19 Questions or Concerns? See Crowell & Moring's COVID-19 Resource Center +Sent: Wednesday, July 22, 2020 4:51 PM +To: McGorty, Glen < +Cc: +External Email +Glen, +No problem. Would tomorrow at 2:00 p.m. work for you? Or if not, we should be pretty flexible, if you want to suggest +an alternate time. +thanks, +From: McGorty, Glen < +Sent: Wednesday, July 22, 2020 09:53 +Cc: + + +Sorry for the delay. We've spoken to +Best, +Glen +Glen G. McGorty | Crowell & Moring LLP +Managing Partner, New York Office +Let us know when might be a good time for a call over the next couple days. +www.crowell.com +Privileged and Confidential • Attorney-Client Communication • Attorney Work Product +This message contains privileged and confidential information. IF IT WAS SENT TO YOU BY MISTAKE, DO NOT READ IT. +Instead, please notify the sender (or postmaster@crowell.com) by reply e-mail, and delete this e-mail. +Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited. +COVID-19 Questions or Concerns? See Crowell & Moring's COVID-19 Resource Center +Sent: Thursday, July 16, 2020 2:32 PM +To: McGorty, Glen < +Cc: +External Email +Glen, +Thanks again for following up with us on this issue previously, and we wanted to circle back to take you up on the offer to +convey some additional information to your client to see if it causes him to recall anything additional. If you could please +of the following additional information? And then we can have a call similar to our last one to check in. +The individual whose photo we sent is named +is an employee of the U.S. Customs and +Border Protection agency and worked in Saint Thomas for a number of years, and may have had a friendship with Jeffrey +Epstein during that time. In particular, +nas been to Epstein's home in the Virgin Islands and has accompanied +Epstein on boat, helicopter, and/or plane trips. +Mr. +was listed as a contact in +at a bar or other location in the Virgin Islands. +phone, and +may have introduced one or more individuals to L +Please let us know when you've had an opportunity to provide this additional information? And we hope you're well and +look forward to being in touch. +thanks, +From: McGorty, Glen < +Sent: Monday, June 22, 2020 14:27 + + +Cc +Would you all be available for a call on Wednesday morning? I think we could do any time before noon. +We will let you know if Mr. I +recognizes the individual in the photo. +Best, +Glen +Glen G. McGorty | Crowell & Moring LLP +Managing Partner, New York Office +www.crowell.com +Privileged and Confidential • Attorney-Client Communication • Attorney Work Product +This message contains privileged and confidential information. IFIT WAS SENT TO YOU BY MISTAKE, DO NOT READ IT. +Instead, please notify the sender (or postmaster@crowell.com) by reply e-mail, and delete this e-mail. +Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited. +COVID-19 Questions or Concerns? See Crowell & Moring's COVID-19 Resource Center +Sent: Monday, June 22, 2020 12:49 PM +To: McGorty, Glen < +Cc: +External Email +Glen, +It was indeed quite a weekend, but we continue to do our work as always, and the kind words are appreciated. +Thanks also for getting back to us, and we're available for a call this week if that would be helpful, and/or if you want to +let us know in the first instance about the photo in particular, we can also just go from there. Let us know, and we're +around. +thanks, +From: McGorty, Glen < +Sent: Saturday, June 20, 2020 17:28 +Cc: +Belated thanks, +We will circle up with Mr. +and maybe we can have a call early this coming week. + + +Crazy times in the Office these days - I hope you are all doing okay. I was on a number of e-mail threads since last night +and there are many efforts afoot from generations of alums to publicly support the Office as an institution and all it stands +for (and to express profound disappointment over the recent developments). Hang in there. +Glen G. McGorty | Crowell & Moring LLP +Managing Partner, New York Office +www.crowell.com +Privileged and Confidential • Attorney-Client Communication • Attorney Work Product +This message contains privileged and confidential information. IF IT WAS SENT TO YOU BY MISTAKE, DO NOT READ IT. +Instead, please notify the sender (or postmaster@crowell.com) by reply e-mail, and delete this e-mail. +Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited. +COVID-19 Questions or Concerns? See Crowell & Moring's COVID-19 Resource Center +Sent: Friday, June 19, 2020 3:07 PM +To: McGorty, Glen < +Cc: +Subject: FW: Meeting with +External Email +Glen, +Per my previous email, please see the below. +thanks, +Sent: Wednesday, June 17, 2020 18:29 +To: Donnie Murrell < +Cc:/ +Donnie, +It's been a while since we've been in touch, and obviously our world changed substantially very shortly after the below +email exchange from August 9. But we wanted to reach back out because we were wondering if you would be willing to +ask Mr. +La couple specific, relatively narrow questions relating to an ongoing investigation. Ordinarily we would ask +ourselves, in the context of the discussion we had planned to have-and still hope to schedule, once health and safety +permits-but given all of the current circumstances, we'd like to make the request through you. +The initial question is whether Mr. +recognizes the individual in the attached photo, and if so, generally how he +knows the individual. And if Mr. +does know the individual, we may ask you to please convey limited follow-up +questions, or to schedule a brief call. If it would be at all useful to discuss this request, please let us know; if that is +helpful we can chat at your convenience. +Thank you, and hope this finds you well. + + +Assistant U.S. Attorney +Southern District of New York +Sent: Friday, August 09, 2019 15:20 +To: Donnie Murrell < +Cc: +Donnie, +Our schedule is a bit up in the air right now, but we are tentatively looking at dates during the week of the 1gth +'. We will +let you know as soon as our plans firm up, and thanks for being flexible. +Best, +From: Donnie Murrell < +Sent: Friday, August 9, 2019 11:19 AM +Subject: Meeting with +Ms. +Have you firmed up the date/s you will be down here? +L.D. MURRELL, P.A. +Donald "Donnie" Murrell, Jr. +Board Certified Criminal Trial Lawyer \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/08cc86f89071d7648fbbcad6e9b0aaa6e357626cb5974bd4643faf3561118bf7.receipt.json b/vision-fixhub/ds9-parsed-01/08cc86f89071d7648fbbcad6e9b0aaa6e357626cb5974bd4643faf3561118bf7.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..5c2143ebae72ea1e14bb7d0f256740e33770c8d4 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/08cc86f89071d7648fbbcad6e9b0aaa6e357626cb5974bd4643faf3561118bf7.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -553, + "dataset": "marble-joined", + "doc_id": "08cc86f89071d7648fbbcad6e9b0aaa6e357626cb5974bd4643faf3561118bf7", + "engine": "marble-apple-vision", + "event_count": 7, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "12c1ed9b15969db19b9c32a88c535f40a55684913c90ce818c5509985cca9ffd", + "output_sha256": "c8b2aa8649f8836a283df06efe042fbd18c6625678482e3199d1d2db04780dbb", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/08d3921c16b22b5ddd58143fbcce1083daba9671ebee32b15973f5e697e4813a.md b/vision-fixhub/ds9-parsed-01/08d3921c16b22b5ddd58143fbcce1083daba9671ebee32b15973f5e697e4813a.md new file mode 100644 index 0000000000000000000000000000000000000000..c4e6ce7e3fd13ccedfe198b6164d8961b46e58ca --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/08d3921c16b22b5ddd58143fbcce1083daba9671ebee32b15973f5e697e4813a.md @@ -0,0 +1,15 @@ +From: +To: +Subject: +Date: +Attachments: +Epstein Jewish Burial +Wednesday, August 14, 2019 7:40:33 AM +IEXT.htm +Good Morning, +I know you are very busy, but when you get the chance, please read the below article. Very interesting +https://forward.com/news/national/429406/will-jeffrey-epstein-get-a-jewish-burial-despite-his-crimes-and-sins/ +Respectfully, +646-836-6454 +"Trust yourself when all men doubt you, but make allowance for their +doubting too" R. Kipling diff --git a/vision-fixhub/ds9-parsed-01/08d3921c16b22b5ddd58143fbcce1083daba9671ebee32b15973f5e697e4813a.receipt.json b/vision-fixhub/ds9-parsed-01/08d3921c16b22b5ddd58143fbcce1083daba9671ebee32b15973f5e697e4813a.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..7e37527f1261a482853151d2475d53f326531de7 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/08d3921c16b22b5ddd58143fbcce1083daba9671ebee32b15973f5e697e4813a.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "08d3921c16b22b5ddd58143fbcce1083daba9671ebee32b15973f5e697e4813a", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "1caea2fe1625c4b884935d746846658a44e053b4a414f39eff216d0aef66ad5b", + "output_sha256": "a32fafdaa82bcdbedff8c1bcf64b70b9d56e05aff1acd6519183bbbd2e4491b1", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/093e7c8184ed2c2fe3e84772f9e548ccaccaa515c4207bf4b79146b05ebb0208.md b/vision-fixhub/ds9-parsed-01/093e7c8184ed2c2fe3e84772f9e548ccaccaa515c4207bf4b79146b05ebb0208.md new file mode 100644 index 0000000000000000000000000000000000000000..9bff37a45b9b1ecac20599c61b3f061423ac566d --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/093e7c8184ed2c2fe3e84772f9e548ccaccaa515c4207bf4b79146b05ebb0208.md @@ -0,0 +1,26 @@ +From: +Cc: " +To: "Strauss, Audrey (USANYS)" { +(USANYS)" { +(USANYS)" { +1)". +Subject: Friendly Subpoena to +Date: Fri, 26 Mar 2021 16:05:00 +0000 +Attachments: 2021.03.26, +(USANYS)" +Attorney +Hi Audrey, +The Maxwell team would like to send the attached "friendly subpoena" to +attorney +During our interviews in Florida, +informed me that he has a copy of the settlement agreement between +and +Epstein, which resolved +2009 civil suit against Epstein. L +is willing to provide us with a copy of the +agreement, but he indicated that he believes he needs a subpoena before he can do so. His firm has already provided us +with copies of all other court filings and deposition transcripts from the civil case voluntarily. The settlement agreement +resolving the case is relevant to our ongoing investigation into Maxwell's participation in the abuse of D +Land other +underage girls. +Thanks, diff --git a/vision-fixhub/ds9-parsed-01/093e7c8184ed2c2fe3e84772f9e548ccaccaa515c4207bf4b79146b05ebb0208.receipt.json b/vision-fixhub/ds9-parsed-01/093e7c8184ed2c2fe3e84772f9e548ccaccaa515c4207bf4b79146b05ebb0208.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..c2dd4e207a32ebb98a2da6141d2a673ad3c6fe58 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/093e7c8184ed2c2fe3e84772f9e548ccaccaa515c4207bf4b79146b05ebb0208.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "093e7c8184ed2c2fe3e84772f9e548ccaccaa515c4207bf4b79146b05ebb0208", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "03659a13212cc7273ec415ba48a5fdbf155c2ee0ff57966f1e246f32c5238fdb", + "output_sha256": "7684b3301ce53b1adf30c197817cce4713df6e6462e9e1275d73dda2ce212dfb", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/097062b062f7366d48d868d2edab36faa5ce4fc63c95b26ad1a72d265f1037f8.md b/vision-fixhub/ds9-parsed-01/097062b062f7366d48d868d2edab36faa5ce4fc63c95b26ad1a72d265f1037f8.md new file mode 100644 index 0000000000000000000000000000000000000000..eb4deaaed829cbad72b6c24e81b4a16df2612177 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/097062b062f7366d48d868d2edab36faa5ce4fc63c95b26ad1a72d265f1037f8.md @@ -0,0 +1,555 @@ +JEFFREY S. POP & ASSOCIATES +A LAW CORPORATION +BEVERLY HILLS, CALIFORNIA 90212-3428 +TEPHONE +January 3, 2020 +1, Esq. +Assistant U.S. Attorney +Southern District of New York +Re: Attorney Proffer +Epstein ( +Via Electronic Mail +Dear +The following is my understanding of the facts and evidence that +would bring forward regarding Jeffrey Epstein. Her most relevant introduction with Epstein +occurred between April 19, 2004 to approximately April 2007. +I. Background +My client, +, prefers to be called +. She was born in +on +- She was an only child. She moved to the United States in +1993. Her mom and dad were not proficient in English and took classes to learn. They +worked during the day and took classes at night in order to better themselves in this country. +went to school but was left isolated at home. Her parents did not have or spend the +time necessary to understand her. Her education during the adolescent years from a social +point of view was without guidance. She spent time studying but had little emotional support +from her parents as she grew up in Brooklyn. +had an interest in modeling but her +parents stressed education. +uddenly, her father died from cancer iust before she turned seventeen. Her parents ke +the fact that he had cancer from her so +vas very shocked at her father's passing. SI +didn't get a chance to say goodbye. Her first significant boyfriend was when she was 18 +years old; He was older, age 30. They dated for almost 4 years. Thereafter, +wanted to +pursue modeling and went to casting. She learned that the cut off age for new models is +usually 23. Her modeling agency found her a job as a hostess. +then learned to be a +cocktail waitress. In March 2004, she moved from Brooklyn to Manhattan due to the strained +relationship with her mother and because she felt she'd have better modeling opportunities in +Manhattan. She was trying to make ends meet in April 2004. Her significant contact with +Epstein began on April 19, 2004 and ended in February 2007. + + + +II. Approach - Re: Massage +was working three jobs, six days a week but worried about making her rent and +paying bills. A girl, approximately 25 years old, named worked a promotional job with +Thereafter, +and +aw each other at a party. As they chatted +said +she was struggling financially where upon +mentioned that she knew a guy who paid hel +$300.00 to give him a massage. +and +Farther, aropes ve wou was ipl coithat he liked oking andpadmites or edud tim. +"urtner, at times, +Notwithstanding, the guy had a sexual fetish and would masturbate himself at the end of the +topless massage. +agreed to meet the guy. +had told +that she had met +at a club and that +was the contact. +At the time, +knew +last name. +was attempting to be in the hair +styling business and lived in Harlem. +said she was from Paris and was also a model. +said she was 28 years old (Attorney investigations indicate +contact +information email is +met +at a Starbucks. +looked at +and criticized her teeth as being too yellow but said that she was very pretty +and she would do well with this guy who sometimes had women travel with him to the +Caribbean. He potentially would buy them clothes and help pay for school. +confirmed what +had said to +the evening before. The next day it was arranged +and +went to the address that she was given. +III. Introduction to Epstein +On April 19, 2004, +went to the man's residence. It was a large building. +was let into a waiting room. She waited for approximately 25 minutes when a man came and +smiled and said "I'm Jeffrey." +After introductions, he said "Give me 5 minutes, Lynn will show you upstairs." In a short +time, Lynn came and +rode in an elevator. +was in awe that the residence was +so large that he needed an elevator. The elevator opened and +was lead into a massage +room. In the room, there was a massage table and it was semi-dark. There were pictures on +the wall, a table with lotions, a telephone and pen and paper. The ceiling of the room was +concave and painted as clear blue skies. The massage went as expected in the beginning. +Epstein laid face down and instructed +to massage his back and legs, then proceeded +to make phone calls. Then he turned over and started talking to +. He thanked her for +coming, gave her compliments on her looks and asked her about herself. He instructed +to massage his chest, then he touched her stomach and underwear. +cringed, +she thought Epstein would take her underwear off. Epstein sensed her tension. He said: +"Relax. I want you to have fun. If you're uncomfortable with something I am doing, you +have to be straight with me and tell me, it's not a big deal." He respected +wishes. +The massage ended. Jeffrey masturbated and made a loud noise when he ejaculated. +Afterwards he said, "I'll give you some money and I'd like to see you again, could you write + + + +your number down. My office will be in touch with you." +wrote her number on a pad +which was personalized with the Epstein name. The first session ended. +During the same week, roughly two days later, the office called and made an appointment +for +to meet him again. By the second encounter, +knew Epstein had grown up +in Brooklyn and was a self-made billionaire. She was astonished by what he had +accomplished. She went and saw Jeffrey for a second time. During this second massage, +Jeffrey asked +a number of questions about herself, about her background about her +schooling, where she was raised, what her career aspirations were, whether she wanted to +become a model or not, and showed genuine interest in who she was. +asked him +some questions. +After the massage, Jeffery gave +a personal tour of three or four floors of his +mansion. Each room was very unique and was decorated lavishly. +was extremely +impressed by the extravagant décor that she saw from room to room. There were many +pictures which she later understood were of famous or important people as well as beautiful +women. She left home that day feeling that she had a connection and chemistry with Jeffery. +believed that Jeffrey was very charming and felt lucky to have met him. +IV. Important Long Term Friends, Employees, Close Associates and Girlfriends +Jeffrey's Long Term Fiends +1. Jean Luc Brunel +He was a friend of Jeffrey before +met him. +believes that he had been +friends with Epstein approximately for more than 10 years. Jean Luc lived at +Street. At this address, Epstein owned several apartments that he would either give or lease +out to staff, friends, girlfriends, and traveling girls. +believes that Jean Lue was an owner or part owner of Karin Modeling. Jean Luc +also had an interest in modeling agencies and had an interest or ran Karin Modeling agency +in Miami. Later on, +became aware that Jean Luc may have had an interest in a +nodeling agency in Israel. The Karin Modeling agency changed its name to MC ir +approximately 2006. From +›bservations, Jean Luc was one of Epstein's closes +friends. +In late 2006; +heard (but doesn't know firsthand) that the FBI went to +Street where some Brazilian models that Jean Luc brought, had been staying. They were +frightened when confronted by law enforcement. In general, most people that lived at +Street. in Enstein's apartments, were held in higher esteem. Generally, those that +stayed in +Street were stati, his girlfriends or girls that traveled with him +regularly, or girls that visited Epstein from out of town or out of country. + + + +2. Ghislaine Maxwell. +met Maxwell about the 4* time that she met Epstein. +was with Epstein +when he suggested that they go to meet some friends at the Spice Market restaurant. When +they got there, there was a scientist and Maxwell. +sat while they all had dessert. +The next time +met Maxwell was at the island after Jeffrey asked her to come on +a trip with him. +saw Maxwell at Jeffrey's office, the house or at a charity event. +From +view point, Maxwell was intimidating. She instructed +to take +down her telephone number and to call her if she ever needed anything. +did not have +a warm feeling about Maxwell and never called. She attempted to stay away from Maxwell +as much as possible. +recalls between mid-2004 and 2006. She saw Maxwell +approximately 4-5 times at the island. Maxwell was in New Mexico the one time +went there in the summer of 2005. +Maxwell seemed to make fun of some of the girls at the island and put them down. It +was +understanding that Maxwell helped coordinate the supplies of dresses, +swimsuits, and skin care products at the island. Epstein told +that Maxwell was the +"original girl finder" +tried to stay away from Maxwell as much as possible because +she felt that she was a domineering, aggressive female that placed fear into younger women. +3. Eva Dubin +She was an ex-girlfriend of Epstein. +was Jeffrey Epstein's' +1. Jeffrey cared a lot for Eva and +• He had a large photograph of him and +Eva once came to the Caribbean island with her children and spouse. +accompanied Epstein to Eva Dubin's home when he was saying goodbye to people before he +went to jail. +4. Faith Kates +She was a friend of Epstein since the 1980's. She owned Next Model Management. +understood that she introduced +to Jeffrey sometime in 2005. +believes that she might be significant because she heard Epstein ask her to introduce +him to girls +Epstein Employees +1. Lesley Groff (Executive Secretary) +She called +to schedule appointments with Epstein and called to connect +with Jeffrey to talk. Most of the time, she was the one who made travel arrangements for +Epstein told +that he kept things professional at the office and showed respect +to his employees; +believed that Lesley Groff was Jeffrey's right hand at the office. She was in +charge of his call list. Groff was polite, neutral and positive with her words. She also had a + + + +cheerful attitude and was easy to talk to. Epstein told +that +was invaluable to +him, in part, because she would observe him and anticipate his needs without having to +check with him. +'s desk was in an office that was adjacent to Epstein's with an openings in-between. +could actually see Epstein when he was at his desk if she turned and looked in that +direction but she could not see in his total office because she was in the adjoining or +connecting office. At the time +met +n 2004, +would estimate that +was in her early forties. +(Personal Assistant) +She was approximately +age, maybe a little older. Her duties including handling +done. The times that +traveled with Epstein, +would be there slightly less than +50% of the time. +found +• quiet, friendly and reserved. +was from al +She didn't want to follow in the +heard that +Iradition +so she left her family. She moved to Hawaii where she lived with a boyfriend. Then | +roke up with her boytriend and had nowhere to go. That's when she received a call from +irl she knew with an offer to work as Epstein's assistant. +believes the girl's name +was +and that +was Epstein's former assistant. Apparently, +came +right away to take the job with Epstein. +believes that +was 20 years old when +she was hired by Jeffrey. +never heard or witnessed +make phone calls at Jeffrey Epstein's request. +ooking for girls or approaching anyone. She did +believes that +might be a +victim of Epstein. +(Office Assistant) +Erom 2004 to 2006, she was an office assistant to Epstein. Her senior was Lesley Groff. +believes that +was from Sweden originally, and heard that she was introduced to +Epstein by Eva Dubin. After +finished graduate school, she left approximately in early +2006. She had plans to move to Dubai. +She was approximately a 21 year old model from +when she met Epstein. +heard that +met Epstein at an art event in New York. Epstein had +travel with +thin for a month or two as a potential girlfiend. Several months later +became aware +was a second assistant to Jeffrey. Epstein was obsessed with +body +and made a comment that just looking at her figure put him in a good mood. Approximately + + + +that +a few months later, +left Epstein's employment and Epstein told +had gotten married in Miami and moved. +Jeffrey's Girlfriends +1. +Soon after +was introduced and got to know Jeffrey Epstein, she became aware +that +was Jeffrey Epstein's girlfriend. +was 19 at the time when +From +knowledge, +met Jeffrey Epstein through Jean Luc Brunnel who was a +close friend of Jeffrey Epstein's. +remained Jeffrey's girlfriend through approximately +2007 and possibly longer. She lived at +was Jeffrey's second girlfriend. At the time she was 21 and was a professional +model. +met her in approximately 2005. +traveled with Epstein until 2006 +when she was in a vehicle accident. After the accident, +is not certain whether +remained Jeffrey's girlfriend. +V. J.E. and +'s Relationship +As discussed in detail, her relationship with Epstein began on April 19, 2004 was that she +was interested in Epstein as a person. She believed that he had a strange fetish. From talking +to him, she believed that he had a difficult childhood and experienced daily stress from +talking to many people a day and making business decisions where a lot was at stake. Early +on, Epstein showed interest in +as to her background, career, and in her future. +Within weeks, Epstein started asking +if she had friends to introduce him to. As +time when on, the request to introduce friends became a pressure to find girls. +was +reluctant but Jeffrey explained it was no big deal. +was told that she could do very well with Jeffrey Epstein if she helped him and +followed his rules as far as being truthful. During this time she was aware that Jeffrey had +helped people with schooling, their career or with medical situations if he liked them. +Jeffrey also had certain rules and was direct about them. He told +that he +demanded honesty and did not want people around him that lied to him at all. He also said +that he did not want people who drank a lot, had any type of criminal background, used drugs +or were involved in prostitution or were stripping. +Shortly after meeting Epstein, +stopped working her three jobs and did +promotional modeling as well as club promotions. With this schedule, +was available +for Epstein upon his request. After +traveled with Epstein for several months, he sent +her to his hairstylist. He would also instruct +on what clothe were to his liking. He +explained to +that his mentor taught him how to dress. Epstein would take a few of the + + + +girls that were with him to go shopping. He pointed out what he thought was in good taste +and looked good as compared to combinations that he didn't think looked good. +learned how to dress from his comments. +Over the years, +got to understand Epstein in some ways and not at all in others. +She was impressed with his accomplishments and the way he handled people. She attended +dinner parties at his house with other young girls about her age and business associates of +Epstein. These parties were interesting and +could see how much respect people had +for Jeffrey Epstein. To +knowledge, there were no sexual encounters at these parties. +Social, business acquaintances and Epstein's friends were present at these parties. +also was invited to teas at Epstein's house with Epstein's friends, business +acquaintances, and beautiful women. In these settings, the matters were purely social and +not related to anything sexual. Epstein would call +to his office and she would spend +time with him, but not in a sexual manner and potentially for a part of the day. There were +times he'd call +to the office for her company and then leave in a car to run errands. +Basically, he helped +with her living expenses but wanted her available to be with +him and accompany him on trips upon request. Epstein, in fact, helped +with dental +work that she needed. +During the first three months, there were discussions about +and her aspirations +regarding whether she wanted to be a model. She replied that she thought she was too old to +be a working model. During this time there were also discussions whether she would be +interested in working or running a modeling agency. +This conversation came up a few times, but Epstein said that he wanted to help +and was interested in buying an agency. +During discussion about the modeling agency, Enstein said that he was interested in +buying a modeling agency and that he thought that +could run it. +mentioned +that she had no experience and he said that if she worked for an agency for a year, she could +pick it up because she's smart and there's not that much to it. At the time that he said this in +2004, +had known, through Google and her search that Epstein had been interested in +buying an agency and she thought she was lucky that he maybe would follow through and do +this because it would give her a good career opportunity. +thought that she was lucky +and in the right place at the right time. +By late summer 2004, +was aware that there were other individuals who were +helping Epstein find new girls for him to see. She did not know exactly who they were but +there were days believed knew that Epstein saw girls for a massage three times a day when +he was in New York. This number, if true, was far in excess of the number of girls that +indirectly or directly, introduced to Epstein. +During the times that they traveled to the island Little St. James, +would be there +with two or three other girls and sometimes including +1, Jeffrey's assistant. The +activities on the island were somewhat structured which +liked. The people that came + + + +with him would have breakfast, lunch and dinner together. There were times they had group +activities which would include snorkeling, being in the pool, or going to St. Thomas to do +shopping or visiting his office there. The group of them would even go out for ice cream +after business. They also biked, hiked, and snorkeled. These group activities were generally +something that +welcomed and enjoyed. There were times when Epstein just had +around just to check how she was doing. Sometimes at the island, +was called +to see Epstein for a bubble bath on more than one occasion which turned out to be nonsexual. +Epstein would inquire how +was doing and ask if she was having fun. On many +occasions, Epstein asked | +to only give him a foot massage when they were on the +island. +When the modeling agency didn't work out and more pressure was coming from Epstein +regarding finding girls, +became frustrated. +recalled in 2005 that she asked +Epstein on two occasions, about three months apart, about whether she could be his second +assistant. She thought there was going to be an opening in that position. Epstein replied, "Not +now, but let's talk about it later." At the end of this period, +believed that he was +stringing her along. She disliked the pressure that Epstein was putting on her to find girls. +In August 2006, Jeffrey Epstein told +he had been arrested and the FBI was +involved. He told her she should not bring any girls or look for any girls for him at that time. +was scared because she didn't understand what happened. Epstein cut the +conversation short and didn't want to talk about it. +For the next 2-3 weeks, +access to Epstein was limited as he was traveling and +unavailable. As far as Florida was concerned, all the information that +got was from +Google alerts and whatever newspaper articles they picked up and forwarded to her. She +never discussed this with people in the Epstein's circle of influence. +Starting in May or June of 2004, Epstein used sexual toys such as vibrators on +was not experienced with these before. Later the type of vibrators changed; +faked orgasms Eventually, +told Epstein that the vibrator hurt her. +By early 2005, Epstein suggested threesomes. Before this happened, he told +that +kissing and being with women would help her learn how to please a man. The threesomes +occurred 3-4 times in New York, New Mexico, or on the Island. Sometimes Epstein's +girlfriends were involved. +In late 2005, Epstein asked +to see male friend on his behalf. The first time Epstein +said it would be good for you to meet this guy. +Thereafter, Epstein directed +to go to a hotel room and give a massage or be with +his friend. This happened about every three months for different friends. +was upset +and very hurt about being told to be with his friends. + + + +VI. Employment -Introductions +1. In the fall of 2006, +was placed by Enstein an intern for +in New York. At the time, +was a well-recognized agency. +worked as an intern at that agency until February 2007. +2. In February 2007, Enstein called +and said he had an opportunity of a lifetime +for her to work at +In 2007, +started at +continued until May 2008. It was a difficult job for +and +was in the news and people at +knew that she got the job because of +Epstein. +took an English course to improve her writing skills. By March +2008, Natalie was able to study, take and pass the Series 7 exam. By May 2008, she +voluntarily left +due to personal reasons. +VII. Jeffrey's Incarceration +During the time that Jeffrey was incarcerated, +occasionally sent emails to see how +he was doing. Some emails were answered and some were not. These were personal in +matter. At this time, +life was difficult on many levels, most of which were due to +the trauma and relationship she had had with Epstein. +Post Epstein's incarceration, +spoke to Epstein in New York in November 2010 by +telephone. During that conversation Epstein asked +to look for girls, but +declined, and the conversation ended. At that point, +decided that she had to leave +New York. +left in early 2011. +In February 2017, +received an email from Epstein stating that he was being sued +and that she had been named in a lawsuit filed by +should get an +attorney and that it would be best if they did not communicate. As it turned out, +was +never served in the case entitled Doe 43 v. Epstein et al. +VIll. +Hindsight +realized that she missed the warning signs regarding Epstein's character and +motives. The following summarizes her hindsight beliefs: +1. Looking back, the surroundings and the way Epstein conducted business made it +possible for him to manipulate people and brainwash them. +2. The people around Epstein who were involved in sexual encounters such as +and others, had nowhere else to go. They had no family, and were young, +easily trapped and manipulated. +: + + + +3. All these girls were unable to separate the aura of success, the private jet, the island, +the many houses, and the various influential people who looked up to Epstein from +the truth of what was going on and how he was pulling strings and working at sorting +through young woman for his own benefit. +4. +now believes that Epstein was picking through the numerous girls who he +could control for his own gratification and to eventually either provide service for +Epstein's friends of his or who he could introduce to important people for marriage. +Either way, all were, for Epstein's benefit and to increase his influence. +5. +is still troubled and haunted by Epstein and what happened to girls who may +have been vulnerable and hurt. It is now over 15 years and +continues to suffer +psychologically and emotionally from Epstein's control and domination. +The following 16 points is +1 perception of how Epstein manipulated women +(girls) for his purpose: +1. Show interest in the girl personally— make her feel special; +2. Gain trust sexually, have fun, feel comfortable, just say something bothers you - no +big deal, makes you feel comfortable; +3. Impress with accomplishments, wealth, power interaction with important people and +show mansion; +4. Surround young girls by happy people, fun loving, powerful, beautiful and +successful people to create an aura of privilege and normalcy; +5. Ask friends- massage; +6. Promise a path to success - modeling agency, you can do well with me; +7. Increase financial support and dependency; +8. Massage - find willing girls no older than 23; +9. Control life by making "Epsetin only consideration"-must be available; +10. Dominate sexually; +11. Increase pressure for more introductions; +12. Introduce: sexual devices (vibrators); + + + +13. Introduce threesome —group sex with Epstein; +14. Direct— strongly suggest sexual encounters with his "friends"; +15. Order sexual encounters with "friends" for Epstein's benefit; and +16. Discard girls after use when old (age 27) become unstable or unwilling to bear fruit +(more introductions). +Accept my apologies for the length of this document; however, it provides an outline of +the environment my client experienced years ago. +Sincerely, +Jeffrey S. Pop +Attorney at Law diff --git a/vision-fixhub/ds9-parsed-01/097062b062f7366d48d868d2edab36faa5ce4fc63c95b26ad1a72d265f1037f8.receipt.json b/vision-fixhub/ds9-parsed-01/097062b062f7366d48d868d2edab36faa5ce4fc63c95b26ad1a72d265f1037f8.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..5f8ebf198b04bbe4640211f5cf12d15d5b46980a --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/097062b062f7366d48d868d2edab36faa5ce4fc63c95b26ad1a72d265f1037f8.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -640, + "dataset": "marble-joined", + "doc_id": "097062b062f7366d48d868d2edab36faa5ce4fc63c95b26ad1a72d265f1037f8", + "engine": "marble-apple-vision", + "event_count": 23, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "e96dae6211daff83a05a31bc18eced83e69643f0f663c3f8576c17981806a36d", + "output_sha256": "52b81d285afe8f6f946692035f5373117adc637fedc9f66013c761fc9ef72778", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/099e4fe3321cefad5667e35e64486f87fab1d831a7ce1b60ad8ab4c2f63f7098.md b/vision-fixhub/ds9-parsed-01/099e4fe3321cefad5667e35e64486f87fab1d831a7ce1b60ad8ab4c2f63f7098.md new file mode 100644 index 0000000000000000000000000000000000000000..8ffb1e944b9c4f23991c262636d53ab859361e38 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/099e4fe3321cefad5667e35e64486f87fab1d831a7ce1b60ad8ab4c2f63f7098.md @@ -0,0 +1,13 @@ +From: +To: +Subject: FW: FBINET to UNET Uploaded Files +Date: Mon, 09 Mar 2020 21:33:17 +0000 +Attachments: MCC_DVRs_.._Status_regarding_system_failures.msg +Special Agent +FBI New York Field Office +Violent Crimes Task Force +-----Original Message-.--- +From: +Sent: Monday, March 09, 2020 5:11 PM +To: +Subject: FBINET to UNET Uploaded Files diff --git a/vision-fixhub/ds9-parsed-01/099e4fe3321cefad5667e35e64486f87fab1d831a7ce1b60ad8ab4c2f63f7098.receipt.json b/vision-fixhub/ds9-parsed-01/099e4fe3321cefad5667e35e64486f87fab1d831a7ce1b60ad8ab4c2f63f7098.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..6a7ca2bf6f996d87b7ec76132604b279b7b6423b --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/099e4fe3321cefad5667e35e64486f87fab1d831a7ce1b60ad8ab4c2f63f7098.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "099e4fe3321cefad5667e35e64486f87fab1d831a7ce1b60ad8ab4c2f63f7098", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "d20c1cdb03ba73cd4d8c99975e86035f9e00d6ab3f46241dd9167798279952d4", + "output_sha256": "4ac163343d4649d692c97907a7b6870733b04dd4e20d2fc2f0928809f44ffc27", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/099fde950093b20100421389fb0050c489e6ca16c30f6b07ff885a88b522ce7a.md b/vision-fixhub/ds9-parsed-01/099fde950093b20100421389fb0050c489e6ca16c30f6b07ff885a88b522ce7a.md new file mode 100644 index 0000000000000000000000000000000000000000..b4764fb5fde9efd7b8209febf5b46ffd94169f09 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/099fde950093b20100421389fb0050c489e6ca16c30f6b07ff885a88b522ce7a.md @@ -0,0 +1 @@ +No Images Produced diff --git a/vision-fixhub/ds9-parsed-01/099fde950093b20100421389fb0050c489e6ca16c30f6b07ff885a88b522ce7a.receipt.json b/vision-fixhub/ds9-parsed-01/099fde950093b20100421389fb0050c489e6ca16c30f6b07ff885a88b522ce7a.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..1ba964becb4abe798addc875adc2beab078d6923 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/099fde950093b20100421389fb0050c489e6ca16c30f6b07ff885a88b522ce7a.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "099fde950093b20100421389fb0050c489e6ca16c30f6b07ff885a88b522ce7a", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "94421adde54e2eb0035f67c52665b875a291ce3bdd0227f4680f17c0702b7c86", + "output_sha256": "3874328764c818fba06683a6d5ddc2edc2d7850aaf4ba18646f81d3f8420a729", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/09e7ae1af620a36b97ceaa9e47664113ce66278cc559227d7d4ef9bb58f28942.md b/vision-fixhub/ds9-parsed-01/09e7ae1af620a36b97ceaa9e47664113ce66278cc559227d7d4ef9bb58f28942.md new file mode 100644 index 0000000000000000000000000000000000000000..318cb9e41e05b0cf353d0b546f69410e3dfba161 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/09e7ae1af620a36b97ceaa9e47664113ce66278cc559227d7d4ef9bb58f28942.md @@ -0,0 +1,121 @@ +TERI +COMSULT YOUR LAWYER BIPORI SIGNING THIS INSTRUMINT - THIS INITRUMANT SHOULD I UID BY LAWYERS OMY +THIS INDENTURE, melatino oth day of Septerne, nineten hundred and Blohty-lne +BETWEEN +BIRCH NATHEN SCHOOL, INC., having an address al +East It Street, New York, New York +party of the fine part, and +an address at +party of the secund part, +party the pay at then if the fe are rendere al an ole pay ofter and an it im +i enigne of the party of the second part forever, +Tina at are a lor us or are an a by county and are of he rag, in. +bounded and described as followat +eaten on act in he mad by the idea on of the data do +5th Avenue with the northerly aide of 7lat Street; running +thence Easterly along the northerly side of Tat Street 50 feet; +¿tra or ens Bick a dean Lar an an ere 202 coat 2 inches to the centre +thence westerly along the said center line and paralled with 7lat Street +50 feet; +hether i a stat eldet at the point or place of lochen to the +This deed is executed in accordance with Supreme Court Order o! +the State of New York held in and for the County of New York +on the 6th day of February, 1989, Illed an Index No. 2225/89, +the second part forever. +AND the party uf the first part covenanta that the party of the frot part has not done or suffered anything whereby +part will receive the cons +trust fund to be applied first for the purpose of paying the colt of the improvement and will apply the same first to +he payment of the cost of the improvement before using any part of the total of the same for any other purpose +The word "party" ghail be construed as if it read "parties" whenever the sense of this indenture so require +IN WITNESS WHEREOF, the party of the firt part har duly executed this deed die day and year first abore +written. +IN PRESENCE OF: +вікт мена: вскод, тк. +plex +PID: 3. +goon +chattman add President + + +HPDA +Don ely came +so eated es fores to tried, +Partially came day of +19 , before soc +STATE OP MEW YORK, COUNTY OF +On the ! ot +New York +19 g9, before m +STATS O9 NIW YORK, COUNTY OF +On the +day of +persunally came +MI +19 +" before me +точ +that +he la the Chairnan +of Birch Mathen School, +and Prosicent +he corporation describer +in and which execuled the forgoing instrument; that +that he knows +to be the individual +lescribed in and who executed the foregoing instrument: +that +he, sald subecribing witness, was presnt and sav +doned by ender of themed h +of directors of mid corpora +exsoute the same; and that +he, sald witnee, +he signed hiBname thereo-by Tee +der. at the same time subsoribed h +name as witnom thereto. +Queen Cassor l +Notary Public +соу . 1901 +Bargain ant dosie Beeb +PITH COVEMANT ARAIRIT GRANTONS AÇT +TITLE NO. +BIRCH WATHEN SCHOOL, INC. +TO +5-50,100- +REAL ESTATE™ +30490 +SECTION 5 +BLOCK +1386 +LOT +10 +COUNTY OR TOWN +Manhattan +framina: 4 East 7ist street +SEP 1 1 1989 +TRANSER TE +NINE BAST 71ST STREET CORPORATE UNTY +RETURN BY MAIL TO: +Jack S. Levey. +Schwartz, Kelm, +Eag. +Warren & Rubinscein +41 South Migh Street +columbus, chio +Zip No. +43215 +Lex Terrac, Led. +331 Madison Avenue +New Port, N. y. 10017 +(218/ $99-1300 +A -19 +52,800 - +7625$ 1 + + +$3.00 +RECORDED IN NEW YORK COUNTY +OFFIGE OF THE CITY REGISTER +ME9 SEP || P 303 +jay is. +CITY MEGISTER +IPT 7. diff --git a/vision-fixhub/ds9-parsed-01/09e7ae1af620a36b97ceaa9e47664113ce66278cc559227d7d4ef9bb58f28942.receipt.json b/vision-fixhub/ds9-parsed-01/09e7ae1af620a36b97ceaa9e47664113ce66278cc559227d7d4ef9bb58f28942.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..4fa76df41e6928b35aa04fd579244769fe7bfbba --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/09e7ae1af620a36b97ceaa9e47664113ce66278cc559227d7d4ef9bb58f28942.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -36, + "dataset": "marble-joined", + "doc_id": "09e7ae1af620a36b97ceaa9e47664113ce66278cc559227d7d4ef9bb58f28942", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "c7251c57c198473d31458a576f63181d5539cbb8ea8dea56a72c42f39d32175b", + "output_sha256": "d58fe2de11ad34c6a0fcff76836b84e606a1c0425fb25800fb3cfc1c9933285e", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/09f2c49a4d5a4d3a0453606e49485fa81c91249f24224b4788919579dbc5b4dd.md b/vision-fixhub/ds9-parsed-01/09f2c49a4d5a4d3a0453606e49485fa81c91249f24224b4788919579dbc5b4dd.md new file mode 100644 index 0000000000000000000000000000000000000000..8173dc13c7bf1b14dd6034e55fdd3af180158971 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/09f2c49a4d5a4d3a0453606e49485fa81c91249f24224b4788919579dbc5b4dd.md @@ -0,0 +1,17 @@ +From: +To: +(USANYS)" = +(USANYS)" • +Subject: RE: to do +Date: Thu, 05 Sep 2019 22:22:43 +0000 +Importance: Normal +From: +I (USANYS) < +Sent: Tuesday, September 03, 2019 6:22 PM +To: [ +(USANYS) < +Subject: RE: to do +Tuesday: +- Update on Epstein ccs + + diff --git a/vision-fixhub/ds9-parsed-01/09f2c49a4d5a4d3a0453606e49485fa81c91249f24224b4788919579dbc5b4dd.receipt.json b/vision-fixhub/ds9-parsed-01/09f2c49a4d5a4d3a0453606e49485fa81c91249f24224b4788919579dbc5b4dd.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..c05f66c26924761666b74580d6a64c952591857b --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/09f2c49a4d5a4d3a0453606e49485fa81c91249f24224b4788919579dbc5b4dd.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "09f2c49a4d5a4d3a0453606e49485fa81c91249f24224b4788919579dbc5b4dd", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "6af87d45e23f17a321b8e31a92c2a1a1fe94235030ff70297e8cfee7fb841d4f", + "output_sha256": "b8562f9fd9db49b54dbf6b9f4a10ca85c02b11a78a9b1a18e6dc571a7adc7381", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0a07b1108312c9b8e77ee312a2c656c226c092bfe62376cdd1a7be4f706a0542.md b/vision-fixhub/ds9-parsed-01/0a07b1108312c9b8e77ee312a2c656c226c092bfe62376cdd1a7be4f706a0542.md new file mode 100644 index 0000000000000000000000000000000000000000..29ecdd003b03307fbbf292939d39203269e91502 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0a07b1108312c9b8e77ee312a2c656c226c092bfe62376cdd1a7be4f706a0542.md @@ -0,0 +1,31 @@ +From: " +To: " +Ce: "l +Subject: RE: IG +Date: Thu, 13 Aug 2020 03:52:24 +0000 +Thanks very much - good to meet you both, and I'm excited to join the team! +Assistant U.S. Attorney +Southern District of New York +From: +Sent: Wednesday, August 12, 2020 16:54 +To: +Cc: +Subject: RE: lIG +Great. Nice to meet you +Welcome aboard +Pil +U.S. Securities and Exchange Commission +Division of Enforcement +From: +Sent: Wednesday, August 12, 2020 4:09 PM +Subject: IIG +CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you +recognize the sender and know the content is safe. +wanted to introduce you to +Public Corruption where he prosecuted boring cases like Jeffrey Epstein. +we're lucky to have him. +who is joining the IIG team. He recently joined the unit from +and I started in the office the same day, and +Assistant United States Attorney +Southern District of New York +New York, NY 10007 diff --git a/vision-fixhub/ds9-parsed-01/0a07b1108312c9b8e77ee312a2c656c226c092bfe62376cdd1a7be4f706a0542.receipt.json b/vision-fixhub/ds9-parsed-01/0a07b1108312c9b8e77ee312a2c656c226c092bfe62376cdd1a7be4f706a0542.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..02415b0ccade78d56a117178dd1f41f13a130a8c --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0a07b1108312c9b8e77ee312a2c656c226c092bfe62376cdd1a7be4f706a0542.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "0a07b1108312c9b8e77ee312a2c656c226c092bfe62376cdd1a7be4f706a0542", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "cc228fbd77b2cb60e26ecc8b8529fa0d54bfb00f7c523c40e59fe3229fc5afd8", + "output_sha256": "e5153f005111873bace363ae314a56df0233046252120102468387177d96d241", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0a0e2d31057267bb897c9de4944369a683b96cfa4f8ded1bf9ccc6278f60dc30.md b/vision-fixhub/ds9-parsed-01/0a0e2d31057267bb897c9de4944369a683b96cfa4f8ded1bf9ccc6278f60dc30.md new file mode 100644 index 0000000000000000000000000000000000000000..0b5bb750d9af67d1a7fb752ffe308224bd94cc64 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0a0e2d31057267bb897c9de4944369a683b96cfa4f8ded1bf9ccc6278f60dc30.md @@ -0,0 +1,1220 @@ +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 1 of 14 +U.S. Department of Justice +United States Attorney +Southern District of New York +The Silvio J. Mollo Building +One Saint Andrew's Plaza +New York, New York 10007 +July 12, 2019 +VIA ECE +The Honorable Richard M. Berman +United States District Court +Southern District of New York +United States Courthouse +500 Pearl Street +New York, New York 10007 +Re: +United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) +Dear Judge Berman: +The Government respectfully submits this letter in response to the defendant's Motion for +Pretrial Release (the "Release Motion"), dated July 11, 2019 (Dkt. 6), and in further support of its +Memorandum in Support of Detention (the "Detention Memo"), submitted to Magistrate Judge +Pitman on July 8, 2019, which is attached hereto and incorporated herein (Ex. A). +PRELIMINARY STATEMENT +The defendant is a serial sexual predator who is charged with abusing underage girls for +years. A grand jury has returned an indictment alleging that he sexually exploited dozens of +minors, including girls as young as 14 years old, in New York and Florida. To this day, he is a +registered sex offender designated by New York State in the highest category of risk to reoffend, +despite unsuccessfully attempting to have that classification lowered. And any doubt that the +defendant is unrepentant and unreformed was eliminated when law enforcement agents discovered +hundreds or thousands of nude and seminude photographs of young females in his Manhattan +mansion on the night of his arrest, more than a decade after he was first convicted of a sex crime +involving a juvenile. +The defendant also faces substantial evidence of his guilt, founded on the corroborated +testimony of numerous victims, and this case presents the very real possibility that he will go to +prison for the rest of his life. The defendant has at his disposal a vast fortune, the details of which +remain largely concealed from the Court. He also has a history of obstruction and manipulation +of witnesses, including, as detailed herein, as recently as within the past year, when media reports +about his conduct reemerged. And he continues to show a shocking lack of understanding of the +gravity of the harm he has perpetrated, including through the minimization of his conduct and +casual disparagement of victims in his arguments. +Against this backdrop of significant-and rapidly-expanding evidence, serious charges, +and the prospect of a lengthy prison sentence, the defendant proposes to be released on conditions +that are woefully inadequate. The Release Motion misconstrues and misunderstands the relevant + + +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 2 of 14 +July 12, 2019 +Page 2 +law, seeks to diminish and demean the harm caused to the many victims of the defendant's +appalling sexual abuse, and utterly fails to meet its burden of rebutting the presumption that no +condition or combination of conditions will reasonably assure the appearance of the defendant as +required and the safety of the community. Rather than even attempting to address the grave risks +of releasing a defendant with extraordinary financial resources and a history of abusing minors, +the defendant instead proposes a bail package that amounts to little more than a barely-secured +bond masquerading as a 14-point plan. The Court should reject the defendant's application and +order him detained pending trial. +Among other things, the proposed bail package contemplates the defendant pledging as the +principal security a property that has already been identified by the Government as subject to +forfeiture upon the defendant's conviction, and which therefore is of no value as collateral. His +proposed global waiver of extradition is unenforceable, and even if enforceable would be little +comfort to victims forced to wait additional years while the defendant is located and returned to +this country. The promise to "deregister or otherwise ground" his private jet is meaningless given +his wealth and ability to easily secure other means of travel. The two co-signers he proposes only +further highlight his minimal community ties, including his lack of any family in or near the +District. Electronic monitoring would merely give the defendant less of a head start in fleeing +and does not guard against the risk of him endangering victims in the very home where he has +continued to hoard nude images of young women and girls. And the private security force he +proposes to guard his gilded cage, a proposal already rejected by this Court in similar +circumstances, simply reinforces the obvious fact that the defendant should be housed where he +can be secured at all times: a federal correctional center. +The defendant faces a presumption of detention, Pretrial Services has recommended +detention, and victims of the defendant seek his detention. Because there are no set of conditions +short of incarceration that can reasonably assure the appearance of the defendant or reasonably +protect the community from the dangers he poses if released, the Court should order him detained. +BACKGROUND +As previously set forth, a federal grand jury in this District returned an indictment (the +"Indictment") charging the defendant with violating Title 18, United States Code Section 1519, +and conspiracy to commit the same. +As charged by the grand jury, the facts giving rise to those counts involve a years-long +scheme to sexually abuse underage girls. Specifically, the defendant enticed and recruited dozens +of minor girls to engage in sex acts with him, for which he paid the vietims hundreds of dollars in +cash, in at least two different states. Victims were initially recruited to provide "massages" to the +defendant, which would be performed nude or partially nude, would become increasingly sexual +in nature, and would typically include one or more sex acts, including groping and direct or indirect +contact with victims' genitals. To perpetuate this exploitation of underage girls, the defendant +actively encouraged certain victims to recruit additional girls to be similarly sexually abused. He +paid these victim-recruiters hundreds of dollars for each additional girl they brought to him, +creating a network of underage victims for him to exploit in New York and Palm Beach. + + +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 3 of 14 +July 12, 2019 +Page 3 +The defendant, through counsel, continues to evidence a complete lack of appreciation for +the gravity of the offenses with which he is charged.' As an initial matter, there can be no plausible +suggestion that the allegations against the defendant involve isolated or aberrational conduct; they +involve repeated, regular acts of sexual abuse committed over a period of many years. And +following the defendant's prior conviction, as described previously by the Government, the +defendant continued to maintain at least hundreds and possibly thousands of nude photos of young +subjects. The defendant's victims in this case, often particularly vulnerable girls, were as young +as 14 years old when he abused them. The defendant knew he was abusing minors, including +because victims told him directly they were underage. And he preyed on his victims habitually +and repeatedly—day after day, month after month, year after year. +The defense calls these disturbing alleged acts "simple prostitution." Mag. Tr. 12:12; see +also D. Tr. at 6:15-19 ("This is basically the Feds today ... redoing the same conduct that was +investigated 10 years ago and calling it, instead of prostitution, calling it sex trafficking"). That +characterization is not only offensive but also utterly irrelevant given that federal law does not +recognize the concept of a child prostitute-there are only trafficking victims because a child +cannot legally consent to being exploited. Defense counsel's repeated assertion that the +Government's case is infirm because no threats or coercion are alleged e.g., Mag. Tr. at 12 +("There was no coercion. There were no threats. There was no violence."), 17 ("there was no +coercion. There was no intimidation. There is no deception."); Release Motion at 2 ("There are +no allegations ... that he forced, coerced, defrauded, or enslaved anybody ....")—is equally +irrelevant because the offense with which the defendant has been charged requires no such proof. +See, e.g., United States v. Afyare, 632 F. App'x 272, 278 (6th Cir. 2016) ("We hold that § 1591(a) +criminalizes the sex trafficking of children (less than 18 years old) with or without any force, fraud, +or coercion, and it also criminalizes the sex trafficking of adults (18 or older), but only if done by +force, fraud, or coercion."). +Far more important, the defense has already effectively conceded that the Government will +be able to present evidence of the actual primary elements of the charged offense i.e., that the +defendant engaged in sex acts for money with girls he knew were underage. See Release Motion +at 2. On this record, the Government agrees with Pretrial Services that the defendant should be +detained pending trial. He poses a tremendous risk of flight and a danger to the community, and +he cannot overcome the statutory presumption in favor of detention in this case. +' Such arguments are unsurprising from a defendant who previously compared himself to a "person +who steals a bagel" or a tragic mythical figure. See, e.g., Amber Southerland, Billionaire Jeffrey +Epstein: I'm a sex offender, not a predator, N.Y. Post (2011) (**I'm not a sexual predator, I'm an +"offender," the financier told The Post yesterday. 'It's the difference between a murderer and a +person who steals a bagel."); Philip Weiss, The Fantasist, NY Magazine (2007) (**It's the Icarus +story, someone who flies too close to the sun, ' I said. 'Did Icarus like massages?' Epstein asked."). +2 "Mag. Tr." refers to the transcript of the hearing before Magistrate Judge Pitman on July 8, 2019; +"D. Tr." refers to the transcript of the hearing before this Court on July 8, 2019. + + +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 4 of 14 +July 12, 2019 +Page 4 +ARGUMENT +The Government respectfully submits that the defendant cannot overcome the statutory +presumption in favor of detention in this case for the following reasons, among others: +1. +Victims Seek Detention +Pursuant to the Crime Victims' Rights Act ("CVRA"), a crime victim has the right to be +reasonably heard at certain public proceedings in the district court, including proceedings +involving release. 18 U.S.C. § 3771(a)(4). Consistent with that requirement, the Government has +been in contact with victims and counsel identified through this investigation in connection with +the argument regarding bail. +Multiple victims and/or their counsel have asked the Government to seek detention (and to +inform the Court of their views in that respect) for multiple reasons. First, they believe that the +defendant's continued detention is necessary under the CVRA's right to be reasonably protected +from the accused. 18 U.S.C. § 3771(a)(1). They have specifically conveyed to the Government +that they would be fearful for their safety if the defendant were released. For the reasons articulated +herein, the Government believes those concerns to be well-founded. +Additionally, certain victims have asked the Government to advise the Court that they are +specifically concerned about the defendant's proposal to be released even if under conditions that +included home detention and full-time private guards. They believe it would be unfair to victims +of a wealthy defendant, like Epstein, if he were to be given greater freedoms than others would be +in similar circumstances, and that such an arrangement would be inconsistent with their rights. +They specifically asked the Government to advise the Court that they believed such an arrangement +could result in harassment and abuse by the defendant. 3 +II. The Defendant's Proposal Does Nothing to Mitigate His Flight Risk +Each of the relevant factors to be considered as to flight risk—the nature and circumstances +of the offense, the strength of the evidence, and the history and characteristics of the defendant— +counsel strongly in favor of detention, and the defendant's proposed package would do nothing +whatsoever to mitigate those risks. +A. Defendant Proposes No Infringement Upon His Ability to Use his Vast Wealth to Flee +It might not be immediately apparent to a reader of the Release Motion that the defendant +is extravagantly wealthy and worth, according to records relating to the defendant recently +obtained by the Government from a financial institution ("Institution-1"), more than $500 million. +3 The Government is aware of at least one additional attorney for a victim who has publicly stated +that her client supports the pretrial detention of the defendant. The Government is unaware of any +victim who has expressed support for the defendant being granted pretrial release on bail. + + +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 5 of 14 +July 12, 2019 +Page 5 +Indeed, while the defendant has still not filled out a financial affidavit, under penalty of +perjury, in connection with his application for bail, his token effort to account for his finances +makes painfully clear the need for detention. The defendant reports having an extraordinary +amount of money in both total assets and cash or cash-equivalent holdings. And while the +defendant repeatedly represents in his Release Motion that his assets are "in the United States," +there is absolutely nothing in the defendant's minimal financial submission to verify that. +Indeed, and as discussed further below, even assuming the defendant's assets are presently +in the United States, nothing in the proposed package would prevent the defendant from +transferring liquid assets out of the country quickly and in anticipation of flight or relocation. The +defendant is an incredibly sophisticated financial actor with decades of experience in the industry +and significant ties to financial institutions and actors around the world. He could easily transfer +funds and holdings on a moment's to places where the Government would never find them so as +to ensure he could live comfortably while a fugitive. +But perhaps most important, even were the defendant to sacrifice literally all of his current +assets, there is every indication that he would immediately be able to resume making millions or +tens of millions of dollars per year outside of the United States. He already earns at least +$10,000,000 per year, according to records from Institution-1, while living in the U.S. Virgin +Islands, traveling extensively abroad, and residing in part in Paris, France; there would be little to +stop the defendant from fleeing, transferring his unknown assets abroad, and then continuing to do +whatever it is he does to earn his vast wealth from a computer terminal beyond the reach of +extradition.* +That the defendant faces up to 45 years of incarceration on the current counts with which +he is charged provides the motive for him do so and is another significant factor in assessing the +risk of flight. See United States v. Jackson, 823 F.2d 4, 7 (2d Cir. 1987). So too is the strength of' +the evidence, detailed above and in the Government's Detention Memo. Indeed, that evidence, +already robust less than a week ago when the Indictment was unsealed, is growing stronger by the +day. Just since the Indictment was unsealed, several additional women, in multiple jurisdictions, +have identified themselves to the Government as having been victimized by the defendant when +they were minors. Moreover, pursuant to judicially-authorized search warrants, the Government +has discovered and seized a significant volume of photographs of nude and seminude young +women and girls in the defendant's Manhattan residence, and is in the process of reviewing dozens +of electronic discs that contain still more such photos. And dozens of individuals have called the +Government in recent days to convey information regarding the defendant and the allegations ++ As noted in the Government's Detention Memo, the defendant is a frequent traveler and regularly +travels to and from the United States, including approximately more than 20 flights in which he +traveled to or from a foreign country since 2018 alone. Extensive international travel of this nature +further demonstrates a significant risk of flight. See, e.g., United States v. Anderson, 384 F. Supp. +2d 32, 36 (D.D.C. 2005). +5 The Government's review of these materials, seized earlier this week, remains ongoing. + + +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 6 of 14 +July 12, 2019 +Page 6 +contained in the Indictment. All this in less than a week, and all in addition to an Indictment that +already alleges the existence of dozens of victims in New York and dozens of victims in Florida. +B. The Proposed Bond is Inadequate to Overcome the Presumption of Detention +The defendant's "slate of highly restrictive" measures which purportedly "amply suffice to +secure his release" are neither highly restrictive nor amply sufficient. Rather, they are effectively +standard conditions of home confinement, monitoring, and bond unsecured by the defendant's +assets broken out into 14 pieces. The Government will address the most concerning and salient +elements of the defendant's proposal below. +1. Lack of Meaningful Bond Security +The defendant proposes that the Court accept his Manhattan mansion as the primary +security for a personal recognizance bond of an indeterminate amount, to be co-signed by the +defendant's brother and a friend. Release Motion at 4. This is plainly insufficient. +As an initial matter, and as noted above, the defendant's Manhattan mansion has been +identified in the Indictment as subject to forfeiture because it is alleged to have been used to +commit or facilitate the commission of the sex trafficking offenses charged there. See 18 U.S.C. +§ 1594(c)(1). Because the defendant would thus be likely to lose that property following a +conviction, it provides no value whatsoever as collateral. See 18 U.S.C. § 3142(g)(4) ('In +considering the conditions of release described ... the judicial officer ... shall decline to accept +the designation, or the use as collateral, of property that, because of its source, will not reasonably +assure the appearance of the person as required."). And while the defendant offers to also pledge +his private jet as additional collateral, there is absolutely no reason to assume that the defendant +would not readily trade his private plane for his freedom. Indeed, the defendant, who has a net +worth of more than $500 million, by his own admission recently sold a second plane and thus +presumably has cash on hand to replace the posted aircraft without difficulty if need be. +Nor does the proposed security of properties owned by two identified co-signers +meaningfully change the calculus. As further described below, the defendant provides no +information about the value or equity of the property of his brother, Mark (the "Palm Beach +Property"), or the significance of that property in the context of his brother's own net worth.® +Similarly, the defendant provides no details regarding the "investment interests" of his friend Mr. +Mitchell, nor any reason to believe the loss of those "interests" would be meaningful to Mr. +Mitchell, let alone the defendant. More generally, given the defendant's proffered net worth, the +defendant could easily make his co-signers whole - and even reward them - were he to flee. +The proposed security, in sum, should give the Court little comfort the defendant would +appear in Court if released on bail. +" In fact, the defendant's own submission makes clear that the Palm Beach Property is not his +brother's exclusive residence and that his brother lives elsewhere for half of the year. + + +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 7 of 14 +July 12, 2019 +Page 7 +2. Co-Signers, Moral Suasion, and Ties to the Community +The dearth of detailed financial information about the defendant himself, much less his +brother or friend, further shows the hollowness of the proposal. The Court cannot possibly +evaluate whether there would be any incentive whatsoever for those the two proposed co-signers +to exercise moral suasion over the defendant—or whether, as noted above, the defendant could +easily compensate them, perhaps many times over, for any loss they incurred through the +defendant's flight from justice. The defendant provides no information about his brother other +many nime pove +than that he lives half the year in the home he purportedly would pledge, and even less information +about Mr. Mitchell, other than that he is "Mr. Epstein's friend," his "close personal friend of +decades," and his "close personal friend." Release Motion at 4, 9. Their willingness to "guarantee" +his appearance, Release Motion at 9, is meaningless in the absence of such information. +Moreover, the notion that any individual co-signer could meaningfully secure a bond for +this defendant strains credulity. Given the defendant's wealth and his extraordinary risk of flight, +any bond for this defendant would assuredly have to be in the hundreds of millions of dollars to +even be claimed to be sufficient to guard against the risks posed by the defendant's release. The +defendant offers no reason to believe any co-signers could meaningfully sign such a bond, much +less these two particular individuals, which is yet another reason the proposed package is patently +insufficient. +3. The Defendant's "Consent" to Extradition is Unenforceable and Impractical +The defendant's offer to sign a so-called "consent" to extradition provides no additional +reassurance whatsoever. As an initial matter, the Government would need to find and re-arrest the +defendant before such a waiver would even come into play. Moreover, even assuming the +Government could locate and apprehend the defendant, numerous courts have recognized that such +purported waivers are unenforceable and effectively meaningless because any defendant who signs +such a purported waiver and then flees will assuredly contest the validity and/or voluntariness of +the waiver, and will get to do so in the jurisdiction of his choosing (i.e., the one to which he chose +to flee). See, e.g., United States v. Morrison, No. 16-MR-118, 2016 WL 7421924, at *4 (W.D.N.Y. +Dec. 23, 2016); United States v. Kazeem, No. 15 Cr. 172, 2015 WL 4645357, at *3 (D. Or. Aug. +3, 2015); United States v. Young, Nos. 12 Cr. 502, 12 Cr. 645, 2013 WL 12131300, at *7 (D. Utah +Aug. 27, 2013); United States v. Cohen, No. C 10-00547, 2010 WL 5387757, at *9 n.11 (N.D. +Cal. Dec. 20, 2010); United States v. Bohn, 330 F. Supp. 2d 960, 961 (W.D. Tenn. 2004); United +States v. Stroh, No. 396 Cr. 139, 2000 WL 1832956, at *5 (D. Conn. Nov. 3, 2000); United States +v. Botero, 604 F. Supp. 1028, 1035 (S.D. Fla. 1985). . The Department of Justice's Office of +International Affairs is unaware of any country anywhere in the world that would consider an +anticipatory extradition waiver binding. And, of course, the defendant could choose to flee to a +jurisdiction with which the United States does not have an extradition treaty. +Beyond being impossible to guarantee, extradition is typically a lengthy, complicated and +expensive process, and the possibility that it would be successful neither provides any real +deterrent to the defendant's incentive to flee nor any measure of justice to the victims who would +be required to wait years for his return. + + +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 8 of 14 +July 12, 2019 +Page 8 +4. Home Confinement and Electronic Monitoring Provide No Assurance +The defendant's proposal of ankle-bracelet monitoring should be of no comfort to the +Court. In particular, the defendant's endorsement of a GPS monitoring bracelet rather than a radio +frequency bracelet is farcical because neither one is useful or effective after it has been removed. +At best, home confinement and electronic monitoring would reduce his head start should he decide +to cut the bracelet and flee. See United States v. Zarger, No. 00 Cr. 773, 2000 WL 1134364, at *1 +(E.D.N.Y. Aug. 4, 2000) (rejecting defendant's application for bail in part because home detention +Cr. 099, 2002 WL 31410262, at *3 (E.D.N.Y. Oct. 10, 2002) (same). +5. Private Security is Inadequate, Unfair, and Impractical Here +The defendant also proposes the use of a private security force to march him to and from +court under the threat of deadly force. This proposal should be rejected. +At the outset, it is far from clear that private jail, which seeks to replicate the conditions of +a government-run detention facility in the defendant's home, is a condition of "release" that +implicates the Bail Reform Act. "[T]here is a debate within the judiciary over whether a defendant, +if she is able to perfectly replicate a private jail in her own home at her own cost, has a right to do +so under the Bail Reform Act and the United States Constitution." United States v. Valerio, 9 F. +Supp. 3d 283, 292 (E.D.N.Y. 2014) (Bianco, J.) (collecting cases). The Second Circuit has never +directly addressed this issue. See United States v. Sabhnani, 493 F.3d 63, 78 n.18 (2d Cir. 2007) +("The government has not argued and, therefore, we have no occasion to consider whether it would +be "contrary to the principles of detention and release on bail' to allow wealthy defendants 'to buy +their way out by constructing a private jail." (citations omitted)). Indeed, a decision by this Court +reasoned that "the very severe restrictions" in the private jail proposal presented to him did "not +appear to contemplate 'release' so much as it describes a very expensive form of private jail or +detention." United States v. Zarrab, 2016 WL 3681423, at *10 (S.D.N.Y. June 16, 2016). +Courts have long been troubled by private jail proposals like the defendant's which, "at +best 'elaborately replicate a detention facility without the confidence of security such a facility +instills."" United States v. Orena, 986 F.2d 628, 632 (2d Cir. 1993) (quoting United States v. Gotti, +776 F. Supp. 666, 672 (E.D.N.Y. 1991) (rejecting private jail proposal)); see also Valerio, 9 F. +Supp. 3d at 295 ("The questions about the legal authorization for the private security firm to use +force against defendant should he violate the terms of his release, and the questions over whether +the guards can or should be armed, underscore the legal and practical uncertainties indeed, the +imperfections of the private jail-like concept envisioned by defendant, as compared to the more +secure option of an actual jail."). A private security firm simply cannot replicate the controlled +environment of a federal correctional facility, in which, typically, all of the needs to the prisoner +can be attended to without placing the prisoner in the community at large; the defendant's proposed +private jail arrangement would have the effect of permanently placing him in just such a highflight-risk circumstance. The risk of a public escape attempt while in the community and involving + + +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 9 of 14 +July 12, 2019 +Page 9 +armed private guards attempting to stop the defendant, potentially by force-rather than the +defendant being in the environment of a federal facility—also greatly magnifies the danger of the +defendant's flight to the public. See United States v. Boustani, 356 F. Supp. 3d 246, 257 (E.D.N.Y. +2019). "This is why, as the Government correctly notes, federal prisoners should be detained in +facilities run by trained personnel from federal correctional facilities." Id. at 258 (citing Sabhnani, +493 F.3d at 74 n. 13 ("To the extent [armed private guards] implies an expectation that deadly force +may need to be used to assure defendant['s] presence at trial ... [s]uch a conclusion would, in fact, +demand a defendant's detention*). +The Second Circuit has held it is not legal error "for a district court to decline to accept," +as "a substitute for detention," a defendant hiring private security guards to monitor him. United +States v. Banki, 369 Fed. App'x 152, 153-54 (2d Cir. 2010). In the same decision, the Second +Circuit noted that it was "troubled" by the possibility of "allow[ing] wealthy defendants to buy +their way out by constructing a private jail." (internal quotation marks omitted)). Id.; accord, e.g., +United States v. Cilins, No. 13 Cr. 315 (WHP), 2013 WL 3802012, at *3 (S.D.N.Y. July 19, 2013) +("*'it is contrary to underlying principles of detention and release on bail that individuals otherwise +ineligible for release should be able to buy their way out by constructing a private jail, policed by +security guards not trained or ultimately accountable to the Government, even if carefully +selected'" (quoting Borodin v. Ashcroft, 136 F. Supp. 2d 125, 134 (E.D.N.Y. 2001))); Valerio, 9 +F. Supp. 3d at 293-94 (E.D.N.Y. 2014) ("There is nothing in the Bail Reform Act that would +suggest that a defendant (or even, hypothetically, a group of defendants with private funding) has +a statutory right to replicate or construct a private jail in a home or some other location."). +The defendant's payment of his guards also raises the conflict of interest inherent in having +the defendant having extraordinary influence over a private security company tasked with guarding +him, leaving the company's incentives entirely aligned with the defendant. See, e.g., Boustani, +356 F. Supp. 3d at 257 (in finding that private armed guards would not reasonably assure the +appearance of a defendant, noting a "clear conflict of interest private prison guards paid by an +inmate" and noting that in a recent S.D.N.Y. case involving private security guards the defendant +"was outside of his apartment virtually all day, every weekday; was visited by a masseuse for a +total of 160 hours in a 30-day period; and went on an unauthorized visit to a restaurant in +Chinatown with his private guards in tow"); see also United States v. Tajideen, 17 Cr. 046, 2018 +WL 1342475, at *5-6 (D.D.C. Mar. 15, 2018) (finding Zarrab "particularly instructive" and further +noting: "While the Court has no reason to believe that the individuals selected for the defendant's +security detail would intentionally violate federal law and assist the defendant in fleeing the Court's +jurisdiction, it nonetheless is mindful of the power of money and its potential to corrupt or +undermine laudable objectives. And although these realities cannot control the Court's ruling, they +also cannot be absolutely discounted or ignored."). +Finally, in Zarrab this Court found that "the Defendant's privately funded armed guard +proposal is unreasonable because it helps to foster inequity and unequal treatment in favor of a +very small cohort of criminal defendants who are extremely wealthy, such as Mr. Zarrab." 2016 +WL 3681423, at *13; see also Boustani, 356 F. Supp. 3d at 258 ("although this Defendant has vast +financial resources to construct his own "private prison,' the Court is not convinced 'disparate +treatment based on wealth is permissible under the Bail Reform Act) (quoting United States v. + + +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 10 of 14 +July 12, 2019 +Page 10 +Bruno, 89 F. Supp. 3d 425, 432 (E.D.N.Y. 2015) (***Even if Defendant had the financial capacity +to replicate a private jail within his own home, this Court is not convinced that such a set of +conditions would be sufficiently effective in this case to protect the community from Defendant, +or that such disparate treatment based on wealth is permissible under the Bail Act.")); Borodin, +136 F. Supp. 2d at 134 (E.D.N.Y. 2001) (Nickerson, J.) ("It is contrary to underlying principles of +detention and release on bail that individuals otherwise ineligible for release should be able to buy +their way out by constructing a private jail, policed by security guards not trained or ultimately +accountable to the government, even if carefully selected."). +If the defendant's appearance can only be assured through use of round-the-clock guards, +the defendant belongs in a federal detention center, not released under bail conditions that +effectively create a private prison of one, using guards to be paid by the defendant himself. It is +frankly outrageous for the defendant to suggest that preventing him from using his vast wealth to +duplicate a private prison that cannot control, monitor, and contain him consistent with the +requirements of the Bail Act would cause him to somehow "bear a special disadvantage." Release +Motion at 12 n.9. Indeed: "What more compelling case for an order of detention is there than a +case in which only an armed guard and the threat of deadly force is sufficient to assure the +defendant's appearance?" Zarrab, 2016 WL 3681432, at *12 (quoting United States v. Valerio, 9 +F. Supp. 3d at 295). +III. +The Defendant Provides No Assurance He is Not a Danger to the Community and a +Risk to Obstruct Justice +A. Danger to the Community +In the first instance, the defendant's argument that 14 years without a criminal conviction +eliminates "any danger presumption" should be rejected. Were that the case— which is certainly +is not—a lack of criminal record for any defendant would automatically rebut the presumption +applicable to crimes such as sex trafficking. That is manifestly incorrect. See United States v. +Artis, 607 F. App'x 95, 97 (2d Cir. 2015) (finding that a defendant's lack of criminal record was +"not so compelling as to defeat the presumption or to manifest clear error in the district court's +determination that no combination of release conditions ... could reasonably assure against +dangerousness and the risk of flight"). Moreover, here, the defendant not only has a criminal +record, but has been convicted of a sex crime involving a minor. +But the ongoing and forward-looking danger posed by the defendant is further +demonstrated by the defendant's maintenance of a substantial collection of photographic trophies +of his victims and other young females in his mansion, as discovered by the Government through +its search warrants. As indicated in the Detention Memo, the many dises found in the defendant's +residence included those with hand-written labels including the following: "Young [Name] + +[Name]," "Mise nudes 1," and "Girl pies nude." Not surprisingly, the Government has found that +such discs contain photographs of sexually suggestive photographs of fully- or partially-nude +females appearing to be underage. + + +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 11 of 14 +July 12, 2019 +Page 11 +B. Danger to Obstruct Justice +The defendant has also already demonstrated a willingness to use intimidation and +aggressive tactics in connection with a criminal investigation. Far from being "musty," Release +Motion at 6 n.6, the defendant's past behavior in connection with being investigated for sexually +abusing children is the best predictor of his likely incentives and activities in connection with being +charged with sexually abusing children. For example, in the incident the defendant now claims +was not attributable to or authorized by him, the contemporaneous police report indicates that +pressure tactics were at the very least coordinated closely with individuals in the defendant's orbit. +See Palm Beach Police Report (the "Police Report") (Ex. B). According to the Police Report, the +parent of one of the defendant's victims was driven off the road by a private investigator. The +Police Report provides further information regarding victim and witness threats and intimidation +reported against an individual who was directly in contact with an assistant of the defendant, +followed "immediately" by a call to that same individual from a phone number associated with the +defendant's businesses and associates. +Separately, and in addition, there are also extensive allegations of obstruction and +tampering in connection with civil lawsuits brought against the defendant following his 2008 +conviction. See Doe v. United States, 08 Civ. 80736 (S.D. Fla.), Dkt. 291-15 at 21-23, 31. +Moreover, police reports suggest that an associate of Epstein's was offering to buy victims" silence +during the course of the prior investigation. Specifically, one victim reported that "she was +personally contacted through a source that has maintained contact with Epstein," who "assured +[the victim] that she would receive monetary compensation for her assistance in not cooperating +with law enforcement." Indeed, the victim reported having been told: "Those who help him will +be compensated and those who hurt him will be dealt with." See Palm Beach Police Report +(Ex. C). +And Epstein's efforts to influence witnesses continue to this day. As in the past, within +recent months. he paid significant amounts of money to influence individuals who were close to +him during the time period charged in this case and who might be witnesses against him at a trial. +By way of background, on or about November 28, 2018, the Miami Herald began publishing a +series of articles relating to the defendant, his conduct, and the circumstances of his prior +conviction and the non-prosecution agreement ("NPA"). Records obtained by the Government +from Institution-1 appear to show that just two days later, on or about November 30, 2018, the +defendant wired $100,000 from a trust account he controlled to an individual named as a possible +co-conspirator in the NPA. The same records appear to show that just three days after that, on or +about December 3, 2018, the defendant wired $250,000 from the same trust account to another +individual named as a possible co-conspirator in the NPA and also identified as one of the +defendant's employees in the Indictment. Neither of these payments appears to be recurring or +repeating during the approximately five years of bank records presently available to the +Government. +This course of action, and in particular its timing, suggests the defendant was +attempting to further influence co-conspirators who might provide information against him in light +of the recently re-emerging allegations + + +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 12 of 14 +July 12, 2019 +Page 12 +IV. The Defendant Raises Legal Arguments Not Relevant Here +Finally, the defendant raises certain legal arguments he contends he will litigate at the +appropriate stage and which he further suggests mitigate in favor of bail. None is meritorious, and +certainly none should give the Court any comfort whatsoever that the defendant would, if granted +bail, refrain from fleeing so he could attempt to vindicate himself via dubious legal strategies. +Nevertheless, the Government will address the defendant's arguments briefly in turn. +A. The Non-Prosecution Agreement Does Not Preclude Prosecution +As an initial matter, as the Court itself noted at the parties' initial appearance earlier this +week, and as the defendant appears to concede, the instant Indictment charges conduct well beyond +the scope of the NPA - that is, alleged conduet that occurred here in New York and involving New +York based victims. D. Tr. 6-8; Release Motion at 2. For present purposes, that alone is sufficient +to put this issue to rest, because even assuming the defendant were to mount a meritorious +challenge to the NPA, he would still have to stand trial on Count Two of the Indictment and +additional charges brought based on New York conduct. +But more generally, the reasons the defendant can be prosecuted in the Southern District +of New York-or anywhere else outside the SDFL—are manifold. The language of the NPA +overwhelmingly refers to the SDFL, and the core terms and text of the agreement are limited to +the SDFL. The prefatory language states: "THEREFORE, on the authority of R. Alexander +Acosta, United States Attorney for the Southern District of Florida, prosecution in this District for +these offenses shall be deferred in favor of prosecution by the State of Florida."? The final +paragraph of the prefatory language also states, among other things, that after fulfilling the terms +of the agreement, "no prosecution for the [sex abuse] offenses set out on pages 1 and 2 of this +Agreement, nor any other offenses that have been the subject of the joint investigation by the +Federal Bureau of Investigation and the United States Attorney's Office, nor any offenses that +arose from the Federal Grand Jury investigation will be instituted in this District." +In its terms section, the NPA further states that Epstein's signature "is not to be construed +as an admission of civil or criminal liability or a waiver of any jurisdictional or other defense" as +to any victim whose identity was not disclosed by SDFL to Epstein, as provided for in the NPA, +and additionally states that neither Epstein's signature nor any resulting waivers or civil +settlements "are to be construed as admissions or evidence of civil or criminal liability or a waiver +of any jurisdictional or other defense as to any person." These provisions show the parties +contemplated possible criminal prosecutions in other jurisdictions and/or based on victims not +initially identified in the Florida investigations (whether in Florida or elsewhere). The final +substantive paragraph of the NPA states that "Epstein hereby requests that the United States +Attorney for the Southern District of Florida defer [...] prosecution." +It is well settled in the Second Circuit that "a plea agreement in one U.S. Attorney's office +does not, unless otherwise stated, bind another." United States v. Prisco, 391 F. App'x 920, 921 +"All emphases relating to the NPA are added unless otherwise specified. + + +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 13 of 14 +July 12, 2019 +Page 13 +(2d Cir. 2010) ("A plea agreement binds only the office of the United States Attorney for the +district in which the plea is entered unless it affirmatively appears that the agreement contemplates +a broader restriction.") (citing United States v. Annabi, 771 F.2d 670, 672 (2d Cir. 1985) (per +curiam)). Moreover, any references in an NPA to the "Government" or the "United States" do not +abrogate these principles. Annabi, 771 F.2d at 672 ("[A] plea agreement whereby a federal +prosecutor agrees that 'the Government' will dismiss counts of an indictment ... might be thought +to bar the United States from reprosecuting the dismissed charges in any judicial district unless the +agreement expressly limits the scope of the agreement.... However, the law has evolved to the +contrary."). "The mere use of the term "government' in the plea agreement does not create an +affirmative appearance that the agreement contemplated barring districts other than the particular +district entering into the agreement." United States v. Salameh, 152 F.3d 88, 120 (2d Cir. 1998) +(citations and internal quotation marks omitted); see also United States v. Brown, No. 99-1230, +2002 WL 34244994, at *2 (2d Cir. Apr. 26, 2002) (in analyzing an SDFL plea agreement, +reiterating the holding of Annabi and noting that it applies "even if the plea agreement purports to +bind 'the Government'" or the "United States") (summary order); United States v. Bruno, 159 F. +Supp. 3d 311, 321 (E.D.N.Y. 2016) ("The Court disagrees with Defendant's argument that the +phrase 'United States" shows an intent to bind all United States Attorney's Offices. Rather, the +plea agreement covers only Defendant's liability in the SDFL.").* +In sum, this issue is a distraction that has little relevance to the bail determination and does +nothing to address the defendant's risk of flight or mitigate the danger he poses to the community. +B. The Defendant Wrongly Argues the Statute Does Not Apply to His Sex Trafficking +Next, the defendant wrongly argues that the "principal conduct" giving rise to the charges +is his payment of underage girls for sex acts, and that such conduct could not possibly fall under +the charged statutes. As the defendant implicitly concedes, Release Motion at 14, this is an issue +for a motion to dismiss. Nevertheless, the defendant's argument is incorrect for two reasons. +First, although the defendant undoubtedly participated on the demand side of the crime, he +was also instrumental on the supply side given his role in recruiting and causing others to recruit +additional victims. He organized, funded, and perpetuated a sex trafficking scheme in two states, +including with co-conspirators. The fact that he did so for his own eventual and frequent sexual +gratification does not vitiate his role in enticing and recruiting victims, consistent with the elements +of the offense with which he is charged. The defendant was the leader of a sex-trafficking +enterprise, not a mere consumer. +& This analysis similarly extends to a non-prosecution agreement. See United States v. Laskow, +688 F. Supp. 851, 854 (E.D.N.Y. 1988) ("Defendant's argument, in effect, is that unless there is +an explicit statement to the contrary, it is presumed that a non-prosecution agreement binds offices +of the United States Attorney that are not parties to the agreement. This position is at odds with +the law in this Circuit, which presumes a narrow reading of the boundaries of a plea agreement +unless a defendant can affirmatively establish that a more expansive interpretation was +contemplated.") (citing Annabi, 771 F.2d at 672). + + +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 14 of 14 +July 12, 2019 +Page 14 +Second, he is also wrong on the law. Courts have found that Section 1591 applied to both +suppliers and consumers of commercial sex acts. See, e.g., United States v. Jungers, 702 F.3d +1066, 1069 (8th Cir. 2013) (upholding the conviction of a defendant who attempted to pay for oral +sex from an underage girl and explaining: "The sole issue raised on appeal is whether '[t]he plain +and unambiguous provisions of 18 U.S.C. § 1591 apply to both suppliers and consumers of +commercial sex acts.' We conclude they do.") (alteration in original). The lone case cited by the +defendant, Fierro v. Taylor, No. 11 Civ. 8573, 2012 WL 13042630 (S.D.N.Y. July 2, 2012), relied +heavily on the statutory interpretation undertaken by two district courts in the District of South +Dakota, United States v. Bonestroo, No. 11 Cr. 40016, 2012 WL 13704 (D.S.D. Jan. 4, 2012), and +United States v. Jungers, 11 Cr. 40018, 2011 WL 6046495 (D.S.D. Dec. 5, 2011), both of which +were explicitly overruled by the Eighth Circuit decision in Jungers, 702 F.3d 1066. In the seven +years since Fierro has been decided, it does not appear to have been cited by a single other court. +Additionally, other cases in this Circuit and elsewhere have upheld convictions of procurers or +customers. See United States v. O'Connor, 650 F.3d 839 (2d Cir. 2011) (upholding convictions +under Section 1591 of both the buyer and seller of a child); United States v. Cook, 782 F.3d 983 +(8th Cir. 2015) (rejecting a constitutional challenge that Section 1591 would be void for vagueness +if applied to purchasers); United States v. Mikoloyck, No. 09 Cr. 036, 2009 WL 4798900 (W.D. +Mo. Dec. 7, 2009) ("contrary to defendant's argument, 18 U.S.C. § 1591 clearly applies to those +who attempt to purchase underage sex, not merely the pimps of actual exploited children") (citing +United States v. Roberts, 174 F. App's 475 (11th Cir. 2006) (in which defendant was convicted +under sections 1591(a) and 1594(a) even though no actual children were involved)). +CONCLUSION +As set forth above, the defendant's proposed bail package is insufficient and insubstantial +Pretrial Services, victims, and the Government all recommend pretrial detention due to the unusual +and concerning confluence of factors in this case, including the defendant's extraordinary wealth, +demonstrated willingness to interfere with victims and witnesses, continued possession of lewd +photographs of young females, and both the incentive and means to flee prosecution. +Very truly yours, +GEOFFREY S. BERMAN +United States Attorney +By: +Assistant United States Attorney +Southern District of New York +Tel: (212) 637-2415 / 2225 / 2324 +Cc: +Martin Weinberg, Esq., and Reid Weingarten, Esq., counsel for defendant + + +Case 1:19-cr-00490-RMB Document 11-1 Filed 07/12/19 Page 1 of 10 +U.S. Department of Justice +United States Attorney +Southern District of New York +The Silvio J. Mollo Building +One Saint Andrew's Plaza +New York, New York 10007 +July 8, 2019 +VIA ECE +The Honorable Henry Pitman +United States District Court +Southern District of New York +United States Courthouse +500 Pearl Street +New York, New York 10007 +Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) +Dear Judge Pitman: +The Government respectfully submits this letter in advance of the bail hearing scheduled +for July 8, 2019, in the above-captioned case. For the reasons set forth herein, the Court should +order that the defendant be detained pending trial; he cannot meet his burden of overcoming the +presumption that there is no combination of conditions that would reasonably assure his continued +appearance in this case or protect the safety of the community were he to be released. +As set forth below, the charges in this case are exceptionally serious: the defendant is +alleged to be a serial sexual predator who preyed on dozens of minor girls over a period of years, +and he now faces a potentially massive prison sentence predicated on substantial and multifaceted +evidence of his guilt. In light of the strength of the Government's evidence and the substantial +incarceratory term the defendant would face upon conviction, there is an extraordinary risk of +flight, particularly given the defendant's exorbitant wealth, his ownership of and access to private +planes capable of international travel, and his significant international ties. Indeed, the arrest of +the defendant occurred when he arrived in the United States on his private jet after having returned +from a multi-week stay abroad. +The defendant thus cannot overcome the statutory presumption that detention is appropriate in thi +case, and the Court should order that he be detained pending trial. + + +Case 1:19-Cr-00490-RMB Document 11-1 Filed 07/12/19 Page 2 of 10 +July 8, 2019 +Page 2 +BACKGROUND +A. Overview +On July 2, 2019, a federal grand jury in the Southern District of New York returned a sealed +indictment (the "Indictment") charging the defendant with one count of sex trafficking of minors, +in violation of 18 U.S.C. § 1591, and one count of conspiracy to commit sex trafficking of minors, +in violation of 18 U.S.C. § 371. +As charged by the grand jury, the facts underlying the charges in the Indictment arise from +a years-long scheme to sexually abuse underage girls. In particular, beginning in at least 2002, the +defendant enticed and recruited dozens of minor girls to engage in sex acts with him, for which he +paid the victims hundreds of dollars in cash. +He undertook this activity in at least two different locations, including his mansion in +Manhattan, New York (the "New York Residence") and his estate in Palm Beach, Florida (the +"Palm Beach Residence"). In both New York and Florida, the defendant perpetuated this abuse in +similar ways. Victims were initially recruited to provide "massages" to the defendant, which +would be performed nude or partially nude, would become increasingly sexual in nature, and +would typically include one or more sex acts, including groping and direct or indirect contact with +victims' +genitals. The defendant paid his victims hundreds of dollars in cash for each separate +encounter. +Moreover, the defendant actively encouraged certain of his victims to recruit additional +girls to be similarly sexually abused. He incentivized his victims to become recruiters by paying +these victim-recruiters hundreds of dollars for each additional girl they brought to him. In this +fashion, the defendant created a vast network of underage vietims for him to exploit, in locations +including New York and Palm Beach. +The defendant's victims were as young as 14 years old when he abused them. Many of his +victims were, for various reasons, often particularly vulnerable to exploitation. The defendant +intentionally sought out — and knew that he was abusing minors. Indeed, in some instances, his +victims expressly told him they were underage before or during the period in which he abused +them. +In creating and maintaining a network of minor victims whom he abused, the defendant +worked with others, including employees and associates who facilitated his exploitation of minors +by, among other things, contacting victims and scheduling their sexual encounters with the +defendant, both in New York and in Florida. +B. The Defendant +Jeffrey Epstein designed, financed, and perpetrated this scheme, both as its main participant +and through his direction of others, including certain of his employees, to further facilitate his +rampant abuse of underage girls. + + +Case 1:19-Cr-00490-RMB Document 11-1 Filed 07/12/19 Page 3 of 10 +July 8, 2019 +Page 3 +As has been widely reported, the defendant is extraordinarily wealthy, and he owns and +maintains luxury properties and residences around the world, including in Manhattan, New York; +Palm Beach, Florida; Stanley, New Mexico; and Paris, France. Additionally, Epstein owns a +private island in the U.S. Virgin Islands which, as noted above, is believed to be his primary +residence in the United States. His mansion in Manhattan alone—a multi-story townhouse +reported to be one of the largest single residences in all of Manhattan, which previously housed a +school and which he owns through an LLChas been valued at approximately $77 million. +Entities controlled by the defendant also own at least two private jets in active service, at least one +of which is capable of intercontinental travel. +As described further below, the defendant possesses three active United States passports, +and his international connections and travels are extensive. For example, in addition to +maintaining a residence in Paris, France, as described above, in the past 18 months alone, the +defendant has traveled abroad, via private jet, either into or out of the country on approximately +more than 20 occasions. +C. The Prior Florida Investigation +In or about 2005, the defendant was investigated by local police in Palm Beach, Florida, in +connection with allegations that he had committed similar sex offenses against minor girls. The +investigation ultimately also involved federal authorities, namely the U.S. Attorney's Office for +the Southern District of Florida ("SDFL") and the FBI's Miami Office, and included interviews +with victims based in the Palm Beach area, including some of the alleged victims relevant to Count +One of the instant Indictment.' +In fall 2007, the defendant entered into a non-prosecution agreement with the SDFL in +connection with the conduct at issue in that investigation, which the non-prosecution agreement +identified as including investigations into the defendant's abuse of minor girls in the Palm Beach +area. The Southern District of New York was not a signatory to that agreement, and the defendant +was never charged federally. In June 2008, the defendant pled guilty in state court to one count +of procuring a person under the age of 18 for prostitution, a felony, and one count of solicitation +of prostitution, a felony. As a result, the defendant was designated as a sex offender with +registration requirements under the national Sex Offender Registration and Notification Act. +' The non-prosecution agreement, further discussed below, was entered into at the conclusion of +the SDFL investigation and did not purport to cover any victims outside of the State of Florida. +As noted above, the instant Indictment expressly alleges the existence of dozens of victims who +were abused in this District in addition to dozens of victims who were abused in Florida. +2 While beyond the scope of a bail hearing, as discussed further below, it is well-established in the +Second Circuit that absent an express provision to the contrary in the agreement, one District is +not bound by the terms of an agreement entered into between a defendant and a U.S. Attorney's +Office in another district. See page 6, infra. + + +Case 1:19-Cr-00490-RMB Document 11-1 Filed 07/12/19 Page 4 of 10 +July 8, 2019 +Page 4 +ARGUMENT +1. +Applicable Law +Under the Bail Reform Act, 18 U.S.C. §§ 3141 et seq., federal courts are empowered to +order a defendant's detention pending trial upon a determination that the defendant is either a +danger to the community or a risk of flight. 18 U.S.C. § 3142(e) ("no condition or combination of +conditions would reasonably assure the appearance of the person as required and the safety of any +other person and the community"). A finding of risk of flight must be supported by a +preponderance of the evidence. See, e.g., United States v. Jackson, 823 F.2d 4, 5 (2d Cir. 1987); +United States v. Chimurenga, 760 F.2d 400, 405 (2d Cir. 1985). A finding of dangerousness must +be supported by clear and convincing evidence. See, e.g., United States v. Ferranti, 66 F.3d 540, +542 (2d Cir. 1995); Chimurenga, 760 F.2d at 405. In addition, a court may also order detention if +there is "a serious risk that the [defendant] will ... attempt to obstruct justice, or ... to threaten, +injure, or intimidate, a prospective witness or juror." 18 U.S.C. § 3142(f(2)(B); see also United +States v. Friedman, 837 F.2d 48 (2d Cir. 1988). +The Bail Reform Act lists four factors to be considered in the detention analysis: (1) the +nature and circumstances of the crimes charged; (2) the weight of the evidence against the person; +(3) the history and characteristics of the defendant, including the person's "character ... [and] +financial resources"; and (4) the seriousness of the danger posed by the defendant's release. See +18 U.S.C. § 3142(g). Evidentiary rules do not apply at detention hearings and the government is +entitled to present evidence by way of proffer, among other means. See 18 U.S.C. § 3142(f)(2); +see also United States v. LaFontaine, 210 F.3d 125, 130-31 (2d Cir. 2000) (government entitled +to proceed by proffer in detention hearings); Ferranti, 66 F.3d at 542 (same); United States v. +Martir, 782 F.2d 1141, 1145 (2d Cir. 1986) (same). +Where a judicial officer concludes after a hearing that "no condition or combination of +conditions will reasonably assure the appearance of the person as required and the safety of any +other person and the community, such judicial officer shall order the detention of the person before +18 U.S.C. § 3142(e)(1). Additionally, where, as here, a defendant is charged with +committing an offense involving a minor victim under 18 U.S.C. § 1591, it shall be presumed, +subject to rebuttal, that no condition or combination of conditions will reasonably assure the +appearance of the defendant as required and the safety of the community. 18 U.S.C. +§ 3142(e)(3)(E). +II. +Discussion +The defendant should be detained pending trial. For the reasons set forth below, it is +difficult to overstate the risk of flight and danger to the community if the defendant is released, +and for those reasons, the defendant cannot overcome the statutory presumption in favor of +detention in this case. + + +Case 1:19-Cr-00490-RMB Document 11-1 Filed 07/12/19 Page 5 of 10 +July 8, 2019 +Page 5 +A. The Defendant Poses an Extreme Flight Risk +Each of the relevant factors to be considered as to flight risk - the nature and circumstances +of the offense, the strength of the evidence, and the history and characteristics of the defendant - +counsel strongly in favor of detention. +1. The Nature and Circumstances of the Offense and the Strength of the Evidence +The "nature and circumstances" of this offense plainly favor detention. 18 U.S.C. +§ 3142(g)(1) (specifically enumerating "whether the offense. .. involves a minor victim" as a +factor in bail applications). Indeed, the crime of sex trafficking of a minor is so serious that for a +detendant charged with that offense, there is a presumption that no condition or combination of +conditions will reasonably assure the appearance of the defendant as required and the safety of the +community. 18 U.S.C. § 3142 (e)(3)(E). Here, as specified in the Indictment, the defendant's +conduct was committed serially, over a period of years, and affected dozens of victims. +The seriousness of the charge is also reflected in the penalties the defendant faces, which +include up to 45 years of incarceration for Counts One and Two of the Indictment.? As the Second +Circuit has noted. +1, the possibility of a severe sentence is a significant factor in assessing the risk of +flight. See Jackson, 823 F.2d at 7; see also United States v. Cisneros, 328 F.3d 610, 618 (10th Cir. +2003) (defendant was a flight risk because her knowledge of the seriousness of the charges against her +gave her a strong incentive to abscond); United States v. Townsend, 897 F.2d 989, 995 (9th Cir. 1990) +("Facing the much graver penalties possible under the present indictment, the defendants have an even +greater incentive to consider flight."). Here, the defendant is facing a statutory maximum of decades +in prison. Even in the absence of means —which, as discussed in detail below, the defendant has +in abundancethis fact alone would provide a compelling incentive for anyone to fail to appear. +It is particularly compelling for a defendant who is 66 years old and therefore faces the very real +prospect of spending the rest of his life in prison if convicted. +The likelihood of a substantial period of incarceration is buttressed by the strength of the +evidence. As set forth in the Indictment, the evidence in this case is strong. The Indictment alleges +that the defendant sexually abused dozens of minor victims, and the conspiracy count lists +numerous overt acts committed in furtherance of the defendant's crimes.* +3 The current penalties for violations of 18 U.S.C. § 1591 include a 10 year mandatory minimum +sentence. However, that punishment was created through an amendment to the statute in 2006. +The penalty for a violation of Section 1591 during the period charged in the Indictment, and +therefore relevant here, was a maximum of 40 years' imprisonment. ++ With respect to the evidence in this case, the Court should start its analysis by accepting that the +Indictment is sufficient, on its own, to establish probable cause that the defendant committed the +crimes of sex trafficking and sex trafficking conspiracy. Contreras, 776 F.2d at 54. ("Were an +evidentiary hearing addressing the existence of probable cause required in every § 3142(e) case in +which an indictment had been filed, the court would spend scarce judicial resources considering +that which a grand jury had already determined, and have less time to focus on the application of + + +Case 1:19-Cr-00490-RMB Document 11-1 Filed 07/12/19 Page 6 of 10 +July 8, 2019 +Page 6 +Multiple victims, including several specified in the Indictment, have provided information +against the defendant. That information is detailed, credible, and corroborated, in many instances, +by other witnesses and contemporaneous documents, records and other evidence—including, as +further detailed below, evidence from a search of the New York Residence on the night of the +defendant's arrest that reflects an extraordinary volume of photographs of nude and partially-nude +young women or girls. Such corroborating evidence also includes documents and other materials, +such as contemporaneous notes, messages recovered from the defendant's residence that include +names and contact information for certain victims, and call records that confirm the defendant and +his agents were repeatedly in contact with various victims during the charged period. Put simply, +all of this evidence - the voluminous and credible testimony of individuals who were sexually +abused by the defendant as minors, each of whom are backed up by other evidence - will be +devastating evidence of guilt at any trial in this case and weighs heavily in favor of detention. +Finally, it bears noting that neither the age of the conduct nor the defendant's previous nonprosecution agreement ("NPA") with a different federal district pose any impediment to his +conviction. As an initial matter, all of the conduct is timely charged, pursuant to 18 U.S.C. § 3283, +which was amended in 2003 to extend the limitations period for conduct that was timely as of the +date of the amendment, to any time during the lifetime of the minor victim. See United States v. +Chief, 438 F.3d 920, 922-25 (9th Cir. 2006) (finding that because Congress extended the statute +of limitations for sex offenses involving minors during the time the previous statute was still +running, the extension was permissible); United States v. Pierre-Louis, No. 16 Cr. 541 (CM), 2018 +WL 4043140, at *1 (S.D.N.Y. Aug. 9, 2018) (same). +Moreover, with respect to the NPA, that agreement, to which the Southern District of New +York was not a party, which by its express language pertained exclusively to the SDFL +investigation, and which did not purport to bind any other Office or District, does not preclude +prosecution in this District for at least two reasons. First, it is well settled in the Second Circuit +that "a plea agreement in one U.S. Attorney's office does not, unless otherwise stated, bind +another." United States v. Prisco, 391 F. App'x 920, 921 (2d Cir. 2010) ("A plea agreement binds +only the office of the United States Attorney for the district in which the plea is entered unless it +affirmatively appears that the agreement contemplates a broader restriction.") (citing United States +v. Annabi, 771 F.2d 670, 672 (2d Cir. 1985) (per curiam)). This is true even if the text of the +agreement purports to bind "the Government." See Annabi, 771 F.2d at 672. This analysis +similarly extends to a non-prosecution agreement. See United States v. Laskow, 688 F. Supp. 851, +854 (E.D.N.Y. 1988) ("Defendant's argument, in effect, is that unless there is an explicit statement +to the contrary, it is presumed that a non-prosecution agreement binds offices of the United States +Attorney that are not parties to the agreement. This position is at odds with the law in this Circuit, +which presumes a narrow reading of the boundaries of a plea agreement unless a defendant can +affirmatively establish that a more expansive interpretation was contemplated.") (citing Annabi, +771 F.2d at 672). Second, the Indictment charges conduct not covered by the NPA, namely +the presumptions and the § 3142(g) factors in deciding whether the defendant should be +detained."). + + +Case 1:19-Cr-00490-RMB Document 11-1 Filed 07/12/19 Page 7 of 10 +July 8, 2019 +Page 7 +conduct that occurred in New York. The prior NPA included a list of several dozen victims +identified in the prior investigation, all of whom were abused in the State of Florida, and none of +whom are a part of the conduct charged in Count Two of the instant Indictment. +Each of these factors the seriousness of the allegations, the strength of the evidence, and +the possibility of lengthy incarceration creates an extraordinary incentive to flee. And as further +described below, the defendant has the means and money to do so. +2. The Characteristics of the Defendant +The history and characteristics of the defendant also strongly support detention. The +defendant is extraordinarily wealthy and has access to vast financial resources to fund any attempt +to flee. Indeed, his potential avenues of flight from justice are practically limitless. +As the defendant acknowledged in his most recent New York State sex offender +registration, he has six residences, including two in the U.S. Virgin Islands (including his own +private island), and one each in Palm Beach, Florida; Paris, France; New York, New York; and +Stanley, New Mexico. The most recent estimated value of the defendant's New York City mansion +alone is more than $77 million. The most recent tax-assessed value of the defendant's Palm Beach +estate is more than $12 million. The defendant's primary residence is a private island in the U.S. +Virgin Islands, a place where any sort of meaningful supervision would be all but impossible. +Moreover, the defendant has access to innumerable means to flee. His sex registration +documentation of "current vehicles" lists no fewer than 15 motor vehicles, including seven +Chevrolet Suburbans, a cargo van, a Range Rover, a Mercedez-Benz sedan, a Cadillac Escalade, +and a Hummer II. These cars are registered in various states and territories including the Virgin +Islands, New York, Florida, and New Mexico. The defendant also has access to two private jets, +giving him the ability to leave the country secretly and on a moment's notice and to go virtually +anywhere he wants to travel. He is a very frequent international traveler and regularly travels to +and from the United States by private plane. In particular, between January 1, 2018, and the +present, U.S. Customs and Border Patrol has logged approximately more than 20 flights in which +Epstein was traveling to or from a foreign country. Indeed, he was arrested at Teterboro Airport +arriving on just such a private international flight after having spent approximately three weeks +abroad. Extensive international travel of this nature further demonstrates a significant risk of +flight. See, e.g., United States v. Anderson, 384 F. Supp. 2d 32, 36 (D.D.C. 2005). There can be +no assurance that, upon release, the defendant would suddenly lack access to such means of travel. +Finally, the defendant has no meaningful ties that would keep him in this country. The +defendant has no known immediate family. He is not married and has no children. He has friends +and associates worldwide, as demonstrated by his extensive international travel, and his +professional obligations, if any, can and seemingly are plainly capable of being handled by the +defendant remotely. Simply put, there would be no meaningful reason for the defendant to remain +in the country, while he would have every incentive (and every resource needed) to flee. +Nor would home confinement with electronic monitoring reasonably assure the +defendant's presence as required. At best, home confinement with electronic monitoring would + + +Case 1:19-Cr-00490-RMB Document 11-1 Filed 07/12/19 Page 8 of 10 +July 8, 2019 +Page 8 +merely reduce his head start should he decide to flee. See United States v. Zarger, No. 00 Cr. 773, +2000 WL 1134364, at *1 (E.D.N.Y. Aug. 4, 2000) (Gleeson, J.) (rejecting defendant's application +for bail in part because home detention with electronic monitoring "at best ... limits a fleeing +defendant's head start"); see also United States v. Casteneda, No. 18 Cr. 047, 2018 WL 888744, +at *9 (N.D. Cal. Feb. 2018) (same); United States v. Anderson, 384 F.Supp.2d 32, 41 (D.D.C +2005) (same); United States v. Benatar, No. 02 Cr. 099, 2002 WL 31410262, at *3 (E.D.N.Y. +Oct. 10, 2002) (same). +Finally, there can be little doubt that the defendant is in a position to abandon millions of +dollars in cash and property securing any potential bond and still live comfortably for the rest of +his life. These resources, and the ease with which the defendant could flee and live outside the +reach of law enforcement-particularly considering his vast wealth and lack of meaningful ties to +this District— make the risk of flight exceptionally high in this case, particularly when considered +in conjunction with the strength of the government's case and the lengthy sentence the defendant +could receive if convicted. +B. The Defendant Poses a Risk of Danger to the Community and of Engaging in +Obstruction of Justice +The release of the defendant, under any conditions, would pose a significant threat to the +community and to the ongoing investigation. +As described above, where there is probable cause to believe that an individual has +committed an offense under 18 U.S.C. § 1591, it is presumed that no condition or combination of +conditions can reasonably assure the safety of the community. 18 U.S.C. § 3142(e)(3). Here, not +only is the defendant charged with very serious sex crimes against minors, he has already +previously admitted to and been convicted of engaging in related conduct. Specifically, in +June 2008, the defendant pled guilty in state court to one count of procuring a person under the +age of 18 +for prostitution, a felony, and he currently is a registered sex offender, under +classification level three in New York-defined as presenting a "high" risk of committing another +sex crime and harm to the community. While the conduct presently alleged does not post-date the +2008 conviction, it nevertheless underscores the risk he poses to the community if released. +Additionally, and in connection with the investigation of the defendant's offense in Florida, +there were credible allegations that the defendant engaged in witness tampering, harassment, or +other obstructive behaviors. In fact, according to publicly-filed court documents, there were +discussions between prosecutors and the defendant's then-counsel about the possibility of the +defendant pleading guilty to counts relating to "obstruction," as well as "harassment," with +reference to 18 U.S.C. § 1512, which criminalizes "[t]ampering with a witness, vietim, or +informant." For example, in a communication from the defendant's then-counsel to prosecutors +in SDFL, his counsel set forth a possible factual proffer that included statements that the defendant +had "attempted to harass both [redacted] delay and hinder their receipt of a [redacted] to attend an +official proceeding" and that the defendant "in particular, changed travel plans and flew with both +[redacted] to the United States Virgin Islands rather than to an airport in New Jersey in order to +attempt to delay their receipt of what Mr. Epstein expected to be a [redacted]" and "further verbally + + +Case 1:19-cr-00490-RMB Document 11-1 Filed 07/12/19 Page 9 of 10 +July 8, 2019 +Page 9 +harassed both [redacted] in connection to this attempt to delay their voluntary receipt of process +all in violation of 18 USC 1512(d)(1)." Doe v. United States, 08 Civ. 80736 (S.D. Fla.), Dkts. +361 at 3-4, 361-7 through 361-11. In addition to 18 U.S.C. § 1512(d), prosecutors also proposed +that the defendant could plead guilty to 18 U.S.C. § 403, that is, a knowing or intentional violation +of the privacy protection of child victims and child witnesses, to which the defendant's thencounsel replied: "Already thinking about the same statutes." Id. Dkt. 361-11. They also discussed +a possible obstruction plea that "could rely on the incident where Mr. Epstein's private +investigators followed [redacted] father, forcing off the road." Id. Dkt. 361-10. +The defendant's apparent previous willingness to obstruct a federal investigation, harass or +tamper with witnesses, and hire private investigators that "forcled] off the road" the father of an +individual relevant in the investigation is alarming. It should especially weigh on the Court's +consideration here because the defendant was apparently willing to take those steps before even +being charged and thus facing federal indictment; the incentive to interfere in the Government's +case here, where an Indictment has been returned, is exponentially greater. And as discussed +above, the defendant has nearly limitless means to do so. +Finally, despite having been previously convicted of a sex offense involving an underage +victim, the defendant has continued to maintain a vast trove of lewd photographs of young-looking +women or girls in his Manhattan mansion. In a search of the New York Residence on the night of +his arrest, on July 6-7, 2019, pursuant to judicially-authorized warrants, law enforcement officers +discovered not only specific evidence consistent with victim recollections of the inside of the +mansion, further strengthening the evidence of the conduct charged in the Indictment, but also at +least hundreds-and perhaps thousands of sexually suggestive photographs of fully- or partiallynude females. While these items were only seized this weekend and are still being reviewed, some +of the nude or partially-nude photographs appear to be of underage girls, including at least one girl +who, according to her counsel, was underage at the time the relevant photographs were taken. +Additionally, some of the photographs referenced herein were discovered in a locked safe, in which +law enforcement officers also found compact dises with hand-written labels including the +following: "Young [Name] + [Name]," "Mise nudes 1," and "Girl pics nude." The defendant, a +registered sex offender, is not reformed, he is not chastened, he is not repentant;" rather, he is a +continuing danger to the community and an individual who faces devastating evidence supporting +deeply serious charges. +5 The redactions above are contained in the publicly filed version of the quoted document. +" See, e.g., Amber Southerland, Billionaire Jeffrey Epstein: I'm a sex offender, not a predator, +N.Y. Post (2011) (*'I'm not a sexual predator, I'm an "offender," the financier told The Post +yesterday. 'It's the difference between a murderer and a person who steals a bagel."'); Philip +Weiss, The Fantasist, New York Magazine (2007) (*'It's the Icarus story, someone who flies too +close to the sun, ' I said. 'Did Icarus like massages?' Epstein asked."). + + +Case 1:19-cr-00490-RMB Document 11-1 Filed 07/12/19 Page 10 of 10 +July 8, 2019 +Page 10 +CONCLUSION +As set forth above, in this case, the risk of flight in this case is extraordinarily real. The +defendant is extremely wealthy, has extensive foreign contacts, and is charged with serious +offenses that carry a potential statutory sentence of up to 45 years' imprisonment even a fraction +of which could result in the defendant, who is 66 years old, spending the rest of his life in jail. In +sum, the defendant's transient lifestyle, his lack of family or community ties, his extensive +international travel and ties outside the country, and his vast wealth, including his access to and +ownership of private planes, all provide the defendant with the motive and means to become a +successful fugitive. Further, the nature of the offenses he is alleged to have perpetrated—the abuse +dozens of underage, vulnerable girls—along with his demonstrated willingness to harass, +intimidate and otherwise tamper with victims and other potential witnesses against him, render his +dangerousness readily apparent. +Accordingly, the Government respectfully submits that the defendant cannot and will not +be able to meet his burden of overcoming the strong presumption in favor of detention, that there +are no conditions of bail that would assure the defendant's presence in court proceedings in this +case or protect the safety of the community, and that any application for bail should be denied. +Very truly yours, +GEOFFREY S. BERMAN +United States Attorney +By: +Assistant United States Attorney +Southern District of New York +Tel: (212) 637-2415 / 2225 / 2324 +Cc: +Martin Weinberg, Esq., and Reid Weingarten, Esq., counsel for defendant +Hon. Richard M. Berman, United States District Judge + + +Date: +Time: +Case 1:19-cr-00490-RMB_ Document 11-2_ Filed 97/12/19 Page 1 o1 2 +M BEACH POLICE DEPARTMENI +Incident Report +Page: +Program: +Case No. . +(Continued) +Entered By.: +On +2006, I received several phone calls throughout the day +from +who stated he had been followed aggressively by a private +investigator. +• stated that as he drove to and from work and +running errands throughout the county, the same vehicle was behind him +running other vehicles off the road in an attempt not to lose sight of +I's vehicle. +I explained to him as Mr. Epstein had retained new legal council it +was possible it would be new private investigators following him to +observe his daily activities. I also explained to him that there was +and +at +I attempted to call +private investigators following +scheduled on +to inform +of the +however; +I received other phone calls from | +and +who +advised they were able to acquire the private investigators license +plate information. The subject following them was again driving very +aggressively and caused l +to run off the road. +stated +the vehicle is a green Chevy +bearing Florida tag. +The vehicle is registered to +| Florida. +is employed with +Investigations from +Florida. +is a licensed Private Investigator in the State of Florida. +Since the discovery of the threat made against one of the victims in +this case +, I requested subpoenas for all calls made to and +received from +during the month of March 2006 for her +cell phone and home phone. I had confirmed with Florida State +the exact dates of Spring Break +.. The Spring Break +was from March 4, 2006 through March 12, 2006. I received a subpoena +from +with all calls made during the month of +I reviewed the 989 calls made and received during the month of March +2006. I observed on +2006, +made and received thirty +five calls during that day. +Date +Time +Seconds +In/Out +To/From +I-06 11:03 AM +492 +Outbound +06 11:16 AM +6 +Inbound +-06 11:22 AM +887.2 +Inbound +-06 11:37 AM +48 +Outbound +-06 11:39 AM +28.2 +Inbound +-06 12:02 PM +727.2 Inbound +The table reflects the date of the calls, time of day (EST), duration + + +Date: +Time: +Case 1:19-cr-00490-RMB Document 11-2 Filed 07/12/19 Page 2 of 2 +IM BEACH POLICE DEPARTMENL +Incident Report +Page: +Program: +Case No. . . +(Continued) +of call in seconds, inbound or outbound calls and calls made to or +from +phone. +On +| 2006, at 11:03 am, +made a call +to the victim which lasted 492 seconds (8 minutes and 2 seconds) . +The victim then returned the call at 11:16 am which lasted 6 seconds. +The victim then made contact with +at 11:22 am for 877.2 seconds +(14 minutes and 6 seconds) . +These sequences of calls were consistent +with what the victim had described to me on the date of the +intimidation. Immediately after speaking with the victim, +makes +a call to +, Epstein's assistant, which lasts for +forty-eight seconds. A call is then immediately received, a telephone +number registered to a Corporation affiliated with Jeffrey Epstein +located at 457 Madison Ave in New York. An extensive computer check +revealed 457 Madison Ave is a business +his corporations assigned to. Epstein had corporation attorney, +register the businesses and register himself as an +agent. +I also observed Epstein has his El Zorro Ranch Corporation, +New York Strategy Group, Ghislaine Corporation, J Epstein and Company +and the Financial Strategy Group registered to this same address. +Finally, a third call is received by | +at 12:02 pm from the same +corporate number which lasts 12 minutes and 1 second. It should be +noted that there is no further contact with either the victim during +the month of | +I also noted that there was no +further contact with +Jor Jeffrey Epstein during the +remainder of the month of +2006. +On +2006, +meeting that occurred with Atty. +this case. +telephoned me to inform me of the +and +reference +Inv Continues. + + +Case 1:19-cr-00490-RMB Document 11-3 Filed 07/12/19 Page 1 of 2 +ate: +7/19/06 +ime: 15:01:37 +PALM BEACH POLICE DEPARTMENT +Incident +Report +Page: +82 +Program: CMS301L +**** NARRATIVE # 42 ****** +Reported.: RECY, CA. +on April 5, +**** +4/14/06 +4/18/06 + + +Case 1:19-cr-00490-RMB +Document 11-3 Filed 07/12/19 Page 2 of 2 +ate: +7/19/06 +ime: 15:01:37 +PALM BEACH POLICE DEPARTMENT +Incident Report +Page: +Program: +Ise No. +10, +: 1-05-000368 +(Continued) +2006, at approximately 2:30 p.m., I served pat her residence in +The subpoena was given to her mother, +• that she was personally +contacted through a source that has maintained contact with Epstein. +The source assured she would receive monetary compensation for her +assistance in not cooperating with law enforcement. +also stated +she was told, "Those who help him will be compensated and those who +hurt him will be dealt with." I told that tampering with a +witness/victim is an arrestable offense and very serious. I asked her +who approached her during this encounter. Doriginally was reluctant +to provide the name of the person who approached her to offer her not +to testify because she felt they were still friends. +on April 11, 2006, Det Dawson and I traveled to Tallahassee, Florida +and met with the +• identified fill +as the person who approached her in Royal Palm Beach while +she was home during Spring Break in March 2006. also stated she +did not want to pursue the intimidation charges on aun +1 was +concerned that the defense attorney was given a copy of the report as +certain things she had told me in confidence were repeated to her by +83 +CMS301L \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/0a0e2d31057267bb897c9de4944369a683b96cfa4f8ded1bf9ccc6278f60dc30.receipt.json b/vision-fixhub/ds9-parsed-01/0a0e2d31057267bb897c9de4944369a683b96cfa4f8ded1bf9ccc6278f60dc30.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..359defdd098e816f228fd91522e90f4cc7fe38b1 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0a0e2d31057267bb897c9de4944369a683b96cfa4f8ded1bf9ccc6278f60dc30.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -1572, + "dataset": "marble-joined", + "doc_id": "0a0e2d31057267bb897c9de4944369a683b96cfa4f8ded1bf9ccc6278f60dc30", + "engine": "marble-apple-vision", + "event_count": 33, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "7da30a45ad5095062cfd20ae08ac6abc782f2dd7e30c2495ec77c68aad7c0e67", + "output_sha256": "e71e20ea57a8027899b993ad5993a49af81c1eb2ed9b3327eb3aba9b71362e00", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0a334918c08414aed06791225244e23ffcf9d39af7892f9f98728a2c7fbe368f.md b/vision-fixhub/ds9-parsed-01/0a334918c08414aed06791225244e23ffcf9d39af7892f9f98728a2c7fbe368f.md new file mode 100644 index 0000000000000000000000000000000000000000..dca742c34c3b679296604f9090e9b46f291f6e57 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0a334918c08414aed06791225244e23ffcf9d39af7892f9f98728a2c7fbe368f.md @@ -0,0 +1,87 @@ +From: +To: +Cc: +Subject: RE: Taint Review - Epstein +Date: Mon, 30 Sep 2019 17:53:30 +0000 +Attachments: SW_Executed_7.11.19. +_report.pdf +Following up on the Epstein materials, it seems to us like 20,000 documents is exceedingly low given the volume of +devices we seized. Can you please tell us how many source devices those documents are from, so we can crossreference? The seizure records appear to reflect that there were approximately 38 computers and/or electronic storage +devices seized along with an additional approximately 55 CDs-see the attached seizure report. I just can't imagine that +would only result in 20,000 documents. Please advise? +thanks, +-----Original Message-.... +From: +Sent: Thursday, September 26, 2019 11:37 +To: +Subject: FW: Taint Review - Epstein +FYI. +----Original Message-.... +From: +Sent: Thursday, September 26, 2019 11:37 AM +To: +Subject: Re: Taint Review - Epstein +About 20K but a lot are non-user files, like adobe instructions. +Assistant United States Attorney +Southern District of New York +New York, NY 10007 +> On Sep 26, 2019, at 11:32 AM, +> Out of curiosity, do you know what the volume of NP documents is? Thanks. +> +>--Original Message.... +> From: +> Sent: Thursday, September 26, 2019 T1R0Z AM +> To: +> Cc: +wrote: + + +> Subject: RE: Taint Review - Epstein +> +> I've run all the terms that Epstein's attorney gave me and segregated the hits, there were not many. Can I release the +NP or did you come to some agreement with the defense that we would give them notice or let them review them first? +> +> Thanks, +> +>-----Original Message--.-. +> From: +> Sent: Monday, September 23, 2019 8:46 PM +> To: +> Cc: +> Subject: RE: Taint Review +> +> Great, thanks very much. +> +> +>---Original Message----. +> From: +> Sent: Monday, September 23, 2019 16:56 +> To: +> Cc: +> Subject: RE: Taint Review +> +> +> We are running the lawyer/paralegal names now, you should have access in a couple of days. +>---Original Message-..-- +> Subject: FW: Taint Review +> +> +> +> The agents on the Epstein case have asked, below, about the status of the taint review of the materials seized from his +Manhattan residence, which were made available on September 10 (see attached). I know that you had dealt directly +with Epstein's attorneys regarding search terms, etc., so we haven't had visibility on that, but could you please let us know +the current status, and when you expect we'll be able to get access to the materials? +> thanks very much, +≥---Original Message-.... +> From: +> Sent: Tuesday, September 17, 2019 17:17 +> To: +> Subject: Taint Review +> +> Hey guys, + + +> +> Our supervisors are requesting a status update on the taint review process on your end. I simple percentage complete is +fine, they just want to know before tomorrow they have a meeting with the ADIC about the case. +> Thanks diff --git a/vision-fixhub/ds9-parsed-01/0a334918c08414aed06791225244e23ffcf9d39af7892f9f98728a2c7fbe368f.receipt.json b/vision-fixhub/ds9-parsed-01/0a334918c08414aed06791225244e23ffcf9d39af7892f9f98728a2c7fbe368f.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..792b3663665cc7a459efc1e73720f785d3156dc6 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0a334918c08414aed06791225244e23ffcf9d39af7892f9f98728a2c7fbe368f.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -38, + "dataset": "marble-joined", + "doc_id": "0a334918c08414aed06791225244e23ffcf9d39af7892f9f98728a2c7fbe368f", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": 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Sai: 13 +325/2019:22:28 AM + + +Thursday August 08, 2019 +Page 10 +Ops Lt. Evening Watch Signature: +Captain's Signature: +1/25/2019 7:22:28 AM \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/0a4ea29c4c060eb3bf84bb498a9760f8e1659ee36db2d4bcf4a73d69cb5b8141.receipt.json b/vision-fixhub/ds9-parsed-01/0a4ea29c4c060eb3bf84bb498a9760f8e1659ee36db2d4bcf4a73d69cb5b8141.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..ffd293d71730e7259b393c6bff391b2cb018d7c5 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0a4ea29c4c060eb3bf84bb498a9760f8e1659ee36db2d4bcf4a73d69cb5b8141.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -803, + "dataset": "marble-joined", + "doc_id": "0a4ea29c4c060eb3bf84bb498a9760f8e1659ee36db2d4bcf4a73d69cb5b8141", + "engine": "marble-apple-vision", + "event_count": 11, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "003e249ace07219a77f9db16298284f79efd48906a257bb118b19fa134564782", + "output_sha256": "3ebbff8aaec7b0ffe7188ffc97323c52ac9ebfcf676164a73abf4d7b83e42ea0", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0a7b0925c8749c9b947ea15b2af76d40a251d66114257832961d3898f5ab0c27.md b/vision-fixhub/ds9-parsed-01/0a7b0925c8749c9b947ea15b2af76d40a251d66114257832961d3898f5ab0c27.md new file mode 100644 index 0000000000000000000000000000000000000000..0be667c00a33148e3309fbfc1375b60ff94d36df --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0a7b0925c8749c9b947ea15b2af76d40a251d66114257832961d3898f5ab0c27.md @@ -0,0 +1,376 @@ +FD-302 (Rev. 5-8-10) +- 1 of 5- +FEDERAL BUREAU OF INVESTIGATION +OFFICIAL RECORD +Cramerica come hagals sel +Date of entry +10/13/2023 +phone number +1. home address +was interviewed via Microsoft Teams +videoconferencing by United States Postal Inspection Service Inspector +|, United States Attorney's Office Special Agent +• and Federal Bureau of Investigation Special Agent +Also present for the interview was +, legal counsel to +• After being advised of the identity of the interviewing Agents +and the nature of the interview, +provided the following +information: +is not currently employed and supports herself with proceeds +from the sale of an insurance agency approximately two years ago. +frequently travels internationally for tourism. +Pre-Investment Background // Investment Promotion +was introduced to +by a mutual friend, | +who +has known since +was approximately 14 +years old. +Epstein. +recruited +to be "sold off" to Jeffrey +lives in +and her phone number is +is associated with individuals who may be involved in violent +criminal activity, including +boyfriend at the time, First Name +Unknown (FNU) Last Name Unknown (LNU) (hereinafter " +boyfriend"). +[Agent Note: +inquired about the confidentiality of her interview +statements +and expressed concern about "retribution" against her by +unidentified individuals if her cooperation with federal investigators was +made public. No further information.] +A little over one year ago, +promoted an investment opportunity to +involving +and +real estate business that +involved buying, renovating, and re-selling ("flipping") properties. +told +that +• was involved and associated with +celebrities and that +was offering a great investment opportunity. +told +had invested with +1. m +at +(Videoconference)) +Investigation on +10/12/2023 +File # 318B-NK-3825937 +by +1. United States (Other +Date drafted 10/13/2023 +To be distribute outside nitro recommendations nor conclusions of the FEB. is he property of the FBI and is loaned to your agency; it and is contents are not + + +Continuation of FD-302 of 12, 2023 +on October +, On 10/12/2023 +_ Page 2 of 5 +met +| approximately one year ago, amidst +relentless promotion of the investment opportunity with +At the time, +was living at her current home address and maintained a residence +at +met +in +• office in +was escorted by car to that first meeting with +from +house by +boyfriend. +I showed I +around +_ office while talking +with +about the real estate deals in which +I wanted +to invest. +boyfriend was the only other person in that first +meeting between +and +At the end of the first meeting +did not sign any paperwork and instead wanted to do some due +diligence and think more about the investment opportunity. +harassed +agreed +to invest with +boyfriend +the properties +for approximately one month before +met +a second time along with +at the time, +wanted +visited with +to invest in and flip, including +(hereinafter "the +''). +and +(hereinafter "the +," and together with the +"the Investment Properties"). The +had ongoing construction/renovation at the time +visited the +property. +[Agent Note: +address +I refers to the property with the street +and +both pressured +to invest with +1. often +flaunting +celebrity connections including Snoop Dogg, DJ ENVY, and +others, to help legitimize +business ventures. +[Agent Note: RAASHAUN CASEY is the individual known as DJ ENVY, a nationally +syndicated disc jockey +and radio personality based out of +City. 1 +with +at WEALTHSPIRE ADVISORS. +investment with +did not attend any real estate seminars prior to investing +discussed the opportunity with her financial advisors +WEALTHSPIRE ADVISORS advised against the +[Agent Note: WEALTHSPIRE ADVISORS is a national investment advisory firm +with +approximately $20 billion assets +under management, according to its +public website, www.wealthspire.com.] + + +Continuation of FD-302 of 12, 2023 +on +October +, On +10/12/2023 +, Page +3 of 5 +searched briefly for legal counsel related to the investment +with +but was turned off by the large associated expense. +offered +his own lawyer, ANTHONY VARGAS, to meet with +agreed +and met with +for a third time, +along with VARGAS. +VARGAS promoted the +investment opportunity to +"privilege" for +telling +it was a +to invest with +To help convince +to invest with +offered a personal guarantee on +investment. VARGAS told +VARGAS never saw +offer a personal +guarantee like the one offered to l +1. +VARGAS was the same lawyer who drafted the agreements executed by +and +• including joint venture agreements for the Investment +Properties and the personal guarantee of +investment by +wife, +"). +and +[Agent Note: +is also known as +OI +helped +the legal entity through which +insisted the entity, +in +create a limited liability company to be used as +would invest with +, be registered in +rather than +is the sole member of +and +has not been engaged in any other business activity other than that +described below with +does not intend to further utilize +for investment or other purposes. +Prior and subsequent to +with +texted +and +communication with +entering into investment agreements +conmunicated with +• mostly via text message. +at two different numbers +had for M +may have also had email +Investments with FROM START 2 FLIPPING LIC and +Personal Guarantee Thereof +and +[Agent Note: at this point in the interview Special Agent +displayed +Exhibits A, +B, and C to the civil complaint filed on May 15, 2023 by +• through +, against +and +business, +FROM START 2 FLIPPLING, LIC. +Exhibit A is a Joint Venture Agreement between +FROM START 2 FLIPPING LLC and +I regarding the +dated September 9, 2022 and signed by | +and +Exhibit B is a Joint Venture Agreement between FROM START TO FLIPPING LLC +and +regarding the | +dated September 9, + + +Continuation of FD-302 of 12, 2023 +on October +, On 10/12/2023 +., Page +4 Of 5 +2022 and signed by +and +with notarization by +Exhibit C is a Personal Guarantee of an investment of +$500,000 from +signed by +and +I, dated September 9, +2022. These agreements are attached hereto and will be maintained in the 1A +section of the case file. Exhibits A and B are collectively referred to as +"the Joint Venture Agreements."] +agreed to invest $500,000 with +$250,000 for the +renovation and resale of the +and $250,000 for the +renovation and resale of the +signed both +Joint Venture Agreements in +presence. +Per the Joint Venture +Agreements, +was to provide +for each investment an interest +payment of $50,000, or a 208 return, after five months. +[Agent Note: both joint venture agreements state in Section III.C that the +total return to +would be $360,000; +and +stated +this was most likely a typo in the agreement and the understanding was that +would receive $300,000 from +after five months. Interviewing +Agents flagged for +that the second page of Exhibit A seems to be a +copy of the same second page for Exhibit B. +will follow up with the +correct second page for the +Joint Venture Agreement.] +witnessed +sign the personal guarantee. +had Power of Attorney for +but +recall if she witnessed +sign for +on one occasion, when +was berating +during +first meeting with +told +did not +only saw +at +office +did not witness notarization of either the Joint Venture +Agreements or the Personal Guarantee but +told +that +a notary in the office. +had +At the time of +investment with +stated he owned +the Investment Properties. +I did not identify any other investors in the +Investment Properties or any mortgages or liens on the Investment +Properties. +relied on +representations and did not conduct +her own independent due diligence. +with her +$500,000 capital contribution via wire transfer from +account +held with Charles Schwab to the account +• identified in wire payment +instructions +sent +• via text message. +sourced the +$500,000 via a margin loan against her brokerage account at Charles Schwab. +As of the date of this interview, +has received only $30,000 + + +Continuation of FD-302 of 12, 2023 +on October +, On +10/12/2023 +, Page +5 of 5 +out of the $600,000 promised in the Joint Venture Agreements. Leading up to +the Joint Venture Agreements' investment maturity date +sent text +messages to +to ask about how and when she would receive her investment +back. +stalled in his response to +and "kicked the can down +the road." +was patient with +as she learned +father +had recently passed away. +Eventually +needed some money to help +pay her bills. +sent a $30,000 wire transfer to +bank +account with Chase Bank after the five-month investment maturity date came +and went and only after +specifically requested the partial +payment during a phone call from +to +engaged recently over social media with the social media +influencer known as TONY THE CLOSER. +discussed with TONY THE +CLOSER her investment with +and +failure to return +investment. Following that event | +• received several private +messages on Instagram from individuals identifying themselves as victims of +fraudulent investment scheme. +[Agent Note: +Instagram.] +will follow up with interviewing Agents, through +, regarding the identities of other victims who contacted her on +knew +received a settlement related to her involvement +with JEFFREY EPSTEIN. +is a "psychopath" who manipulated +with, amongst other things, promises of joining | +on a forthcoming +documentary with "50 Cent." \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/0a7b0925c8749c9b947ea15b2af76d40a251d66114257832961d3898f5ab0c27.receipt.json b/vision-fixhub/ds9-parsed-01/0a7b0925c8749c9b947ea15b2af76d40a251d66114257832961d3898f5ab0c27.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..427d98d40471c7ed5a74b761781ce2dc858e5bc9 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0a7b0925c8749c9b947ea15b2af76d40a251d66114257832961d3898f5ab0c27.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -281, + "dataset": "marble-joined", + "doc_id": "0a7b0925c8749c9b947ea15b2af76d40a251d66114257832961d3898f5ab0c27", + "engine": "marble-apple-vision", + "event_count": 6, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "8aeb7725960e892e737bded21cce8ab113ab9df29c0f21b66eae8fe8fcc476d8", + "output_sha256": "94add7ebcae94bfdac0039878771ebd31a80eb09ec719eefd7505bcfcd9a0867", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0a827e7a5deed0936ab6ef5f4140fab6e207ffa5719f3f8f058a1494cb9de16d.md b/vision-fixhub/ds9-parsed-01/0a827e7a5deed0936ab6ef5f4140fab6e207ffa5719f3f8f058a1494cb9de16d.md new file mode 100644 index 0000000000000000000000000000000000000000..afc2e08c6801f67ac875a94a7794a0958e72aab7 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0a827e7a5deed0936ab6ef5f4140fab6e207ffa5719f3f8f058a1494cb9de16d.md @@ -0,0 +1,121 @@ +U.S. Department of Justice +United States Attorney +Southern District of New York +The Silvio J. Mollo Building +Wee Saint, No To 10007 +August 16, 2019 +Experian Information Solutions, Inc. +701 Experian Parkway +Allen, TX 75013 +Attn: Subpoena Compliance Dept. +Re: +Grand Jury Subpoena +Please be advised that the accompanying grand jury subpoena has been issued in +connection with an official criminal investigation of a suspected felony being conducted by a +the eal strane orthe she Coena to ant hered yarest the you are under ering from to consin +with our request, we are requesting you not to make any disclosure in order to preserve the +confidentiality of the investigation and because disclosure of the existence of this investigation +might interfere with and impede the investigation. +Thank you for your cooperation in this matter. +Very truly yours, +GEOFFREY S. BERMAN +United States Attorney +By: +Assistant United States Attorney +Southern District of New York + + +Grand Jury Subpoena +United States District Court +SOUTHERN DISTRICT OF NEW YORK +TO: +Experian Information Solutions, Inc. +701 Experian Parkway +Allen, TX 75013 +Attn: Subpoena Compliance Dept. +GREETINGS: +WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend +before the GRAND JURY of the people of the United States for the Southern District of New York, at +the United States Courthouse, 40 Foley Square, Room 220, in the Borough of Manhattan, City of New +York, New York, in the Southern District of New York, at the following date, time and place: +Appearance Date: +August 30, 2019 +Appearance Time: 10 a.m. +to testify and give evidence in regard to alleged violations of federal criminal law, including: +18 U.S.C. §§ 1591, 1594(c), 2422(b), 371 +and not to depart the Grand Jury without leave thereof, or of the United States Attorney, and that you +bring with you and produce at the above time and place the following: +SEE ATTACHED RIDER. Personal appearance is not required if the requested records are (1) +produced by on or before the return date to Special Agent +Federal Bureau of +Investigation, 26 Federal Plaza, New York, NY 10278, telephone +and (2) accompanied by an executed copy of the attached Declaration of Custodian of Records. Please +contact Forensic Accountant +with any questions. +Failure to attend and produce any items hereby demanded will constitute contempt of court and will +subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law. +DATED: New York, New York +August 16, 2019 +GEOFFREY S. BERMAN +United States Attorney for the +Southern District of New York +Assistant United States Attorney +One St. Andrew's Plaza +New York, New York 10007 +Telephone: + + +(Grand Jury Subpoena 10 Experian, dated August 16, 2019) +Please provide any and all credit reports, fraud alerts, and related documents pertaining to the +Please utilize the identifiers below: +NAME +DOB +SSN +ADDRESS +PHONE +GHISLAINE MAXWELL +NAME +DOB +GHISLAINE MAXWELL +N.B.: Personal appearance is not required if the requested records are (1) produced by on or +before the return date to Special Agent Q +1 and (2) +accompanied by an executed copy of the attached Declaration of Custodian of Records. +PLEASE PROVIDE IN ELECTRONIC FORMAT IF POSSIBLE. +Please contact Forensic Accountant | +with any questions. +at +IMPORTANT: REQUEST FOR NON-DISCLOSURE +Due to the ongoing nature of the investigation, it is requested that you do not +disclose any information relating to this Grand Jury subpoena request to any third party. +3 + + +Declaration of Custodian of Records +Pursuant to 28 U.S.C. § 1746, I, the undersigned, hereby declare: +My name is +(name of declarant) +I am a United States citizen and I am over eighteen years of age. I am the custodian of +records of the business named below, or I am otherwise qualified as a result of my position with +the business named below to make this declaration. +I am in receipt of a Grand Jury Subpoena, dated August 16, 2019, and signed by Assistant +United States Attorney +requesting specified records of the business name +elow. Pursuant to Rules 902(11) and 803(6) of the Federal Rules of Evidence, I hereby certif +that the records provided herewith and in response to the Subpoena: +(1) were made at or near the time of the occurrence of the matters set forth in the records, +by, or from information transmitted by, a person with knowledge of those matters; +(2) were kept in the course of regularly conducted business activity; and +(3) were made by the regularly conducted business activity as a regular practice. +I declare under penalty of perjury that the foregoing is true and correct. +Executed on +(date) +(signature of declarant) +(name and title of declarant) +(name of business) +(business address) +Definitions of terms used above: +As defined in Fed. R. Evid. 803(6), "record" includes a memorandum, report, record, or data +compilation, in any form, of acts, events, conditions, opinions, or diagnoses. The term, "business" +as used in Fed. R. Evid. 803(6) and the above declaration includes business, institution, +association, profession, occupation, and calling of every kind, whether or not conducted for profit. diff --git a/vision-fixhub/ds9-parsed-01/0a827e7a5deed0936ab6ef5f4140fab6e207ffa5719f3f8f058a1494cb9de16d.receipt.json b/vision-fixhub/ds9-parsed-01/0a827e7a5deed0936ab6ef5f4140fab6e207ffa5719f3f8f058a1494cb9de16d.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..e0597892ed7968f637907ebb7bf5bc5f4ec34453 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0a827e7a5deed0936ab6ef5f4140fab6e207ffa5719f3f8f058a1494cb9de16d.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -48, + "dataset": "marble-joined", + "doc_id": "0a827e7a5deed0936ab6ef5f4140fab6e207ffa5719f3f8f058a1494cb9de16d", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "8d72209e668e6156cdd5987a75229357e937958cfea8d601a90e8e9e4fce9568", + "output_sha256": "f752e88790610ad6242bc1a120f1acde0b9cba53242f0ae621003b2a4849bf23", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0a9410ef2d0874775fe830f4d9adc500ff28334aeaa5430077e5bb1c2f1530df.md b/vision-fixhub/ds9-parsed-01/0a9410ef2d0874775fe830f4d9adc500ff28334aeaa5430077e5bb1c2f1530df.md new file mode 100644 index 0000000000000000000000000000000000000000..953750a7c65aa12da8adb66dadcbc7126e9f35cc --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0a9410ef2d0874775fe830f4d9adc500ff28334aeaa5430077e5bb1c2f1530df.md @@ -0,0 +1,26 @@ +From: +Sent: +To: +Subject: +2/25/2014 11:35:35 AM +Classification: Public +Saam, +Plan D LLC is owned by our client Jeffrey Epstein. Jeffrey Epstein is worth roughly $1B and currently has about $230MM +here at the bank and we are expecting at least another $100MM from him within the next few months. Jeffrey is trying to +send a $250,000 payment to Insured Aircraft Title Services for one of his many planes. I would ask that this go through +because he is a very important client. Not only is he extremely wealthy but he has been introducing our team (Paul Morris +is the private banker) to other billion dollar clients. We are currently in the process of opening a number of accounts for a +multi billionaire who Jeffrey introduced us to. Jeffrey manages a number of our prospects portfolios and if he were to find +that our services were unable to meet his needs we would see the majority of our prospects walk away. He currently has +introduced us to at least 4 different potential clients who would each deposit more than $250MM with the bank (a total of +more than $1B). It is very important that he remains with the bank and that he views DB as being able to handle all of his +Kind regards, +Amanda Kirby +Amanda Kirby +Associate +Deutsche Bank Trust Company Americas +Deutsche Asset A Wealth Manacement +Passion to Perform +Securities offered through Deutsche Bank Securities Inc. +CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) +DB-SDNY-0131011 diff --git a/vision-fixhub/ds9-parsed-01/0a9410ef2d0874775fe830f4d9adc500ff28334aeaa5430077e5bb1c2f1530df.receipt.json b/vision-fixhub/ds9-parsed-01/0a9410ef2d0874775fe830f4d9adc500ff28334aeaa5430077e5bb1c2f1530df.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..41ac32282c0a664242d063cc67e6b02b6d7f7071 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0a9410ef2d0874775fe830f4d9adc500ff28334aeaa5430077e5bb1c2f1530df.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "0a9410ef2d0874775fe830f4d9adc500ff28334aeaa5430077e5bb1c2f1530df", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "17d05a37537fccd95db138eb584f6b1143d3a161a326b3edfe3cc185cfcfc593", + "output_sha256": "7c4af19e614909ce6808f95b33d1029883a3ebf6ada6bcc903311559c9383350", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0a96293dba93dcc559898d2938ec4c5934c7b9cc2d5eaf5402eb5f4f53035d54.md b/vision-fixhub/ds9-parsed-01/0a96293dba93dcc559898d2938ec4c5934c7b9cc2d5eaf5402eb5f4f53035d54.md new file mode 100644 index 0000000000000000000000000000000000000000..d07fc1682ae8e457cd2823ad29035d0f4e7787e3 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0a96293dba93dcc559898d2938ec4c5934c7b9cc2d5eaf5402eb5f4f53035d54.md @@ -0,0 +1,813 @@ + + + +IN THE MATTER OF AN OPINION +ON THE EXTRADITION LAW OF ENGLAND AND WALES +RE GHISLAINE MAXWELL +Overview +1. This Opinion is provided pursuant to instructions from Peters and Peters Solicitors LLP' dated 12 +August 2020 in the context of bail proceedings relating to Ms Ghislaine Maxwell before the United +States District Court, Southern District of New York. Subsequent instructions have confirmed that Ms +Maxwell will execute a waiver of her right to extradition that could be exhibited to a future extradition +request made by the United States and relied upon in any extradition proceedings. The specific +questions asked by Peters and Peters are attached at Annex A. A summary of counsel's relevant +experience is attached at Annex B. The waiver is attached at Annex C. +2. In summary: +(a) Extradition proceedings in the United Kingdom are governed by the Extradition Act 2003 +('the 2003 Act') and, in general, comprise; (i) a hearing before a designated appropriate +judge' (the extradition hearing); and (ii) an appeal, subject to a leave requirement. +(b) In proceedings under the 2003 Act, a requested person may consent to their extradition +which has the effect of removing the need for an extradition hearing and waiving the +person's statutory appeal rights. +(c) In the majority of cases, proceedings in England and Wales in relation to US extradition +requests are concluded in under two years?. The process is significantly shorter if the +requested person consents to their extradition and in those cases the timescales are +approximately between one and three months. +(d) It is extremely unlikely that bail would be granted in an extradition case in circumstances +where the requested person had absconded from criminal proceedings in the United States +prior to trial and in breach of bail. +' The following documents were annexed to the instructions: (a) Superseding Indictment, United States v Ghislaine +2 There is no data as to the duration of extradition proceedings in Northern Ireland and Scotland but it may be inferred +that the timescales are similar. + + +(e) On the basis of the information currently known, it is highly unlikely that Ghislaine +Maxwell would be able successfully to resist extradition to the United States in relation to +the charges in the superseding indietment dated 7 July 2020. +1222623.1 + + +A. Extradition arrangements between the United Kingdom and the United States +The extradition arrangements +3. Extradition relations between the United Kingdom and the United States of America are governed by +an extradition treaty signed on 31 March 2003°, which is given effect in the domestic law of the +United Kingdom" by the 2003 Act. +Overview of the extradition process +4. The United States of America has been designated as a 'Part 2 territory' (also referred to as a +"Category 2 territory') for the purposes of the 2003 Act®. The effect of this designation is that +extradition requests from the United States fall to be considered under Part 2 of the 2003 Act", and the +United States is exempted from the requirement to provide evidence sufficient to make a case to +answer against the requested person ('the prima facie case requirement")* +5. Once a valid request for extradition is made by a Part 2 territory, the Secretary of State must, subject +to very limited exceptions' not applicable here, issue a certificate under section 70. Once a certificate +is issued, the Secretary of State must send the request and certificate to the appropriate judge. In +practice, it is extremely rare for the Secretary of State to refuse to issue a certificate under section 70. +6. Under Part 2 of the 2003 Act, a requested person may be arrested pursuant to either a full extradition +request", or a provisional request pending the service of a full extradition request'?. In both cases, +there is an 'initial hearing' at which the requested person is produced before 'the appropriate judge'"3 +3 Extradition Treaty between the Government of the United States of America and the Government of the United +Kingdom of Great Britain and Northern Ireland, signed 31 March 2003 and ratified on 26 April 2007 +* The Extradition Act 2003 governs extradition to and from the United Kingdom. The Act applies in the three +jurisdictions within the United Kingdom: (a) England and Wales; (b) Scotland; and (c) Northern Ireland. There are +limited regional variations of which the only one of relevance to this Opinion is that the forum bar in s. 83A of the 2003 +Act (see para. [34] below) is not yet in force in Scotland. +§ Extradition Act 2003, c.41, given Royal Assent on 20 November 2003. +° Extradition Act 2003 (Designation of Part 2 Territories) Order 2003/3334, Art. 2. +' Extradition Act 2003, s. 69. +" Extradition Act 2003, ss. 84(7) and 86(7). +' The conditions governing whether a request is valid are in ss. 70(3)-(4A) and (7) of the 2003 Act. +' These relate to cases where: (a) there is a competing extradition request from another state (ss. 70(2)(a) and 126); and +(b) the requested person has been granted refugee status or humanitarian protection in the UK (s. 70(2)(b) and (c)). +' Extradition Act 2003, s. 71. +12 Extradition Act 2003, s. 73. +13 As defined in s. 139 of the Extradition Act 2003. +192223.1 + + +who must consider, amongst other things, whether to remand the person in custody or on bail'". In +cases where the person appears before the court pursuant to a full extradition request, the judge must +set a date for the extradition hearing to begin'. In provisional arrest cases, this date is set after the full +request is served which, in US extradition cases, must be within 65 days of arrest!. +7. At the extradition hearing, the appropriate judge must decide: (a) whether the extradition request +meets certain technical requirements'; (b) whether the person appearing before the judge is the +person whose extradition is requested'"; (c) whether the offence(s) specified in the extradition request +are extradition offence(s)'; (d) whether there are any bars to extradition?"; (e) whether extradition +would be compatible with the person's rights under the European Convention on Human Rights +(ECHR') within the meaning of the Human Rights Act 1998?; and, where applicable, (f) whether +extradition would be oppressive by reason of the person's mental or physical condition? +8. If the appropriate judge decides all the statutory questions in favour of the requesting government, +then they must send the case to the Secretary of State" who must decide whether any of the bars to +extradition that she must consider apply. These bars are different to those considered by the +appropriate judge. The Secretary of State has no power to consider any human rights objections to +extradition?. +. If she decides that no bars apply, she must order the person's extradition,* subject to +very limited exceptions which are not applicable here? +1 Extradition Act 2003, ss. 72(7)(c) and 74(7)(c). +15 Extradition Act 2003, s. 75. +I* Extradition Act 2003, s. 74(11)(b) and Extradition Act 2003 (Designation of Part 2 Territories) Order 2003/3334, Art. +" Extradition Act 2003, s. 78(2). The request must contain: (a) the documents specified in s. 70(9) (the extradition +request and the Secretary of State's certificate); (b) particulars of the offence(s) specified in the request; (c) an arrest +warrant or a certificate of conviction and, where applicable, sentence. The judge must also decide whether the relevant +documentation has been served on the requested person: s. 87(4)(c). +I Extradition Act 2003, s. 78(4)(a). +19 Extradition Act 2003, s. 78(4)(b). +20 The bars to extradition are: (a) the rule against double jeopardy (s. 80); (b) extraneous considerations (s. 81); (c) +passage of time (s. 82); (d) hostage-taking considerations (s. 83); and (e) forum (s. 83A). The bars to extradition are +considered further at paras. 26 to 35 below. +'' Section 87. The rights under the ECHR apply to every person within the jurisdiction of the United Kingdom: ECHR, +Art. 1. +22 Extradition Act 2003, s. 91. +2 Extradition Act 2003, s. 87(3). +The bars to extradition that the Secretary of State must consider are: (a) the death penalty (s. 94); (b) speciality (s. 95); +(c) earlier extradition to the United Kingdom from another territory (s. 96); and (d) earlier transfer to the United +Kingdom from the International Criminal Court (s. 96A). +25 Extradition Act 2003, s. 70(11). +4 + + +9. A requested person may appeal the decision of the appropriate judge to send the case to the Secretary +of State, the decision of the Secretary of State to order extradition, or both?* +, except in consent cases +where the person is deemed to have waived their rights of appeal?. Where the requested person is +discharged at the extradition hearing or by the Secretary of State, the requesting government may +appeal the decision to discharge°. Extradition appeals are heard by the High Court. An appeal may be +brought on a question of law or fact and may not be brought unless the court grants leave to appeal +which requires the Appellant to establish that there is a reasonably arguable ground of appeal". +10. Either party may appeal a decision of the High Court to the Supreme Court, but only where the High +Court has certified that the decision involves a point of law of general public importance, and either +the High Court or the Supreme Court concludes that the point is one that ought to be considered by the +Supreme Court"?. Where leave is granted, the Supreme Court may either grant the appeal, or dismiss +it" +. In practice, such appeals are extremely rare; in the past ten years, only one US extradition case +has been considered by the Supreme Court. +11. In some cases, a requested person may apply to the European Court of Human Rights and seek an +injunction to prevent the extradition from taking place until the application is determined". Such +applications, which must be based on an alleged violation of a right under the ECHR", are also very +rare. +2* Extradition Act 2003, s. 93(4). +27 The exceptions are: (a) that the Secretary of State is informed that the request has been withdrawn (s. 93(4)(a)); (b) +here is a competing claim for extradition from another state (ss. 93(4)(b), 126(2) and 179(2)); (c) the person has bee +ranted asylum or humanitarian protection in the United Kingdom (s. 93(4)(c) and 6(A)); or (d) extradition would b +against the interests of UK national security (s. 208). +2* Extradition Act 2003, ss.103 and 108. +29 Extradition Act 2003, ss. 103(2) and 108(2). +3' Extradition Act 2003, ss. 105 and 110. +"' Extradition Act 2003, ss. 103(4), 105(4), 108(3) and 110(4) and Criminal Procedure Rules ('CrimPR'), r. 50.17(4)(b). +32 Extradition Act 2003, s. 114(4). +33 Extradition Act 2003, s. 115(1). +3* Norris v Government of the United States of America [2010] 2 AC 487. +35 ECHR, Art. 34 and European Court of Human Rights, Rules of the Court, r. 39. +3* ECHR, Art. 34. + + + +An overview of the timeframes in relation to US extradition requests +12. The timescales applicable to extradition proceedings are defined by statute and are set out in Annex D, +along with the circumstances in which the time-limits can be extended. +13. There are few publicly available figures with respect to the timescales in Part 2 extradition cases in +general, and none with respect to US extradition cases. In July 2013, the UK Government estimated that, +on average, Part 2 extradition cases took approximately 10 months to conclude". In practice, contested +US extradition cases can take longer than 10 months, although the majority conclude within two years. +14. These timescales are significantly reduced in cases such as this one where the requested person consents +to his or her extradition at an early stage in the process. In those cases, extradition would be likely to take +place within three months. +B. Consent to extradition +15. At the initial hearing where a requested person is first produced before the court, the appropriate judge is +required to give them "the required information about consent"38. This information is: (a) that the person +may consent to extradition; (b) an explanation of the effect of consent and the procedure that will apply if +consent is given; and (c) that consent must be given in writing and is irrevocable?. +16. Where consent is given before the case has been sent to the Secretary of State, it must be given at a +hearing before the appropriate judge" +". Once the case has been sent to the Secretary of State, consent must +be given to the Secretary of State". +17. Where consent is given before the case is sent to the Secretary of State, the consequences are as follows: +(a) If the appropriate judge has not fixed a date for the extradition hearing, they are not required to do +so*; +(b) If the extradition hearing has begun, the appropriate judge is no longer required to proceed with +it*; +3 HM Government, Decision pursuant to Article 10 of Protocol 36 to the Treaty on the Functioning of the European +Union, July 2013, Cm 8671, page 94. +38 Extradition Act 2003, ss. 72(7)(b) and 74(7)(b). +3ª Extradition Act 2003, ss. 72(8) and 74(8). +4'' Extradition Act 2003, s. 127(4), (б)-(7). +*' Extradition Act 2003, s.127(5). +12 Extradition Act 2003, s. 128(2). +13 Extradition Act 2003, s. 128(3). +6 + + +(c) The appropriate judge is required to send the case to the Secretary of State*; +(d) The speciality bar to extradition no longer applies"s. +18. In all extradition cases, a requested person who consents to extradition loses the right to appeal against +either the decision to send the case to the Secretary of State or the order for extradition". +19. The main effect of a decision by a requested person to consent to extradition is that the overall extradition +procedure is substantially shortened. In the context of US extradition cases, this means that removal can +take place within months, sometimes weeks, as compared to the longer timescales considered above. +C. Bail in extradition cases +20. Where extradition is sought for the purpose of prosecuting the requested person for an offence, the person +has the same right to bail as a defendant in domestic criminal proceedings, namely there is a presumption +that bail will be granted unless one of the exceptions in Schedule I to the Bail Act 1976 applies". The +three exceptions in Schedule 1 that most commonly apply in extradition proceedings are where there are +substantial grounds to believe that the requested person, if released on bail, would: (a) fail to surrender to +custody; (b) commit an offence while on bail; or (c) interfere with witnesses or otherwise obstruct the +course of justice**. +21. In considering whether to grant bail in an extradition case, the appropriate judge must have regard to as +many of the statutory considerations as appear to be relevant. +• Those considerations are: (a) the nature +and seriousness of the offence and the likely sentence; (b) the character, antecedents, associations and +community ties of the requested person; (c) the requested person's record as respects the fulfilment of +their obligations under previous grants of bail in criminal proceedings; (d) the strength of the evidence +against the requested person; and (e) any risk that the requested person may cause physical to mental +injury to another person. +22. The approach taken by the High Court in a number of recent US bail appeals gives an indication as to the +way in which the statutory considerations are approached in practice. In all five cases bail was refused"°. +# Extradition Act 2003, s. 128(4). +1S Extradition Act 2003, s.95(2). The principle of specialty is a rule of extradition law that is intended to ensure that an +extradited person is not dealt with in the requesting state for any offence other than that for which they have been +extradited. +4" Extradition Act 2003, ss. 100(2), 103(2) and 108(2). +* Bail Act 1976, s. 4(2A). There is no presumption of bail where extradition is sought in a conviction case: s. 4(2B). +4 Bail Act 1976, Schedule 1, para. 2(1). +49 Bail Act 1976, Schedule 1, para. 9. +S"' Adeagbo v Government of the United States of America, 5 August 2020 (unreported) (wire fraud, money laundering +and identity theft); Singh y Government of the United States of America [2019] EWHC 1800 (Admin) (drug trafficking); + + +In three of the five cases the applicant was either a British citizen or had significant community and +family ties to the UKS' but these were outweighed by the risk of flight, and in the other case, the lack of +substantial community ties was cited as a factor in refusing bail? +23. As to the question in Peters and Peters' instructions, namely whether a person who absconded from US +criminal proceeding in breach of bail would be likely to be granted bail in any subsequent UK extradition +proceedings, such a person is extremely unlikely to be granted bail. While every bail application falls to +be considered by reference to all the circumstances that are relevant at the time that the application is +made, in practice evidence of both a clear desire to evade prosecution for the offences in the extradition +request, and a previous history of failure to comply with bail conditions, would militate strongly against +the grant of bail in almost all factual circumstances. +D. The bars to extradition that may conceivably be open to Ms Maxwell should she face extradition to +the US in relation to the charges on the superseding indietment dated 7 August 2020 +24. The offences in the superseding indictment are extradition offences within the meaning of section 137 +of the Extradition Act 2003" +25. On the basis of the information available, there does not appear to be any arguable basis upon which +the bars of double jeopardy""; hostage-taking considerations"; death penalty"; speciality"; or earlier +extradition or transfer could be engaged"" +26. On the information available, the remaining bars - abuse of process/political motivation; passage of +time; forum; and mental and physical condition - would almost certainly fail in this case. +" Abdullah; Panovas; Perry; and Adeagbo. +52 Singh. +53 Had the conduct alleged occurred in the United Kingdom it would have amounted offences that include: (a) conspiracy +to commit indecent assault contrary to section 1 of the Criminal Law Act 1967; (b) aiding and abetting or inciting +indecent assault contrary to common law; (c) indecent assault contrary to section 14 of the Sexual Offences Act 1957; +and (d) perjury contrary to section 1 of the Perjury Act 1911. +5 Extradition Act 2003, s. 80. This bar is engaged "if (and only if it appears that the person] would be entitled to be +discharged under any rule of law relating to previous acquittal or conviction if he were charged with the extradition +offence in the part of the United Kingdom where the judge exercises his jurisdiction". +55 Extradition Act 2003, s. 83. One of the requirements of this bar is that the act or omission constituting the extradition +offence also constitutes an offence under s. I of the Taking of Hostages Act 1982 which prohibits the taking of hostages +in the context of international terrorism. +5* Extradition Act 2003, s. 94. +5' Extradition Act 2003, s. 95. See fn 46 above for a definition of 'specialty'. +5" Extradition Act 2003, ss. 96 and 96A. +8 + + +Abuse of process/political motivation +27. Extradition requests are rarely discharged on the basis that the case in the requesting state is politically +motivated or abusive. It is well established that there is a presumption of good faith in relation to a +requesting state, such as the US, which has a long history of respect for democracy, human rights and +the rule of law, and which has longstanding extradition arrangements with the United Kingdom'. +28. It is highly unlikely that Ms. Maxwell would be able to establish that the US prosecutor had acted in +bad faith, for example by seeking her extradition for a collateral motive in circumstances where they +knew there was no real case against herd. +29. It is also highly unlikely that Ms Maxwell would be able to establish that her extradition was sought +for the purpose of prosecuting or punishing her on account of her political opinions, or that she might +be prejudiced at her trial or punished, detained or restricted in her personal liberty by reason of those +opinions"!. +Passage of time +30. Notwithstanding the date of the allegations in the superseding indictment, a judge is unlikely to +conclude that it would be unjust or oppressive to extradite Ms Maxwell by reason of the passage of +time since the alleged commission of the offences". The courts have upheld orders for extradition in +cases with similar timescales to those in Ms Maxwell's case, including two cases involving historic +allegations of sexual offending where the relevant time period was 20 and 33 years. In both cases, the +courts placed emphasis on the public interest in ensuring that extradition arrangements were honoured +and in ensuring that serious allegations were tried 3. +31. As to oppression, the graver the offence the higher the threshold for oppression". Given the +seriousness of the offences in Ms Maxwell's case, it is unlikely that she would be able to establish that +any personal or family hardship that might be caused by the extradition"" should outweigh the public +5ª 1hmad v United Kingdom (2010) 51 EHRR SE6, para. 105. +'"' R (Bermingham) v Director of the Serious Fraud Office [2007] QB 727, para. 100. +" Extradition Act 2003, s. 81. +6 Extradition Act 2003, s. 82. The date range for the offences in the superseding indictment is 1994-1997. +63 Short v Falkland Islands [2020] 1 WLR 1644, paras. 41-49 and Henderson v Government of Australia [2015] EWHC +1421 (Admin), paras. 19-26. +6 Kakis v Government of the Republic of Cyprus [1978] 1 WLR 779 at 784. +65 Oppression requires personal or family hardship greater than that inevitably inherent in the act of extradition when +facing what is likely to be long criminal trial process in another country Gomes y Government of Trinidad and Tobago +[2009] 1 WLR 1038, para. 36; Norris v Government of United States of America [2007] 1 WLR 1730. + + +interest in these offences being tried a +". Similarly, there is a high threshold in relation to injustice*? +and it is very unlikely that Ms Maxwell would be able to meet it. There is a general presumption that +justice will be done despite the passage of time and the burden is on the requested person to establish +the contrary. In assessing injustice, the appropriate judge would have regard to the procedural +safeguards that exist under US domestic law®. Further, the judge is very likely to place weight on the +fact that Ms Maxwell had, in the hypothetical scenario under consideration, absconded from ongoing +proceedings that would otherwise have resulted in her trial in the US. As the English High Court +expressed it in Tollman "the very fact that the accused invokes justice to prevent [their] extradition +requires consideration of the circumstances which have led to the fact that [they are] not facing +justice in the country from which [they have] fled "7. +. In those circumstances it is very unlikely that +Ms Maxwell would be able to rely on the bar of passage of time to defeat extradition. +Forum +32. It is highly unlikely that Ms Maxwell would be able to rely on the bar of forum, which applies where +extradition would not be in the interests of justice because: (a) a substantial measure of the requested +person's "relevant activity'" occurred in the UK; and (b) having regard to 'the specified matters'72 +relating to the interests of justice (and only those matters), the extradition should not take place?. +33. Although some of the conduct alleged in the superseding indictment is said to have occurred in +London* +, three of the 'specified matters' are likely to weigh heavily against a finding that extradition +would be barred by forum. First, it appears that the majority of the harm caused by the offending? +alleged in the superseding indictment occurred in the United States. An extradition judge would treat +6* Kakis at 784. Although the passage of time bar was successfully relied on in the US extradition case of Eason V +Government of the United States of America [2020] EWHC 604 (Admin) +the case-law is clear that a fact-specific +enquiry is required, and that authorities are of "very limited value" when considering the facts of individual cases: +Steblins v Government of Latvia [2006] EWHC 1272 (Admin), para. 13. +6 Gomes, para. 36 and Lisowski-v-Regional Court of Bialystock (Poland) [2006] EWHC 3227 (Admin), para. 9. +6 Gomes, para. 36. +69 Woodcock v Government of New Zealand [2004] 1 WLR 47, para. 29; Gomes, para. 32; Linkevicius v Prosecutor +General's Office of the Republic of Lithuania [2006] EWHC 3481 (Admin) at para. 17; and Crean v Government of +Ireland [2007] EWHC 814 (Admin) at para. 21; Henderson, paras. 19-26. +'' Government of the United States of America v Tollman [2008] EWHC 184 (Admin), para. 53. +" 'Relevant activity' means activity which is material to the commission of the extradition offence and is alleged to have +been performed by the requested person: Extradition Act 2003, s. 83A(6). +" As defined in s. 83A(3) of the Extradition Act 2003. +73 Extradition Act 2003, s. 83A(1) and (2). +1ª Superseding indictment dated 7 August 2020, para. 6. +15 Extradition Act 2003, s. 83A(3)(a). +10 + + +this as a weighty factor? +. Second, a court would be likely to consider that the interests of the +victims" would be best served by a trial in the United States. The High Court has held that the +interests of victims™* "will be in having a trial at a place where, if they do give evidence or wish to be +present, they can be so" "9. Third, Ms Maxwell's connections to the UK"° do not appear to be of a +type likely to be considered substantial in this context. +Mental and physical condition +34. It is highly unlikely that Ms Maxwell would be able to establish that her physical or mental condition +is such that it would be unjust or oppressive to extradite her*!. In order to rely on her physical or +mental health in opposition to extradition, Ms Maxwell would need to serve evidence sufficient to +meet the statutory test. Most cases in the unjust' category relate to the persons' fitness to plead to +otherwise to participate in trial proceedings. Oppression is a high threshold, not easily surmountable* +and stress and hardship, which occur in most extradition cases, are not sufficient". Even in cases +where the requested person suffers from a serious medical conditions, it is often possible for the +requesting state gives an assurance as to the medical care that will be provided* +, or an undertaking to +return an individual if they are later found to be unfit to plead", and thus ensure that extradition is +possible notwithstanding the requested person's medical problems. +* Love v United States [2018] 1 WLR 2889, para. 28. +" Extradition Act 2003, s. 83A(3)(a). +'® Extradition Act 2003, s. 83A(3)(a). +→ i he ned aty 120, 0 VICe 654 As mad paragemen in person be and ier pro read tate it rene. +was read to the court by the prosecutor: United States of America v Ghislaine Maxwell, Transcript of hearing, 14 July +2020, pp. 38-40. +8º Extradition Act 2003, s. 83A(3)(g). +" Extradition Act 2003, s. 91. +" Love v Government of the United States, para. 122. +$ Dewani v Govenrment of South Africa [2012] EWHC 842 (Admin), para. 73. +8 Miao v Government of the United States of America [2020] EWHC 2178 (Admin), para. 37. +8 Dewani. +11 + + +E. The human rights objections that may conceivably be open to Ms Maxwell should she face +extradition to the US in relation to the charges on the superseding indictment dated 7 August 2020 +35. Finally, it is highly unlikely that Ms Maxwell would be able to demonstrate that her extradition would +be incompatible with her rights under the ECHR*. The human rights grounds that might potentially +be relied upon by Ms Maxwell are considered in the paragraphs that follow*?. +Article 3 (prison conditions) +36. Article 3 protects the right not to be subject to torture or inhuman or degrading treatment. The test is +whether substantial grounds have been shown that, if extradited, the person faces a "real risk" of +treatment contrary to Article 3*. The test is a stringent one and a strong case is required to make +good a violation of Article 3*9. +• Mistreatment must attain a minimum level of severity before Article 3 +is engaged. Prison conditions can meet that test although, whether they do, depends on all the +circumstances, including the personal characteristics of the detainee. Although Article 3 complaints +based on prison conditions are not uncommon in US cases, the courts have repeatedly rejected such +submissions"' 92. Further, even if there were to be a case where the systemic conditions at one or more +US detention facilities were found to give rise to a serious risk that Article 3 would be breached by +extradition, such difficulties are capable of being surmounted by the provision of assurances that the +requested person will not be detained in those particular prisons, or by giving guarantees in relation to +8* Extradition Act 2003, s. 87. +8 There does not appear to be any basis upon which it could be said that the following rights are engaged: (a) Art. 2 (the +right to life); (b) Art. 4 (freedom from slavery); (c) Art. 5 (unlawful detention); Art. 7 (no punishment without law); Art. +9 (freedom of thought, conscience and religion); Art. 10 (freedom of speech); Art. 11 (freedom of assembly); Art. 12 (the +right to marry); Art. 14 (discrimination); Arts. 1-3 of the First Protocol (protection of property; right to education; right to +free elections); and Art. 1 of the Thirteenth Protocol (abolition of the death penalty). +$" Soering v United Kingdom (1989) 11 EHRR 439, paras. 88 and 91. +89 Elashmawy v Court of Brescia, Italy and Ors [2015] EWHC 28 (Admin), para. 49. +9' Ireland v United Kingdom (1979-80) 2 EHRR 25, para. 162. +" Including: Ahmad v United Kingdom (2013) 56 EHRR 1, paras. 207-210; Pham v Government of the United States of +America [2014] EWHC 4167 (Admin), paras. 44-51; Bedwell v Government of the United States [2019] EWHC 3131 +(Admin), para. 36; Dempsey, paras. 35-50; Sanchez v Government of the United States of America [2020] EWHC 508 +(Admin); and Miao, para. 41. +92 The conditions at the New York detention facilities, MDC and MCC were a factor in the court's conclusion in Love +(see fn 76 above) that extradition would be oppressive in light of Mr Love's "rather particular circumstances" which +included a serious health condition (paras 102 and 106-108). The decision in Love was based on section 91 of the 2003 +Act, and the court made no finding under Article 3 (para 123). In Hafeez, which was decided in January 2020, the High +Court received the same evidence as has been before the court in Love, and concluded that "the evidence in this case falls +well short of the necessary threshold" to prove a breach of Article 3 based on the conditions at MDC and MCC (see +Hafeez v Government of the United States of America [2020] EWHC 155 (Admin), para. 66). +12 + + +specific concerns, such as access to medical care"3 +. In those circumstances, it is highly unlikely that +Ms Maxwell would be able to rely on Article 3 to defeat a request for her extradition. +Article 6 (fair trial) +37. Article 6 ECHR protects the right to a fair trial, and the European Court of Human Rights has noted +that Article 6 is "strikingly similar" to the Eighth Amendment to the US Constitution". An issue may +exceptionally be raised under Article 6 in an extradition case in circumstances where the requested +person risks suffering a flagrant denial of justice in the requesting country". +. The test of 'flagrant +denial' is particularly high, requiring a court to find not only that the trial would be unfair, but that +there would be "a total nullification of the right to a fair trial"* In practice, this threshold is rarely +overcome in extradition cases and it has never been met in a US extradition case. In those +circumstances, it is highly unlikely that Ms Maxwell would be able to successfully invoke Article 6 to +resist her extradition. +Article 8 (private and family life) +38. Article 8 ECHR protects the right to private and family life. In assessing Article 8, the court is +required to conduct a balancing exercise where factors in favour of extradition, including the +"constant and weighty" public interests in honouring extradition treaties and ensuring that people +accused of crimes should be brought to trial, are weighed against any personal or other factors that +would render extradition an interreference with private or family life. The test is whether any +interference would be disproportionate to the legitimate aims pursued by extradition". In practice, the +more serious the offence, the more difficult it is to establish that extradition would be +disproportionate. Given the nature of the charges that she faces, it is highly unlikely that such an +argument would succeed in Ms Maxwell's case. +Conclusion +39. In conclusion, if the United States were to request Ms Maxwell's extradition in circumstances where +she had absconded to the United Kingdom in breach of bail conditions imposed in the United States, it +is extremely unlikely that she would be granted bail and highly unlikely that she would be able +' See, for example, Miao at para. 37 where the court stated that: "Assurances are commonly given in extradition cases in +order to mitigate risks which might otherwise bar extradition. It is common for assurances to be given in respect of +conditions of detention and the treatment of physical and mental illness (and associated suicide prevention) and they +form an important part of extradition law". +94 Ahmad v United Kingdom 51 EHRR SE6, para. 133. +95 Othman v United Kingdom (2012) 55 EHRR 1, para. 258. +** Othman, para. 260. +" R (on the application of HH) v Westminster City Magistrates' Court [2013] 1 AC 338, para. 30. +13 + + +successfully to resist the request for her extradition. Further, the waiver of her right to extradition +(Annex C) would be admissible in any extradition proceedings and, in cases, such as this one, where +the requested person consents to their extradition, the extradition process is likely to take between one +and three months to complete. +David Perry QC +6KBW College Hill +8 October 2020 +14 + + +Annex A + + +Annex A - Questions set out in the Peters and Peters instructions dated 12 August 2020 +Counsel is instructed to prepare an expert opinion in respect of the following: +(a) Outline the extradition arrangements between the United Kingdom and the United +States, including an overview of the general manner in which the arrangements work +and the general timeframe for UK extradition proceedings in relation to requests from +the US. Address any means by which UK extradition proceedings may be expedited. +(b) Describe the manner in which a requested person may consent to extradition (at all +stages of the extradition process), and the impact of any such consent on the process +by which the requested person may be subsequently removed. +(c) Outline the arrangements in respect of bail pending extradition, and whether a +requested person is likely to be remanded on bail pending the hearing of an extradition +request by the US, and any subsequent removal of that person from the UK. In a case +where a person, subject to prosecution in US criminal proceedings, flees to the UK in +breach of bail conditions imposed by a US court, outline the likelihood of that person +being remanded on bail in the UK pending the hearing of the extradition request, and +their subsequent removal from the UK. +(d) Outline the bars to extradition, and identify those which might, based on current +instructions, be conceivably open to Ms Maxwell were she to be arrested in the UK +and subject to UK extradition proceedings pursuant to a request from the US, such as +passage of time (section 82), forum (section 83A) and physical or mental condition +(section 91). Address, in general terms, the prospects of Ms Maxwell successfully +availing herself of any such bars, given the current approach in UK extradition caselaw and the general thresholds required. +(e) Outline the nature of the obligation for any extradition to be compatible with the +requested person's human rights (section 87) and identify those arguments that might +conceivably be open to Ms Maxwell in any future extradition proceedings, such as +Article 3 and Article 6. Address, in general terms, the prospects of Ms Maxwell +successfully availing herself of any such bars, given the current approach in UK +extradition case-law and the general thresholds required. + + +Annex B + + +Annex B - CV of David Perry QC +1. David Perry QC +1.1. David Perry QC is a barrister and former head of chambers at 6KBW College Hill. From +1991 to 1997, he was one of the Standing Counsel to the Department of Trade and +Industry. From 1997 to 2001, he was Junior Treasury Counsel to the Crown at the Central +Criminal Court and Senior Treasury Counsel from 2001 until 2006, when he 'took silk' +(i.e. was appointed Queen's Counsel). He is a deputy High Court Judge and a judge of +the Court of Appeal of Jersey and Guernsey. +1.2. Mr Perry prosecutes and defends and has extensive experience of extradition and mutual +legal assistance cases, both in the United Kingdom and overseas. He is a member of the +Editorial Board of the Criminal Law Review and a joint editor of Blackstone's Criminal +Practice, a leading practitioners' work. +2. Extradition - Experience and Expertise +2.1. Mr Perry is widely considered one of the UK's pre-eminent extradition practitioners and +is listed as such in the leading industry journals. He has acted on behalf of many overseas +governments and appeared in the High Court, House of Lords and Supreme Court in the +leading cases. He has acted as an expert consultant to the Commonwealth Secretariat on +international co-operation and has advised overseas governments on the drafting and +implementation of their domestic legislation. +3. Independent review of the United Kingdom's extradition arrangements +3.1. In 2011/12, together with Lord Justice Scott Baker and Anand Doobay, Mr Perry was +appointed by the UK Government to conduct the Home Office's Independent Review of +the UK's extradition arrangements. The review formed the basis of changes to the +Extradition Act 2003. +3.2. The year-long review looked in detail at the following five areas: +• +the Home Secretary's discretionary powers to stop extradition. +the operation of the European Arrest Warrant, which deals with extradition +requests between European countries. +where a crime is mainly committed in the UK, whether the person should be tried +in the UK. +whether the US-UK Extradition Treaty is unbalanced. +whether requesting countries should be required to provide sufficient evidence to +prove an allegation. +3.3. The report, totalling 488 pages and presented to the Home Secretary on 30 September +2011, made a series of recommendations in respect of the UK's extradition arrangements. +Part 7 of the report looked specifically at extradition arrangements between the United +States and United Kingdom under the 2003 UK-US Treaty on Extradition. It assessed the +effectiveness of the tests used in each jurisdiction and laid out the authors' observations +on the procedures under the treaty. Their conclusion was that the 2003 treaty was +operating fairly and there was no basis to seek its renegotiation. + + +4. Practical Experience +4.1. Mr Perry has acted for governments and individuals in the most important and highprofile extradition matters, including extradition requests between the United Kingdom +and the United States: +USA v Mackellar: Acted on behalf of the Governor of the Cayman Islands in +extradition proceedings brought on behalf of the Government of the United States. +USA v Brian Dempsey [2020] EWHC 603 (Admin): Appeared for the Government +of the United States in relation to an extradition request for an individual who had +travelled to Syria as part of the on-going conflict. +• +Russia v Alexander Zmikhnovskiy Westminster Magistrates Court, 15 April 2019 +(unreported): Extradition request of former CEO of Oboronenergosbyt JSC, who +was alleged to have been involved in fraud by the Russian Federation, his +extradition was refused on several grounds. +• +Russia v Yurov, Westminster Magistrates Court, 28 September 2018 (unreported): +Appeared for Ilya Yurov, former Chairman of a large Russian bank and previously +accused of fraud, to successfully resist an extradition request from Russia. +• +Russia v A: Instructed to advise A in respect of a prospective extradition request +from Russia. The issues in the case relate to prison conditions, health, and fair trial. +• R (HH) v Westminster Magistrates' Court [2012] UKSC 25; [2012] 3 WLR 90: +one of the leading cases on the application of Article 8 ECHR in extradition +proceedings +Norris v Government of the United States of America [2010] UKSC 9; [2010] 2 +AC 487: Represented the Government of the United States in the Supreme Court +in the leading case on the application of Articles 3 and 8 of the Convention in +extradition proceedings. +Norris v Government of the United States of America [2008] UKHL 16, [2008] 1 +AC 920: Represented the Government of the United States in the House of Lords +in the leading case on cartels and competition law, and the requirement of double +criminality in extradition proceedings. +R (Bermingham) v Director of the Serious Fraud Office [2006] EWHC 200 +(Admin); [2007] QB 727: the extradition of the 'Natwest Three', one of the first +cases US cases to proceed under the Extradition Act 2003. + + +Annex C + + +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +UNITED STATES OF AMERICA, +- against - +GHISLAINE MAXWELL, +Docket No. 20-CR-330 (AJN) +AFFIDAVIT AND WAIVER OF +EXTRADITION +Defendant. +Ghislaine Maxwell, being duly sworn, deposes and says: +I am the named defendant in the above-captioned case. I am a citizen of the +United States, the United Kingdom, and France. I have resided in the United States since +approximately 1991. I am currently incarcerated at the Metropolitan Detention Center in +Brooklyn, New York. +2. +I have reviewed with my counsel, Mark S. Cohen and Christian R. Everdell of +Cohen & Gresser, LLP, the charges contained in the superseding indictment in the abovecaptioned case (the "Indictment"). In addition, I have been informed by United States and +United Kingdom counsel, with whom I am satisfied, of my rights under the United Kingdom's +Extradition Act 2003 (the "Act"), which gives effect to the Extradition Treaty between the +Government of the United Kingdom of Great Britain and Northern Ireland and the Government +of the United States of America (the "Treaty"). I understand that, in proceedings in the United +Kingdom under the Act in respect of an extradition request by the United States under the Treaty +in connection with the Indictment, I would be entitled to argue that I should not be extradited to +the United States. I understand that in the absence of my consent to extradition, I cannot be + + +surrendered to the United States authorities unless and until a court in the United Kingdom issues +a ruling finding that there are no bars to my extradition. +3. +If I am released on bail in connection with the Indictment, I hereby voluntarily +and irrevocably waive any rights to contest any extradition request by the United States under the +Treaty with respect to the offenses charged in the Indictment. Specifically, I consent to +extradition pursuant to Part 2 sections 127 and 128 of the Act in connection with the offenses +charged in the Indictment. In addition, to the extent that it might be relevant, I waive any rights +to assert that any bars to extradition apply, and I confirm that no such bars apply. +4. +In the event that I violate my bail conditions after being released, I understand +that the purpose of this affidavit is for the government to offer it to the authorities in the United +Kingdom when my extradition is sought by the United States government in relation to the +charges in the Indictment. I understand that the United Kingdom authorities may use this +affidavit to assist in determining my extraditability. +I make this waiver freely and voluntarily, after having consulted with counsel. +Dated this +_ day of December 2020. +Ghislaine Maxwell +I hereby certify that on this +day of December 2020, Ghislaine Maxwell personally appeared +before me and made his oath in due form of law that the statements herein are true. +The Honorable Alison J. Nathan +United States District Judge +Southern District of New York +2 + + +Annex D + + +Annex D-time-limits in relation to US extradition requests under the Extradition Act +2003 +Stage +Preliminary stages +Certification of the +extradition request +Time-limit +No statutory time-limit' +Comment [1]: there is no consistent practice as to the length +The sending of the request +and the certificate to the +extradition judge +Arrest under a provisional +warrant +Arrest pursuant to a full +extradition request +cases where the US authorities request expedition +No statutory time-limit? +Comment [2): in practice, the documents are usually sent to +the appropriate judge on the same day that the request is +certified +The requested person must be brought before the extraditior +judge "as soon as practicable" after arrest, unless bail is +granted by the arresting officer? +The full extradition request must be served within 65 days* +Comment [3]: bail is rarely granted prior to the requested +person's production in court and never in cases where the +Crown Prosecution Service objects to bail +The requested person must be brought before the extradition +judge "as soon as practicable" after arrest, unless bail is +granted by the arresting officer +Comment [4): see Comment [3] +'Extradition Act 2003, s. 70(1). +2 Extradition Act 2003, s. 70(9). +3 Extradition Act 2003, s. 74(3). +* Extradition Act 2003, s. 74(11)(b) and Extradition Act 2003 (Designation of Part 2 Territories) Order +2003/3334, Art. 2 +5 Extradition Act 2003, s. 72(3). + + +Cases where the requested person consents to extradition +Sending the case to the +Secretary of State +No statutory time-limit" +Comment [5]: in practice, where the requested person +consents to extradition, the case is sent to the Secretary of +State straight away +Order for extradition +wo months of the date on which the case is sent to tl +cretary of Stati +Comment [6]: where the requested person consents to +extradition, the Secretary of State does not need to wait four +veeks to consider any representations from the requested +person before ordering extradition: section 93(7) +Removal +28 days of the order for extradition" +Cases where there is an extradition hearing +The date of the extradition +hearing (provisional arrest) +Two months from the date on which the Secretary of State +sends the documents to the extradition judge. That date can be +extended by the extradition judge on application by one of the +parties where the judge considers it to be "in the interests of +justice" to fix a later date. The time-limit can be extended +The date of the extradition +hearing (arrest pursuant to a +full request) +omment [7]: in practice, the extradition judge ofte +opens" the extradition hearing at the initial hearing with th +effect that this time-limit ceases to run +Two months from the initial hearing. That date can be +extended by the extradition judge on application by one of the +arties where the judge considers it to be "in the interests o +ustice" to fix a later date. The time-limit can be extende +Comment [8]: in practice, the extradition judge often +"opens" the extradition hearing at the initial hearing with the +effect that this time-limit ceases to run +• Extradition Act 2003, s. 128. +7 Extradition Act 2003, s. 99(3). +" Extradition Act 2003, s. 117(2)(a). +° Extradition Act 2003, s. 76(3) (4). +I Extradition Act 2003, s. 75(2) (3). + + +Sending the case to the +Secretary of State +Order for extradition +No statutory time-limit! +Comment [9]: in practice, the judge sends the case to th +ecretary of State straight awa +Two months of the date on which the case is sent to the +Secretary of State! +Extradition may not be ordered during the first four weeks of +this period ('the permitted period") to allow the requested +person to make representations!3 +Cases where there is no appeal +Removal +| 28 days starting with: (a) the day on which the requested +erson is informed that an order for extradition has been mad +in cases where no in-time appeal is lodged); or (b) the day o +which leave to appeal is refused by the High Court'4 +Cases where there is an appeal +Lodging an application for +permission to appeal a +lecision to send the case to +the Secretary of State +Notice of application for leave to appeal must be lodged +within 14 days of the day on which the requested person was +informed of the Secretary of State's decision to order +Lodging an application for +permission to appeal against +an order for extradition +This time-limit may be extended if the person "did everything +reasonably possible to ensure that the notice was given as +soon as it could be given "° +Notice of application for leave to appeal must be lodged +within 14 days of the day on which the requested person was +informed of the Secretary of State's decision to order +extradition? +" Extradition Act 2003, s. 87. +12 Extradition Act 2003, s. 99(3). +1 Extradition Act 2003, s. 93(5) (6). +" Extradition Act 2003, s. 117(1) (2). +15 Extradition Act 2003, s. 103(9). +1 Extradition Act 2003, s. 103(10). +' Extradition Act 2003, s. 108(4)(b). + + +Lodging an application for +Lodging an application for +permission to appeal against +discharge by the Secretary +of State +Lodging an application for +leave to appeal to the High +Notice of application for leave to appeal must be lodged +was made days of the day on which the order for discharge +This time-limit may not be extended +Notice of application for leave to appeal must be lodged +within 14 days of the day on which the requesting government +is informed of the order for discharge? +This time-limit may not be extended +14 days, starting on the day on which the court makes it +decision on the appeal to it?! +Lodging an application to +the Supreme Court for leave +14 days, starting on the day on which the High Court refuse +leave to appeal? +to appeal +Lodging an appeal if leave it 28 days starting on the day on which leave is granted23 +granted +Extradition following appeal +Removal +28 days starting with: (a) the day on which the decision of the +relevant court becomes final, or (b) the day on which +proceedings on the appeal are discontinued24 +I Extradition Act 2003, s. 108(7A) and (8). +19 Extradition Act 2003, s. 105(5). +2" Extradition Act 2003, s. 110(5). +" Extradition Act 2003, s. 114(5). +22 Extradition Act 2003, s. 114(6). +23 Extradition Act 2003, s. 114(7). +24 Extradition Act 2003, s. 118(2). + + +In cases where there is no appeal to the Supreme Court, the +relevant court is the High Court and the decision becomes +final when the period for applying for permission to appeal +ends and there is no such application, or leave to appeal is +refused?. +In cases where there is an appeal to the Supreme Court, the +relevant court is the Supreme Court and the decision becomes +final when it is made?". +25 Extradition Act 2003, s. 118(3) and (4). +26 Extradition Act 2003, s. 118(3) and (6). \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/0a96293dba93dcc559898d2938ec4c5934c7b9cc2d5eaf5402eb5f4f53035d54.receipt.json b/vision-fixhub/ds9-parsed-01/0a96293dba93dcc559898d2938ec4c5934c7b9cc2d5eaf5402eb5f4f53035d54.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..80731326018200c4f0f09982bdd41a9216bde40c --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0a96293dba93dcc559898d2938ec4c5934c7b9cc2d5eaf5402eb5f4f53035d54.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -451, + "dataset": "marble-joined", + "doc_id": "0a96293dba93dcc559898d2938ec4c5934c7b9cc2d5eaf5402eb5f4f53035d54", + "engine": "marble-apple-vision", + "event_count": 35, + "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "6c890cee0ca7a9a9e8f7f0d21294cf3a9d46bbcdbe5253eb2a909a3c9ddfd3ab", + "output_sha256": "f3542c11a0319aa1a2b9695e3d97d67cf125662fabd67a6c7bf91d477f73ad8c", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0a975b81f80175de20a3d2ca1acdb69a19ab87e5a0ba8a44e2ab29dbb45ac7c2.md b/vision-fixhub/ds9-parsed-01/0a975b81f80175de20a3d2ca1acdb69a19ab87e5a0ba8a44e2ab29dbb45ac7c2.md new file mode 100644 index 0000000000000000000000000000000000000000..ebfbd34208e9c4fe4fa054faf70852f2082c3d6d --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0a975b81f80175de20a3d2ca1acdb69a19ab87e5a0ba8a44e2ab29dbb45ac7c2.md @@ -0,0 +1,21 @@ +From: "Strauss, Audrey (USANYS)" < +To: " +(USANYS)" < +Subject: RE: Maxwell +Date: Fri, 20 Dec 2019 20:02:48 +0000 +Good; I hope that fact is helpful to our theory. +From: +(USANYS) < +Sent: Friday, December 20, 2019 10:21 AM +To: Strauss, Audrey (USANYS) < +Subject: Maxwell +You're right - she was an employee prior to becoming a romantic partner: +e. How long did you work for Mr. +8 Epstein? +9 A. I started working for him at some +10 point in 1992 and the nature of my work +11 relationship with him changed over time +so +12 from around 2002, 2003, the work +lessened +13 considerably. diff --git a/vision-fixhub/ds9-parsed-01/0a975b81f80175de20a3d2ca1acdb69a19ab87e5a0ba8a44e2ab29dbb45ac7c2.receipt.json b/vision-fixhub/ds9-parsed-01/0a975b81f80175de20a3d2ca1acdb69a19ab87e5a0ba8a44e2ab29dbb45ac7c2.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..db69bd43082b82c091d23d95a3a6fabe82b2a1af --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0a975b81f80175de20a3d2ca1acdb69a19ab87e5a0ba8a44e2ab29dbb45ac7c2.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "0a975b81f80175de20a3d2ca1acdb69a19ab87e5a0ba8a44e2ab29dbb45ac7c2", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "67eeeaef6498e2dbf77433c044f612b30da10b6e64501a4500d75b34063955ef", + "output_sha256": "30e3bcba790b836d679421e911723ffe5ab0ff819f7087aae489249f8c78f6e2", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0ad39b96e8fc114cd62ccd002e9c6723aa14b38f010bfd274b0503f9be6d6b65.md b/vision-fixhub/ds9-parsed-01/0ad39b96e8fc114cd62ccd002e9c6723aa14b38f010bfd274b0503f9be6d6b65.md new file mode 100644 index 0000000000000000000000000000000000000000..c2408555ca32a3c06918edb36a4e1677611a75b5 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0ad39b96e8fc114cd62ccd002e9c6723aa14b38f010bfd274b0503f9be6d6b65.md @@ -0,0 +1,188 @@ +" DATE | NAMe | Signature INMate ++ 7/23 +G. Tali +7|23 Colon +s. Epstein +J. Epstein +7/23 +7123 +7/23 +1773 +Fidele. +Saddle +2. TalL. +psteix.. +Peg # +OVT +76318-054 1217 +76318-054 12:00 +76318-054 +2:205.20 +Rest-son +25 +743/8-054 +5:20 + + +7/20 G. Tali +alas (olon. +7|23 +Idule BE +saelln +v. Eptein +.]. testein +76318-054 1217 +76318-054 12:00 +Gesteun +Ipsa +• Epstein +26318-05Y +2:05.20 +Rest sên +25 +76318-054 5:20 110204 + + + +LEDATE NAME +1 Signature |InMate | Regt +TIMe TIMe +IN +'DUE, DATE. +Isignature INmate Regit | Tine Tins +lal24 C.Tuti Mr J.Epstein 76 318-008:37 +7/21 Calico nit lEosta +7º3265y |30 |3rm +Salele +IAs +Ere-hon +Pasair +2.55 |8Er + + +1ab4 G.Tar +7/1 Calde +14l. bpeon Savel +124. Colon +17/24. +Scavelti +12l Cala. +Про Траки +Epstein 76318-054 10:40 +76515-C5410:40 +liso: +-V Bastm +176318-054 1473 +10:20 l +Soska +17638-851 zi l3pa +Feston +7315.094 +2.57 +8kr + + +1-3628 +G. Tali +1. Epoten +76318-654 8:28 1125 +Tas Saella +H2r G.TaliM +225 Caller bar sten +26318:054 11:45 +726G. Tali +Epsten +1631805 20 G0 +Epstein +781815:1063 +23516-089 610 205 +W. Epstein . +1763/8-0818:08/2136 + + +alar G. Tali +M +Sastein +7225 Suelle +Eptan +J. Epstein. +763173r5:20 6i55 +70516-289 60 70K +76638-0888:08 12130 + + +DATE +SigNATUre +Innate /Regst +(к " +7126 +Epstein +743K-04 121BI +72V20 1231G3P 768427 +720 Calient +pstan 76,515-051 5:201 + + + + +7126 +Saetlu +Epsteir +343K-5412 +A3 UDO 1BGp 768347 +:726 Caliet +Epstan 76315-051|5:20 +7127 +Miller +1(r2 +Lpts +224 G.TN: +JAFAton +Eptir +lafpm +Ensln +76 050 185 +83742053 85 +06318054|10#5 21 + + +DATE +SigNaTure Inuate Pega +Tue +7/28/19 +Santla +G. Tali +Epsten +735-054 +asein +(:40 +765,834 +5.30 +5: 570 +76318-01412:55 +5:20 +Sten 76315 1830 +100 +7/28/14 + + +FEAC Gsten 176380 18301100 +7/28/11 Sacka, 2B +Epur 2365- бік 85al + + +RATE +SigNaTUre InMate |Regtt +TiMe Tir +HErn 1231805 12:55; +123-4C nw Distin 12318045330 +1). Enstein +176318-057 9:00aa/1 + + +F: 26114 Jala +He Ersth +26318-54 12:5511 +• 23t-19 Cali +2 Bestel 76318054 5:30 +8lilig G. Tali VEstein 76318-081 9:00aml \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/0ad39b96e8fc114cd62ccd002e9c6723aa14b38f010bfd274b0503f9be6d6b65.receipt.json b/vision-fixhub/ds9-parsed-01/0ad39b96e8fc114cd62ccd002e9c6723aa14b38f010bfd274b0503f9be6d6b65.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..0469ce032a8a9e388d08d2fbe0346bc1e6e3124a --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0ad39b96e8fc114cd62ccd002e9c6723aa14b38f010bfd274b0503f9be6d6b65.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -191, + "dataset": "marble-joined", + "doc_id": "0ad39b96e8fc114cd62ccd002e9c6723aa14b38f010bfd274b0503f9be6d6b65", + "engine": "marble-apple-vision", + "event_count": 15, + "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "f4526ec7d4a101a0bc15990ca6bbe532504b0553dbed15a9937aa1f297254e78", + "output_sha256": "2421c215418bfa0d8912fab235a173067da322a5f85941472bc15c12963bf3d1", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0b1d6f98a6a592303c7d29c6d47cee9a83f844d705bf8d697821487e013bd273.md b/vision-fixhub/ds9-parsed-01/0b1d6f98a6a592303c7d29c6d47cee9a83f844d705bf8d697821487e013bd273.md new file mode 100644 index 0000000000000000000000000000000000000000..bc4100d50f5c611066af8158ed9afbd0146d89e7 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0b1d6f98a6a592303c7d29c6d47cee9a83f844d705bf8d697821487e013bd273.md @@ -0,0 +1,10 @@ +From: +Subject: Epstein, Reg. No. 76318-054 +Date: Sat, 10 Aug 2019 22:14:04 + 0000 +Importance: Normal +Attachments: TEXT.htm; 2019_08_10_18_12_55.pdf;_ +Psych Ops discontinued on 7/30/18 at 8:15 am +MCC New York +New York, NY 10007 +ext. 6451 +NYM/AW-Programs~@bop.gov diff --git a/vision-fixhub/ds9-parsed-01/0b1d6f98a6a592303c7d29c6d47cee9a83f844d705bf8d697821487e013bd273.receipt.json b/vision-fixhub/ds9-parsed-01/0b1d6f98a6a592303c7d29c6d47cee9a83f844d705bf8d697821487e013bd273.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..3b5b584664612e6a23deac198983964178e480c3 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0b1d6f98a6a592303c7d29c6d47cee9a83f844d705bf8d697821487e013bd273.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "0b1d6f98a6a592303c7d29c6d47cee9a83f844d705bf8d697821487e013bd273", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "0e62fa20bb8e0a6bcefbe15b63b3cb8dfb88d26f813c380d0f0e5a61b9a9f661", + "output_sha256": "c1ee6b4a00e58350e0fad0028d1da10d0d7b9d3837736886927c975120dab0b4", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0b5190d18681f1c12e7a90f4f45890d0b59877a089b521fb01d8e6c872aa5479.md b/vision-fixhub/ds9-parsed-01/0b5190d18681f1c12e7a90f4f45890d0b59877a089b521fb01d8e6c872aa5479.md new file mode 100644 index 0000000000000000000000000000000000000000..1ad79407ee58c7d8d9138b9fa11c04b97c70a824 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0b5190d18681f1c12e7a90f4f45890d0b59877a089b521fb01d8e6c872aa5479.md @@ -0,0 +1,501 @@ +Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 1 of 18 +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +- - +UNITED STATES OF AMERICA +- V. +GHISLAINE MAXWELL, +Defendant. +SUPERSEDING INDICTMENT +S1 20 Cr. 330 (AJN) +COUNT ONE +(Conspiracy to Entice Minors to Travel to Engage in +Illegal Sex Acts) +The Grand Jury charges: +OVERVIEW +1. The charges set forth herein stem from the role +Of GHISLAINE MAXWELL, the defendant, in the sexual exploitation +and abuse of multiple minor girls by Jeffrey Epstein. In +particular, from at least in or about 1994, up to and including +at least in or about 1997, MAXWELL assisted, facilitated, and +contributed to Jeffrey Epstein's abuse of minor girls by, among +other things, helping Epstein to recruit, groom, and ultimately +abuse victims known to MAXWELL and Epstein to be under the age +of 18. The victims were as young as 14 years old when they were +groomed and abused by MAXWELL and Epstein, both of whom knew +that certain victims were in fact under the age of 18. +2. As a part and in furtherance of their scheme to +abuse minor victims, GHISLAINE MAXWELL, the defendant, and +Jeffrey Epstein enticed and caused minor victims to travel to + + +Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 2 of 18 +Epstein's residences +in different states, which MAXWELL knew and +intended would result in their grooming for and subjection to +sexual abuse. +Moreover, in an effort to conceal her crimes, +MAXWELL repeatedly lied when questioned about her conduct, +including in relation to some of the minor victims described +herein, when providing testimony under oath in 2016. +FACTUAL BACKGROUND +3. During the time periods charged in this +Indictment, GHISLAINE MAXWELL, the defendant, had a personal and +professional relationship with Jeffrey Epstein and was among his +closest associates. In particular, between in or about 1994 and +in or about 1997, MAXWELL was in an intimate relationship with +Epstein and also was paid by Epstein to manage his various +properties. Over the course of their relationship, MAXWELL and +Epstein were photographed together on multiple occasions, +including in the below image: +2 + + +Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 3 of 18 +4. +Beginning in at least 1994, GHISLAINE MAXWELL, +the defendant, enticed and groomed multiple minor girls to +engage in sex +acts with Jeffrey Epstein, through a variety of +means and methods, including but not limited to the following: +a. +MAXWELL first attempted to befriend some of +Epstein's minor victims prior to their abuse, including by +asking the victims about their lives, their schools, and their +families. MAXWELL and Epstein would spend time building +friendships with minor victims by, for example, taking minor +victims to the movies or shopping. Some of these outings would +involve MAXWELL and Epstein spending time together with a minor +victim, while some would involve MAXWELL or Epstein spending +time alone with a minor victim. +b. Having developed a rapport with a victim, +MAXWELL would try to normalize sexual abuse for a minor victim +by, among other things, discussing sexual topics, undressing in +front of the victim, being present when a minor victim was +undressed, and/or being present for sex acts involving the minor +victim and Epstein. +C. MAXWELL'S presence during minor victims' +interactions with Epstein, including interactions where the +minor victim was +• undressed or that involved sex acts with +Epstein, helped put the victims at ease because an adult woman +was present. +For example, in some instances, MAXWELL would +3 + + +Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 4 of 18 +massage Epstein in front of a minor victim. In other instances, +MAXWELL encouraged minor victims to provide massages to Epstein, +including sexualized massages during which a minor victim would +be fully or partially nude. Many of those massages resulted in +Epstein sexually abusing the minor victims. +d. +In addition, Epstein offered to help some +minor victims by paying for travel and/or educational +opportunities, and MAXWELL encouraged certain victims to accept +Epstein's assistance. As a result, victims were made to feel +indebted and believed that MAXWELL and Epstein were trying to +help them. +e. Through this process, MAXWELL and Epstein +enticed victims to engage in sexual activity with Epstein. In +some instances, MAXWELL was present for and participated in the +sexual abuse of minor victims. +Some such incidents occurred in +the context of massages, which developed into sexual encounters. +5. +GHISLAINE MAXWELL, the defendant, facilitated +Jeffrey Epstein's access to minor victims knowing that he had a +sexual preference +for underage girls and that he intended to +engage in sexual activity with those victims. Epstein's +resulting abuse of minor victims included, among other things, +touching a victim's breast, touching a victim's genitals, +placing a sex toy such as a vibrator on a victim's genitals, +4 + + +Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 5 of 18 +directing a victim to touch Epstein while he masturbated, and +directing a victim to touch Epstein's genitals. +MAXWELL AND EPSTEIN'S VICTIMS +6. +Between approximately in or about 1994 and in or +about 1997, GHISLAINE MAXWELL, the defendant, facilitated +Jeffrey Epstein's access to minor victims by, among other +things, inducing and enticing, and aiding and abetting the +inducement and enticement of, multiple minor victims. Victims +were groomed and/or abused at multiple locations, including the +following: +a. A a multi-story private residence on the +Upper East Side of Manhattan, New York owned by Epstein (the +"New +York Residence"), which is depicted in the following +photograph: + + +Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 6 of 18 +b. An estate in Palm Beach, Florida owned by +Epstein (the "Palm Beach Residence"), which is depicted in the +following photograph: +c. A ranch in Santa Fe, New Mexico owned by +Epstein (the "New Mexico Residence"), which is depicted in the +following photograph: + + +Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 7 of 18 +d. +MAXWELL's personal residence in London, +England. +7. +Among the victims induced or enticed by GHISLAINE +MAXWELL, the defendant, were minor victims identified herein as +Minor Victim-1, Minor Victim-2, and Minor Victim-3. +In +particular, +and during time periods relevant to this Indictment, +MAXWELL engaged in the following acts, among others, with +respect to minor victims: +a. +MAXWELL met Minor Victim-1 when Minor +Victim-1 was approximately 14 years old. MAXWELL subsequently +interacted with Minor Victim-1 on multiple occasions at +Epstein's residences, knowing that Minor Victim-1 was under the +age of 18 at the time. +During these interactions, which took +place between approximately 1994 and 1997, MAXWELL groomed Minor +Victim-1 to engage in sexual acts with Epstein through multiple +means. First, MAXWELL and Epstein attempted to befriend Minor +Victim-1, taking her to the movies and on shopping trips. +MAXWELL also asked Minor Victim-1 about school, her classes, her +family, and other aspects of her life. MAXWELL then sought to +normalize inappropriate and abusive conduct by, among other +things, undressing in front of Minor Victim-1 and being present +when Minor Victim-1 undressed +I in front of Epstein. Within the +first year after MAXWELL and Epstein met Minor Victim-1, Epstein +began sexually abusing Minor Victim-1. MAXWELL was present for +7 + + +Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 8 of 18 +and involved in some of this abuse. In particular, MAXWELL +involved Minor Victim-1 in group sexualized massages of Epstein. +During those group sexualized massages, MAXWELL and/or Minor +Victim-1 would engage in sex acts with Epstein. Epstein and +MAXWELL both encouraged Minor Victim-l to travel to Epstein's +residences in both New York and Florida. As a result, Minor +Victim-1 was sexually abused by Epstein in both New York and +Florida. Minor Victim-l was enticed to travel across state +lines for the purpose of sexual encounters with Epstein, and +MAXWELL was aware that Epstein engaged in sexual activity with +Minor Victim-1 after Minor-Victim-1 traveled to Epstein's +properties, including in the context of a sexualized massage. +b. MAXWELL interacted with Minor Victim-2 on at +least one occasion in or about 1996 at Epstein's residence in +New Mexico when Minor Victim-2 was under the age of 18. Minor +Victim-2 had flown into New Mexico from out of state at +Epstein's invitation for the purpose of being groomed for and/or +subjected to acts of sexual abuse. MAXWELL knew that Minor +Victim-2 was under the age of 18 at the time. While in New +Mexico, MAXWELL and Epstein took Minor Victim-2 to a movie and +MAXWELL took Minor Victim-2 shopping. MAXWELL also discussed +Minor Victim-2's school, classes, and family with Minor Victim- +2. In New Mexico, MAXWELL began her efforts to groom Minor +Victim-2 for abuse by Epstein by, among other things, providing +8 + + +Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 9 of 18 +an unsolicited massage to Minor Victim-2, during which Minor +Victim-2 was topless. MAXWELL also encouraged Minor Victim-2 to +massage Epstein. +C. +MAXWELL groomed and befriended Minor +Victim-3 in London, England between approximately 1994 and 1995, +including during a period of time in which MAXWELL knew that +Minor Victim-3 was under the age of 18. Among other things, +MAXWELL discussed Minor Victim-3's life and family with Minor +Victim-3. MAXWELL introduced Minor Victim-3 to Epstein and +arranged for multiple interactions between Minor Victim-3 and +Epstein. During those interactions, MAXWELL encouraged Minor +Victim-3 to massage Epstein, +knowing that Epstein would engage +in sex acts with Minor Victim-3 during those massages. Minor +Victim-3 provided Epstein with the requested massages, and +during those massages, Epstein sexually abused Minor Victim-3. +MAXWELL was aware that Epstein engaged in sexual activity with +Minor Victim-3 on multiple occasions, including at times when +Minor Victim-3 was under the age of 18, including in the context +of a sexualized massage. +MAXWELL'S EFFORTS TO CONCEAL HER CONDUCT +In or around 2016, in the context of a deposition +as part of civil litigation, GHISLAINE MAXWELL, the defendant, +repeatedly provided false and perjurious statements, under oath, +regarding, among other subjects, her role in facilitating the +9 + + +Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 10 of 18 +abuse of minor victims by Jeffrey Epstein, including some of the +specific events and acts of abuse detailed above. +STATUTORY ALLEGATIONS +9. From at least in or about 1994, up to and +including in or about 1997, in the Southern District of New York +and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey +Epstein, and others known and unknown, willfully and knowingly +did combine, conspire, confederate, and agree together and with +each other to commit an offense against the United States, to +wit, enticement, in violation of Title 18, United States Code, +Section 2422. +10. It was a part and object of the conspiracy that +GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others +known and unknown, would and did knowingly persuade, induce, +entice, and coerce one and more individuals to travel in +interstate and foreign commerce, to engage in sexual activity +for which a person can be charged with a criminal offense, in +violation of Title 18, United States Code, Section 2422. +Overt Acts +11. In furtherance of the conspiracy and to effect +the illegal object thereof, the following overt acts, among +others, +were committed in the Southern District of New York and +elsewhere: +10 + + +Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 11 of 18 +a. +Between in or about 1994 and in or about +1997, when Minor Victim-1 was under the age of 18, MAXWELI +participated in multiple group sexual encounters with Epstein +and Minor Victim-1 in New York and Florida. +b. In or about 1996, when Minor Victim-1 was +under the age of 18, Minor Victim-1 was enticed to travel from +Florida to New York for purposes of sexually abusing her at the +New York Residence, in violation of New York Penal Law, Section +130.55. +c. In or about 1996, when Minor Victim-2 was +under the age of 18, MAXWELL provided Minor Victim-2 with an +unsolicited massage in New Mexico, during which Minor Victim-2 +was topless. +d. Between in or about 1994 and in or about +1995, when Minor Victim-3 was under the age of 18, MAXWELI +encouraged Minor Victim-3 to provide massages to Epstein in +London, England, knowing that Epstein intended to sexually abuse +Minor Victim-3 during those massages. +(Title 18, United States Code, Section 371.) +COUNT IWO +(Enticement of a Minor to Travel to Engage in Illegal Sex Acts) +The Grand Jury further charges: +12. The allegations contained in paragraphs 1 +through 8 of this Indictment are repeated and realleged as if +fully set forth within. +11 + + +Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 12 of 18 +13. From at least in or about 1994, up to and +including in or about 1997, in the Southern District of New York +and elsewhere, GHISLAINE MAXWELL, the defendant, knowingly did +persuade, induce, entice, and coerce an individual to travel in +interstate and foreign commerce to engage in sexual activity for +which a person can be charged with a criminal offense, and +attempted to do the same, and aided and abetted the same, to +wit, MAXWELL persuaded, induced, enticed, and coerced Minor +Victim-1 to travel from Florida to New York, New York on +multiple occasions with the intention that Minor Victim-1 would +engage in one or more sex acts with Jeffrey Epstein, in +violation of New York Penal Law, Section 130.55. +(Title 18, United States Code, Sections 2422 and 2.) +COUNT THREE +(Conspiracy to Transport Minors with Intent to +Engage in Criminal Sexual Activity) +The Grand Jury further charges: +14. The allegations contained in paragraphs 1 +through 8 of this Indictment are repeated and realleged as if +fully set forth within. +15. From at least in or about 1994, up to and +including +in or about 1997, in the Southern District of New York +and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey +Epstein, and others known and unknown, willfully and knowingly +did combine, conspire, confederate, and agree together and with +each other to commit an offense against the United States, to +12 + + +Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 13 of 18 +wit, transportation of minors, in violation of Title 18, United +States Code, Section 2423(a). +16. It was a part and object of the conspiracy that +GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others +known and unknown, would and did, knowingly transport an +individual who had not attained the age of 18 in interstate and +foreign commerce, with intent that the individual engage in +sexual activity for which a person can be charged with a +criminal offense, in violation of Title 18, United States Code, +Section 2423 (a) . +Overt Acts +17. In furtherance of the conspiracy and to effect +the illegal object thereof, the following overt acts, among +others, were committed in the Southern District of New York and +elsewhere: +a. +Between in or about 1994 and in or about +1997, when Minor Victim-1 was under the age of 18, MAXWELL, +participated in multiple group sexual encounters with EPSTEIN +and Minor Victim-1 in New York and Florida. +b. In or about 1996, when Minor Victim-1 was +under the age of 18, Minor Victim-1 was enticed to travel from +Florida to New York for purposes of sexually abusing her at the +13 + + +Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 14 of 18 +New York Residence, in violation of New York Penal Law, Section +130.55. +.C. +In or about 1996, when Minor Victim-2 was +under the age of 18, MAXWELL provided Minor Victim-2 with an +unsolicited massage in New Mexico, during which Minor Victim-2 +was topless. +d. Between in or about 1994 and in or about +1995, when Minor Victim-3 was under the age of 18, MAXWELL +encouraged Minor Victim-3 to provide massages to Epstein in +London, England, knowing that Epstein intended to sexually abuse +Minor Victim-3 during those massages. +(Title 18, United States Code, Section 371.) +COUNT FOUR +(Transportation of a Minor with Intent to +Engage in Criminal Sexual Activity) +The Grand Jury further charges: +18. The allegations contained in paragraphs 1 +through 8 of this Indictment are repeated and realleged as if +fully set forth within. +19. From at least in or about 1994, up to and +including in or about 1997, in the Southern District of New York +and elsewhere, GHISLAINE MAXWELL, the defendant, knowingly did +transport an individual who had not attained the age of 18 in +interstate and foreign commerce, with the intent that the +individual engage in sexual activity for which a person can be +charged with a criminal offense, and attempted to do so, and + + +Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 15 of 18 +aided and abetted the same, to wit, MAXWELL arranged for Minor +Victim-1 to be transported from Florida to New York, New York on +multiple occasions with the intention that Minor Victim-1 would +engage in one or more sex acts with Jeffrey Epstein, in +violation of New York Penal Law, Section 130.55. +(Title 18, United States Code, Sections 2423(a) and 2.) +COUNT FIVE +(Perjury) +The Grand Jury further charges: +20. The allegations contained in paragraphs 1 +through 8 of this Indictment are repeated and realleged as if +fully set forth within. +21. On or about April 22, 2016, in the Southern +District of New York, GHISLAINE MAXWELI, the defendant, having +taken an oath to testify truthfully in a deposition in +connection with a case then pending before the United States +District Court for the Southern District of New York under +docket number 15 Civ. 7433, knowingly made false material +declarations, to wit, MAXWELL gave the following underlined +false testimony: +l. Did Jeffrey Epstein have a scheme to recruit +underage girls for sexual massages? If you know. +A. I don't know what you're talking about. +15 + + +Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 16 of 18 +List all the people under the age of 18 that you +interacted with at any of Jeffrey's properties? +I'm not aware of anybody that I interacted with, +other than obviously [the plaintiff] who was 17 +at this point. +(Title 18, United States Code, Section 1623.) +COUNT STA +(Perjury) +The Grand Jury further charges: +22. The allegations contained in paragraphs 1 +through 8 of this Indictment are repeated and realleged as if +fully set forth within. +23. On or about July 22, 2016, in the Southern +District of New York, GHISLAINE MAXWELL, the defendant, having +taken an oath to testify truthfully in a deposition in +connection with a case then pending before the United States +District Court for the Southern District of New York under +docket number 15 Civ. 7433, knowingly made false material +declarations, to wit, MAXWELL gave the following underlined +false testimony: +0: Were you aware of the presence of sex toys or +devices used in sexual activities in Mr. +Epstein's Palm Beach house? +A: No, not that I recall. • • +l. Do you know whether Mr. Epstein possessed sex +toys or devices used in sexual activities? +A. No. +16 + + +Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 17 of 18 +A. +A. +Other than yourself and the blond and brunette +that you have identified as having been involved +in three-way sexual activities, with whom did Mr. +Epstein have sexual activities? +I wasn't aware that he was having sexual +activities +with anyone when I was with him other +than myself: +I want to be sure that I'm clear. +Is it your +testimony that in the 1990s and 2000s, you were +not aware that Mr. Epstein was having sexual +activities with anyone other than yourself and +the blond and brunette on those few occasions +when they were involved with you? +That is my testimony, that is correct. +• +e. +A. +A. +A. +Is it your testimony that you've never given +anybody a massage? +I have not given anyone a massage. +You never gave Mr. Epstein a massage, is that +your testimony? +That is my testimony. +You never gave +[Minor Victim-2] a massage is your +testimony? +I never gave [Minor Victim-2] a massage. +(Title 18, United States Code, Section 1623.) +FOREPERSON +Strauss +AUDREY +Acting United States Attorne +17 + + +Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 18 of 18 +Form No. USA-33s-274 (Ed. +9-25-58) +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +UNITED STATES OF AMERICA +v. +GHISLAINE MAXWELL, +Defendant. +SUPERSEDING INDICTMENT +S1 20 Cr. 330 (AJN) +(18 U.S.C. SS 371, 1623, 2422, 2423 (a), +and 2) +AUDREY STRAUSS +Acting United States Attorney +Foreperson +18 diff --git a/vision-fixhub/ds9-parsed-01/0b5190d18681f1c12e7a90f4f45890d0b59877a089b521fb01d8e6c872aa5479.receipt.json b/vision-fixhub/ds9-parsed-01/0b5190d18681f1c12e7a90f4f45890d0b59877a089b521fb01d8e6c872aa5479.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..db1d4cc4b40b0a079666081cd831759141f4a19d --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0b5190d18681f1c12e7a90f4f45890d0b59877a089b521fb01d8e6c872aa5479.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -216, + "dataset": "marble-joined", + "doc_id": "0b5190d18681f1c12e7a90f4f45890d0b59877a089b521fb01d8e6c872aa5479", + "engine": "marble-apple-vision", + "event_count": 18, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "854d588da1906d95c676bb718914caab1fe63ce0443b1de1a341501ccdb95a78", + "output_sha256": "8d8b3eb9ddd5e0955e2aa99dd64064434af614c97a5917c3a3f574b52b8cccab", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0b66e9b7330a6481987a92955687dc2ebdd4a94417f8e63a594ff67945e6acf3.md b/vision-fixhub/ds9-parsed-01/0b66e9b7330a6481987a92955687dc2ebdd4a94417f8e63a594ff67945e6acf3.md new file mode 100644 index 0000000000000000000000000000000000000000..0dbc42bdce5acb2e74e18c68b7bfa68cfbda6b31 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0b66e9b7330a6481987a92955687dc2ebdd4a94417f8e63a594ff67945e6acf3.md @@ -0,0 +1,32 @@ +From: "Tyrrell, Edward (USANYS)" ‹ +To: ' +Cc: ' +Subject: Re: travel approval request +Date: Thu, 04 Apr 2019 00:46:10 +0000 +Importance: Normal +•, "Duncan, Michele (USANYS)" +Approved +Sent from my iPad +On Apr 3, 2019, at 8:02 PM, +Ed, +> wrote: +For the same case as below, United States v. Epstein, 2018R01618, an investigation relating to enticement of minors for +sexual activity, Alison and I would like to please request permission to travel for approximately three days next week for +meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly down Tuesday night and +Please let us know if any other information would be helpful, and thanks very much. +Alex. +From: +Sent: Thursday, March 14, 2019 18:32 +To: Tyrrell, Edward (USANYS) ‹ +Cc:| +Subject: travel approval request +Ed, +Land I would like to please request permission for travel for United States v. Epstein, 2018R01618, an +investigation relating to enticement of minors for sexual activity, for two days of meetings and interviews in West Palm +Beach and/or Fort Lauderdale, Florida. As of now we're hoping to fly down next Wednesday night and return on +Saturday. +Please let us know if any other information would be helpful, and thanks as always. +Alex. +Assistant U.S. Attorney +Southern District of New York +212.637.2415 diff --git a/vision-fixhub/ds9-parsed-01/0b66e9b7330a6481987a92955687dc2ebdd4a94417f8e63a594ff67945e6acf3.receipt.json b/vision-fixhub/ds9-parsed-01/0b66e9b7330a6481987a92955687dc2ebdd4a94417f8e63a594ff67945e6acf3.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..bd23c051f992184ec1cd44e3714eb5316e9d74d1 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0b66e9b7330a6481987a92955687dc2ebdd4a94417f8e63a594ff67945e6acf3.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "0b66e9b7330a6481987a92955687dc2ebdd4a94417f8e63a594ff67945e6acf3", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "8e28078eef69aacef8f857d577268ed6c7aa963d70f81c58128716bb8e96a85f", + "output_sha256": "b32e5ca14f1b7d0628351b51bc9dfc85f0b39f6f27bc1181bab4563d0f988afd", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0b920496dad860a510dc53b7bcb53b4cc572bff43a76bad71bb1b002788f9da5.md b/vision-fixhub/ds9-parsed-01/0b920496dad860a510dc53b7bcb53b4cc572bff43a76bad71bb1b002788f9da5.md new file mode 100644 index 0000000000000000000000000000000000000000..a33a4838e527f7581aa1787b15613390d817c9e3 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0b920496dad860a510dc53b7bcb53b4cc572bff43a76bad71bb1b002788f9da5.md @@ -0,0 +1,151 @@ +FD-1057 (Rev. 5-8-10) +FEDERAL BUREAU OF INVESTIGATION +Electronic Communication +Title: (U//FOUO) INTERVIEW OF ANTHONY LUIS ZAC +FIGUEROA +Date: 12/04/2018 +Drafted By: Missing +Case ID #: 31E-MM-NEW +(U) EPSTEIN, JEFFREY KELLEN, SARAH +Details: +01/10/2007 ANTHONY LUIS ZAC FIGUEROA was interviewed in +West Palm Beach, Florida, regarding a federal investigation involving +the sexual exploitation of minors. After being advised of the identity +of the interviewing agents and the nature of the interview, FIGUEROA +provided the following information: FIGUEROA first met JEFFREY EPSTEIN +through his girlfriend, +• date of birth +• FIGUEROA and +dated +both of them dropping out +o1 sendol. +left scnool first and FIGUEROA stopped attending +Royal Palm bean High School around his 10th grade year. They began +dating again when, through a mutual friend, they ran into each other. +had not yet turned eighteen and FIGUEROA believed it may have +ween +In the month of May. +was residing at HIDDEN HARBOR, an +apartment complex located In Royal Palm Beach, North of Okeechobee +Boulevard on the left side of the street. FIGUEROA moved in with +approximately one month later. FIGUEROA stated that EPSTEIN +paid +the rent for the apartment. FIGUEROA believed the rent was +between $980.00 - $1200.00. +who had no other job, was +EPSTEIN's Personal Assistant. +FIGUEROA stated +provided +massages to EPSTEIN. +was also to locate +adartional females to +perform massages for +EPSTEIN. According to FIGUEROA, +traveled +with EPSTEIN, accompanying him on trips frequently. +FIGUEROR stated +that +had just returned from a trip with EPSTEIN when he and +reunited. FIGUEROA believed +was with EPSTEIN in New +IDIK +at EPSTEIN's island. When asked by the interviewing agent if +was sexual involved with EPSTEIN, FIGUEROA stated he never +asked her, but that he was not stupid. FIGUEROA continued stating, "if +your girlfriend was sucking another man's dick would you want to +know." FIGUEROA said that +was paid well and they both +benefitted from the money EPSIEIN was paying +• FIGUEROA stated +that he transported females to the EPSTEIN residence +so they could +provide EPSTEIN with a massage. FIGUEROA would be paid $200.00 by +EPSTEIN for driving or bringing females to the EPSTEIN residence. He +drove a red Dodge Dakota or sometimes he used a white Pontiac Grand AM +to transport the females. On occasion, FIGUEROA had friends that would +drive with him. FIGUEROA also found other females to perform massages + +SDNY_GM_00332929 + + +Title: (U//FOUO) INTERVIEW OF ANTHONY LUIS ZAC FIGUEROA +Re: 31E-MM-NEW, 12/04/2018 +for EPSTEIN. FIGUEROA said they would find females at different +places: the mall, the clubs or the schools. FIGUEROA said that LESLIE +LNU (area code 212) or GHISALINE MAXWELL would also call and ask him to +pick up a specific girl and bring them to EPSTEIN's residence. +FIGUEROA believed MAXWELL was EPSTEIN's wife at first, but he knows +now that was not the case. FIGUEROA stated that when he was at the +EPSTEIN's residence, while waiting for a female, he would, on +occasion, see EPSTEIN's chef. FIGUEROA described him as a Spanish guy +with dark hair. FIGUEROA said that sometimes after he had taken the +females to EPSTEIN's residence, he would not receive the $200.00 fee +from EPSTEIN. FIGUEROA explained stating that the females would either +go on their own or they would bring a new female. FIGUEROA could only +remember the names of two girls, +and +• that he had +taken to EPSTEIN's residence. When asked by the Interviewing agent if +he recalled someone by the name of +, he stated that she had +attended Royal Palm Beach High School and she was another one of the +females working for EPSTEIN. He said that he and +had +recruited +to work for EPSTEIN. FIGUEROA said +chat when +was twenty EPSTEIN paid for her to travel to Thailand to +attend a school specializing in massages. FIGUEROA said after +was there for a month, he received a letter from +that +STIe +would not be returning and that they were over as a couple. FIGUEROA +has not seen nor heard from +since that time. FIGUEROA stated +that he still has her dog. FIgurer also went on to say that he has a +$3000.00 telephone bill that his parents had to pay. +told +FIGUEROA that she would take care of phone bill upon +return from +Thailand. FIGUEROA had not worried about the bill because of +association with EPSTEIN. FIGUEROA said that he would like +reimburse his parents. FIGUEROA eventually stopped working +LO +TOT EPSTEIN +mainly due to the fact that +did not return from Thailand. +FIGUEROA said that EPSTEIN would call and inquire about +whereabouts and if he had heard from +FIGUEROA berteved +that +EPSTEIN knew where +was because +he was +the one responsible for +sending her to Thailand. FIGUEROA stated that he had loved +and +that he and EPSTEIN had argued about +not returning. +FIGUEROA +said that EPSTEIN told him to make sure +females the he brought to +him were eighteen. FIGUEROA said he was the driver and working for +EPSTEIN was an easy way to make $200.00 for 30-45 minutes work. +FIGUEROA said that he had never been upstairs in EPSTEIN's residence. +FIGUEROA has also never traveled with EPSTEIN. FIGUEROA said that +EPSTEIN had given him +$500.00 in cash to help pay off car tickets. +2 + +SDNY_GM_00332930 + + +Title: +(U//FOUO) INTERVIEW OF ANTHONY LUIS ZAC FIGUEROA +Re: +31E-MM-NEW, 12/04/2018 +(Overall Document Classification +Required) +3 + +SDNY_GM_00332931 \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/0b920496dad860a510dc53b7bcb53b4cc572bff43a76bad71bb1b002788f9da5.receipt.json b/vision-fixhub/ds9-parsed-01/0b920496dad860a510dc53b7bcb53b4cc572bff43a76bad71bb1b002788f9da5.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..d1456da08348a1dc35e3c1151b68972b5c140a21 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0b920496dad860a510dc53b7bcb53b4cc572bff43a76bad71bb1b002788f9da5.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -288, + "dataset": "marble-joined", + "doc_id": "0b920496dad860a510dc53b7bcb53b4cc572bff43a76bad71bb1b002788f9da5", + "engine": "marble-apple-vision", + "event_count": 7, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "ed4042090ac0e0099ef4551e5baf26528d7105971bfe9d40be0ac7b6773840e8", + "output_sha256": "67dbf392436375fe20ca82381981571e1e91c81878aba0c0adca6c1123df0b2d", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0bad1d089ec462638153041b6632fa6dbb5fe20d90eea5024890d129ba998df6.md b/vision-fixhub/ds9-parsed-01/0bad1d089ec462638153041b6632fa6dbb5fe20d90eea5024890d129ba998df6.md new file mode 100644 index 0000000000000000000000000000000000000000..512e51c173e14d9fc86af5de7592e85f71b2aefe --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0bad1d089ec462638153041b6632fa6dbb5fe20d90eea5024890d129ba998df6.md @@ -0,0 +1,18 @@ +From: +To: "testimony@att.com" +Cc: " +Subject: AT&T Subpoena +Date: Mon, 19 Jul 2021 22:27:32 +0000 +Attachments: 2021.07.19_Court_Subpoena_-_AT&T_- subpoena_2.pdf; 2021.07.19_Court_Subpoena_- +_AT&T_-_subpoena_1.pdf; 2021.07.15_ATT_Certification.pdf +James, +Thanks again for the call on Friday. Attached are two subpoenas, one for the particular invoice we discussed, and one that +is somewhat broader. I've also attached again a draft certification for the particular invoice, but if AT&T has a certification +of its own, that would likely suffice. +Please let us know if you need any more information or a different subpoena, and please let us know if you are able to +find the responsive records. +Thanks, +Assistant United States Attorney +Southern District of New York +1 Saint Andrews Plaza +New York, New York 10007 diff --git a/vision-fixhub/ds9-parsed-01/0bad1d089ec462638153041b6632fa6dbb5fe20d90eea5024890d129ba998df6.receipt.json b/vision-fixhub/ds9-parsed-01/0bad1d089ec462638153041b6632fa6dbb5fe20d90eea5024890d129ba998df6.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..f29df6931da749d0d8c8c574092054499d012e86 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0bad1d089ec462638153041b6632fa6dbb5fe20d90eea5024890d129ba998df6.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "0bad1d089ec462638153041b6632fa6dbb5fe20d90eea5024890d129ba998df6", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "c33dd8281734fef2bda0b9135ba06ba29711600bdc7e8dd76f6f871401418d3b", + "output_sha256": "33577dc36107e011726aa6de02475bb2d2086cbac600b6da247a58b235d0a1ac", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0bba4c5b069709fe31a5b13e191389d6fcbab762e6768aa45f5423dbe46ac939.md b/vision-fixhub/ds9-parsed-01/0bba4c5b069709fe31a5b13e191389d6fcbab762e6768aa45f5423dbe46ac939.md new file mode 100644 index 0000000000000000000000000000000000000000..d058b3ceb46cad130be0e3660df5a9a39ad52d6f --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0bba4c5b069709fe31a5b13e191389d6fcbab762e6768aa45f5423dbe46ac939.md @@ -0,0 +1,2651 @@ +Signature Page Summary +Ghislaine Maxwell +Account Number and Description +RMA Domestic - Sole Owner +RMA Domestic - Sole Owner +RMA Domestic - Sole Owner +RMA Domestic - Sole Owner +RMA Domestic - Sole Owner +RMA Domestic - Sole Owner +RMA Domestic - Sole Owner +RMA Domestic - Sole Owner +RMA Domestic - Sole Owner +RMA Domestic - Sole Owner +Signature Requirement +Client Relationship Agreement +Client Relationship Agreement +Client Relationship Agreement +Client Relationship Agreement +Client Relationship Agreement +Client Relationship Agreement +Client Relationship Agreement +Client Relationship Agreement +Client Relationship Agreement +Client Relationship Agreement +93830915_0177 +de 0177 2386 4771 02/12/2014 +Package ID: 0093830915 +1 +SDNY_GM_00274192 + + +de 0177 2386 4772 02/12/2014 +SDNY_GM_00274193 + + +3 +Ghislaine Maxwell +Personal Information +Name +Citizenship +Gender +Date of Birth +Marital Status +Ghislaine Maxwell +United States +Female +Single +Contact Information +Residential Address +City, State, Zip Code +Home Phone +E-mail Address +New York, NY 10065-7007 +(212) 535 - 6833 +Employment Information +Employment Status +Occupation +Occupation Industry +Employer Name +Business Address +City, State, Zip Code +Employed +Other +Other +The TerraMar Project +New York, NY 10065 - 7007 +Net Worth Information +Annual Income +Range from $200,000 - $499,999 +Liquid Assets (cash and marketable securities) +Range from $10,000,000 AND ABOVE +Net Worth (excluding primary residence) +Range from $10,000,000 AND ABOVE +You have indicated that you do not derive a substantial amount of your income / wealth (over 50%) from a +country outside of the United States. +Investment Information +Years you have held investment accounts +Equities +Bonds +Futures +Options-Buy +Options-Sell +Knowledge of investments +Percentage of total investable assets held at UBS +20 +None +None +None +None +None +You have indicated you are an experienced investor +in financial markets and market investments +Less than 20% +Other +Own Home or Rent? +Own +Affiliations +Affiliated with securities firms or broker/dealer? +No +You have indicated that you are not an employee of UBS AG, its subsidiary or affiliates. +You have indicated that you are not related to an employee of UBS AG, its subsidiary or affiliates. +U.S. Federal law requires us +to obtain, verify and record +information that identifies +each person or entity +that opens an Account with +us. When you open an +Account, we will ask for +your name, street address. +date of birth and a tax +identrication number, such +is a Socia/ Secunty number +Ne may aso ask to see a +driver's icense or other +documents that wil allow +us to Identify you. +Please review and verify all +of the information that you +provided to us when you +opened your Account. if +you have changes, +corrections or additions, +notify your Financial Advisor +as soon as possible. +If you share assets with +another person, the net +worth figure here shows +your portion oniy, based +upon instructions you +provided +Investment infornation: +This section reflects answers +you provided related to +your investment experience, +marker knowledge and +other assets and is used to +ensure our vestment +recommendations are +stable for your situation. +3 +SDNY_GM_00274194 + + +You have indicated that you are not a control person (Policy-maker, director or 10% shareholder) of a publicly +traded corporation. +4 +SDNY_GM_00274195 + + +Your Account +Account Number +Account Title +Account Address +City, State zip +Ghislaine Maxwell +New York, NY 10065-7007 +Cards and Checks for this account, if requested, will +be mailed to this address +Primary Account Holder +New York, NY 10065-7007 +Ghislaine Maxwell +UBS will not disclose your name, address and security +Disclosure of Beneficial Ownership +Action to issuers of any securities held in your +Margin +Yes +You have agreed that the Margin Agreement in the Completing Your Account Opening Process +package governs your use of margin in this account and all other accounts you have now or any +accounts that you may open in the future. As described in the Margin Agreement, certain securities +in your Account may be loaned to UBS or to other persons or entities. +Cost Basis Method +First In, First Out +Features and Services +Checking +VISA Credit (W/Rewards points) +Premier - RMA / BSA +Account Objectives and Risk Profile +Account Risk Protile +Your answers to our profiling questions: +Risk Tolerance +Aggressive/Speculative +Investment Objective +Risk/Return Objectives +Investment Time Horizon +Short-Term Liquidity Needs +Sweep Account Election +Primary Sweep Fund +High Risk +Produce a combination of income and capital +appreciation +Higher Fluctuations, Higher Returns +Longer than 10 years (through several market cycles) +No +UBS BANK USA DEPOSIT ACCOUNT +Secondary Sweep Fund +UBS AG DEPOSIT ACCOUNT +U.S. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory, beneficial +owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of their +immediate family members or close associates is a Current U.5. Political Official. +Non-U.5. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory, +eneficial owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of +heir immediate family members or close associates is a Current or Former non-U.S. Political official or non-U.S +Religious Group/Organization or Senior/Influential representative of a non-U.5. Religious Group/Organization. +Source of Funds in the Account +You have indicated the following as the source of +funds for this account: +Other Income Source +transfer +Please review the information +about each of your accounts +and notty your financal +Advisor immediately if you +have any changes or +corrections. +For more information, please +refer to the UBS Deposit +Account Sweep Program +Disclosure Statement. +ase note the account i +ofile and investme +profiles and investment +objectives. +Your Account Risk Profile for +this particular account is defined +as: +Aggressive: Willing to accept +hugh risk to principal and Migh +volatility to seek high retums over +time. +Different accounts may have +different risk profiles +ur Investment Objecti +oduce a Combination +Income and Capital +Appreciation Investments +seeking both the generation of +income and growth of principal. +A senior political official is +defined as a President or Vice +President, Cabinet Merber, +Supreme Court Justice, +member of the Joint Chief's +Staff, Member of Congress or +a Parliament, Chairperson, +Head or Servor Leader of a +SDNY_GM_00274196 + + +Electronic Delivery of Shareholder Communications: You have elected to receive shareholder communications +Via detons of this set in this UBS account. Please refer to Client Relationship Agreement for Terms and +E-mail Address +UBS Credit Card Profile (With Rewards points) +Applicant +UBS Card Program +Card Security Contact Phone Number (Applicant) +GHISLAINE MAXWELL +UBS Visa Signature Credit Card +(212) 535-6833 +SDNY_GM_00274197 + +Your Account +Account Number +Account Title +Account Address +City, State zip +Ghislaine Maxwell +New York, NY 10065-7007 +ards and Checks tor this account, if requested, wi +e mailed to this address +Primary Account Holder +New York, NY 10065-7007 +Ghislaine Maxwell +UBS will not disclose your name, address and security +Disclosure of Beneficial Ownership +position to issuers of any securities held in your +Margin +No +If you did not choose Margin when you opened this account, you may ask to establish margin by +contacting your Financial Advisor. You agree that the Margin Agreement in the Completing Your +Account Opening Process package will govern your use of margin in this account and all other +accounts you have now or may open in the future. +Cost Basis Method +First In, First Out +Features and Services +Premier- RMA / BSA +Account Objectives and Risk Profile +Account Risk Profile +Your answers to our profiling questions: +Risk Tolerance +Moderate +Investment Objective +Risk/Return Objectives +Investment Time Horizon +Short-Term Liquidity Needs +Moderately High Risk +Produce a combination of income and capital +appreciation +Moderate Fluctuations, Moderate Returns +7 - 10 years +Yes +Sweep Account Election +Primary Sweep Fund +UBS BANK USA DEPOSIT ACCOUNT +Sweep Cap Election +Yes +Cap Amount +$250000.00 +Secondary Sweep Fund +UBS AG DEPOSIT ACCOUNT +U.5. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory, beneficial +owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of their +immediate family members or close associates is a Current U.S. Political Official. +Non-U.S. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory, +beneficial owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of +their immediate family members or close associates is a Current or Former non-U.S. Political official or non-U.5. +Religious Group/Organization or Senior/Influential representative of a non-U.S. Religious Group/Organization. +Please review the information +about each of your accounts +and notify your Financial +Advisor immediately if you +have any changes or +corrections. +For more information, please +refer to the LIBS Deposit +count sweep Progra +sclosure Statemer +Please note: the account risk +profile and investment +objective below are specific only +To this account other accounts +may have different account risk +profiles and investment +objectives. +Your Account Risk Profile for +this particular account is defined +as: +Moderate Willing to accept +me risk to principal and toler +me volatility to seek hig +returns. +Different accounts may have +different risk profiles +Your Investment Objective +Produce a Combination of +Income and Capital +Appreciation: investments +seeking both the generation of +income and growth of principal. +In accounts with conservative +or moderate risk profiles, +investment eligibility +considerations help us +Identify whether you may be +eligible to invest in certain +higher risk securities as a +portion of your portfolio. +These investments offer +additional diversification. +A senior political official is +defined as a President or Vice +President, Cabinet Member, +Supreme Court Justice, +member of the Joint Chief's +Staft, Member of Congress o +a Parliament, Chairperson +Head or Senior Leader of a +Source of Funds in the Account +You have indicated the following as the source of +funds for this account: +Other Income Source +transter +7 +SDNY_GM_00274198 + + +Account ( +Information +Electronic Delivery of Shareholder Communications: You have elected to receive shareholder communications +ionditions or fois set in this US account. Please refer to Client Relationship Agreement for Terms and +E-mail Address +8 +SDNY_GM_00274199 + + +Your Account +Account Number +Account Title +Account Address +City, State zip +Ghislaine Maxwell +New York, NY 10065-7007 +ards and Checks tor this account, if requested, wi +e mailed to this addres +Primary Account Holder +New York, NY 10065-7007 +Ghislaine Maxwell +UBS will not disclose your name, address and security +Disclosure of Beneficial Ownership +position to issuers of any securities held in your +Margin +No +If you did not choose Margin when you opened this account, you may ask to establish margin by +contacting your Financial Advisor. You agree that the Margin Agreement in the Completing Your +Account Opening Process package will govern your use of margin in this account and all other +accounts you have now or may open in the future. +Cost Basis Method +First In, First Out +Features and Services +Premier- RMA / BSA +Account Objectives and Risk Profile +Account Risk Profile +Your answers to our profiling questions: +Risk Tolerance +Moderate +Investment Objective +Risk/Return Objectives +Investment Time Horizon +Moderately High Risk +Produce a combination of income and capital +appreciation +Higher Fluctuations, Higher Returns +7 - 10 years +Short-Term Liquidity Needs +Sweep Account Election +Primary Sweep Fund +UBS BANK USA DEPOSIT ACCOUNT +Sweep Cap Election +Yes +Cap Amount +$250000.00 +Secondary Sweep Fund +UBS AG DEPOSIT ACCOUNT +J.5. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory, beneticia +owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of their +immediate family members or close associates is a Current U.S. Political Official. +Non-U.S. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory, +beneficial owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of +their immediate family members or close associates is a Current or Former non-U.S. Political official or non-U.S. +Religious Group/Organization or Senior/Influential representative of a non-U.S. Religious Group/Organization. +Please review the information +about each of your accounts +and notify your Financial +Advisor immediately if you +have any changes or +corrections. +For more information, please +refer to the LIBS Deposit +count Sweep Progra +closure Stateme +Please note: the account risk +profile and investment +objective below are specific only +To this account other accounts +may have different account risk +profiles and investment +objectives. +Your Account Risk Profile for +this particular account is defined +as: +Moderate Willing to accept +me risk to principal and toler +me volatility to seek hig +returns. +Different accounts may have +different risk profiles +Your Investment Objective +Produce a Combination of +Income and Capital +Appreciation: investments +seeking both the generation of +income and growth of principal. +In accounts with conservative +or moderate risk profiles, +investment eligibility +considerations help us +Identify whether you may be +eligible to invest in certain +higher risk securities as a +portion of your portfolio. +These investments offer +additional diversification. +A senior political official is +defined as a President or Vice +President, Cabinet Member, +Supreme Court Justice, +member of the Joint Chief's +Staft, Member of Congress o +1 Panament, Chairpersor +Head or Senior Leader of a +Source of Funds in the Account +You have indicated the following as the source of +funds for this account: +Other Income Source +transter +SDNY_GM_00274200 +9 + + +Electronic Delivery of Shareholder Communications: You have elected to receive shareholder communications +conditions of foris se in this UBS account. +Please refer to Client Relationship Agreement for Terms and +E-mail Address +10 +SDNY_GM_00274201 + + +11 +Your Account +Account Number +Account Title +Account Address +City, State zip +Ghislaine Maxwell +New York, NY 10065-7007 +Cards and Checks for this account, if requested, will +be mailed to this address: +Primary Account Holder +New York, NY 10065-7007 +Ghislaine Maxwell +UBS will not disclose your name, address and security +Disclosure of Beneficial Ownership +Action to issues of any securities held in your +Margin +No +If you did not choose Margin when you opened this account, you may ask to establish margin by +contacting your Financial Advisor. You agree that the Margin Agreement in the Completing Your +count Opening Process package will govern your use of margin in this account and all oth +counts you have now or may open in the futur +Cost Basis Method +First In, First Out +Features and Services +Premier - RMA / BSA +Account Objectives and Risk Profile +Account Risk Profile +Your answers to our profiling questions: +Risk Tolerance +Moderate +Investment Objective +Risk/Return Objectives +Investment Time Horizon +Short-Term Liquidity Needs +Moderately High Risk +Produce a combination of income and capital +appreciation +Moderate Fluctuations, Moderate Returns +7 - 10 years +No +Sweep Account Election +Primary Sweep Fund +UBS BANK USA DEPOSIT ACCOUNT +Sweep Cap Election +Yes +Cap Amount +S250000.00 +Secondary Sweep Fund +UBS AG DEPOSIT ACCOUNT +J.5. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory, beneficial +owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of their +immediate family members or close associates is a Current U.S. Political Official. +Non-U.5. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory, +beneficial owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of +their immediate family members or close associates is a Current or Former non-U.S. Political official or non-U.5. +Religious Group/Organization or Senior/Influential representative of a non-U.5. Religious Group/Organization. +Source of Funds in the Account +You have indicated the following as the source of +funds for this account: +Other Income Source +transfer +Please review the information +about each of your accounts +and notify your Financial +Advisor immediately if you +have any changes or +corrections. +For more information, please +refer to the UBS Deposit +ccount Sweep progra +isclosure Statemer +Please note: the account risk +profile and investment +objective below are specific only +to this account: other accounts +may have different account risk +profiles and investment +objectives. +Your Account Risk Profile for +this particular account is defined +a5: +Moderate: Willing to accept +me nsk to principal and tolera +me volatity to seek higr +returs. +Different accounts may have +different risk profiles +Your Investment Objective +Produce a Combination of +Income and Capital +Appreciation. Investments +seeking both the generation of +income and growth of principa! +in accounts wth conservative +or moderate risk profiles, +investment eligibility +considerations help us +identify whether you may be +eligible to invest in certain +higher risk securities as a +portion of your portfolio. +These investments offer +additional diversification. +A senior political official is +defined as a President or Vice +President, Cabinet Member, +Supreme Court Justice, +member of the Joint Chief's +Head or Senior Leader of a +11 +SDNY_GM_00274202 + + +Electronic Delivery of Shareholder Communications: You have elected to receive shareholder communications +conditions of foris se in this UBS account. +Please refer to Client Relationship Agreement for Terms and +E-mail Address +12 +SDNY_GM_00274203 + + +13 +Your Account +Account Number +Account Title +Account Address +City, State zip +Ghislaine Maxwell +New York, NY 10065-7007 +Cards and Checks for this account, if requested, will +be mailed to this address +Primary Account Holder +New York, NY 10065-7007 +Ghislaine Maxwell +UBS will not disclose your name, address and security +Disclosure of Beneficial Ownership +Account issue any securities held in your +Margin +No +If you did not choose Margin when you opened this account, you may ask to establish margin by +contacting your Financial Advisor. You agree that the Margin Agreement in the Completing Your +count Opening Process package will govern your use of margin in this account and all oth +counts vou have now or may open in the futur +Cost Basis Method +First In, First Out +Features and Services +Premier - RMA / BSA +Account Objectives and Risk Profile +Account Risk Profile +Your answers to our profiling questions: +Risk Tolerance +Moderate +Investment Objective +Risk/Return Objectives +Investment Time Horizon +Short-Term Liquidity Needs +Moderately High Risk +Produce a combination of income and capital +appreciation +Moderate Fluctuations, Moderate Returns +7 - 10 years +No +Sweep Account Election +Primary Sweep Fund +UBS BANK USA DEPOSIT ACCOUNT +Sweep Cap Election +Yes +Cap Amount +S250000.00 +Secondary Sweep Fund +UBS AG DEPOSIT ACCOUNT +J.5. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory, beneficia +owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of their +immediate family members or close associates is a Current U.S. Political Official. +Non-U.5. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory, +beneficial owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of +their immediate family members or close associates is a Current or Former non-U.S. Political official or non-U.S. +Religious Group/Organization or Senior/Influential representative of a non-U.5. Religious Group/Organization. +Source of Funds in the Account +You have indicated the following as the source of +funds for this account: +Other Income Source +transfer +Please review the information +about each of your accounts +and notify your Financial +Advisor immediately if you +have any changes or +corrections. +For more information, please +refer to the UBS Deposit +iccount Sweep Progra +isclosure Statemen +Please note: the account risk +profile and investment +objective below are specific only +to this account: other accounts +may have different account risk +profiles and investment +objectives. +Your Account Risk Profile for +this particular account is defined +a5: +Moderate: Willing to accept +me nsk to principal and tolera +me volatity to seek higr +returs. +Different accounts may have +different risk profiles +Your Investment Objective +Produce a Combination of +Income and Capital +Appreciation. Investments +seeking both the generation of +income and growth of principa! +in accounts wth conservative +or moderate risk profiles, +investment eligibility +considerations help us +identify whether you may be +eligible to invest in certain +higher risk securities as a +portion of your portfolio. +These investments offer +additional diversification. +A senior political official is +defined as a President or Vice +President, Cabinet Member, +Supreme Court Justice, +member of the Joint Chief's +Head or Senior Leader of a +SDNY_GM_00274204 + + +Electronic Delivery of Shareholder Communications: You have elected to receive shareholder communications +conditions of for set in this US account. Please refer to Client Relationship Agreement for Terms and +E-mail Address +14 +SDNY_GM_00274205 + + +Your Account +Account Number +Account Title +Account Address +City, State zip +Ghislaine Maxwell +New York, NY 10065-7007 +Cards and Checks for this account, if requested, will +be mailed to this address +Primary Account Holder +New York, NY 10065-7007 +Ghislaine Maxwell +UBS will not disclose your name, address and security +Disclosure of Beneficial Ownership +Asion to issuers of any securities held in your +Margin +No +If you did not choose Margin when you opened this account, you may ask to establish margin by +contacting your Financial Advisor. You agree that the Margin Agreement in the Completing Your +count Opening Process package will govern your use of margin in this account and all oth +counts vou have now or may open in the futur +Cost Basis Method +First In, First Out +Features and Services +Premier - RMA / BSA +Account Objectives and Risk Profile +Account Risk Profile +Your answers to our profiling questions: +Risk Tolerance +Moderate +Investment Objective +Risk/Return Objectives +Investment Time Horizon +Short-Term Liquidity Needs +Moderately High Risk +Produce a combination of income and capital +appreciation +Higher Fluctuations, Higher Returns +7 - 10 years +No +Sweep Account Election +Primary Sweep Fund +UBS BANK USA DEPOSIT ACCOUNT +Sweep Cap Election +Yes +Cap Amount +S250000.00 +Secondary Sweep Fund +UBS AG DEPOSIT ACCOUNT +J.5. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory, beneficia +owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of their +immediate family members or close associates is a Current U.S. Political Official. +Non-U.5. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory, +beneficial owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of +their immediate family members or close associates is a Current or Former non-U.S. Political official or non-U.S. +Religious Group/Organization or Senior/Influential representative of a non-U.5. Religious Group/Organization. +Please review the information +about each of your accounts +and notify your Financial +Advisor immediately if you +have any changes or +corrections. +For more information, please +refer to the UBS Deposit +iccount Sweep Progra +Asclosure Statemen +Please note: the account risk +profile and investment +objective below are specific only +to this account: other accounts +may have different account risk +profiles and investment +objectives. +Your Account Risk Profile for +this particular account is defined +a5: +Moderate: Willing to accept +me nsk to principal and tolera +me volatity to seek higr +returs. +Different accounts may have +different risk profiles +Your Investment Objective +Produce a Combination of +Income and Capital +Appreciation. Investments +seeking both the generation of +income and growth of principa! +in accounts wth conservative +or moderate risk profiles, +investment eligibility +considerations help us +identify whether you may be +eligible to invest in certain +higher risk securities as a +portion of your portfolio. +These investments offer +additional diversification. +A senior political official is +defined as a President or Vice +President, Cabinet Member, +Supreme Court Justice, +member of the Joint Chief's +Head or Senior Leader of a +Source of Funds in the Account +You have indicated the following as the source of +funds for this account: +Other Income Source +transfer +15 +SDNY_GM_00274206 + + +Electronic Delivery of Shareholder Communications: You have elected to receive shareholder communications +conditions of foris se in this UBS account. +Please refer to Client Relationship Agreement for Terms and +E-mail Address +16 +16 +SDNY_GM_00274207 + +17 +Your Account +Account Number +Account Title +Account Address +City, State zip +Ghislaine Maxwell +New York, NY 10065-7007 +Cards and Checks for this account, if requested, will +be mailed to this address +Primary Account Holder +New York, NY 10065-7007 +Ghislaine Maxwell +UBS will not disclose your name, address and security +Disclosure of Beneficial Ownership +counto sues any securities held in your +Margin +No +If you did not choose Margin when you opened this account, you may ask to establish margin by +contacting your Financial Advisor. You agree that the Margin Agreement in the Completing Your +count Opening Process package will govern your use of margin in this account and all oth +counts vou have now or may open in the futur +Cost Basis Method +First In, First Out +Features and Services +Premier - RMA / BSA +Account Objectives and Risk Profile +Account Risk Profile +Your answers to our profiling questions: +Risk Tolerance +Moderate +Investment Objective +Risk/Return Objectives +Investment Time Horizon +Short-Term Liquidity Needs +Moderately High Risk +Produce a combination of income and capital +appreciation +Moderate Fluctuations, Moderate Returns +7 - 10 years +No +Sweep Account Election +Primary Sweep Fund +UBS BANK USA DEPOSIT ACCOUNT +Sweep Cap Election +Yes +Cap Amount +S250000.00 +Secondary Sweep Fund +UBS AG DEPOSIT ACCOUNT +J.5. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory, beneficial +owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of their +immediate family members or close associates is a Current U.S. Political Official. +Non-U.5. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory, +beneficial owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of +their immediate family members or close associates is a Current or Former non-U.S. Political official or non-U.5. +Religious Group/Organization or Senior/Influential representative of a non-U.S. Religious Group/Organization. +Source of Funds in the Account +You have indicated the following as the source of +funds for this account: +Other Income Source +transfer +Please review the information +about each of your accounts +and notify your Financial +Advisor immediately if you +have any changes or +corrections. +For more information, please +refer to the UBS Deposit +count Sweep Proor: +sclosure Statemer +Please note: the account risk +profile and investment +objective below are specific only +to this account: other accounts +may have different account risk +profiles and investment +objectives. +Your Account Risk Profile for +this particular account is defined +a5: +Moderate: Willing to accept +me nsk to principal and tolera +me volatity to seek higr +returs. +Different accounts may have +different risk profiles +Your Investment Objective +Produce a Combination of +Income and Capital +Appreciation. Investments +seeking both the generation of +income and growth of principa! +in accounts wth conservative +or moderate risk profiles, +investment eligibility +considerations help us +identify whether you may be +eligible to invest in certain +higher risk securities as a +portion of your portfolio. +These investments offer +additional diversification. +A senior political official is +defined as a President or Vice +President, Cabinet Member, +Supreme Court Justice, +member of the Joint Chief's +Head or Senior Leader of a +SDNY_GM_00274208 + + +Electronic Delivery of Shareholder Communications: You have elected to receive shareholder communications +Conditions or tors series accounte +Please refer to Client Relationship Agreement for Terms and +E-mail Address +18 +18 +SDNY_GM_00274209 + + +19 +Your Account +Account Number +Account Title +Account Address +City, State zip +Ghislaine Maxwell +New York, NY 10065-7007 +Cards and Checks for this account, if requested, will +be mailed to this address +Primary Account Holder +New York, NT T0065-7007 +Ghislaine Maxwell +UBS will not disclose your name, address and security +Disclosure of Beneficial Ownership +position to issuers of any securities held in your +Margin +No +If you did not choose Margin when you opened this account, you may ask to establish margin by +contacting your Financial Advisor. You agree that the Margin Agreement in the Completing Your +count Opening Process package will govern your use of margin in this account and all oth +counts vou have now or may open in the futur +Cost Basis Method +First In, First Out +Features and Services +Premier - RMA / BSA +Account Objectives and Risk Profile +Account Risk Profile +Your answers to our profiling questions: +Risk Tolerance +Moderate +Investment Objective +Risk/Return Objectives +Investment Time Horizon +Short-Term Liquidity Needs +Moderately High Risk +Produce a combination of income and capital +appreciation +Moderate Fluctuations, Moderate Returns +7 - 10 years +No +Sweep Account Election +Primary Sweep Fund +UBS BANK USA DEPOSIT ACCOUNT +Sweep Cap Election +Yes +Cap Amount +S250000.00 +Secondary Sweep Fund +UBS AG DEPOSIT ACCOUNT +J.5. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory, beneficial +owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of their +immediate family members or close associates is a Current U.S. Political Official. +Non-U.5. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory, +beneficial owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of +their immediate family members or close associates is a Current or Former non-U.S. Political official or non-U.S. +Religious Group/Organization or Senior/Influential representative of a non-U.5. Religious Group/Organization. +Source of Funds in the Account +You have indicated the following as the source of +funds for this account: +Other Income Source +transter +Please review the information +about each of your accounts +and notify your Financial +Advisor immediately if you +have any changes or +corrections. +For more information, please +refer to the UBS Deposit +ccount Sweep progra +isclosure Statemen +Please note: the account risk +profile and investment +objective below are specific only +to this account: other accounts +may have different account risk +profiles and investment +objectives. +Your Account Risk Profile for +this particular account is defined +a5: +Moderate: Willing to accept +me nsk to principal and tolera +me volatity to seek higr +returs. +Different accounts may have +different risk profiles +Your Investment Objective +Produce a Combination of +Income and Capital +Appreciation. Investments +seeking both the generation of +income and growth of principa! +in accounts wth conservative +or moderate risk profiles, +investment eligibility +considerations help us +identify whether you may be +eligible to invest in certain +higher risk securities as a +portion of your portfolio. +These investments offer +additional diversification. +A senior political official is +defined as a President or Vice +President, Cabinet Member, +Supreme Court Justice, +member of the Joint Chief's +Head or Senior Leader of a +SDNY_GM_00274210 +19 + + +Electronic Delivery of Shareholder Communications: You have elected to receive shareholder communications +conditions of this ser ithis UBS account. Please refer to Client Relationship Agreement for Terms and +E-mail Address +20 +SDNY_GM_00274211 +20 + + +21 +Your Account +Account Number +Account Title +Account Address +City, State zip +Ghislaine Maxwell +New York, NY 10065-7007 +Cards and Checks for this account, if requested, will +be mailed to this address +Primary Account Holder +NEW TOIR, NT 10065-7007 +Ghislaine Maxwell +UB5 will not disclose your name, address and security +Disclosure of Beneficial Ownership +Account issuers of any securities held in your +Margin +No +If you did not choose Margin when you opened this account, you may ask to establish margin by +contacting your Financial Advisor. You agree that the Margin Agreement in the Completing Your +Account Opening Process package will govern your use of margin in this account and all other +accounts you have now or may open in the future. +Cost Basis Method +First In, First Out +Features and Services +Premier- RMA / BSA +Account Objectives and Risk Profile +Account Risk Profile +Your answers to our profiling questions: +Risk Tolerance +Moderate +Investment Objective +Risk/Return Objectives +Investment Time Horizon +Short-Term Liquidity Needs +Moderately High Risk +Produce a combination of income and capital +appreciation +Higher Fluctuations, Higher Returns +7 - 10 years +No +Sweep Account Election +Primary Sweep Fund +UBS BANK USA DEPOSIT ACCOUNT +Sweep Cap Election +Yes +Cap Amount +$250000.00 +Secondary Sweep Fund +UBS AG DEPOSIT ACCOUNT +U.5. Senior Political Affiliation: You have indicated that no account holder +, an authorized signatory, beneticia +owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of their +immediate family members or close associates is a Current U.5. Political Official. +Non-U.5. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory, +kagos croup ranso anothers presente of nuts agou Group gentrang . +Source of Funds in the Account +You have indicated the following as the source of +funds for this account: +Other Income Source +transfer +Please review the information +about each of your accounts +and notify your Financial +Advisor immediately if you +have any changes or +corrections. +For more information, please +refer to the UBS Deposit +count sweep progr +closure Stateme +lease note the account ni +rofile and investmer +to this color ate ecou only +may have different account risk +profiles and investment +objectives. +Your Account Risk Profile to +this particular account is definer +85: +Moderate: Willing to accept +some vik to py to set and halerate +returns. +Different accounts may have +different risk profiles +Your Investment Objective +Produce a Combination of +income and Capital +Appreciation. Investments +seeking both the generation of +income and growth of principal +in accounts wth conservative +or moderate risk profiles, +investment eligibility +considerations help us +identify whether you may be +eligible to invest in certain +higher risk securities as a +porton of your portfolio +These investments offer +additional diversification. +A servor political official is +defined as a President or Vice +President, Cabinet Member, +Supreme Court Justice, +member of the Joint Chief's +f, Member of Congress +arliament, Chairpers +Head or Senior Leader of a +21 +SDNY_GM_00274212 + + +Electronic Delivery of Shareholder Communications: You have elected to receive shareholder communications +conditions of this serviceis UBS account. +Please refer to Client Relationship Agreement for Terms and +E-mail Address +22 +SDNY_GM_00274213 +22 + + +23 +Your Account +Account Number +Account Title +Account Address +City, State zip +Ghislaine Maxwell +New York, NY 10065-7007 +Cards and Checks for this account, if requested, will +be mailed to this address: +Primary Account Holder +New York, NY 10065-7007 +Ghislaine Maxwell +UBS will not disclose your name, address and security +Disclosure of Beneficial Ownership +position to issuers of any securities held in your +Margin +No +If you did not choose Margin when you opened this account, you may ask to establish margin by +contacting your Financial Advisor. You agree that the Margin Agreement in the Completing Your +Account Opening Process package will govern your use of margin in this account and all other +accounts you have now or may open in the future. +Cost Basis Method +First In, First Out +Features and Services +Premier- RMA / BSA +Account Objectives and Risk Profile +Account Risk Profile +Your answers to our profiling questions: +Risk Tolerance +Moderate +Investment Objective +Risk/Return Objectives +Investment Time Horizon +Short-Term Liquidity Needs +Moderately High Risk +Produce a combination of income and capital +appreciation +Moderate Fluctuations, Moderate Returns +7 - 10 years +No +Sweep Account Election +Primary Sweep Fund +UBS BANK USA DEPOSIT ACCOUNT +Sweep Cap Election +Yes +Cap Amount +$250000.00 +Secondary Sweep Fund +UBS AG DEPOSIT ACCOUNT +U.5. Senior Political Affiliation: You have indicated that no account holder +, an authorized signatory, beneticia +owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of their +immediate family members or close associates is a Current U.S. Political Official. +Non-U.5. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory, +beneficial owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of +their immediate family members or close associates is a Current or Former non-U.S. Political official or non-U.5. +Religious Group/Organization or Senior/Influential representative of a non-U.S. Religious Group/Organization. +Source of Funds in the Account +You have indicated the following as the source of +funds for this account: +Other Income Source +transfer +Please review the information +about each of your accounts +and notify your Financial +Advisor immediately if you +have any changes or +corrections. +For more information, please +refer to the UBS Deposit +ccount Sweep progra +isclosure Statemer +Please note the account risk +profile and investment +objective below are specific only +to this account: other accounts +may have different account risk +profiles and investment +objectives. +Your Account Risk Profile to +this particular account is definer +85: +Moderate: Willing to accept +some vik to py to seal and halerate +returns. +Different accounts may have +different risk profiles +Your Investment Objective +Produce a Combination of +income and Capital +Appreciation. Investments +seeking both the generation of +income and growth of principal +in accounts wth conservative +or moderate risk profiles, +investment eligibility +considerations help us +identify whether you may be +eligible to invest in certain +higher risk securities as a +porton of your portfolio +These investments offer +additional diversification. +A servor political official is +defined as a President or Vice +President, Cabinet Member, +Supreme Court Justice, +member of the Joint Chief's +aft, Member of Congress +Pariament, Chairperst +Head or Senior Leader of a +SDNY_GM_00274214 +23 + + +Electronic Delivery of Shareholder Communications: You have elected to receive shareholder communications +Vianditions of for serin this US account. Please refer to Client Relationship Agreement for Terms and +E-mail Address +24 +24 +SDNY_GM_00274215 + + +de 0177 2398 4795 02/12/2014 +Introduction +At UBS, we understand that we succeed only when our clients succeed. With that in mind, +we provide a customized approach to wealth management, built on your personal +relationship with your Financial Advisor and shaped by an understanding of your needs +and aspirations. +Known as the Client Relationship Agreement, this document outlines the terms and +onditions of your relationship with us. By maintaining your Accounts at UBS, you agree t +hese terms and conditions and the other agreements and disclosures we refer to here. I +signatures are required, please return the signed signature page in the enclosed envelope. +us promptly if there are any updates or corrections. +Please note: this Client Relationship Agreement applies to all of your accounts at UBS, +including any Accounts you may already have with us and Accounts you may open in the +future. You will not receive another copy of the Client Relationship Agreement or the +Agreements and Disclosures unless there are updates and amendments, or if we require +your signature on this Agreement when you open Accounts in another capacity. Some of +the information in this document and the other agreements and disclosures we send you +may not apply to you now. Please retain these documents for future reference because +they contain important information if you decide to add services or open new Accounts. +The terms and conditions in this Client Relationship Agreement apply to all Accounts you +open with UBS Financial Services Inc. or UBS Financial Services Incorporated of Puerto Rico +or any other introducing broker-dealer that has a clearing agreement with UBS Financial +Services Inc. In addition, we will send you other agreements and disclosures for the UBS +ccounts and services you choose when you open your account, as well as features you +nay add in the future. We refer to all these documents, including any amendments, as the +Agreements and Disclosures booklet. +Your acceptance of your initial Client Relationship Agreement will serve as your agreement +to the terms and conditions governing any new Accounts, features or services. Deposits of +cash or securities and your continued use of your UBS Accounts constitute your agreement +to all of the terms and conditions applicable to your Accounts. If you do not agree to the +terms and conditions, you may cancel a feature or service or close vour account. +As a UBS client, you may decide to open additional Accounts or take advantage of services +and account features in the future. With some exceptions, you will be able to do so +without signing additional documents or agreements. Upon approval of your accounts and +"Accounts" refers to all securities +accounts, brokerage accounts, +margin accounts, deposit accounts or +other accounts you open with us +now or in the future. +We refer to the Client Relationship +Agreement together with all other +agreements and disclosures that we +make avail, to yor, andamentvith you +We also refer to the "Completing +Your Account Opening Process"" +package, which includes Signature +Pages, optional forms and other +required documents. +if a Signature Page is included, please +have all named account holders sign +the Signature Page and return it to +us in the enclosed envelope. +This column contains important +definitions applicable to our +Agreement with you. +"You," "your" and "yours" refer to +you as a client of UBS. +"UBS," "We, " "us, " "our" and "ours" +refer to UBS Financial Services Inc. +and unless we indicate otherwise, its +successor firms, subsidiaries, +coresponds ta and aflamy, uss +"Affiliates" refers to UBS Financial +Services incorporated of Puerto Rico +(which clears through UBS Financia +Services Inc.), UBS Bank USA, UBS +Vil fen a sacies for our your rancil disor wil a very dear on ed rear +other subsidiaries and affiliates. +25 +SDNY_GM_00274216 + + +Please refer to the Fees and Charges +section of the Agreements and +Antosures bout or mand charges. +If you have questions, please contac +unpaid fees and charges. +26 +Representations +By signing a Client Relationship Agreement, you make the following representations: +• You are at least 18 years old or have reached the age of majority according to the laws +of the state in which you reside and the laws of the State of New York. +You have notified us if you, your spouse or any beneficial owner of the Accounts) are +or become employed by any of the following: a member firm of FINRA or other +exchange (including broker/dealer subsidiary of a bank, insurance company or other +financial institution), or securities or commodities exchange or self-regulatory +organization or any of their affiliated organizations or UBS's independent auditor. You +agree to notify us promptly of any changes. +No one other than you, and the individuals identified to UBS in connection with the +opening of the Account, has or will have an interest in your Account unless you notify +us in writing and UBS Financial Services Inc. agrees to continue to carry the Account. +• All of the personal and financial information you have supplied to UBS is true and +accurate, and you will notify UBS promptly of any material changes, particularly the +information regarding your residence, financial situation, investment objectives or tax +• You understand that UBS provides financial and investment services only and does not +provide legal or tax advice. +• You represent that you have fulfilled and will continue to fulfill all tax related and +reporting obligations associated with any assets in your UBS accounts. +• If you are acting as executor, trustee, conservator, guardian or custodian: +- You understand that you are a fiduciary on behalf of the beneficial owners +of the Account and that you have a duty to use the services and features +provided through the Account for the benefit of the beneficial owners of +the Account and not for your own benefit. +- You acknowledge that you will make an independent determination that +any activity in the Account is suitable and appropriate for the beneficial +owners and that the compensation we receive is reasonable. +- You understand and agree that this determination is solely your +responsibility and not ours. +Fees and Charges +As a client of UBS, you agree to pay all fees and charges relating to your accounts for any +secutes transactions fees for spectic ses ces you equest and ces or barges gy a es for +party that we incur in the course of providing services to you. +Please review and verify the +information about you and your +Accounts in the "Completing Your +Account Opening Process" package. +If you have questions, changes or +corrections, call your Financial +Advisor. +SDNY_GM_00274217 + + +de 0177 2399 4797 02/12/2014 +Individual Retirement Accounts +The Agreements and Disclosures booklet contains the UBS IRA Custodial Agreements and +the IRA Disclosure Statements that apply to any Traditional, Roth, SEP or SIMPLE Individual +stirement Accounts (IRAs) vou open with us now or in the future. If we make changes t +ne UBS IRA Custodial Agreement and the IRA Disclosure Statement we will send yo +updated documents, and you agree to be subject to those updated terms and conditions. +ccording to the UBS IRA Custodial Agreements, UBS Financial Services Inc. is named a +he custodian of vour IRA when we accept the Account. At vour death, the beneficiary o +beneficiaries whose name(s) are shown on the Account Intormation pages of the +Completing Your New Account Process package will become entitled to your IRA +Beneficiaries must be named in writing. Your written designation may apply to future +accounts, and in that case, we will confirm your designation in the Completing Your +Custodial Account fee in connection with this IRA. +If this IRA account is funded via transfer from a non-UBS account, you represent that all +dicated on this IRA Account Application (eng., Traditional IRA, Roth IRA) and/or a dire +dicated on this IRA Account Application (e.a., T +rollover from a qualified plan which named you as beneficiary. +Mand you s entasy. +Accounts with Cash Management Features +the cash management features you may select. All requests to enroll in cash management +features are subject to approval. We consider your continued use of your Account as your +acceptance of the applicable terms and conditions. +There are important differences in the cash management features and other services that +re available to U.S. residents through UBS accounts and those that are available to client +who reside outside the U.S. For example, we have different sweep programs for uninvester +ash and different Card programs for these accounts. This agreement and the Agreement +ind Disclosures booklet describe which programs apolv to which types of accounts +Verbal Authorization to Upgrade or Add Cash Management Features to an Account +For any account you have with us now or may open in the future, we may accept verbal +requests to upgrade or add cash management features to your Account. Generally, we +permit any authorized person to provide verbal instructions to upgrade or add services to +your Account unless you instruct us otherwise. In some circumstances, we may ask you o +another person who is named on the account to sign additional documents or provide +additional information for those additional features. We will provide you updated term: +and conditions for the services you request if we have not already sent them to you or +another owner of the Account. We consider your use of the Account as your acceptance of +the applicable terms and conditions. +Our Sweep Options and Your Sweep Election +As a service to you, we offer options for the automatic investment or deposit of available +cash balances ("sweep") in your Accounts. Current Sweep Options include the UBS Bank +Sweep Programs and the Sweep Funds. The available Sweep Options and their features, +discontinuing specific Sweep Options. We may establish criteria for Sweep Options offered +to different člients, including, but not limited to, establishing minimum asset requirements +for clients to qualify for specific Sweep Options. +You authorize and direct us to deposit or invest your available cash balances on each +business day in your Sweep Option and to withdraw your funds from, or liguidate vour +The features and fees of your IRA are +fully described in the Agreements +and Disclosures booklet. +Please note: UBS does not extend +margin for Individual Retirement +Accounts. +Employers with a SEP IRA or SIMPLE +A plan tor their businesses mu +an a separate plan document. I +accept any approved plan +whether they were produced by UBS, +an IRS model or a document from +copy of the SEP IRA Plan or SIMPLE +RA Plan prototype document fron +UBS offers a variety of accounts with +cash management features, including +the Resource Management +Account® (RMA), Business Services +Account BSA® (BSA) and +International Resource Management +Account@ (IRMA®). +• Debit cards +Credit cards +Rewards programs +Eil Paymic Runds Transfer +Margin loans +Sweep Options' refers to the options +made available by UBS for the +utomatic investment or deposi +"sweep") of available cash balance +in your Account. Sweep Options +include the UBS Bank Sweep +Programs, the Sweep Funds, the +Puerto Rico Short Term Investment +Fund, the International Deposit +Account Sweep Program and any +other sweep investments we may +make available from time to time for +27 +SDNY_GM _00274218 + + +28 +shares in your Sweep Option, as described in this section and in the General Terms and +Conditions in the Agreements and Disclosures booklet, and any amendments. +Please refer to the UBS Bank Sweep Programs Disclosure Statement for a description of the +eligibility requirements for the UBS Bank Sweep Programs. If your Account is not eligible +for the UBS Bank Sweep Programs, you may select an available Sweep Fund as the Sweep +Option for your Account. +For Accounts eligible for one of the UBS Bank Sweep Programs, unless you are eligible for +and select an available tax-advantaged Sweep Fund, your Sweep Option will be one of the +UBS Bank Sweep Programs. +In general, most clients with a Resource Management Account® (RMA®), Individual +Retirement Account (IRA), Basic Investment Account, Business Services Account® (BSA®), +Coverdell Education Savings Account and certain Investment Advisory Accounts will be +eligible for one of the UBS Bank Sweep Programs. Eligibility is based primarily upon the +type of client. Most non-business clients and employee benefit plans qualified under +Section 401(a) or Section 403(b)(7) of the Internal Revenue Code of 1986, as amended, or +under any other employee retirement or welfare plan subject to the Employee Retirement +Income Security Act of 1974, as amended (ERISA) (Plans) are eligible for the Deposit +Program. In cases where a participant in a Plan has established a Securities Account for +purposes of participation in the Plan (each a Plan Participant), the Plan Participant will be +eligible for the Deposit Program. Most business clients are eligible for the Business +Program. +The UBS Bank Sweep Programs +Through each of the UBS Bank Sweep Programs, available cash balances in each eligible +Account are automatically deposited into deposit accounts at Bank USA up to the Bank +JSA Sweep Cap. Available cash balances in excess of the Bank USA Sweep Cap will be +automatically swept without limit to your Secondary Sweep Option. +Unless you select an available Sweep Fund, the Secondary Sweep Option for eligible +Accounts other than Investment Advisory Accounts is deposit accounts at AG Stamford +Branch. Investment Advisory Accounts will not sweep to the AG Stamford Branch; instead +the Secondary Sweep Option for Investment Advisory Accounts will be an available Sweep +Funds in deposit accounts at AG Stamford Branch are not eligible for FDIC +insurance or protection by SIPC. Sweep Funds are not FDIC-insured, not guaranteed by +a bank, are sold by prospectus only and may lose value. +Deposits held at Bank USA through the Business Program are subject to monthly +withdrawal limits, as described in the UBS Bank Sweep Programs Disclosure Statement. If +your withdrawals in a month reach the limit, all funds on deposit through the Business +Program will be withdrawn from Bank USA and transferred into your Secondary Sweep +Option and available cash balances will sweep to your Secondary Sweep Option for the +remainder of the month. These funds, up to the Bank USA Sweep Cap, will be transferred +back to Bank USA on the first business day of the following month. +FDIC Insurance Coverage and Limitations: If you have more than one Account that +sweeps to Bank USA, the amount deposited at Bank USA may exceed the amount covered +by FDIC insurance (currently $250,000 per insurable capacity). You are responsible for +monitoring the total amount of deposits that you have with Bank USA to +determine the extent of FDIC deposit insurance coverage available to you. Please +refer to the UBS Bank Sweep Programs Disclosure Statement for more detailed information +regarding the UBS Bank Sweep Programs and FDIC insurance. +Alternatives to the UBS Bank Sweep Programs +your available cash balances deposited with Bank USA, you may elect at any time to have +"Sweep Funds" refers to one or more +of the UBS money market funds +made available as a Sweep Option. +Sweep Funds are described in the +respective prospectuses for the UBS +RMA Funds, UBS Cashfund, UBS +Retirement Money Market Funds, +UBS Liquid Assets Fund, UBS Cash +Reserves Fund and the UBS Select +Capital Money Market Funds. +The "UBS Bank Sweep Programs" +collectively refers to the UBS Deposit +Account Sweep Program (the +"Deposit Program") and the UBS +Business Account Sweep Program +(the "Business Program") as more +fully described in the UBS Bank +Sweep Programs Disclosure +Statement. +UBS Bank USA (Member FDIC) (Bank +USA"), is an FDIC-member bank +affiliate of UBS. +UBS AG, Stamford Branch (AG +Stamford Branch") is a US branch of +UBS AG, a Swiss Bank that is the +parent of UBS Financial Services Inc. +and UBS Financial Services +Incorporated of Puerto Rico. +For clients other than Plans and Plan +participants, the Bank USA Sweep +de 0177 2399 4798 02/12/2014 +Please refer to the UBS Bank Sweep +the UBS Bank Sweep Programs work +how the Bank Sweep Cap is +determined, eligibility, interest rates +withdrawal limits, FDIC insurance and +SDNY_GM_00274219 + + +your available cash balances swept without limit to a tax-advantaged Sweep Fund or, for +Puerto Rico residents only, the Puerto Rico Short Term Investment Fund, Inc +The following tax-advantaged Sweep Funds currently are available: +• UBS RMA Tax-Free Fund Inc. +UBS RMA California Municipal Money Fund +UBS RMA New York Municipal Money Fund +The Puerto Rico Short Term Investment Fund, Inc +UBS Select Tax-Free Capital Fund (subject to minimum asset requirements) +State-specific municipal funds are intended for residents of those states only. The Puerto +Rico Short Term Investment Fund, Inc. is offered exclusively to Puerto Rico residents as +defined in the fund's prospectus. The Puerto Rico Short Term Investment Fund is not a +money market fund registered under the U.S. Investment Company Act of 1940, does not +comply with rules applicable to U.S. registered funds, presents a higher degree of risk than +those funds, and is for Puerto Rico residents holding accounts with UBS Financial Services +Incorporated of Puerto Rico only. The Puerto Rico Short Term Investment Fund and the +Sweep Funds are sold by prospectus only, and are not FDIC-insured, not guaranteed by +a bank, and may lose value. +If your Account is tax-advantaged, or is a Basic Investment Account, whether +ax-aovantaged or not, you are not eligible to select a tax-advantaged Sweep Fund as +weep Option. Tax-advantaged Accounts include, but are not limited to, Accounts o +Plans, Plan Participants and IRAs. If your tax-advantaged Account or Basic Investment +Investment Advisory Account, available cash balances must be swept through a Bank +Sweep Program. +Changing Your Sweep Option +You may change your sweep election to an available alternative Sweep Option at any time. +election by contacting your Financial Advisor. +and to the prospectuses for the Sweep Funds and the Puerto Rico Short Term Investment +Fund. +Institutional Sweep Funds and Automatic Exchanges +We may offer Institutional Sweep Funds as Sweep Options or Secondary Sweep Options +for clients (except for Plans and IRAs in investment advisory programs) who meet certain +minimum asset thresholds. Current eligibility criteria may be obtained from your Financial +Advisor. UBS may change the eligibility criteria at any time in its discretion without notice +o you. Institutional Sweep Funds will generally offer a higher yield than other Sweep +unds, though there is no guarantee that the vield will be, or will remain, higher +Clients other than Plans and Plan Participants +Your eligibility for the Institutional Sweep Funds will be determined at the end of each +Institutional Sweep Fund. +Plans and Plan Participants +A Plan's eligibility for the Institutional Sweep Funds will be determined at the end of each +month, based on the value of the Plan's QP Relationship assets, as determined in the sole +"Secondary Sweep Option" refers to +leposit accounts at AG Stamfor +Branch or one of the available Swee +Funds. +"Investment Advisory Account" refers +to an Account enrolled in any of the +following investment advisory +programs: Managed Accounts +Consulting Program, Portfolio +Management Program, ACCESS, +Managed Portfolio Program, UBS +Strategic Wealth Portfolio, UB5 +Strategic Advisor, and Private Wealth +Solutions and such other programs as +UBS may add from time to time. +Please refer to the section +"International Accounts" for +information about the sweep option +for the International RMA. +UBS Client Relationship Agr +eement +"Institutional Sweep Funds" refers to +one or more of the UBS money +marker sunch made alane by we +asset thresholds +"OP Relationship assets" is defined in +the UBS Bank Sweep Programs +Disclosure Statement. +29 +SDNY_GM_00274220 + + +30 +discretion of UBS. A Plan Participant's eligibility for the Institutional Sweep Funds will be +determined at the end of each month, based on the greater of the value of the Plan's QP +Relationship assets and the Plan Participant's Marketing Relationship assets, both as +determined in the sole discretion of UBS. If the value of a Plan's QP Relationship assets or +a Plan Participant's Marketing Relationship assets reaches the minimum asset threshold at +any time other than the end of the month, the Plan or Plan Participant will not be eligible +for an Institutional Sweep Fund. +If you are eligible for an Institutional Sweep Fund as either your Sweep Fund or your +Secondary Sweep Option for one of the Bank Sweep Programs, we will liquidate your +shares in your current Sweep Fund or your Secondary Sweep Option, as applicable, and +purchase shares in the Institutional Sweep Fund with the same investment objectives +without direction from you. Thereafter, your Sweep Fund or Secondary Sweep Option, as +applicable, will be the Institutional Sweep Fund. Once an Account's Sweep Option or +Secondary Sweep Option, as applicable, is an Institutional Sweep Fund and a first purchase +has been made into the Fund, that Institutional Sweep Fund will remain the Account's +Sweep Option or Secondary Sweep Option even if the Account's Marketing Relationship +assets cease to meet the minimum asset thresholds for that Institutional Sweep Fund. QP +Relationship assets as a means to determine eligibility will not be available until on or +about Dec 2, 2013. +Check Writing +Many UBS accounts incorporate a check writing feature. If you choose this feature for your +account, you authorize us and our Check Provider to honor checks that bear your +signature(s) and unsigned drafts that are presented on the basis of separate written +drafts are presented to the Check Provider. We may delay or deny payment if there are +insufficient available assets in your Account to cover payment on the day you write the +accounts to pay the check or draft. +Bill Payment and Electronic Funds Transfer Services +апу UBS accounts incorporate the Bill Payment and Electronic Funds Transfer services. I +ou enroll in these services, you authorize UBS and its processing bank to effect the type +A green. This senice agreement also apies to other ileuroni transers to or rom +your Accounts, including transfers made with UBS CashConnect feature and certain +payments made through the Automated Clearing House ("ACH") system, even if you do +not enroll in this service. +"Check Provider" is the provider and +processor we have appointed to +landle payment of your checks and +drafts. We reserve the right to +change check providers from time to +The Bill Payment and Electronic Funds +Transfer Service Agreement is locateo +in the Agreements and Disclosures +booklet. +Bly escats in the sailable to +Transfers through the ACH system +are only available to and from +accounts at financial institutions and +banks within the U.S. +de 0177 2400 4800 02/12/2014 +SDNY_GM_00274221 + + +UBS Visa Debit Card for RMA or BSA +Brokerage accounts with cash management features include the UBS Visa Debit Card +"Withdrawal Limit," as described in the Agreements and Disclosures booklet. +and transactions may be denied if there are insufficient assets in your account to make full +payment for any Card transactions as they are processed. As your Card cash withdrawals +e processed, we will deduct funds from your Account to reimburse the Card Issuer. On +ch calendar month, we will deduct from vour Account the amount of purchases mat +Aith tnt. are Card issuer ey espend or canCer cards if there arenseducient assets tur +Agreements and Disclosures booklet. +UBS Credit Card for RMA or BSA +You may apply for a UBS Visa Signature credit card or UBS Preferred Visa Signature credit +card (Credit Card) either verbally or in writing. If your application is approved by the Card +Issuer, you will be issued one or more Credit Cards. We will bill transactions made with +your Credit Card separately from your eligible brokerage account. You may pay your +Credit Card balance automatically each month from your eligible brokerage account, or +you may pay the bill from other sources or allow a balance to revolve. The Credit Card +terms and conditions describes rates, fees and other costs for the Credit Card. The Card +Issuer will issue and manage your Credit Card according to Utah law and the UBS Credit +Card Cardholder agreement (Credit Card Agreement). The Card Issuer will include the +Credit Card Agreement with your Credit Card. +Your use of the Credit Card constitutes your agreement to the terms and conditions in the +Credit Card Agreement, which may change occasionally. The Credit Card is not subject to +the General Terms and Conditions of this UBS Client Relationship Agreement. To fulfill +your application for a Credit Card, we will share the personal information the Card Issuer +requires to open your Credit Card Account, and we share your personal information such +as application data, approval status and transaction information on a regular basis to +update your UBS monthly account statement and our records. +When you request a Credit Card, the Card Issuer will obtain a credit report as part of your +application and after it establishes your Credit Card account to administer your Credit Card +account and report its credit experience with you to others. At your request, the Card +Issuer will provide the name and address of each consumer reporting agency from which it +obtained a report about you. After your Credit Card account is open, you will have the +opportunity to select how the Card Issuer can use or share information about you for +marketing or Credit Card account maintenance purposes. +Any ispures you may rang in the a lease oil rese rei can greate For +By requesting Credit Card, you agree with the following statements: +• 1 (we) am at least 18 years old and a permanent resident of the United States. +• I (we) have reviewed and agree to the Important Information about the UBS Credit +Card Account Terms and Conditions that was provided with this Client Relationship +Agreement. +• All information provided to UBS and the Card Issuer was truthful and complete. +"Card Issuer" means UBS Bank USA, +is sens and asic apor ther +our sole discretion +Your UBS Visa Debit Cards) will be +mailed to you under separate cover +after your Account has been +approved. +UBS Client Relationship. +Agreement +Your UBS Credit Cards), if approved +for issuance by the Card Issuer, will +be mailed to you under separate +cover after your Account has been +approved. +Express Delivery: If you are +approved for an account and your +card was requested next day delivery, +your card will be sent the next day +after your account is opened if the +request is made before 3:00 p.m. +Eastern time of that day. A signature +is required for Express Delivery. +The information contained in these +disclosures is accurate as of +04/04/2012 and may change after +The UBS Credit Card is not available +with the International RMA. +The Credit Card terms and +conditions describe the fees for the +UBS Credit Card. +31 +SDNY_GM_00274222 + + +agent, UBS Financial Services Inc. will make the necessary withdrawals from the New York +deposit account to satisfy debits or charges in your Account in accordance with the +avman Islands branches of UBS AG are not elicible for federal c +Federal Deposit Insurance Corporation (FDIC). +A full description of the IDA Sweep Program is included in the Agreements and Disclosures +Booklet. At times, we may update or modify the terms of the IDA Sweep Program and/or +change the Sweep Options we make available. +UBS Visa Debit Card® +The International RMA includes the UBS Visa Debit Card (Card). If you are eligible for the +Card under applicable law and UBS policies and you request this feature either verbally or +in writing, you will be issued one or more Cards) by the Card Issuer. UBS or the Card +Issuer will complete any transactions you initiate using the Cards). Your use of the Card +constitutes your agreement to the terms and conditions in the UBS Visa Debit Card +Cardholder Agreement that is included in the Agreements and Disclosures booklet. +The Card Issuer will approve transactions up to your account's "Withdrawal Limit," as +"Card Issuer" refers to UBS Bank +USA, its successors or assigns, a +the issuer of the UBS Card we +appoint in our sole discretion. +The UBS Credit Card and the UBS +Rewards Program are not features +of the international RMA. +Card transactions as they are processed. +As your Card cash withdrawals are processed, we will deduct funds from your Account to +reimburse the Card Issuer. Once each calendar month, we will deduct from your Account +thet not yet dedure rem your it the. are ard asser may seven or hence cards it +there are insufficient assets to cover transactions. +32 +International Accounts +Please note: The International RMA and certain of its cash management features and other +services are not available in all countries and may be changed at any time. +In connection with your certification regarding purchases made in reliance on Regulation S, +including off-shore mutual fund purchases, the definition of a U.S. Person is 1) any resident +of the United States; 2) any partnership or corporation organized in or under the laws of +the United States; 3) any estate or trust in which the executor, administrator or trustee is a +U.S. person and/or if the income from the estate or trust is subject to U.S. federal income +taxation (regardless of the source of the income); 4) any corporation, partnership, estate, +trust or other entity that is directly or indirectly controlled by one or more of the above +categories of U.S. Persons; 5) any agency or branch of a foreign entity that is located in the +U.S.; 6) any non-discretionary account (other than an estate or trust) held by a dealer or +other fiduciary for the benefit or account of a U.S. Person; 7) any discretionary account +(other than an estate or trust) held by a dealer or fiduciary that is a U.S. Person, not +including those held for the benefit of a non-U.S. Person; 8) certain partnerships or +corporations that are organized or incorporated under the laws of any non-U.S. jurisdiction +that have formed principally for the purpose of investing in securities not registered under +the U.S. Securities Act of 1933; and 9) any other person or entity considered a U.S. Person +for purposes of U.S. tax law and/or Regulations under the Securities Act of 1933. +International Deposit Account Sweep Program +The Sweep Option for International Accounts is generally the UBS International Deposit +ccount Sweep Program (IDA). The IDA Is an interest-bearing account maintained by Us +G at the Cavman Islands Branch where funds are invested into short-term denosits. +The features and fees of your +International Resource Management +Account are more fully described in +the Agreements and Disclosures +booklet. +SDNY_GM_00274223 + + +Insurance Accounts +As a service to clients, we also offer accounts to maintain or permit the purchase of +insurance products and services. By signing the Signature Page for your non-brokerage +insurance account, you accept the Client Relationship Agreement and the other documents +referred to here, and as a result, you may be able to open brokerage accounts with us in +the future without having to sign additional agreements. +Joint Accounts +For joint accounts, each person or entity named on the Account has full power and +uthority over the Account, and the account holders are jointly and severally liable for a +bligations with respect to the Account. Please refer to the "Joint Accounts" section of the +General Terms and Conditions for more information about the terms and conditions that +apply to joint accounts. +When we open additional joint accounts for the same account holders, we establish them +with the same legal ownership as the most recently-opened joint account, unless we are +instructed otherwise. If you request a different form of ownership, we will request your +signature acknowledging that election. For example, if you open an account as joint +tenants with rights of survivorship, your next account with the same parties will also be +established as joint tenants with rights of survivorship, unless you tell us you want a +different type of ownership for that account. +Margin Agreement and Margin Requirements +All Accounts that you open now or in the future will be established with margin, it eligible +unless you instruct us that you do not want margin privileges for specific Accounts. By +igning the Signature Page for any Account except for an ERISA Plan or for an Estate, yo +gree that the Margin Agreement governs vour use of margin in all of vour curren +Accounts and any Accounts that you may open in the future. +There to use margin, stays are it do So e wet sigu ng an it al forms. Likewise. +if you cancel your margin privileges on an Account, your margin agreement with us will +remain in effect and you may request to use margin again at any time. In either event, we +will confirm your request. +nen you use your margin privileges, we hold your securities in your Account as collater +Jainst the amounts you borrow, and vour securities may be loaned to UBS or to others a +escribed in the Margin Agreement. In addition, margin-eligible Accounts are subject +pplicable statutes, rules, regulations, procedures or industry customs. We may deem +necessary or advisable to establish additional requirements for margin accounts. You agree +to maintain sufficient assets to satisfy all applicable statutes, rules or regulations, or as we +deem necessary or advisable. You also agree to maintain sufficient assets in your Account +to satisfy any and all margin calls issued in connection with the Account. +As long as your Account is a margin account, you authorize UBS in the usual course of +business to lend, pledge as collateral, hypothecate, relend or repledge any Property we +carry for you on margin, whether separately or together with Property of others, either to +ourselves or to others. This authorization remains in effect until we receive payment for +such Property. +When you use your margin privileges, as permitted by law, we may use certain securities in +your account for, among other things, settling short sales and lending securities for short +sales. We may receive and retain compensation in connection with such transactions. If +you are engaged in short selling a security, you may incur a charge due to certain +borrowing costs for that particular security. +Subject to applicable rules and regulations, we may amend, the requirements applicable to +your margin account at any time in our sole discretion, including changing the level of +credit available to you and applicable maintenance requirements without notice to you. A +prior demand or call, or prior notice of the time and place of such sale or purchase shall +not be considered a waiver of our right to sell or buy without demand or notice as +described here. For additional terms, please refer to the section "Liquidation of Collateral +or Account" below. +UBS Client Relationship +ent +If you do not want to establish +margin for your current accounts or +please contact your financa Absor. +Please note: UBS does not extend +margin for the following accounts: +Individual Retirement Accounts +ERISA Plans +Coverdell Education Savings +Account +403(b)(7) Accounts +UGMA +UTMA +Estate +529 Plan Accounts +Hypothecation is the pledging of +securities or other assets to secure a +loan such as debit balance in a +margin account. +"Property" includes, but is not limited +to, securities, securities entitlements, +investment property and financial +assets, including without limitation, +money, stocks, options, bonds, +notes, futures contracts, +commodities, commercial paper, +certificates of deposit and other +obligations, contracts, all other +property usually and customarily +dealt in by brokerage firms and any +other property that can be recorded +in any of your Accounts, as well as +the Accounts themselves. +SDNY_GM_00274224 +33 + + +34 +le have the right to satisfy a margin call or to obtain full or partial payment of a margi +an at any time without a demand for margin or additional margin or other notice. T +satisfy a margin call or to obtain full or partial payment of the margin loan, in addition to +all rights provided by law, we have the right to: +require additional collateral, +sell any Property in any of your Accounts with us, whether carried individually or +jointly with others, +buy any Property which may be held short in your Account, +cancel any open orders and close any or all outstanding contracts, or +liquidate any of your Accounts with us. +We may also exercise these rights if in our discretion we consider it necessary for your or +our protection; if a bankruptcy petition, or petition for the appointment of a receiver, is +filled by or against vou; if an attachment is levied against any Account; or in the event of +your death or dissolution. +You understand that there are substantial risks involved in trading securities on +margin, using leverage as a liquidity source or as part of your investment strategy, +or otherwise pledging your securities in order to obtain credit. Please review the +Loan Disclosure Statement included in the Agreements and Disclosures booklet +carefully for a detailed discussion of these risks. +Security Interest +As security for the payment of all liabilities or indebtedness presently outstanding or to be +incurred under this or any other agreement between you and any UBS Entity, including but +not limited to any loans or promissory notes, you hereby grant to each UBS Entity a security +interest in and lien on any and all Property held or carried by any UBS Entity for vou or on +your behalf in or credited to any UBS Accounts) (other than qualified plan or IRA accounts +or other accounts where doing so would be a prohibited transaction or violation of +applicable law or regulation) and in any other Account with any UBS Entity in which you +may have any legal, equitable or other interest. +All such Property will be subject to such security interest as collateral for the discharge of +your obligations to any UBS Entity, wherever or however arising and without regard to +whether or not we made loans with respect to that Property. In enforcing our security +nterest, we have the discretion to determine the amount, order and manner in which the +Property will be sold and have all the rights and remedies available to a secured party +under the Uniform Commercial Code (UCC) in addition to all other rights provided in this +Agreement or by law. +You will not cause or allow any of the Property held in any of your UBS Accounts, whether +owned now or acquired later, to be or become subject to any liens, security interests, +mortgages or encumbrances of any nature other than our security interest, without our +prior written consent. Each UBS Entity shall act as agent for and on behalf of each UBS +Entity for purposes of perfecting, maintaining and enforcing the security interests granted +ereunder or by operation of law. Each UBS Entity acting in the capacity of a deposit bank +ecurities intermediary or commodities intermediary, agrees to follow the instructions and +ntitlement orders of each other UBS Entity with respect to the Property as a secured par +ithout further consent by you. You hereby authorize and direct each UBS Entity to follo +the instructions and entitlement orders of each other UBS Entity. +Please refer to the UBS Statement of +Credit Practices for additional +information. +"UBS, " "we, " "us, " "our" and "ours" +refer to UBS Financial Services inc. +and, unless we indicate otherwise, its +successor firms, subsidiaries, +correspondents and Affiliates, +including without limitation, its +parent company, UBS AG. +"Affiliates" refers to UBS Financial +Services Incorporated of Puerto Rico +(which clears through UBS Financial +Services Inc.), UBS Bank USA, UBS +Credit Corp., UBS Trust Company, +N.A. and their insurance agency +affiliates and subsidiaries, and all +other subsidiaries and affiliates. +"UBS Entity" refers to UBS Financial +Services Inc. and each of these +Affiliates. +sher arms are in pre ace. +¡ection 8-102(a)(14) of the Unite +itates Uniform Commercial Cod +de 0177 2402 4804 02/12/2014 +SDNY_GM_00274225 + + +Liquidation of Collateral or Account +Ne may satisty any and all amounts you owe us in connection with any of your Account: +or agreements with us, or any other agreement between you and any UBS Entity, including +out not limited to any loans or promissory notes, +your Accoutes tian us othern qualited plan or I apery or other accent any re +doing so would be a prohibited transaction or violation of applicable law or regulation). +Additionally, we may sell any or all Property held in any of your Accounts with us and +cancel any open orders for the purchase or sale of any Property without notice in the event +of your death or dissolution, or whenever in our discretion it is necessary for our +protection. In these instances, we may also borrow or buy-in all Property held in any of +your Accounts required to make delivery against any sale initiated for you. These sales or +purchases may be public or private and may be made without advertising or notice to you +and in the manner we determine in our sole discretion. You waive diligence, presentment, +protest, demand for payment and notice of nonpayment and further waive all other +notices and formalities to which you may be entitled under applicable law or otherwise, to +the extent the waiver of such notices and other formalities is permissible under applicable +law. Your waiver will not be invalidated by any demands, calls, tenders or notices that we +may make. At any sale, we may purchase the Property or any portion thereof free of any +right of redemption and you will remain liable for any deficiency in any of your Accounts, +plus any accrued interest on the deficiency at our then customary rate, if applicable, or at +the maximum rate allowable by law. We will not be liable to you in any way for any loses +or adverse tax consequences resulting from a liquidation of your Property. +USA Patriot Act +o nep the government fight the tunding of terrorism and money laundering activities +ederal law requires all financial institutions to obtain. verify and record information and +cumentation identifying each account holder. Therefore, when you open an Accoun +re ask for vour name, address, date of birth and other identifving information about voi +Ve mav ask to see vour driver's license or other identifying documents. We may also +creen vour name against various databases to verify your identity. If we are unable to +eccountu in the eneral terms and of the ans inhe Agreements and Disclosures bookiet. +Credit Report +When you open an account with us, we may obtain your credit report or other credit +eferences and verify or update the credit information you may have given to us previously. +Ne may make verbal and written inquiries concerning your credit history. Likewise, we +may request your credit report or other credit information and provide it to our Card +Issuers and Check Provider or to our affiliates, as necessary or advisable to service and +maintain your Accounts. We also use this information to offer you additional products that +may be of interest to you. +UBS +Client Relationshi +ent +35 +SDNY_GM_00274226 + + +36 +Your Privacy +At UBS, we are committed to safeguarding your personal information. Please refer to the +UBS Client Privacy Notice in the Agreements and Disclosures booklet, which describes the +personal information we collect about you and how we handle and protect it. +Disclosure of Beneficial Ownership +The issuers of securities held in your Accounts may request your name, address and +security position so that they may contact you directly for proxy voting and other +shareholder communications. You may instruct us not to supply this information, in which +case, you will receive information regarding those securities from UBS instead of the +issuers. Your current instructions are reflected on the Account Information pages of the +Completing Your Account Opening Process package. If you would like to change your +instructions, please call your Financial Advisor. +As described in the section "Foreign Securities" in the General Terms and Conditions, we +may share information about the beneficial ownership of foreign securities in your +Accounts with the issuers of those securities, foreign government authorities of their +agent, to obtain reduced tax withholding rates, to comply with local law or to respond to +Householding of Statements and Other Communications +As a convenience to you, we may consolidate periodic communications for certain +accounts with the same address. This practice, called "householding," applies to account +statements, trade confirmations, personal and financial information required to be sent by +regulation, preliminary and final prospectuses and Summary of Accounts statements, +which provide consolidated information for all of the accounts in your household. +Households are determined as follows: +• Accounts that share the same name, address and Social Security or Tax ID +Number are automatically placed in the same household. +• Accounts that share only the same address will be placed in the same household +only with the express consent of all the Account holders. +We mail househeld communications in a single envelope (if you receive paper delivery) or, +you receive electronic delivery, we make them available through UBS Online Services +ther electronic delivery method. Anv member of vour household who is enrolled in UE +Online Services can have access to view all Accounts in the household. +he composition of a household will change as clients move away from the household +nailing address, and the addressee for househeld mailings may also change over time +Where owners of joint accounts live at different addresses, househeld mailings will be sent +to at least one account owner's address and may be included with mailings for other +accounts at that address under the conditions described above. +Periodically we are required by industry regulators to send records of certain +personal and financial information to our clients. Because we deliver these records +with your account statements, other members of your household may have access to these +records unless you instruct us to send them to you separately. +If you do not want your statements and other periodic communications from us to be +bundled by household, please contact your Financial Advisor and ask to receive individual +mailings in separate envelopes or delivered separately via electronic means. +E-mail Communications +We discourage clients from transmitting personal or confidential information through +information (for any purpose) by others who mav intercept or otherwise access the +communications during and after transmission. +Please see the UB5 Client Privacy +Notice in the Agreements and +Disclosures booklet for further +information, including how to +opt-out of certain information +sharing. +Please refer to the Client Privacy +Statement Househornation about +f you do not want your statements +o be bundled by household, please +contact your Financial Advisor and +ask to receive individual account +statements mailed in separate +envelopes or delivered separately via +electronic means. +For more information regarding +electronic delivery of periodic +Please refer to for lectronic Delivery +Agreement below. +de 0177 2403 4806 02/12/2014 +SDNY_GM_00274227 + + +Entire Agreement and Changes to the Agreement +This Client Relationship Agreement and the related documents, including the General +Terms and Conditions and the rest of the Agreements and Disclosures booklet form the +entire "Agreement" between you and us with respect to your accounts). This Agreement +supersedes any prior representations or agreements. +The accounts and services we offer may change over time. We may change our Agreement +with you at any time by sending you a written notice of the change, and the changes wil +se effective on the date of the notice unless we specify a later date. We also may cease to +er services at any time without prior notice. Your continued use of your Accounts al +r products and services constitutes your acceptance of the new terms and conditio +All changes by you to the Agreement will become effective only if offered in writing and +UBS Client Relationship +ent +Applicable Law +This Agreement, including the Arbitration provisions in the next paragraph, and its +enforcement, are governed by the laws of the State of New York, without giving effect to +such State's choice of law or conflict of laws provisions. The Agreement is binding on all +parties provided that there is no inconsistency with the Federal securities laws or the +Federal or State banking laws. In connection with any Card issued, the respective +Cardholder Agreement shall be governed by Federal law and the law designated by the +Card Issuer in that Cardholder Agreement. +In the event that any of the Arbitration provisions below are found to be unenforceable, +rou submit to the exclusive jurisdiction of the courts of the State of New York and the +ederal courts sitting in the Southern District of New York for the purpose of determininc +remaining provisions will remain in full force and will be construed to the fullest extent +permitted by law, to give effect to the intent of any provision that has be called into +Non-Primary Residence Address for Mailing Purposes +Unless you notify us otherwise in writing, you authorize us to use the Account Address you +provided in the Account Application to mail all notices, correspondence and for the +disbursement of Property, even if it is not your primary residence. Based upon this +authorization, we will not telephone you to confirm receipt of property or require a signed +written confirmation from you acknowledging transmittal of property. If you would like to +designate an alternative mailing address for the account, please contact vour Financial +Advisor to provide the necessary authorization. Even when you have provided a mailing +address for the Account, some correspondence may be delivered to your legal residence +address only based upon operational considerations. +Electronic Records +ament sa manual patre eric eat of an area it mad nine +will also be considered to be "in writing." You agree not to dispute the validity or +enforceability of any agreements entered into electronically by you (or by anyone using +your authentication devices, such as a password or PIN). +Electronic Delivery Agreement +UBS offers certain communications through electronic delivery. Categories of +communications you may enroll in for e-Delivery include: +• Statements for your UBS Accounts, which include your UBS Visa Signature® credit +card statement from the Card Issuer; notices delivered on or with statements such as +our annual Client Privacy Notice: and messages about transactions and payments. +• Trade confirmations and notices regarding account activity. +37 +SDNY_GM _00274228 + + +38 +hareholder communications, including annual and other shareholder reports +reliminary and final prospectuses, proxy materials and information about othe +related to investment Advisdry accounts, including form Abs alcise brochurents +manager profiles, asset allocations, performance reports and other disclosures, reports +and notices related to advisory accounts. +••• +Quarterly performance reports. +Corporate Employee Financial Services plan advices. +Tax reporting documents, including 1099s and other tax documents that are available +now or become available in the future. +• Agreements and disclosures relating to the accounts, features and services we offer. +Any member of your household may enroll any other household account in electronic +lelivery of these periodic communications, except for tax reporting documents. By +nrolling in e-Delivery of any communications described above, you agree that we ma +lso deliver similar firm documents electronically that may be available now or in the +uture. When available, confirmations of your personal and account information may be +ncluded with related documents that are delivered electronically through UBS Online +Services or any other secure method. Please note: These confirmations are sent +periodically and to confirm certain changes to your account information. These +confirmations may be viewable by other members of your household through UBS Online +Services or other secure methods. Contact your Financial Advisor if you prefer to receive +private, paper versions of confirmations of personal and account information instead of +lease see the section Householdin +f Statements and Othe +Communications above for further +information regarding how a +household is established. +you enroll in e-Delivery for any of the communications described above, the followir +rms and conditions will apply to all of the UBS accounts (current and future) in vour Uf +statement household. +• A valid e-mail address is required for our e-Delivery services and you are responsible +for notifying UBS when your e-mail address changes; you may update your e-mail +address online through UBS Online Services or by calling your Financial Advisor. +• Access to UBS Online Services is required for e-Delivery of documents that contain any +personal information; we may, however, deliver such documents by other secure +• Enrollment in e-Delivery is effective immediately and may be cancelled at any time, +either by changing your elections online or by contacting your Financial Advisor; we +confirm cancellations and other changes to your delivery preferences by e-mail or +regular mail whether they were initiated by you or UBS. +• Enrollment for any e-Delivery services for any of your accounts will automatically apply +to any accounts that you open in the future at UBS, subject to certain system +• You may request paper copies of any document we are required to deliver to you at +any time for no additional charge by contacting your Financial Advisor. +We notify you by e-mail when a new document is available; to protect your +information, the electronic message generally includes a link to a secure UBS website +where the document can be viewed and downloaded. +• If your e-mail address fails, we will mail paper copies of documents or a paper notice +that a document is available with instructions on how to access it. +• By enrolling in e-Delivery, you confirm that you have access to a printer or other device +to print or save documents you may wish to retain. +• We do not charge for e-Delivery, but your Internet access provider may have separate +de 0177 2404 4808 02/12/2014 +SDNY_GM_00274229 + + +Representations and Agreement for Trustee Certification +Representation of a Trust Agreement in Effect +For trust accounts, each Trustee, certifies, represents and warrants that the trust to which +this certification applies is in full force and effect and that the information you have +supplied to UBS is true and accurate, as we rely on that information to service your +The "UBS Client Relationship +Agreement" plus the additional +information, terms and conditions, +and disclosures pertaining to the +accounts and services you have +Unless we are updated subsequently by the trustees, UBS will rely on this certification, +requested UBS to establish for the +which includes the information you provide on the Signature Page, to service accounts you Trust govern the overall relationship +may open in the future for the same trust. By signing a UBS Trustee Certification and +between the Trust and UBS. +Agreement, you agree that: +• Each trustee (or a corporate officer if the account is a corporate trust) executed the +certification. +• You have full power under the trust agreement and applicable law to submit valid +orders and other instructions relative to the trust Accounts). +• The trust agreement authorizes you to make distributions and transfers from the +trust. +• You have received and read the "UBS Client Relationship Agreement" and the +documents it references and agree to those terms and conditions for all accounts you +open on behalf of the trust. +• As Trustee(s), you have broad investment powers under the Trust and applicable law. +ou have noted any restrictions on your power as trustee(s) on the Signature Page fo +he first trust account you open, and agree that the powers and restrictions lister +here and on the Signature Page are accurate and complete. +Trustee's Ability to Bind the Trust +Unless you indicate otherwise on the Signature Page, you agree that any individual trustee +may independently exercise any of the trust's powers. This means that UBS is authorized to +take instructions from and accept any document on behalf of the trust (including but not +UBS Client Relationship +ment +trustees for certain activities. +By signing a UBS Trustee Certification and Agreement, you agree that: +• Unless you have noted otherwise, you have the authority to pledge, mortgage, assign +or subject to a security interest or lien in favor of UBS, any property of the trust as +security for any liability of the trust. +• You have the authority to execute any and all relevant documents and bind the trust +to any agreements entered into with respect to such activities. +• You understand that, if you have requested margin privileges on behalf of +the trust, UBS holds securities in margin-eligible trust accounts as a lien +against the amounts borrowed by the trust, and you agree to maintair +sufficient collateral in the account to meet margin calls we might issue. +Trustee's Acknowledgement +By signing a UBS Trustee Certification and Agreement, you agree that: +UBS may assume without further inquiry and is not required to confirm your pow +d authority as trustee/s) or to verifv instructions for the delivery of any money +property to you as trustee(s). +UBS is not required to confirm that you are properly exercising your power and +authority unless UBS has actual knowledge to the contrary. +39 +SDNY_GM _00274230 + + +40 +Liability and Indemnification +By signing a UBS Trustee Certification and Agreement, you agree that: +• UBS is acting in reliance on this certification and is not liable for any breach of +fiduciary duty for account activities and transactions that are not specifically identified +in this certification as a limitation on your authority to invest or act on behalf of the +• UBS is not required to inquire whether any transaction represents a proper exercise of +the trustees' power or authority, unless it is demonstrated that UBS had actual +knowledge that either the transaction's proceeds were being improperly used for the +trustees' benefit or that the transaction exceeded or was in breach of the trustees' +powers or authorities. +• You fully indemnify UBS from all losses, liabilities, damages, claims, costs and +expenses, including attorney fees resulting from UBS acting in reliance on this +certification. +• As trustees, you are each jointly liable for performing your obligations under this +certification and agreement +Your obligations and this indemnification remain in effect if the trust is terminated or +its accounts are transferred and shall bind all your successors and assigns. +Duty to Update +You agree to provide UBS an updated certification if there is any amendment to the trust, +any change in the composition of the trustees, or any other event that materially alters the +facts which you have certified and upon which we are relying to service the trust +accounts). +If we are uncertain of the authority conferred by this certification, its continuing +effectiveness, or any other certification of the trustees, we may refrain from taking any +action with respect to the accounts) until we are satisfied as to the authority of the +trustee(s). You agree to indemnify us from any claims, demands, expenses, losses or +damages if we refrain from acting for these reasons. +Authority To Appoint/Hire Investment Advisor or Other Third Party +By signing a UBS Trustee Certification and Agreement, you agree that: +• Unless you have indicated otherwise on the Signature Page, you have the power +under the trust agreement and applicable law to appoint or hire an investment +advisor or other third party to manage and have discretion with respect to the trust' +documentation to UBS as we request. +u have the authority to open the trust accounts), place assets in the tru +counts), make each and every representation and warranty set forth in th +certification and agreement, engage in each of the actions on behalf of the trust se +orth in this certification and agreement, and execute this certification and +agreement. +de 0177 2405 4810 02/12/2014 +SDNY_GM_00274231 + + +Grantor Power to Amend and Revoke - Revocable Trusts Only +By signing a UBS Trustee Certification and Agreement, you agree that either: +You are the grantor of a revocable trust and you have full power and authority under the +trust agreement and applicable law to freely amend and revoke the trust, OR +As a non-grantor trustee, you represent that the grantor has full power and authority +under the trust agreement and applicable law to freely amend and revoke the trust. +Grantor Authorization for Credit Disclosure +By signing a UBS Trustee Certification and Agreement, each grantor agrees that: +You authorize UBS to obtain a credit report or other verbal or written credit references +about your credit history or to verify or update credit information given to UBS. +Introduced Accounts +Accounts opened with UBS Financial Services Incorporated of Puerto Rico or any other +broker-dealer under a clearing agreement with UBS Financial Services Inc. are "introduced" +to UBS Financial Services Inc. and will be carried by UBS Financial Services Inc. in your +name. Please refer to the section titled "Introduced Accounts" in the General Terms and +Conditions for a description of the services provided by your introducing broker and by +UBS Financial Services Inc. +Puerto Rico Residency Representation +If Puerto Rico investments are purchased and/or held in a UBS Financial Services Incorporated +of Puerto Rico account, each account owner, or for an account of an entity, the authorized +person(s), certifies the following: +You may hold or purchase certain investments in your Account, including, but not limited to, +closed-end and open-end mutual funds, preferred stock and debt securities that are not +registered under the U.S. Securities Act of 1933 or the U.S. Investment Company Act of +940 and are exempt from registration under the U.S. Securities Act of 1933 and/or the U.S +vestment Company Act of 1940 (*Puerto Rico Investments"), based in part, on th +equirement that they be offered or sold only to individuals who have thei +residence in Puerto Rico and to enties whose principal office and place of business are in +Puerto Rico ("Puerto Rico Residents"), as disclosed in the respective prospectuses or offering +materials. You are aware that certain Puerto Rico Investments may not be suitable to all +investors as they may be designed primarily for long-term investors. +Accordingly, you hereby represent that: +• You have acquired or propose to acquire Puerto Rico Investments for your own +Account and will be the beneficial owner of those assets. +• If you propose to acquire Puerto Rico Investments for the Account of a retirement plan +rain total, the amount of any such pushase, whether of got the retirement plan i par +r in total. the amount of any such ourchase. 1 +UBS Client Relationship +• As of the date of this agreement, (i) you are an individual whose principal residence i +¡ Puerto Rico, or (ii) if organized as a non-business trust, the trust has its principa +office and principal place of business within Puerto Rico and the trustee and all +beneficiaries of the trust are Puerto Rico Residents, or (iii) if organized as a trust, the +ustee and all beneficiaries of the trust are Puerto Rico Residents, or (iv) if organized a +corporation, partnershio or other form of business organization. the entity has it +principal office and principal place of business within Puerto Rico and has not been +organized for the purpose of acquiring Puerto Rico Investments. +If you cease to be a Puerto Rico Resident, you will (i) notify us within 30 days of ceasing +be a Puerto Rico Resident, (ii) liquidate your holdings in any Puerto Rico Investmer +Puerto Rico Investments. +SDNY_GM_00274232 + + +42 +You acknowledge that if at the time of your acquisition of Puerto Rico Investments you +are not a Puerto Rico Resident, UBS may declare such acquisition null and void. +Arbitration +This Agreement contains a predispute arbitration clause. By signing an arbitration +agreement the parties agree as follows: +All parties to this Agreement are giving up the right to sue each other in court, +including the right to a trial by jury, except as provided by the rules of the arbitration +forum in which a claim is filed +Arbitration awards are generally final and binding; a party's ability to have a court +reverse or modify an arbitration award is very limited +The ability of the parties to obtain documents, witness statements and other +discovery is generally more limited in arbitration than in court proceedings. +The arbitrators do not have to explain the reason(s) for their award, unless, in an +eligible case, a joint request for an explained decision has been submitted by all +parties to the panel at least 20 days prior to the first scheduled hearing date. +The panel of arbitrators will typically include a minority of arbitrators who were or are +affiliated with the securities industry. +he rules of s me erdiras an farm hat is imise time limits io h ringine ardaim in +The rules of the arbitration forum in which the claim is filed, and any amendments to +them, shall be incorporated into this Agreement. +By opening an account at UBS, and by UBS Financial Services Inc. or UBS Financial Services +corporated of Puerto Rico by accepting your application and carrying your account, yoı +BS Financial Services Inc. and UBS Financial Service Incorporated of Puerto Rico agree a +follows: +We agree to resolve any controversy, claim or issue in any controversy that may arise +by arbitration, whether it happen before or after, or at the time this Agreement was +xecuted, including but not limited to controversies, claims or issues in any +ontroversy concerning any account, transaction, dispute or the construction +performance or breach of this Agreement or any other agreement +Any arbitration under this Agreement shall be governed by the Federal Arbitration Act +and shall be conducted before an arbitration panel convened by the Financial Industry +Regulatory Authority (FINRA) or any other national securities exchange's arbitration +forum, upon which UBS Financial Services Inc. is legally required to arbitrate the +controversy with you, including, where applicable, the Municipal Securities +Such arbitration shall be governed by the rules of the organization convening the +All parties to this Agreement agree that the arbitrators shall resolve any controversy in +accordance with applicable law. +The arbitrators will apply state and federal statutes of limitation the same as if the +claim were brought as a civil action in court. +The award of the arbitration panel is not subject to appeal and judgment upon the +award may be entered in any court of competent jurisdiction. +No person shall bring a putative or certified class action to arbitration nor seek to +enforce any pre-dispute arbitration Agreement against any person who has initiated +in court a putative class action; or who is a member of a putative class who has not +opted out of the class with respect to any claims encompassed by the putative class +action until: +the class certification is denied; or +the class is decertified; or +the customer is excluded from the class by the court. Such forbearance to +enforce an agreement to arbitrate shall not constitute a waiver of any rights +under this agreement except to the extent stated herein. +This Arbitration Agreement +represents standard industry practice +and binds you and us to arbitrate any +disagreements that may arise +between us +de 0177 2406 4812 02/12/2014 +SDNY_GM_00274233 + + +Address of Record +116 E 65th Street +New York, NY 10065-7007 +Email Address of Record +gmax1 +de 0177 2407 4813 02/12/2014 +Signature Page +For Your Records +By signing below and depositing cash or securities in my accounts, I acknowledge that I have read, understand and agree with the enclosed UBS Client +Relationship Agreement, as well as the terms, conditions and disclosures in the enclosed Agreements and Disclosures booklet. +Margin Agreement +I acknowledge that when I use margin privileges, UBS will hold the +securities in my Account as collateral against the amounts I borrow. I +agree to keep sufficient positions and margin in my Account to meet any +margin calls UBS may be required to issue. By signing below, I agree that +the Margin Agreement in my Client Relationship Agreement applies to +all of my accounts, including any accounts that I may open in the future. +Note: UBS does not extend margin for certain types of accounts (e.g., +IRA and ERISA Plan accounts, Coverdell Education Savings Accounts, +403(b|(7) Accounts, UGMA/UTMA, Estate or 529 Plan Accounts). +Electronic Delivery Consent +As you requested, we have sent your agreements and disclosure booklet +and other account-related documents electronically to +gmax1@ellmax.com, which we consider to be the e-mail address of +record for all owners of these accounts. The information is also available +at www.ubs.com/accountdisclosures or by request to your Financial +Advisor, Scott Stackman | Lyle Casriel at 1-212-821-7000. +Likewise, 1 acknowledge and agree that certain securities in my account, +including any account I may open in the future, may be loaned to UBS or +to other persons or entities as described in the Margin Agreement. +W-9 Form Certification +Under penalties of perjury, I certify that: (1) the number shown on this form is my correct taxpayer identification number (or I am waiting for a number to +be issued to me), and 2) I am not subject to backup withholding because: (a)l am exempt from backup withholding, or (b)l have not been notified by the +Internal Revenue Service (IR5) that I am subject to backup withholding as a result of a failure to report all interest and dividends, or (c) the IRS has notified +me that I am no longer subject to backup withholding, and (3) I am a U.S. citizen or other U.S. person (defined in the instructions). +Certification Instruction: You must cross out item (2) above if you have been notified by the IRS that you are currently subject to backup withholding +because you have failed to report all interest and dividends on your tax return. +The Internal Revenue Service does not require your consent to +any provision of this document other than the certifications +locatin Relation sep in emer enter precion tea iration classe +required to avoid backup withholding. +Ghislaine Maxwell +For Accounts: +RMA Domestic - Sole Owner +RMA Domestic - Sole Owner +RMA Domestic - Sole Owner +RMA Domestic - Sole Owner +RMA Domestic - Sole Owner +RMA Domestic - Sole Owner +RMA Domestic - Sole Owner +RMA Domestic - Sole Owner +RMA Domestic - Sole Owner +RMA Domestic - Sole Owner +Enter your Tax ID Number: +X +X +X +X +X +X +X X +ENTER SSN HERE +• Check here if you have been notified by the IRS that you are subject to +backup withholding, and therefore have crossed out item (2) above. +XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX +Ghislaine Maxwell +XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX +Date +SIGN AND +DATE HERE +43 +SDNY_GM_00274234 + + +de 0177 2407 4814 02/12/2014 +SDNY_GM_00274235 + + +de 0177 2408 4815 02/12/2014 +a UBS +How can you simplify your life and have your +financial information when you need it? +It's easy with UBS Online Services and +e-Delivery +With UBS Online Services, you can monitor your +accounts, stay informed about the financial markets, +and explore potential investment planning strategies +and much more. +Add electronic delivery of statements, confirmations +and other shareholder communications and +managing your finances become even easier. +Online Services gives you: +• Comprehensive Account Information — +Investment and loan accounts, asset allocation, +updates on your top holdings +• Easy Access to Your Documents—Account +statements, confirmations and Form 10995 +• Convenient Cash Management—Pay bills, view +cash and checking account balances, track credit +card purchases and more +• Quotes, News and Research-Consolidated +quotes and research, including market news and +UBS research for covered companies +• Planning & Insights-Helpful tools and resources +to assist you and your Financial Advisor with +developing a wealth management plan that suits +your financial needs and objectives +And with e-Delivery, you can reduce your paper mail +by choosing which documents you want delivered +electronically. All documents are delivered securely +and you'll receive an e-mail when your documents +are available for viewing. +Enroll now or update your e-Delivery +preferences at ubs.com/ts +#UBS +Welcome So UBS Wealth Management +Enroll Now +Select Profile Settings, then Go Paperless! +to add e-Delivery in one simple step. +UBS Online Services Enrollment +Stag De Salect Services +Take advantage of UBS Online Services and e-Delivery today. +SDNY_GM_00274236 +45 + + +93830915_0177 +de 0177 2408 4816 02/12/2014 +93830915_DE00177_00177_5 +SDNY_GM_00274237 \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/0bba4c5b069709fe31a5b13e191389d6fcbab762e6768aa45f5423dbe46ac939.receipt.json b/vision-fixhub/ds9-parsed-01/0bba4c5b069709fe31a5b13e191389d6fcbab762e6768aa45f5423dbe46ac939.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..9a1192d423cfb2b1699a421966ad06ed481d471f --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0bba4c5b069709fe31a5b13e191389d6fcbab762e6768aa45f5423dbe46ac939.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -2890, + "dataset": "marble-joined", + "doc_id": "0bba4c5b069709fe31a5b13e191389d6fcbab762e6768aa45f5423dbe46ac939", + "engine": "marble-apple-vision", + "event_count": 46, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "b3fba0b93ce5da29c4c043332ad3a810a1e3f929dbcdc3b643ebbd2a541b3030", + "output_sha256": "593fff054b60272dbb02120d47d901b4588cb2ae46f8b9fbf9ca5fc88758eb09", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0bbb45d319dfb3a7f68b397483dcba3450e588cdc23571f9fe0dd1ddd1b05b66.md b/vision-fixhub/ds9-parsed-01/0bbb45d319dfb3a7f68b397483dcba3450e588cdc23571f9fe0dd1ddd1b05b66.md new file mode 100644 index 0000000000000000000000000000000000000000..5e05365ef9c49717e9b032dde5d7716907edf0f0 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0bbb45d319dfb3a7f68b397483dcba3450e588cdc23571f9fe0dd1ddd1b05b66.md @@ -0,0 +1,5300 @@ +1 +2 +3 +4 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +26 +DIGITALLY RECORDED +SWORN STATEMENT +OF +OIG CASE #: +2019-010614 +DEPARTMENT OF JUSTICE +OFFICE OF THE INSPECTOR GENERAL +APRIL 7, 2022 +RESOLUTE DOCUMENTATION SERVICES +28632 Roadside Drive, Suite 285 +Agoura Hills, +CA 91301 +Phone: +(818) 431-5800 + + +1 +APPEARANCES: +2 +3 +4 +5 +6 +7 +8 +WITNESS: +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +26 +2 +OFFICE OF THE INSPECTOR GENERAL +BY: +BY: +OTHER APPEARANCES: + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +3 +This is Special Agent +• Today is April 7, 2022. The +time is 10:21 a.m. The recorder is now on. +My name is L +I'm a Special +Agent with the U.S. Department of Justice, +Office of the Inspector General, New York Field +Office. These are my credentials. +I'm going to -. Man. +: This interview with +Federal Bureau of Prisons employee, +, is being conducted as part of an +official U.S. Department of Justice, Office of +the Inspector General investigation. Today's +date is April 7, 2022. The time is 10:22 a.m. +This interview is being conducted at the +Department of Justice, Office of the Inspector +General, New York Field Office. Also present +are DOJ/OIG Assistant Special Agent-in-Charge, +1, and via phone is DOJ/OIG +Assistant Special Agent-in-Charge, +• +This interview will be recorded by me, +Special Agent +•. Could everyone +please identify themselves for the record and +spell your last name. To start again, I am + + +4 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +DOJ/OIG Special Agent +Assistant Special Agent-in- +Charge +Electronics Technician. Last name, +HI. +ASAC +can you +introduce yourself, please? +: Yes, this is Special Agent-in- +Charge +Thank you. +This is an official DOJ/OIG investigation +into events surrounding the death of inmate +Jeffrey Epstein, and you are being asked to +voluntarily provide answers to our questions. +Will you agree to a voluntary interview with +the DOJ/OIG? +Please review DOJ/OIG form +III-226/2. The form states, United States +Department of Justice, Office of the Inspector +General, Warnings and Assurances form, +Assurances to Employee Requested to Provide +Information on a Voluntary Basis. +"You are + + +5 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +being asked to provide information as part of +an investigation being conducted by the OIG. +This investigation is being conducted pursuant +to the Inspector General Act of 1978, as +amended. This investigation pertains to job +performance failure and security failure. This +is a voluntary interview. +Accordingly, you do +not have to answer any questions. +No +disciplinary action will be taken against you +if you choose not to answer any questions. +Any statement you furnish may be used as +evidence in any future criminal proceedings or +agency disciplinary proceedings or both." +The waiver states, "I understand the +warnings and assurances stated above and I am +willing to make a statement and answer +questions. No promises or threats have been +made to me and no pressure or coercion of any +kind has been used against me." This is the +same form we've provided you before. +Please review it. If you +understand, on the right side, please print +your name and sign your name. If you +understand and agree -- + + +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +form? +Okay. +-- sign and print. +I will sign and print. +Do you understand the +Thank you. +This is Special Agent +I'm +signing on the signature of the Office of the +Inspector General Special Agent. And ASAC -- +: This is -- +I'm sorry. +-- ASAC +I'm signing on the signature of witness line. +: Before starting the +interview, +I would like to place you under +oath. Mr. +, can you please raise your +right hand? Do you swear to tell the truth and +nothing but the truth during this interview? +Thank you. You can put +your right hand down. Please let me know if +you don't understand any questions and I'11 try +to repeat it or try to rephrase it for you. +Okay. +6 + + +7 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Thank you. Thank you for +taking the time to meet with us today. We have +a few follow-up questions. +Mm-hmm. +You met with us twice +before. +And it's based on our +interview, from prior, we had a few follow-up +questions in regards to that, and a few new +questions for you, too. +: Okay. +Before we begin, what is +your current employment status with the BOP? +I'm an electronics +technician at MDC Brooklyn, Com Tech. Same +position I was in MCC. +position now? +: And this is your permanent +And you transferred over? +Yes, when they closed it +down. +Okay. So, let's take a +step back. In August 2019, what was your + + +8 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +typical work schedule? +2:00 p.m. +Monday through Friday? +My schedule was 6:00 to +6:00 to 2:00 p.m. Is that +Monday through Friday. +During that time, I think I was working +overtime because we started the camera project. +The camera project is? +Before all this got +started, we were upgrading the cameras in the +MCC. So, my schedule changed, and I was +working, like, ten or 12 hours a day during +this time. +p.m.? +So, Monday through Friday, +normal schedule would be 6:00 a.m. to 2:00 +eight hours. +So, that would be about +So. if you're working ten +to 12, that means you were working to, what, +about 4:00 p.m., 6:00 p.m.? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +the weekends? +Okay. And what about on +I was working a little bit +of overtime there during that time, too. +Okay. And is that +something you needed prior approval for, or -? +Yes. Well, they knew what +was going on, so I got pretty much prior +approval. If I showed up, I showed up. If it +didn't, they didn't really -. Because the +project was going on. I have a life, too. +I +can't just be working at the prison all the +time, so they understood if I didn't show up or +didn't come in for overtime. Because my +regular schedule is Monday through Friday, 6:00 +to 2:00. +: Okay. And as needed, you +would come in, too? +ASAC +did you have +anything in regards to his schedule? +: I did not. Thanks. +No problem. I'm going to +move on. +In our previous interview, you mentioned +9 + + +10 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +you had recalled having a conversation with SIS +Lieutenant +You remember her, right? +Thursday, August 8th, you +had a conversation with her about cameras not +working inside the MCC. Do you recall that? +Thursday or Friday. +Thursday, August 8th. +No. +: You don't recall having a +conversation with her? +The only time they spoke +about it was Friday, about the cameras, that I +remember. +So, you recall on Friday. +Who did you have a conversation with? +Lieutenant +and +that's when I spoke to +•. She's the +Associate Warden. That's when they told me +that the cameras were down, on that Friday. +On that Friday? +So, just to clarify a +little bit. So, Lieutenant +wasn't +working on Friday, August 9th. They were + + +1 +2 +3 +4 +5 +6 +7 +8 +actually working - +9th. +11 +Mm-hmm. +-- she was off on August +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +August 9th. +Friday, August 9th. She +was working on Thursday, August 8th. +Yeah. +: According to the schedule, +she was working Thursday, August 8th, and the +conversation that she told us about happened on +- she recalls - that it happened on Thursday, +August 8th, Associate Warden +also stated +it happened on Thursday, August 8th. +Oh, so it must have been +Thursday. +: Okay. +I'm not too sure because +everything was jumbled in. +: Okay. And do you recall +what the issue was with the cameras? +recording. +They said they wasn't +Was that the only issue +you remember? Was there anything else with the + + +12 +1 +2 +3 +4 +5 +6 +7 +8 +camera? +They couldn't pull video +for whatever reason. They couldn't extract +video. They were looking for video for +something and they couldn't find it. +So, it wasn't recording, +and they couldn't pull any video? +Do you remember if there +were any cameras -? So, when they were trying +to pull video, where were they trying to pull +video from? +: I have no idea. I don't +really remember what they were trying to pull +video from, or why. +which office were you guys +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +in? +Probably on the second +floor by the - maybe the SIS Office, or it was +in the Video Room. +: All by the -. What's the +difference? +: The Video Room is where +they have the monitors and the SIS Office is +right down the hallway, where the SIS Office + + +13 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +would be. +Okay. And do you remember +standing there trying to help them pull video? +: Yes. +: And when you were trying +to pull video, do you remember looking up at +the screens and seeing any blank screens? +In the SIS Shop? +In the SIS Shop, or on the +monitors. There's a lot of monitors. +Oh, the sIS, that was, +that has been in and out forever. That was not +really working properly even when I got there. +There's been issues. There was issues with +that. +little further? +Can you explain that a +Okay. So, was it in the +Video Room or the SIS Shop? +: I'm not sure where this +happened, so based on recollection, if you can +tell me, if you recall where this happened? +: If I was looking at +multiple monitors, it probably was in the Video +Room. That's where they have -. The live feed + + +1 +goes to the video matrix, and then it's split, +2 +and it goes to all the other cameras. +3 +So, you're saying if it's +4 +in the SIS Shop, and there was issues in the +5 +SIS Shop? +14 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +No, if it was in the SIS +Shop, that's the network. They're on the +computer and they're trying to pull video. If +they're in the Video Room, it's the live feed +that's going to the cameras. +: Okay. +And it's inputted on the +screen. It's split going to the recorder, and +it's split on the output going to the actual +screens. Yeah. +So, which ones had issues +where you couldn't see anything? +I don't know. Because it +was a lot of stuff not working at that time. +can't really -. +I +Do you remember any +screens being black, like blanked out with X's +on them, at that point? +: I don't know. It was - +that room was always a mess when I got there, + + +15 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +as far as stuff not working or working. +But you don't remember +them, Lieutenant | +or +mentioning, +hey, listen these screens are blank. There's +X's on them, they're not working. You just +mentioned that - just on topic - you just +mentioned that there were always issues. +Yes, there were always +issues. Sometimes, I would go in there and +stuff was working. +Sometimes, I'd go in there, +stuff was not working. Exactly what was +working or not working, I'm not too sure of. +So, which one was it? +Just to clarify. I missed that. Which one was +it that wasn't working -- +So, what -. +: -- the SIS or the Video +Room? +It would be the Video +Room. It wouldn't be in SIS, because -. Okay, +the Video Room is the live feed coming from the +analog matrix onto the actual screens. Some of +the cables got disconnected because there was +issues. And then SIS, that would be all of the +cameras in the institution. They would be + + +1 +coming from the network. They'd be trying to +2 +pull video from the actual recorders. +3 +: So that's where basically +16 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +you can log in? +You log in and you try to +pull video. +Okay. So, you can - the +SIS Shop had the ability to log in -- +: Yes, pull video. +-- and review video. +So, but the other part, +the video monitoring +-- +That's just live -- +-- had to be live wired. +- that's just live wire, +yeah. That's everything coming in. +screen? +And if the live wires were +removed by any chance, would that be a black +Yeah, it would be a black +screen, yes. +: So, is it possible this +conversation might have taken place with +Lieutenant +inside the Video Monitor + + +17 +1 +Room? If she recalls that there was - +2 +Yeah, if there were +3 +screens -- +4 +5 +-- screens that -. +-- that's in the Video +6 +Room, yes. +7 +Black screens, okay. So, +8 +do you recall her mentioning on August 8th - by +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +any chance, do you recall? I know it's been a +couple years - +Hmm. +-- it's hard to remember, +but do you recall her mentioning anything +about, hey, there's blank screens, access that +needs to be fixed? +I was working on that +since I got there. I was still working on +that, until I was leaving, so -. It was an +ongoing issue I knew about. But the main thing +was, even if the screens were blank, that +everything would be recorded, going to the +recorders. Like, the live view in the Video +Room, that's extra. But if you could pull +video from the recorders, that's the main thing +I was worried about. I wasn't really worried + + +18 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +about the live view. +That's something I would +have to worry about later. But the main thing +was to make sure the cameras are recording in +the institution. +Okay. And so, this +happened, well based on the fact that this +happened on Thursday, August 8th, do you recall +coming in August 9th fixing anything? On +August 9th? +I'm pretty sure I did. I +must have followed up. Because I was going to +come back Saturday to do something, so I know +on Friday, that's when I went back to the room. +: Okay. I'm going to show +you a memo. +There's a memo dated August 10th, +from T. +, SIS Lieutenant. That would be +Tijuana +Yeah. +TO J. +Captain. +Mm-hmm. +Subject was "NiceVision +Camera System." And for the record, I'm going +to read it, and then I'll show it to you. + + +19 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Okay. +"On August 8, 2019, at +approximately 3:45 p.m., while reviewing the +Nice Camera System, I attempted to recover +video footage from the Unit 5 South Housing +Unit. At this time, +I was unable to recover +any previous recordings from the camera, this +prompting me to review all of the cameras. +None of the cameras on the system were able to +record. Therefore, I called the communication +technician +via radio." That would be +you, right? +Okay. "At approximately +4:00 p.m., +responded to the third floor +Monitoring Room to check the cameras and +notified me that the cameras were not recording +and there was no way to retrieve any video. +stated he fixed the camera system on +Friday, August 9, 2019, when he arrived to +work." +So, it looks like the memo was written on +August 10th and this is in regards to a +conversation she had with you on August 8, +2019, and at the end, she stated that you told + + +20 +1 +her on August 9th, you told her on August 10th +2 +that, when you came into work on August 9th, +3 +you fixed the camera issue. Do you recall +4 +that? +5 +No. (Indiscernible +6 +*00:12:58). +7 +So, I was working after 3:45. So, I was +8 +on overtime that day she called me? +9 +10 +11 +12 +13 +14 +: It might have been. +Because I leave at 2:00. +so, you-. +You want to just read +through that again - +Yeah. +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Yeah. Read through it for +yourself. +-- and just -. +"At approximately 3:45 +p.m. on the Nice System, I attempted to recover +-. At the time I was -." +There might be some +grammatical -. +Yeah, that doesn't really +-. +: +Does that seem accurate, to + + +21 +1 +your recollection? +2 +: NO. +3 +: So, you don't recall +4 +fixing anything? +5 +I might have been looking +6 +at something, but I have to make sure that it's +7 +fixed, like, before I say, hey, you can pull +8 +video and I have to pull video myself. +: But she said there's a +10 +possibility that, when you came in on the 9th, +11 +you might have fixed the issues with the blank +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +screens. +Okay. +And then, you might have +came back in on August 10th, which would be +that Saturday, to fix the recording issue. +Do +you think that might be accurate? +: No. That doesn't really +make any sense to me, either. +: Okay. Do you recall if - +I remember we spoke about this before, I don't +know if your memory hasn't recollected any of +it - but about you not being able to access the +SIS Shop because no one was in the SIS Shop. +Yeah, and I don't have the + + +22 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +key to get in the room. +Okay. +I didn't have access to +get in the room. +Because no one was there +in the SIS Shop. +Yes, nobody was -. Yes. +And normally, there would +be somebody monitoring the phones, right? +Yes, there should be a +phone monitor, if somebody was there, unless +they got pulled to work a different post. +Yeah. +But they're supposed to be +- that's supposed to be a post. +And that Friday, nobody +was there? On August 9th, I think they had +left early or something to that effect - +Mm-hmm. +: -- and then, you couldn't +get in. Do you recall - Lieutenant +mentioned to us that Captain +had the +ability to get you into the room - do you know +if Captain +had his own set of keys for +that room? + + +23 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Yes, he did. +Separate from? +Yeah. The Captain I +think, or the SIS could get in that room. I'm +not too sure. +I know SIS -. Lieutenant +had her own set of keys. +Yeah, could get in with a +key. Yeah - +- but I think the Captain +had the key to let me in the room. I'm not too +sure. Honestly. +: You're not certain? +I'm not certain. +So, the SIS Lieutenant's +keys are kept behind some kind of box in the +control room. +Yeah, everything is kept +behind glass and the technician's, their keys +are kept behind glass. And whoever is in the +Video Room, it's behind glass. +: Okay. But does the +Captain have his own set of keys? + + +24 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +That's not behind glass? +: No. I don't know how they +do the Captain's. I know the SIS Shop, that +was the main key and if I tried to get in, it +was behind glass, to get in the room. +Do you recall approaching +Captain +I asking him for access to that +room on August 9th? +: I don't remember. +Okay. Because I know, +based on Captain | +Captain +was in +the facility until about 8:00 p.m. on that +Friday night, August 9th? He worked until about +8:00 p.m. +Hmm. I didn't know that. +So, but you don't recall +ever seeing him, or talking to him, or asking +for access to that room to fix the cameras? +No. I don't remember. +Maybe I did, maybe I didn't. I don't - that's +-. I don't really -. +could have asked Captain +: Okay. But if needed, you +he could have +let you in? +He would have locked the - + + +25 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +if he had the key, yes, he would let me know. +Okay. ASAC +anything on that topic? +: Yeah, in regard to the memo. +Mr. +| I know that time on August 8th, +that seems way off based on what you had told +and Dennis before, and - +Mm-hmm. +: - frankly, what +had +told us. The key thing that we wanted to find +out is that last line. The " +stated he +fixed the camera system on Friday, August 9th +when he arrived to work." +Mm-hmm. +we just wanted to confirm. +So, that's the main thing +: I don't think I did that. +: Yeah, because the last time, I +know our guys explored pretty in depth what +happened on August 9th. +Mm-hmm. +: That was that Friday where it +sounds like -- +-- you got the hard drives to + + +26 +1 +go repair the thing. and just couldn't get in +2 +because no one was there, or the phone monitor +3 +was leaving. So, we were surprised to see that +4 +there was a statement that you may have told +5 +someone that you had repaired it on August 9th. +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +So, we just wanted to confirm whether or not +you had told someone, specifically Lieutenant +,, that you had repaired that system on +August 9th. +I don't believe so, no. +Because I was still working on it so - +: Okay. +-- I couldn't do it. +: Very good. Thank you, sir, +and that is all I have on that +• thanks. +: Thank you. Just as +normal, can you initial and date it? You're +not attesting to the accuracy, it's just a +document that we showed you. +Hmm. +Today's the 7th. +It's that you reviewed it. +Oh, today is four -- +4/7. +4/7/22. + + +27 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +topic. +We can move on to the next +You mentioned, previously +and even now, that there was a camera upgrade +going on during that time. +: Do you recall if there was +a contract in place for these upgrades? +Yeah, it was supposed to +be NiceVision, but we just ended up doing +pretty much everything inhouse because it was +taking too long. +Okay. I'm going to show +you a contract. +Do you recognize that +contract? +This looks like all +the stuff we put in for to upgrade the camera +system. +second. +Just so -. +Give me one +Just for the record, I'm + + +28 +1 +going to read this out because it's -- +2 +: It's very (Indiscernible +3 +*00:18:26). +4 +This states the - the +5 +contract states up top - it says, MCC New York. +6 +And the contract number is GS-07F-, as in +7 +Frank, 0322T, as in Tom. The award effective +8 +date is 9/21/2018. And the order number is +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +15B-, as in boy, NYM-, as in Mary, 18F-, as in +Frank, I-, as in Tom, P-, as in Peter, 120150. +And the requisition number is 1064-18. +Now, that's the document you were +reviewing, and you believe that is the camera +upgrade? +The initial, probably the +initial one, yes. +When you say initial? +Were there changes? +Yeah, because they had a +contract. This was the original contract, as +far as upgrade goes, and then, like a year +later, there was another bid that we put in for +more upgrades. +But this was the original. + + +29 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +again? +*00:19:31). Oh, 9/21/2018. +in this? +And this is dated when +2018. (Indiscernible +2018. Were you involved +who was the point of +contact for this? +He's, like, +the head of Nice. And then, but the main +person I would talk to was +, but +is the brains behind it. I really +wouldn't talk to l +because he was, like, +overseeing it. The main person I would talk to +was +And I called him asking +him every question, because I never did fiber +before, or network camera systems, so. +: All right, so +is the SigNet point of contact then? +: Yes. +Okay. Who was the point +of contact for BOP then, at the MCC? Who was + + +30 +1 +2 +3 +4 +5 +6 +7 +8 +the point of contact? +That would be the Facility +Manager, whoever that was. Or the General +Foreman. I'm just -- +Who? +-- in 2018, so that was +(Phonetic Sp. *00:20:12) +was the +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +probably, and then +General Foreman. +had left +by August 2018, right? +Okay. +And then, +stepped in? +But +said that +he never really communicated in regards to +this. +Because he said that he +doesn't recall the materials arriving -- +Mm-hmm. +- or any of that stuff. +No, he wasn't there when I +don't think any of this arrived. + + +31 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +And he never spoke with - +Anybody. +-- SigNet. +Signet, yeah. +So, who spoke with Signet +in regards to the materials and all that? +: It was just kind of like a +thing -. I would just call this, every once in +a while, hey, did the stuff come in, or what's +going on? But there was really -. +So, you communicated with +SigNet? +Yeah. SigNet, yes. +: Okay. Was there anybody +else that communicated with SigNet? +No, not until +got +there. +And after that it was +together? +Or was it both of you guys +It was pretty much +He's in charge, you know. +Okay. When did +get + + +32 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +there? +I don't know. Honestly, I +don't. It's around this time, like, August or +July of 2019. +okay. Can you flip to +page four of that? +: And you mentioned it +before, right? What was the name of the +recording system that was ordered for the MCC? +The Nice -- +Nice or -. +- the Nice, NiceVision? +Yeah, NiceVision. Yes. +And that's the type of +system that was ordered, right? +Okay. Do you recall - and +this was placed in September of 2018. +Do you recall when all the +NiceVision, all that stuff in that order was +delivered to the MCC? +It was coming in piece-bypiece. + + +1 +2 +3 +4 +5 +6 +7 +8 +33 +Piece-by-piece. +Yeah. +It wasn't delivered +together? +It might have been, but +the warehouse was, like, a mess. So, whenever +they told me I had packages, I would go and get +it. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: Okay. So, what do you +recall, what came in first? +: As far as what came in, +mainly the recorders and the new rack, and +probably the UPS. +Recorders, and what else? +The UPS and the rack that +the recorders would go in. +: All right. So, the +terminology goes over my head. +Okay, so just the metal +hardware that the UPS would go in, and the +recorders. +So, based on, if you could +look at that and tell us what you're thinking, +and off of the page number four. +So, Nice. So, it would be + + +34 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +the hard drives would come in. That's the line +item two would come in. The decoders would +come in. So, that's line item five. AMS would +come in, line item six. Line item seven would +come in. Oh not - yeah. Line item seven would +come in. Cameras never came in. Line item ten +would come in. And the wall mount never came +in, and a media cabinet. So, that line item +14, yeah. +So, they call came in +around when do you think? +I'm not too sure. +You think soon after the +order was placed, or -? +: It was a little while +because there was stuff on backorder, so it +wasn't, like, right away. +So, was it in 2018, '19? +Probably in the early part +Of 2019. +Early part of 2019? +: Yeah. +: All right. I'm going to +show you an email. This email - I'm going to +go back - it looks like it's an email from you + + +35 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +dated October 7th, that's +That's +That's you? +It's dated October 7, +2019. +1, that's +October 7. +And this is to +Mm-hmm. +and +Hmm. +-- at SigNetinc.com. +Hmm. +And you were asking, "Just +following up on the order for the outside PTC +cameras expected date of delivery." +Mm-hmm. +And looked like +responded back on Monday, October 7th, +2019, right? And he says, " +, everything +was delivered. Most of it on 11/23/2018. The +tracking numbers are below." So, it looks like +this is in 2019. +Yeah. + + +36 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Like, he responded back +with tracking numbers for 2018. +: 2018. Okay. +Does that help recollect +your memory at all about when those -? +I don't remember when all +this stuff -. It was a lot of stuff, and I was +trying to get space for it, so I'm not -. If +that's when they said it came in, that's +probably when it came in. +: Does that email look +familiar? +This email looks +familiar. +So, that is a +communication between you and +looks like +- - +• and it +-- and +Yeah, later on because, +when was this? Yes. +Who's +He's the new contact. +He +came in after the Epstein thing. +Okay. And what's the + + +37 +1 +communication about the PTC cameras? +2 +Oh, those are outside +3 +cameras. +4 +5 +Okay. +Those didn't really have +6 +nothing to do with the recorders or anything. +7 +Those are, like, secondary. They had nothing +8 +to do with the recording. Again, the recorders +and stuff. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +But you think - when he +says that's in 2018 - you think those are the +NiceVision recorders and the decoders and all +that mentioned over here? +delivered - based on +: Yes. +You think those were +email - it was +delivered in the -. +: In the end of November, +during the holidays, so I probably didn't get +it until maybe January, the first week of +January. +: Okay. Where do you think +these items were stored? Once they got +delivered? +They were - and I mean + + +1 +2 +3 +4 +5 +6 +7 +8 +some of it got misplaced because nobody knew +what it was, so it went to Building Four, the +warehouse. +Where's that? +That's in Brooklyn. It's +right next to Steiner Studios. +This is the Brooklyn Navy +Yard? +Yeah, Brooklyn Navy Yard, +38 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +yes. +What about the other +items? You said some went over. +: I think there was a time, +Like, maybe this was the other order that the +decoders got sent over there. Something got +sent over there, it was sent, and nobody knew +what it was, and so they just sent it to +Building Four. +these orders, do you know? +Okay. And who received +The warehouse. +The warehouse? +It was shipped to the MCC? + + +39 +1 +2 +3 +4 +5 +6 +7 +8 +Do you know who signed off +on these? +NO. +Okay. +But someone +received them and somehow, it ended up in +Building Four? +Okay. And what about - +you said that's some of them - what about the +other items? Was there anything housed at the +MCC? +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: Yeah. I had the +recorders, and I had the rack. I had it stored +downstairs or in another room. I remember, +because it was important, so I made sure when I +came in, I put it in MCC. +Where? +So, we didn't have to go +look for it. It might have been in the 30 +Percent Room or in my Video Room, but I think +it was in the 30 Percent Room. +What's the 30 Percent +Room? +It's, right before you go +to the loading dock, there's like a Ready Room + + +40 +1 +that we get stuff in, and there was part of the +2 +Lock Shop. So, if I had storage, or didn't +3 +have space for it, I would ask the Lock Shop, +4 +hey, can I put this in your room because I +5 +don't have space. +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +And it's locked up, it's +secured? +: Yes, secured. Yeah. +They're the only ones with a key. Nobody else +could get in there. +So, we mentioned +everything that's on there, pretty much all the +NiceVision equipment, except for the cameras. +Hmm. +What happened to the +cameras? +That's what happened. I +think the cameras went to Building Four. I was +looking for it, and that's what ended up at +Building Four and maybe some decoders. +So, you think all, but +that's - you mentioned right now that all the +NiceVision equipment ended up there. +Hmm. +So, you think the cameras + + +1 +also got shipped? +2 +41 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Yes. Well, they might +have got shipped, but nobody told me. Whenever +they came in, they came in. I'm not too sure. +You're not sure what +happened to the cameras? +Yeah. +Do you believe the cameras +got shipped or no? +Yeah, they got shipped, +but they ended up going to Building Four. +Whenever they came in because I remember +looking for them and that was one of the +things, I had to figure out what happened to +the actual - because we were going to network +cameras - so I had to figure out where they +were at. And they weren't at the rear gate. +looking for them? +Okay. When do you recall +: I don't really remember. +This is probably around the same time I +probably sent this email. I was trying to +figure out where everything was at. +The cameras. So, do you +think the cameras went to Building Eight -- + + +42 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Hmm. +-- around this time or +back in November 2018? So, that's two +different timings we're talking about. +Yeah, two different +timing, yeah. +So, when do you think the +cameras got shipped and sent to -? +: I think the cameras came +later. +Okay. +everything came right away. +Yeah. +cameras came? +The recorders and +So, when do you think the +Probably after all of +this, so maybe in November. +: okay. +No, not November. So, it +probably came around November 19th, that's when +everything. Yeah. +So, November 2019, after +Epstein? + + +43 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Yes, after Epstein. +Do you know why there was +such a big delay and why +Because, like, when you +order cameras, if you're going to order, like, +300 cameras there's usually a backlog of six +months or eight months. It's not going to be +something you're going to get right away from a +vendor. +Was there any other reason +why the cameras were not shipped? +oh, and there may be a +signature or something. Because I wasn't in +charge, so I couldn't really sign for anything. +That was a part of the problem. So, when stuff +was getting ordered. +: Was there ever +communication between MCC, were you able to +recall any communication between MCC or +yourself and SigNet, asking SigNet not to ship +the cameras? +No. I would never tell +them not to ship the cameras. No. +So, we're going to show +you an email. +This email is from you dated + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +44 +September 5th, 2019, at 8:52 a.m. to +• and +70E9F." +Mm-hmm. +Subject is "MCC New York +Mm-hmm. +And that's the initial +email and it looks like there's a response back +from +The initial email from +you states, "Good morning. There's a +discrepancy with 135 dome cameras." +Mm-hmm. +"The proposal part number +was Wycon IQ M62WRB9. +Mm-hmm. +I received 135 of Wycon +cameras part number, " and it states a part +number. "What is the best way to fix this +problem? The cameras I received are not part +of the approved hardware list for the BOP." +Hmm. +responds on +September 5th, at 8:58 a.m., " +, this +issue is the model number changed because you + + +1 +had us wait to order the cameras." +2 +Hmm. +3 +"The cameras you received +45 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +are part of the replacement model." +Hmm. +"My recommendation, with +the rush to get all this installed, would be to +open a magic ticket and request it be added to +the approved list. +Hmm. +: The biggest issue we have +right now is that 90 percent of the cameras on +the approved list are EOL." Take a 100k at +this and let me know if you recognize that +email. +Yes, I remember this +email, yes. +But I'm not in charge of +saying you can't send cameras, so. +: But that says you - the +statement up top from +is - it clearly +states that you told him to hold off on +ordering and sending the cameras. +Hold on. +No, we're trying + + +46 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +to figure -. Not hold off, but we have to make +sure that - anything we install on the BOP +network - we have to make sure that it's +approved on the list as far as for +(Indiscernible *00:31:29) and everything else. +We can't just order anything and get it +installed. +So, if the original part number was for +these cameras, they would have to ship these +cameras. And if the part number changed before +they send it to us, they have to notify if the +part number changed, then we have to get it +approved through Computer Services before we +install them. We can't just install anything +on the network. +: Okay. Just to give you an +understanding. +We spoke with +-- +that +: Mm-hmm. +-- and one of the things +told us is they send you +all that stuff, and in his communication with +you, you advised him not to ship the cameras - +Cameras. +-- because there's no +where to house the cameras. + + +47 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Yeah, that was the biggest +issue, yes. +So, there's no way to +house the cameras, so you told him not to ship +the cameras, hold off on shipping the cameras +until you get the okay for shipping the +cameras, until there's space to do it. +Mm-hmm. +Until you guys have space +to house the cameras. +Mm-hmm. +Because 300 cameras. I +think the order states there's about 300 +cameras -- +Mm-hmm. +-- right? +That's a lot of cameras. +Yeah. +I'm guessing you need a +lot of space. +So.. this - I mean, I'm +not saying there's anything wrong with it, +like, we get it. + + +48 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +nowhere to house it. +Mm-hmm. Mm-hmm. +Right, hey, there's +Mm-hmm. +If that is an issue, you +can tell us. Hey, we had nowhere to house it. +But if that's a +communication between both you guys, just be up +front and say, hey, no, I told him to hold off +on it. +: No. The hold off was, +this - the cameras have to be approved on a +(Indiscernible *00:32:38) list. And the +problem was the cameras that I had requested, +BOP went and changed, whoever in Central Office +- the original proposal was for access cameras +and the problem was these cameras were not +going to work on the NiceVision. +When you +added them to the software app. I make sure +every time we got something that it's going to +work, because I know when you order a big bulk +like that, you can't just send it back. You +can't say, hey, I don't have the right stuff, +because it's not going to work. And that's + + +49 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +part of the problem now. +Because these Wycon +cameras, 300 of them, I don't know if they're +at MCC now, but when I was leaving MCC, they +were never installed because the next year the +Pogo cameras got installed because the Wycon +cameras never really worked with the +NiceVision. That's why I was telling everybody +to hold off. Because I knew it was going to be +a problem with the network. +Okay. So that's what +clarifies. +So, when this order was +placed, and this bulk order was placed, you're +saying there was an issue with the cameras? +Yes, yes. Because they +have to have a certain plug-in to work on the +system, and we have to make sure, hey these are +the cameras we're going to order, and these are +the ones that are going to get installed. BOP, +somebody changed the part number and I'm, like, +hold off on it, we've got to make sure these +cameras are on our approved list, because they +have to sign off on it. If it's not on the +approved list, you can't have these cameras in + + +1 +the institution. +2 +3 +4 +order. +5 +6 +7 +8 +him to hold off on -- +50 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Because it's just a big +So, that's why - +(Indiscernible *00:33:47). +-- so, that's why you told +Yes -- +-- shipping it? +-- shipping it, yes. +So, you had to verify the +actual -- +Mm-hmm. +-- part number? +Yes. But this, I know +you're talking about this, but this really has +nothing to do with -. +Okay. +Yeah. +So, that's back in - when +did you tell them, when did you initially +figure out the fact there was an issue with the +parts that were ordered? +Right away. + + +51 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Right away, okay. +Who did you contact in +regards to -? +and I told +I contacted +about the problem, as far as +the cameras. +: But +wasn't there +yet. This is going back to November -- +oh. +- November, it was +shipped; the order was placed in September -- +September. +-- of 2018. +Yeah. +Let's just say October. +The estimate was October. +Mm-hmm. +: Did you contact anybody at +BOP and let them know, hey, listen, there's a +problem with the order? +: I spoke to whoever was in +charge at that time. So, Maybe +I spoke to Computer Service +or - oh, +Because he + + +52 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +would have to send a trouble ticket to get it +approved; these cameras approved on the list. +So, you think Computer +Services -- +Mm-hmm. +-- +Mm-hmm. +And you think you spoke to +him and told him -? +Because you have to send +in a trouble ticket, like this says, to make +sure it's approved on the list before it gets +ordered. +So, he would have to +create a trouble ticket -. +approved, yes. +: Ticket to get this +creating a ticket at all? +: And do you remember +: I'm pretty sure, if it +says I spoke to L +then he yeah -. Yeah +| yeah, he was aware of it. The Wycon +cameras. +Because the part number changed. +But it basically sounds +like, based on what he said, the part number + + +53 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +changed because it was -. +long. Because I can't -- +Everything waited too +-- (Indiscernible +*00:35:22) habit. +-- yes, and I can't sign +off on it. That's why +was on the email +because he's the one that has to sign off on +cameras. I can't sign off on anything. I can +do my recommendations, but I can't sign off and +get anything shipped to the institution. +But that's different from +what you said about the part number not +matching up to what you wanted - +Mm-hmm. +- to him stating that, +hey, no - +You waited too long, yes. +-- you waited too long. +That's two different +things. +That's two different +things, yes. +So, what - based on this, + + +54 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +like, according to the contract - what was the +cameras that you guys ordered? +: 350, (Indiscernible +*00:35:49) licenses. +up. I think it was 75 and -. +No, I think it was split +Oh. (Indiscernible +*00:35:57). +oh, 10. Yes, this part number +right here. +And you -. What -? Can +you read it out so we can -. +1QM62WR-B9. One Quebec- +Mike-6-2-Whisky-Romero - Bravo-9. +And there's another one, +too, right? Because that's only one set of +cameras. +That's the pointer +cameras. That really didn't have anything to +do with it. These are the dome cameras. +So, there was nothing +wrong with the dome +cameras? +They never really worked - +even when they changed the part number, this +never worked on the system. +We never even +installed these cameras. + + +55 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +got installed? +So, the dome cameras never +We had them on hand when +they came in eventually, but we have to order - +the next year, those are the cameras we +installed. I installed a few of these cameras +and I had issues, so we had to go to Pelco from +the order from the next year. +: +So, no matter what, you +had issues, but do you recall telling +- +or you said, right now, that you told +to +hold off because there was issues with the +cameras. +right off the back. +(Indiscernible *00:36:55). +You recognized an issue +And it has to get approved +on the (Indiscernible *00:36:57) list. It was +two different issues, but -. +: Okay. So initially, you +recognized there was an issue and you told | +- +Services. +Mm-hmm. +-- +at Computer + + +56 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Through Computer Services. +And you guys created a +ticket, - +Ticket. +- and back in October, +November 2018? '18, right, because -. +This is all '19. +But that's "19. +Yeah. +But I'm talking back then. +Oh, back here? +Back here, when the +initial order -. +Yes, I told him that there +was going to be an issue. But I can't really - +• I mean I can tell them, hey, hold off, but +they're going to ship whatever they're going to +ship. +oh, so, I should clarify. +So, maybe that's where the confusing part is. +said over here. +Mm-hmm. +You're talking about 2018. +His statement to us was, + + +1 +when those recorders in 2018 were shipped - +2 +Yep. +3 +-- he didn't ship out the +4 +cameras -- +5 +The cameras. +6 +-- in 2018 because based +7 +on his conversation with you in 2018. +8 +Yes. The part number was +57 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +wrong. Yes. +No, no. That's not what +he said. +Oh. +He said that you stated +that there was no where to house -- +House them, yes. +-- the cameras -- +-- in 2018, so you asked +him to hold off on shipping. +Yeah, we had to figure out +some stuff logistically. There was -- +But just to -. +-- there was a lot of +stuff going on. +And then, he didn't + + +58 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +receive any communication from you up until +later on -- +2019. +-- in 2019. +Mm-hmm. Mm-hmm. +And we have - let me show +you another email. This is dated - this is +another email, but this is not between you and +him. This looks like +-- +Hmm. +-- to +Pridemore at +SigNet, Inc. +Mm-hmm. +Pridemore. And this +is dated August 19, 2019. +Okay. +Right. It says, " +I +finally got the all-clear from the site to +order the cameras -" — +"-- on this job." +"Lines ten to 14 on the +revest Line 12 needs to be changed to the part +number at -- + + +59 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Mm-hmm. +-- 334 each." That means +- and he, +pointed us to this +saying that's when he got the final all-clear. +the parts. +Final, okay, yes. +From MCC to finally order +Yeah, because there was, +there had to be a signature and I couldn't sign +for it. That was another problem, too, because +there was nobody in charge. No bills am I +assigned for, to get this stuff - hey, these +cameras got to get here, somebody's got to sign +for it. Because during this time, when this +happened, there was really nobody in charge. I +think, I don't know if +was still there +or not there, but to get the cameras shipped, +there had to be a signature, and I couldn't +sign for anything. +So, there was no - a +signature wasn't needed for the recorders? +Because the recorders are an expensive part. +The recorders. Yeah, it's +an expensive part, but the cameras, I couldn't +sign off on. Because remember, +I was going + + +60 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +back and forth about the cameras, hey, I don't +think these cameras are going to work. They +already shipped that stuff for whatever reason. +When it came to the cameras and I was, like, I +don't think this is going to work, and they +actually needed another signature, and I +couldn't sign for it. +I couldn't say, hey, +change the part number. +Wait a minute, say that +again? Explain that slowly. +okay. So, I knew +initially that the cameras weren't going to +work on the system. +Because I had spoke with +• And then, +has to sign off on it. +And then I spoke to -- +This is 2018 or '19? +'19. +No, no. Let's go -. +Oh. +Forget about '19. +'19. +Let's speak about -- +'18. +-- '18 only. +Only '18. +I just + + +61 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +knew it was a problem, so I probably told them, +hey, hold off on shipping the actual cameras. +: Okay. So -. +Until we figure out, like, +where we're going to house it, and what's going +to go on with the cameras. +Okay. So that's, you held +off. And the next communication, the next time +you told him -- +Ship it. +-- ship the cameras would +be after -- +-- Jeffrey Epstein' s +death? +Okay. That's what we +needed. +oh, sorry. +That's it. Everything +else that happened afterwards makes no +difference, but -. +: Difference. Yh. +All right, so that was - +everyone held off and it only because + + +1 +2 +3 +4 +5 +secure. +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +logistically there was no way to house them? +There was no way -- +- to make sure they were +Because you can see, +that's a lot of money. You can't just - and +everything disappears there. +of cameras to house. +Yeah. +And 350 cameras is a lot +Understood. That's fine. +Do you mind if I -- +Go ahead, sorry. +- just clarify. In "18, +and just want to clean this up. In 2018, it +was a matter of the storage -- +no. Well, it was -. +The storage. +-- was the issue. +Yeah. Yeah. +And not -. +Not getting the cameras, +62 + + +63 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +It was not the model. +The model was an issue, +and then storage. Because when I spoke to +about this, the initial, if this is the +-. This is not what we sent up to BOP. The +initial, everything that I sent up to BOP, +everything was supposed to be access +cameras. +They went up to the Central Office, they get +another approval. They change the part number. +When I saw the part number, I'm, like , wait, +hold a minute -- +Okay. +- this is wrong. +Okay. +Yeah. And we don't have +space for it anyway - +Okay. +-- so, can you hold off +and -- +Okay. And that's after this +initial -- +Okay. + + +64 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +the CS, +But none of that, like, +none of that was addressed +up until -- +Until this. +-- '19. +The end of '19? +Yes, when the actual, they +were going to get installed. We had to make +sure that everything was going to work on the +network. +: Sorry. ASAC +: Yeah, I'11 ask one question +now, and then I'll let you ask a couple of +more, looking at your question list. +Once you had the space and they had the +right cameras in October 2018, were you guys at +the institution in a position to install those +right away, anyway? +No. No. +: Okay. All right. +It took - even after that +happened - it took IDY help about a year and a +half pulling fiber through the whole building, +upgrading the infrastructure before we could + + +65 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +even install cameras. And then -- +: Okay. +- Then to install the +cameras, that was another - yeah. +: Yeah. I just wanted to +confirm that, and I think +will ask you a +couple more questions now about what you were +getting into. +Okay. +Thanks. +At that point, now let's +talk about August 10, 2019. Like, this is the +day that - +Yeah. Yeah. +-- Mr. Epstein died. How +much of that conduit and wiring was actually +completed? +I think we started one +housing unit, and then I started -. +That's all that was +completed at that point? +: Well, as far as the +infrastructure, yes. Because I think out of +the IDY - I don't know when - I know there was +TDY help when +first came. It was + + +66 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +and +• They came from Texas. And we +pretty much fired up one unit to make sure, +hey, this is how we're going to - because we +have to pipe all that in for the cameras. You +have to put a conduit in. You can't have the +wires exposed, into each camera. And where are +you going to actually set the cameras up. So, +that took, like about a month for us to do that +-. The first unit took like a month. +And how many housing units +are at the MCC? +So, there's the female +unit, unit on the second floor. The WITSEC +Unit on three. 5 North, 5 South. 7 North, 7 +South. 9 North, SHU, 10 South, 11 South, 11 +North. So, 11 housing units. +: And as of August, only one +housing unit was done at that point? +: I don't really -. +Honestly, I don't remember. There's a lot +going on. +I'm talking an idea at +that point. +time, if +and +Yeah. I think during that +came TDY, that's when + + +67 +1 +maybe one housing unit was totally piped in and +2 +maybe ready to go, but even then, it wasn't +3 +ready to go because you still needed a fiber +4 +upgrade. We could have put it on single mode, +5 +but it would have had issues. It wasn't -. +6 +And then, we still didn't even have CAT-5. +7 +There was a lost of stuff we just didn't have +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +to finish the upgrade. +: Okay. So, after Mr. +Epstein's death, did they bring in more +employees? +: Yes, they brought a lot of +TDY help, and that's when a lot of stuff +happened. +: And once they brought in +all the employees, how long did it take to +actually put the - forget about the cameras - +how long did it take to put the wiring in? +: After Epstein's death - so +they were closing down the prison in August of, +well, we found out August-September. I was +still working, like, two or three times a week +on overtime installing conduit, and running +wires, and installing cameras. And even with +all that said, there was still - I remember I + + +1 +went through all 11 housing units - I still +2 +didn't finish 11 South because that's open +68 +3 +4 +5 +6 +7 +8 +dorm. Unit Iwo never got finished and the +sallyports never got finished. And some +outside cameras. So, even after that happened, +three years, it still was a long undertaking. +So, even after three years +- +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +completed? +-- it's still not +It wasn't completed when +we left, and they shut down that jail. As far +as the IP cameras, that was not completed, no. +And that was just the wire +itself that never got completed? +: No, no. Just hooking up +cameras and the wiring. We put in -. Pretty +much set up the infrastructure where each floor +you could go to a hub to install cameras +everywhere. +Yeah. +: But as far as finishing +the actual units, some of that was not +complete, no. + + +69 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Okay. And do you recall +when the majority of the work was done? +: I was, like, I was working +overtime all the time, so it was -. +was it like a couple of +months? Three months, four months? +It was a couple of years. +I was still working on it -- +It was still ongoing? +- yeah. It was still +ongoing. I was still working on it. It was +never really complete. Because COVID happened. +We had TDY help, and we had the gun thing, +where we had more people come in. So, there +was a lot of stuff that needed to -. +So, they were continuously +being people IDY to help with it? +: Okay. And did the people +actually continue doing work for the cameras, +or were they pulled out to do other things? +They were pulled out to do +other things too, when it came to VI. +What was SigNet's role in +the installation? + + +70 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +They were supposed to do a +boatload of work, but we ended up doing a lot +of the work inhouse. +That's (Indiscernible +*00:45:54). +Yeah. Because -. +Because over here on line, +where is that line? Look SigNet labor says +243,000. +43,000 yeah. +What was their job? +Their job. Okay, so the +main thing we were supposed to do was run pipe +everywhere and, like - +You guys were? Like, the +MCC. +-- right. MCC was +supposed to run the pipe everywhere, put the +box up, and they were just going to come in and +mount the cameras up and put it on the network, +but it was going to take too long, so we just +started doing everything in-house. We started +- well I started - just installing cameras, and +putting them up, and letting them start +recording. So, you have more view. Because + + +71 +1 +2 +3 +4 +5 +6 +7 +8 +one camera we had on the unit, that wasn't +going to solve everything. +So, we had one camera on the unit, and +after, like, all this started happening and +especially, a staff member got assaulted. +That's why I added another camera on the +network, one on top of the bubble, so you could +see like - it's a 270 - so, you can see like +this way. You can pretty much see the whole +unit. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +So, that's the best I could do at the time +for all of the housing units that only had one +camera. And then, eventually we started going +unit by unit and just installing 12 to 13, +however many cameras on each unit. +: Okay. And how long did +SigNet stay after Mr. Epstein's death? Did +they come and stay for a while - +: Oh, yeah, I wouldn't - +-- to finish up +everything, or did they -? +No. After Mr. Epstein' s +death, that's when they came and installed the +recorders. Because this was all on-hand, the +new recorders and the rack. But they had to + + +72 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +get the okay for them to - well, and I called +1, too, about this. I was, like, hey +we're on the list, but we weren't on the list +to get upgraded. +So, but then this +happened, so they came, like, the next day, and +I stayed there to -. +They stayed for a couple +weeks-? +oh, just a couple days. +Just to get the new recorders in. +That's it? +Yeah, it was -. +They didn't help with the +cameras? +No. +So, you guys still +installed the cameras yourselves? +Yeah, we installed all the +cameras. +on that? +ASAC +anything else +: Yeah, a couple of questions. +So, based on what you just said, I just want to + + +1 +make sure I'm clear. We talked about the fact +2 +that if you had the new cameras in October of +73 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +2018, you would not have been able to install +them based on the lack of wiring. +: So, let me ask the same thing +about August 10th, the day of Epstein's death. +If you had received the cameras before that +day, would you have been able to install them +before that time? +: No. +: Okay. And, because it 1o0ks +like - yeah - the cameras I think finally came +in October 2019. +The second question is - let me get back +to my notes here - after Epstein's death, as +you just said, SigNet came in, they got the new +recorders up and running, and you were able to +have video coverage with the old cameras on the +old recorders, correct? +: So, it's not like the +institution was without -- +Cameras, no. +-- cameras, yeah, between -. + + +74 +1 +2 +3 +4 +5 +6 +7 +The cameras were always +working. That's the misinterpretation of the +whole thing. +Okay. +The cameras were always +working. +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: All right. I just wanted to +make sure to get that on the record as well. +And the final question - I don't think, +I, you were going to ask this - is in +regard to the other contract, +, I +believe is the company. +(Indiscernible *00:49:10). +(Indiscernible *00:49:11). +I had a question also. +I'll show him the email also. +I'll let you -. +: Yeah. Perfect. Okay. Then +No, no. You can ask the +question. I'll give him the email, so, if you +want to refer to the email yourself -- +: Mm-hmm. +-- I'll provide it to him. +Yeah, so basically , my + + +75 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +question was going to be in regard to that +contract, do you know approximately when the +materials from that contract came in? +This was -. +: And again, it looked to be +primarily wiring, from my understanding of the +order. +The cable. +: Yeah. +: Is this fiber? I don't -. +No, that came a little bit later, because we +didn't have fiber anything. +Okay. You didn't have +fiber -? +Maybe we had fiber, but +then we had to do another order for fiber +because they wanted to change stuff, so. +: And this, is it the new +order for -? I want to read this just for the +record. This says -. This is from +Who's +officer at the time. He took +Oh, that's the contracting +spot. +He was, like, the cashier. +He's a - it says Financial + + +76 +1 +Program Specialist? +2 +Yes, yes. +3 +Okay. And it was sent to +4 +a bunch of people including +5 +yourself, and it says, +6 +subject is "Anxiter TP12240 and SigNet tech." +7 +It says, "Good afternoon, Ms. +1. After +8 +reviewing my cost report for the Central Office +samples, I went ahead and asked +• OUr +10 +Com Tech, on the status of these particular +11 +POs, and he advised me that they haven't been +12 +13 +14 +15 +16 +17 +able to receive the fiber cable, and without +the cable, they can't proceed with the camera +systems." +Mm-hmm. +"He mentioned that the +company is requiring some sort of +18 +19 +20 +21 +22 +23 +24 +25 +documentation. He should be able to provide +you with the details." +Yeah, because I - like I +said - I couldn't sign for anything. So, +somebody else would have to sign it. I could +advise as much as I can, but I can't sign it. +So, you recall, that's not +the new order, that was the previous? + + +77 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +previous order. +Yeah, probably the +And fiber was never used? +Yes, it was used, yes. +Later on? +Later on, yes. +But not for the initial -. +The initial thing was to +try to get - well, get the pipe in, and then do +a fiber. +Wasn't piping already +there? So, +told us that you guys +had, like, the conduits laid in Building Four. +: I didn't know anything +about that. +Or was that ordered? +: That was maybe for +something else, or maybe it was ordered. I +don't know. +: Where did you guys get the +conduits to run? +conduit from +Mainly, I got most of my +That was the vendor I +used. +So, you guys bought it? + + +78 +1 +2 +3 +4 +5 +6 +7 +8 +Yeah, locally, yes. +Locally. And so, you +bought the conduits from them. What about the +wiring itself? +That was from Anxiter. +Because that's the CAT-6 I use. I got +everything from +All right, so it was from +an outside vendor? +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Yes, yes. +Okay, so there was actual +contracts for that. +For the fiber, yes. +The conduit, we just placed the order and just +bought conduit when we needed it, as much as we +needed to do a unit. +Okay. +: And so, again, I think that +email was from April 2019, so it sounds like, +at least at that point, you guys had not +received the +materials. Do you have +any idea when that finally showed up? +: It was so much stuff +coming in, and like I said - +: Okay. + + +79 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +- we had very limited +space, so. +: No, I understand. +Mm-hmm. +MR. HORNEE: I just wanted to see if you +had a recollection. Thanks. +I have -. +: And that is all I have, +No problem. I have +another email here. It looks like it's a +communication between yourself and +on Friday, +March 22nd, and -? +What year? 2000? +2019. +Okay. Mm-hmm. +: And it says, "Good morning. +Is it possible to overnight some cameras for +MCC New York project?" And you were asking +him, "I would like to mock-up a unit before we +bet started to see what we needed -- +Mm-hmm. +-- 20 dome IPs, five 180- +degree IP, " five - I mean two PTC, dome IPs. + + +80 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Do you recognize this +email? +: And this is prior to them +shipping the cameras. This is just -. Do you +know why you asked them for these cameras? +: That's probably when we +finished the piping on our unit. So, it was +probably in March when we finished the piping. +Which unit was that? +11 North, maybe. +So, this is the first unit +you -? +Yeah, we did, yes. +Okay, so this is the first +unit you're trying to get done, so -. But this +was before the cameras, anything came in? +So, you started doing one +unit? +Yes, we did one unit, as +far as the piping and see where you're going to +put everything. +So, this is basically, you +ordered these pieces just to see where + + +1 +everything would fit? +2 +81 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Yes, and how would it work +on our system. +Okay, no problem. I'm +going to jump onto the next set of questions. +Is that okay? +: Yeah, yeah, it's good with me. +I've got everything on the previous subject +that I needed. Thank you. +: Okay. Now regarding the +NiceVision System, can you confirm that only +the SIS staff and electronics technicians had +the ability to replay, save and export videos, +or could certain other staff, like captains, +lieutenants, anyone else review or save +recorded footage as well? +I think the captain has +authorization. Lieutenants? I'm not too sure +if they had authorization to pull video to -. +Because sometimes they'd have to send a packet +up, so I don't know if it was the SIs or the +lieutenants that saved video. Every +institution is kind of different when it comes +to who can pull the video. +: Is there something called + + +82 +1 +SuperVision? +2 +SuperVision, yes. +3 +So, you would have to have +4 +a specific log-in for it? +5 +: No, SuperVision - yes, you +6 +would have to log for - well, no. But +7 +SuperVision is just mainly for passwords and +8 +stuff. It's not really for anything else. +oh, okay. But to view it, +10 +11 +but don't you have to log in to see? +Yeah, that's the regular +12 +13 +NiceVision -- +Okay. +14 +15 +16 +17 +-- that's in control. You +just have to have access to Control. That's +the part of NiceVision. +And who had access to +18 +19 +20 +21 +22 +23 +24 +25 +that, just the captains and the Com Techs? +Just the Com Techs, yeah. +Maybe the lieutenants had it. I would have to +see the usernames. I'm pretty sure the +lieutenants should have had it. I'm not too +sure. +sure. +okay. So, you're not +You think maybe the captains, maybe the + + +1 +lieutenants? +2 +3 +4 +83 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +No. +: Captains definitely? +: The captain and SIS +definitely had the ability to pull video and +look at video. +And Com Techs. +: And the Com Techs. The +lieutenant's office? Some of the lieutenants I +think had their own password to look at a +video, in case something happened. Just to +look at video. +Does that differentiate +(Indiscernible *00:55:03) between like an +operations lieutenant and activity lieutenant? +: Activity, yes. Depending +on - because you got your GS-11 and GS-9 +lieutenant. +So, there's a possibility +the operations lieutenant had access? +Access, yes. +Okay. For the standard +NiceVision users - example, anyone outside the +use as identified in, like, let's say for the +people like the captain, lieutenant, things + + +84 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +like that - can you confirm that those users +were only able to view live video feeds? +Well, it's depending on +how you set up everybody's profile. Somebody's +profile you can - mainly SIS - they can pull +video under that profile. If you were a +lieutenant, you can probably just view live +Viewing. Because there's - Nice comes and +pretty much sets that all up before you even +get -. +They can see live video? +Yeah. +okay. Who had the ability +to go back? +: I think maybe the +lieutenants, too, because if there's a fight or +something, and they needed to look back at +video, and if SIS wasn't there, they probably +would need access to look back. +The captain? +Captain. +SIS? +SIS. +Com Techs? +Com Techs. + + +85 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +So, basically anyone who +had access should have technically have the +ability to review back. +To look back, yes. +What about Control? +Control just live view? +: Live view, yes. And +that's something we added later. They never +had a password until - well, until we started +upgrading the system. +Okay. Their screens just +stayed live -- +Live view. +- they couldn't mess with +it. +back or pull anything, no. +Yeah, they couldn't go +two questions? +Okay. Anything on those +: Nope, I'm good. So, it sounds +like there's just a couple of types of +accounts. +One is where you can rewind, save +and export video, and the standard user account +is just looking at the live feed. Is that +correct? + + +86 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Okay. +okay. Thank you. +Now for - because they're +standard, as we mentioned, there's different +users, right? Standard user and, like, the +other type of users. +Mm-hmm. +Can they log in from any +computer, +or -? +: Yes, any computer that has +NiceVision on the computer. +oh, so it had to be preinstalled? +: Yes, it had to be preinstalled. And some computers just have +control, they don't have access to SuperVision, +or to, like, go back and play video. +: Yeah. +They just have the +control. But even in control sometimes, you +can play back video that's there with just the +controller setting. You don't need SuperVision +actually on that computer. If your log-in +permits you to go that far. + + +87 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Okay. +: And so, on that, Mr. +so there's just various desktops, if you will, +computers throughout the institution that had +NiceVision installed. +: And if you had an account, you +could get in there, correct? +: Okay. And are there a lot of +shared computers in the institution? +: Yes, everybody shares. +: Is that right? Like, like any +other institution? +: Yes. +: Okay. All right. And that's +all I have on that. Thanks. +: Did the facilities manager +also have keys to the dedicated room containing +the camera DVR system? +Not that I know of. No. +So, it's just the Coms +Tech? +Well, where the DVRs are, +SIS had that key. I never had access to it. + + +88 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +oh SIS, sorry, I said it +wrong. +Yeah, the SIS. +Only the SIS. +Yeah. +So, the facilities +managers -. +we didn't have keys to get +in that room. Because that was the SIS. I +mean that's the room we were talking way before +all this happened, that we needed to get this +fixed and it never did until after. +: Lieutenant +mentioned that downstairs in your office, the +Coms Tech office was in the basement? +Was there, like, a tower +in your office with, like, the recorders and +things like that in the office? +: No. +That gave you access to -? +: No. I just had the live +feed from the old (Indiscernible *00:58:31), so +I could look at the live video, and at my +workstation I could look at -. I had a screen + + +89 +1 +2 +3 +4 +5 +6 +in my shop where I could look at the live feed. +: Yeah. +And then, I had my desktop +computer where I could log into Nice and 1o0k +at what's being recorded, or what's working on +the recorders. +7 +8 +But she mentioned like a +terminal itself. Like, all the recorders, DVRs +and stuff-. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +It probably looked like -. +It was probably my -. That's where the public +address was. And later on, after the install, +I put in a separate, like I put a network in my +shop, but that was later on. The only thing +that was in there was the public address, my +live feed, and my workstation. +: This is prior to the +August 10th, 2019? +Okay. But there's no +actual, like a DVR system, recorders, or +anything like that? +No, there was nothing in +the basement, no. +Okay. Anything else ASAC + + +90 +1 +2 +3 +4 +5 +6 +7 +8 +? +: Yeah. I just want to double +back to the key situation and the rooms there. +So, the actual room with the DVR recorders, +right? +: And so, you had a key to that +and that's -. +No. I never had a key to +that until after all of this happened. After - +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: Okay, so the actual - so there +are two rooms. +: The way I understand it is +there was the phone monitor room, and then +within that room there's another locked room +that had the DVRs, correct? +Yes, yes. +: Okay, so you didn't have a key +to either one of those rooms? +NO. +: okay. +Well, I'm glad I asked +because that was a little confusing. +So, SIS +controlled the keys to both of those rooms? + + +91 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Yes, because that was the +Evidence Room. And like I stated before, I was +told numerous times that we should have our own +key or get your stuff out of the Recorder Room. +: Okay. +: And that's how it is at +most institutions. Just the Recorder Room. +Nobody else but the Com Techs have that key or +should. MDC Brooklyn, I have the same problem +now because that room is - I don't mean to be +talking off - but they use that room for other +stuff, so now you have people that do have the +key. These two institutions are rare because +when I worked in Terre Haute, only the Com +Techs had the key to go in the Recorder Room. +Nobody else should have the key. +These two institutions for space or +whatever, they use an excuse and other people +have the key to go in the room and nobody +should have the key but the Com Techs. +: Okay. So, prior to August +10th, 2019, you did not have a key to that - +: No. +We talked about it +before -- +: -- Recorder Room? + + +92 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +- about me getting access +to having a key so I could get in that room. +But you never did. +okay, so -. +I never got it, no. +: You didn't have one. I'm +assuming the facilities manager didn't have one +either then, back then. +No. +: Okay. And so, you said SIS +controlled those keys. Obviously, the +lieutenant had it. Do you know if the SIS Tech +had the key? +The SIS Tech had the key +and the lieutenant, yes. +: okay. +: And whoever was in the +Phone Monitoring Room or the Video Room. They +would have the key to get in also. +: So, the phone monitor who is +just a CO that's rotating -- +: Yes. +: -- or a staff member rotating +through there on a quarterly basis, they would +be given that DVR Room key, as well? + + +93 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +They would have the key to +get in the room and the door is supposed to be +locked, but usually, I get - if they're already +- I could just go in the room in the back. +: The room in the back. +Is +that locked or is it just kept open? +: It probably should have +been locked. Sometimes I went in there, it was +locked, sometimes it was open. +: Okay, so, but for the phone +monitor, they had a room, obviously to the +Phone Monitor Room -- +: -- but not the actual DVR Room +that key. +I'm not sure if they had +sometimes -? +: - but you're just saying that +I don't know if they have +that key or not, but usually that room is open. +MR. I +: okay. +Because only the SIS would +have that key. +: Okay. +All right. Good. + + +1 +2 +Thanks a lot for clearing that up. And that's +all I had on the keys. I had one more +94 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +question, +1, if you were finished, before +we move on to the phone call. +Yeah. +The DVR and DR training, we +saw some emails -- +Everything was inhouse. +training? +Yeah. +- which I think you -. +I never got training. +: Okay. You did not take that +job. +I've never taken a +training. Everything I've learned is on-the- +: okay. And the version, like - +so, the main thing is, when I started as a Com +Tech, I started in Indiana - and the version of +NiceVision I had was, like, two generations +before the current version when I went to MCC. +So, when I came to MCC, I thought MCC was going +to have the updated version, but they have the +old stuff, and then I had to figure out how + + +95 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +that stuff worked. +: Okay. +backwards, pretty much. +: So, I was learning +: All right. Thanks. I know +you had provided us with an email showing, I +forget the date. It was a certain point in +time you had not had the training. I was just +wondering if that had changed at any time prior +to the incident? +: Up to this day, I've still +had no training -- +: okay. +-- from NiceVision. +: All right. Well, hang in +there. Maybe one of these days. +I think I'm kind of an +expert now because -. +: It sounds like it. All right, +and that's all I had. Thanks. +And onto the last topic. +Mm-hmm. +I'm going to show you a +document. Do you recognize this? + + +96 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +that is? +Can you explain to us what +This is the phone record +they probably made me pull. +Who made you pull? +: The warden or SIS. +: Okay. Can you read that? +Like, can you explain to us the date of the +call? +Okay, so the date is 8/9. +That's August 9th. +August 9th, 2019. +And the time of the call? +Which is 1858:03. +That would be 6:58 p.m. +58, yeah, and three +seconds. And then -. +The location. Would you +be able to say where the location is? +: 6134. That's the caller +station. +where that is? +Do you know, offhand, +housing unit, SHU. +I believe that was a + + +97 +1 +2 +3 +4 +5 +6 +7 +8 +And why did they ask you +to pull that? +Because they believed Mr. +Epstein was given a phone call before all this +happened. +And either the warden or +the SIS asked you to pull that? +: To see if actually he got +a phone call. Io make sure that they put him +in there to see if he really got a phone call. +: And what was the number +that was dialed out? +The number that was dialed +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +out, +: And how long did that call +last? +Oh, so the start time was +1858:03. They answered 19 seconds later, and +then the call ended at 1919:10. +And what system did you +use to pull this up? +That's the PBX Phone +Switch, and that's pretty much anything going + + +98 +1 +into the institution or coming out. That's the +2 +phone record. +3 +And based on your review +4 +when you went in, this is the call? +5 +: That was the call, yes. +6 +And you pulled this up, +7 +you handed it over to the SIS or to +8 +(Indiscernible *00:01:05:07)? +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Whoever wanted me to -. +was a lot going on. I was +Like I said, there +trying to do a lot. +And this was Epstein's - +based on your recollection - this is Epstein's +last - +Phone call. +-- phone call, and that +was provided to the OIG? +Okay. Any questions? +ASAC M +I, do you have any other questions? +: I do not. Thanks. +Well, that's it from us. +Yeah. I thought it was +going to be more. +No. + + +99 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Hey, it's because it is a +lot. I know it's a lot. +It's a little confusing. +I should clarify the timing. +we care only about August +10th and prior. +Prior. Yeah. +And thank God we were able +to clarify that. +: Okay. +Same thing as before. All +the documents we showed you, we just need you +to initial -- +oh, okay. +-- and date it. +Okay. +Yeah, let me put this in +front of you. +Okay. +anywhere on the document. +Just initial and date +Today is the -? +4/7. +I'm bad with dates. +I + + +100 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +should be better. +*00:01:06:08). +(Indiscernible +Same thing. No, you're +fine. +That's part of the same +document. Mr. +thank you for taking the +time to talk with us today. +: Yes. +And we can't say we're not +going to come back here with more questions. +Uh-oh. +We might have more +questions. +You might have more +questions. +We'll reach out to you if +we do. +Okay. +And we'll set up another +interview. +And thank you again. +Uh-huh. +This is Special Agent +The time is 11:28 a.m., I'm +concluding this interview. I'm stopping the + + +1 +recorder. +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +26 +101 + + +1 +2 +3 +4 +5 +6 +7 +8 +102 +CERTIFICATE +I hereby certify that the foregoing pages +represent an accurate transcript of the +electronic sound recording of the proceedings +before the Department of Justice, Office of the +Inspector General in the matter of: +Interview of +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Transcriber \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/0bbb45d319dfb3a7f68b397483dcba3450e588cdc23571f9fe0dd1ddd1b05b66.receipt.json b/vision-fixhub/ds9-parsed-01/0bbb45d319dfb3a7f68b397483dcba3450e588cdc23571f9fe0dd1ddd1b05b66.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..2e530d15dc260f7c9e39250d869c1376b9585ce5 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0bbb45d319dfb3a7f68b397483dcba3450e588cdc23571f9fe0dd1ddd1b05b66.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -7960, + "dataset": "marble-joined", + "doc_id": "0bbb45d319dfb3a7f68b397483dcba3450e588cdc23571f9fe0dd1ddd1b05b66", + "engine": "marble-apple-vision", + "event_count": 106, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "c8847696ff64af293118d1a478910d9cbf68d7f3d6b2819f16220fad8be333d8", + "output_sha256": "ba811a905cb310d0f541cf91337dfefcd23415759c57bc83838f875aaddd7af0", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0bf0e45d15a4e996808dc55917520d48cd4295903d92f4591aafd8fc02f068d1.md b/vision-fixhub/ds9-parsed-01/0bf0e45d15a4e996808dc55917520d48cd4295903d92f4591aafd8fc02f068d1.md new file mode 100644 index 0000000000000000000000000000000000000000..260397fd31abb8eafe6f6a0b4900e8f7fa7c94c6 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0bf0e45d15a4e996808dc55917520d48cd4295903d92f4591aafd8fc02f068d1.md @@ -0,0 +1,11 @@ +From: " +To: " +Cc: "Todd Wallace Blanche (todd.blanche@cwt.com)" < todd.blanche@cwt.com>, "Sean S. Buckley +Esq. (sean.buckley@kobrekim.com)" < sean.buckley@kobrekim.com>, "John Peter Cronan Esq. +(john.cronan@gmail.com)" < john.cronan@gmail.com>, "l +Subject: Re: Rachel continues to kill it +Date: Tue, 13 Aug 2019 01:46:39 +0000 +Nothing stops her!! +On Aug 12, 2019, at 9:10 PM, +https://www.cnn.com/2019/08/12/us/jeffrey-epstein-associates-investigation/index.html +> wrote: diff --git a/vision-fixhub/ds9-parsed-01/0bf0e45d15a4e996808dc55917520d48cd4295903d92f4591aafd8fc02f068d1.receipt.json b/vision-fixhub/ds9-parsed-01/0bf0e45d15a4e996808dc55917520d48cd4295903d92f4591aafd8fc02f068d1.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..1efdd83b5e34b4fcf5cd76841e61fe1328d575b5 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0bf0e45d15a4e996808dc55917520d48cd4295903d92f4591aafd8fc02f068d1.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "0bf0e45d15a4e996808dc55917520d48cd4295903d92f4591aafd8fc02f068d1", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "f7ba92e7c315a55b60a8b87701380b6cd02156b86e5a842dbe5d1eb19720280b", + "output_sha256": "7c5c793f4b4b0ce4dbc0f70261110f4300b1425444b48215ccfa83c6dcabe7f7", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0bf8d57af04eba12818111d28ec4edc40b34ba3e00a2f3e3961d9706006a8aab.md b/vision-fixhub/ds9-parsed-01/0bf8d57af04eba12818111d28ec4edc40b34ba3e00a2f3e3961d9706006a8aab.md new file mode 100644 index 0000000000000000000000000000000000000000..5f8bff360ce7f8443dc967270723d888dfe34fce --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0bf8d57af04eba12818111d28ec4edc40b34ba3e00a2f3e3961d9706006a8aab.md @@ -0,0 +1,132 @@ +FEDERAL BUREAU OF INVESTIGATION +Title: (U) ON OR ABOUT AUGUST OF 2009, BRADLEY +JAMES EDWARDS, DATE OF B +Drafted By: +Case ID #: 72-MM-113327 +(U) RODRIGUEZ, ALFREDO - SEE SUB +Date: 10/27/2009 +Details: +i»¿ +Date: 10/28/2009 +To: MM +From: MM +Contact: MM +Case ID #: 72-MM-113327-ELA +72-MM-113327-ELA +On or about August of 2009, Bradley James Edwards, date of birth +was contacted by Alfredo Rodriguez, date of birth +Edwards is +an +attorney who is representing four female individuals who are suing +Jeffrey +Epstein, Rodriguez was an employee for Epstein. Edward's deposed +Rodriguez and +served him with a federal subpoena to provide any and all documents +relating to +the case. Rodriguez is trying +to sell Edwards documents that he claims + + +(U) ON OR ABOUT AUGUST OF 2009, BRADLEY JAMES EDWARDS, DATE OF B +Re: 72-MM-113327, 10/27/2009 +are +pertinent to the civil case. Edwards explained to Rodriguez that his +demands +are illegal and that he was obligated under the subpoena to turn the +documents +over. Rodriguez is still demanding $50, 000.00 for the documents. Edwards +will +make a consensual call to Rodriguez and +introduce +an Under Cover Employee +(UCE) +to complete the transaction. +identity theft false +U +preliminary investigation false +ALFREDO RODRIGUEZ; OBSTRUCTION OF JUSTICE +UNCLASSIFIED +10/28/2009 +10/28/2009 +On or about August of 2009, Bradley James Edwards, date of b +PB-2 +2 + + +ON OR ABOUT AUGUST OF 2009, BRADLEY JAMES EDWARDS, +Re: +72-MM-113327, 10/27/2009 +MM +MM +FD759 +07-17-2009 +MM +(MM) (FBI) + +Alfredo Rodriguez +10/28/2009 +additional false +Southern District of Florida + + +(U) ON OR ABOUT AUGUST OF 2009, BRADLEY JAMES EDWARDS, +Re: 72-MM-113327, 10/27/2009 +other false +other2 false +Florida +In a Telephone +confidential source false +Bradley J. Edwards +Nonconfidential Party +by request of high ranking doj official false +party in custody of bureau of prisons or usmarshalls false +party member of diplomatic corp false +party member or former witness security false +related to congress judge executive branch or level four executive false +related to governor Itgovernor ag or high judge of state or territory +Collect Evidence +computer trespasser exception false +Telephone +attorney contacted and approved false +authority granted for ninety days +body recorder true +4 + + +(U) ON OR ABOUT AUGUST OF 2009, BRADLEY JAMES EDWARDS, DATE OF B +Re: 72-MM-113327, 10/27/2009 +cctv video only false +consenting party agreed to execute prior to start true +consenting party agreed to testify true +other true +18 +1509 & 1510 +consensual monitoring true +matter of national security false +oia authority for chs false +true +access control desired false +TEMPLATE +Error: InfoPath cannot submit the form. An error occurred while the +form +was +being submitted. i»¿i»¿ The SOAP response indicates that an error +occurred on +the +server: +Server was unable to process request. ---> Invalid Case ID ; +check item +1 +5 + + +(U) ON OR ABOUT AUGUST OF 2009, BRADLEY JAMES EDWARDS, +Re: +72-MM-113327, 10/27/2009 +1 +Upload Document +FAILURE +11/09/2009 +10:13:17 +11/09/2009 +10:13:17 \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/0bf8d57af04eba12818111d28ec4edc40b34ba3e00a2f3e3961d9706006a8aab.receipt.json b/vision-fixhub/ds9-parsed-01/0bf8d57af04eba12818111d28ec4edc40b34ba3e00a2f3e3961d9706006a8aab.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..e74add62c7724ad7d0c19582200914788ed5fc64 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0bf8d57af04eba12818111d28ec4edc40b34ba3e00a2f3e3961d9706006a8aab.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -412, + "dataset": "marble-joined", + "doc_id": "0bf8d57af04eba12818111d28ec4edc40b34ba3e00a2f3e3961d9706006a8aab", + "engine": "marble-apple-vision", + "event_count": 8, + "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "dfc95f06857a70016d8b94f301a402870b0eddf3f45cc34425d9082885e47b9b", + "output_sha256": "7f439f7e65f6ac73e052321d1c92d6ba080b85865bfd2febebd73818a5f2747f", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0c47bcc3202896c7cafdf8db6b800a6fcad19cb43e6f1298aa5f0ddb5aa56868.md b/vision-fixhub/ds9-parsed-01/0c47bcc3202896c7cafdf8db6b800a6fcad19cb43e6f1298aa5f0ddb5aa56868.md new file mode 100644 index 0000000000000000000000000000000000000000..bb2be5a69c2d4bf8e39505e1fb16ad4d61541c76 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0c47bcc3202896c7cafdf8db6b800a6fcad19cb43e6f1298aa5f0ddb5aa56868.md @@ -0,0 +1,53 @@ +Jeffrey Epstein, DOB: +Last Name +EPSTEIN +07-08-2018 +JEFFREY +Medle Name +EDWARD +Salix +м. 6'0" +m.185 +* GRY & BLU +REGH76318-054 NYM *318-034 LPSTEN + +MARTy Wewbong +20581925,1702 +OFFICeR +ofFicen +- both excellent professional +heep +FBI PoLice +ARRiN +192) + +2105 OMCC +1915 has +CAll +Fifty Remalla +completed, +2045 +O SDNY +Ø933 +0916 DepART MCC- SANY +93aTa + + +7/6/19 @appox 1825 has +SPONt +"% JeFfrey Epastein +ANE OUS UHRANCE FETVEHICL +RAVelINgFROM +AIRpORT → 26 FE +Isthis Sex TRAFFicKiNg?' +About A miN to 30 seconds LAtuR +"Is this nbout underrge?' +Entered oN 7/8/19 +7/6/19@ sometime after 1925 hes +appRoximatty TABS Roam 27K4/26 FED +spONtANeous uttrAnce +#This is golig back to 2002"0001 +"oh thisis bad "this is Really bad" +enteréd on 1/8/19 + + diff --git a/vision-fixhub/ds9-parsed-01/0c47bcc3202896c7cafdf8db6b800a6fcad19cb43e6f1298aa5f0ddb5aa56868.receipt.json b/vision-fixhub/ds9-parsed-01/0c47bcc3202896c7cafdf8db6b800a6fcad19cb43e6f1298aa5f0ddb5aa56868.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..09003f27432a70a7cf21a5383103b6aba63abf97 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0c47bcc3202896c7cafdf8db6b800a6fcad19cb43e6f1298aa5f0ddb5aa56868.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -44, + "dataset": "marble-joined", + "doc_id": "0c47bcc3202896c7cafdf8db6b800a6fcad19cb43e6f1298aa5f0ddb5aa56868", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "fa6eb755a0c253c558e8e61334db0f7319ddb49982b4fa7349048c299b711c99", + "output_sha256": "2af19e0b790d41156f73f4c4bc70be2d345d1fa65ae39d4548aac1cfb8ff6889", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0c4c38543dfdb160ee1b1ddd3eed3f0881bfd0ff1aca6b415cd4c1fe6a722704.md b/vision-fixhub/ds9-parsed-01/0c4c38543dfdb160ee1b1ddd3eed3f0881bfd0ff1aca6b415cd4c1fe6a722704.md new file mode 100644 index 0000000000000000000000000000000000000000..b3c375d0ea47c90349f80d265d03ca75956ff6f2 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0c4c38543dfdb160ee1b1ddd3eed3f0881bfd0ff1aca6b415cd4c1fe6a722704.md @@ -0,0 +1,119 @@ +From: +• (FBI)" < +To: +• (USAFLS)" { +Subject: Re: Yarbrough and Epstein stories +Date: Tue, 23 Sep 2008 20:32:01 +0000 +Importance: Normal +Inline-Images: ole0.bmp +Good article on yarbrough at lawfuel.com +From: +(USAFLS) +To: +• (USAFLS); +Sent: Tue Sep 23 14:50:56 2008 +Subject: Yarbrough and Epstein stories +FYI- +From the Palm Beach Post: +WEST PALM BEACH - A federal judge sentenced Marion Yarbrough to 40 years in prison Friday for +sexually abusing a 15-year-old West Palm Beach girl. According to the U.S. Attorney's Office, Yarbrough, of +Kentucky, met the girl on a Web-based social site and arranged to have a Greyhound bus ticket wired to her. The +girl traveled to Tennessee, and Yarbrough took her by car to Kentucky and repeatedly sexually abused her. U.S. +District Court Judge Kenneth A. Marra also ordered Yarbrough to register as a sex offender and to have no +unsupervised contact with children. Yarbrough previously had been charged in Kentucky with sexually abusing +three other minors. +From Palm Beach Daily News: +Plea deal violation could net federal charges for convicted sex offender Jeffrey +Epstein +¿Picture (Device Independent Bitmap)Click-2-Listen +By MICHELE DARGAN +Daily News Staff Writer +Saturday, September 20, 2008 +Convicted sex offender Jeffrey Epstein still faces the possibility of federal criminal charges if he violates any of +the terms of his state plea agreement, according to federal court documents. +Although it was widely reported that federal prosecutors had agreed to drop their investigation of Epstein under +his plea bargain, the documents show that the U.S. Attorney's Office agreed only to defer prosecution while +Epstein completes his sentence. +Under the terms of the federal deferred-prosecution agreement, Epstein will have to comply with court orders +and restrictions even up to 90 days after he completes the house arrest that will follow his 18-month jail term. +Epstein, 55, pleaded guilty June 30 to two felony counts: soliciting prostitution and procuring a person under 18 +for prostitution. He is serving 18 months in jail to be followed by 12 months house arrest. + + +In addition to the criminal charges, there are nine federal and six state lawsuits pending against Epstein, all +containing similar allegations: that Epstein, through his employees and assistants, brought minor girls to his +Palm Beach home at +for erotic massages and sometimes sex. +If Epstein violates any of the conditions of his state plea agreement during his sentence and up to 90 days after, +the U.S. Attorney's Office "reserves the right to indict (or unseal an existing indictment against) Mr. Epstein," +according to federal court documents filed by Epstein attorney Michael Tein. +Tein filed the documents in support of a motion asking U.S. District Judge Kenneth Marra to stay proceedings in +a federal lawsuit by one of Epstein's victims until after Epstein completes all conditions of his sentence plus the +three months. +If the lawsuit is not postponed, anything Epstein says in his defense could be used against him in a federal +prosecution, Tein argued. +Marra denied the motion. +"The court sees no reason to delay this litigation for the next 33 months," he wrote. "After all, defendant is in +control of his own destiny — it is up to him (and him alone) whether the plea agreement reached with the State +of Florida is breached. If defendant does not breach the agreement, then he should have no concerns regarding +his Fifth Amendment right against self-incrimination." +Under the conditions of his plea agreement, Epstein must register as a sex offender for life. While he is serving +the 12 months of house arrest at his Palm Beach home, Epstein must: +* Observe a 10 p.m. to 6 a.m. curfew. +* Have no unsupervised contact with anyone younger than 18. +* Neither view, own nor possess pornographic or sexual materials. +As a convicted sex offender, he will not be allowed to live within 1,000 feet of a school, playground or other +place where children gather. +The federal deferred-prosecution agreement, which is tied to his state plea agreement, is under seal, but Tein's +motion provided glimpses into the sealed agreement. +Paperwork filed by Tein discloses that "under the agreement, the USAO presently retains the continuing right to +indict Mr. Epstein — or to unseal 'any' already-existing federal 'charges' that may already have been handed up +by the federal grand jury and sealed — should he breach any of its provisions." +The Tein motion also indicates that the U.S. Attorney's agreement with Epstein requires that: +* The grand jury's subpoenas remain outstanding. +* The parties must maintain their evidence. +* Any existing charges will not be dismissed until after Epstein has "fulfilled all the terms and conditions of the +agreement." +The agreement also includes "a promise not to prosecute defendant +only if Epstein successfully +fulfills all the terms and conditions of the state agreement." +was investigated for bringing the girls up to the room in his Palm Beach home +where Epstein was waiting and for paying the girls afterward. She has not been charged. + + +Tein did not return calls on Friday. +special counsel to the U.S. Attorney, said via e-mail that the U.S. Attorney's Office had no comment +on the agreement. +Hollywood attorney Brad Edwards is representing some of the victims in state and federal court. Marra recently +granted Edwards' motion that he and two of his clients be allowed to see the sealed agreement. +Edwards — who is under orders by the judge not to discuss the contents of the agreement — +- says he intends to +file a motion to unseal the agreement to the public. +"The public does have a right to know the terms of the agreement," Edwards said. "These are very unusual +circumstances where a prosecutor and a criminal defendant enter into a confidential agreement for the purpose of +keeping it from the public." +Miami attorney Jeffrey Herman, who represents six of the "Jane Does" in federal lawsuits, agreed. +"We anticipate trying to get that document unsealed," he said. "I think it's appropriate and should be seen, +particularly by the victims, but I also think that the public should see it, too." +From Sun-Sentinel: +Kentucky man to serve 40 years for sexually +abusing West Palm Beach girl, 15 +Kentucky man to serve 40 years for abusing girl +By Missy Diaz | South Florida Sun-Sentinel +September 23, 2008 +A Kentucky man will spend 40 years in federal prison followed by a lifetime on supervised release for sexually abusing a 15- +year-old West Palm Beach girl he met over the Internet. +U.S. District Judge Kenneth Marra also ordered Marion Yarbrough to register as a sex offender and have no unsupervised +contact with children. +Yarbrough, 35, met the teen last year on the mobile social networking site itsmy.com. During a series of online chats, +Yarbrough told the girl he was 21. After chatting for several days, he wired the victim a Greyhound bus ticket to Tennessee, +where he picked her up and drove her back to Kentucky. For two weeks, Yarbrough repeatedly sexually abused the teen, +according to the U.S. Attorney's Office. +Yarbrough had previously been charged in Kentucky with sexually abusing three other minors. At the time of his arrest in this +case, he had charges pending for the rape of a 12-year-old Kentucky girl. He is to be returned to Kentucky to face those +Assistant U.S. Attorney +West Palm Beach, FL 33401 +Phone +Fax + + diff --git a/vision-fixhub/ds9-parsed-01/0c4c38543dfdb160ee1b1ddd3eed3f0881bfd0ff1aca6b415cd4c1fe6a722704.receipt.json b/vision-fixhub/ds9-parsed-01/0c4c38543dfdb160ee1b1ddd3eed3f0881bfd0ff1aca6b415cd4c1fe6a722704.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..b24f9ffb7c983443e39cd7bf426663f65483a11f --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0c4c38543dfdb160ee1b1ddd3eed3f0881bfd0ff1aca6b415cd4c1fe6a722704.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -48, + "dataset": "marble-joined", + "doc_id": "0c4c38543dfdb160ee1b1ddd3eed3f0881bfd0ff1aca6b415cd4c1fe6a722704", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "d39baa5230ed8f79767c0e6b40175ef2929e6ca4e37b72429896e98e2241158c", + "output_sha256": "bd1abfb50ea5b3adc4eeeb54cbe0d700cb91a43c855747599b36857b34d00ea3", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0c56b007331095899f02309f87299bdb3e03b525f518a3e9f6e87611e68d311e.md b/vision-fixhub/ds9-parsed-01/0c56b007331095899f02309f87299bdb3e03b525f518a3e9f6e87611e68d311e.md new file mode 100644 index 0000000000000000000000000000000000000000..8f1126ab1892892bfe69f866c3141b24bc0e5e9a --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0c56b007331095899f02309f87299bdb3e03b525f518a3e9f6e87611e68d311e.md @@ -0,0 +1,237 @@ +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +UNITED STATES OF AMERICA, +V. +GHISLAINE MAXWELL, +- x +: +20 Cr. 330 (AJN) +Defendant. +- x +MEMORANDUM IN SUPPORT OF GHISLAINE MAXWELL'S +THIRD MOTION FOR RELEASE ON BAIL +Bobbi C. Sternheim +Law Offices of Bobbi C. Sternheim +Christian R. Everdell +COHEN & GRESSER LLP +Jeffrey S. Pagliuca +Laura A. Menninger +HADDON, MORGAN & FOREMAN P.C. +Attorneys for Ghislaine Maxwell + + +INTRODUCTION +Ghislaine Maxwell respectfully submits this Memorandum in Support of her Third +Motion for Release on Bail. +As Ms. Maxwell has stated on numerous occasions and reaffirms here: she has no +intention or desire to leave this country. She is an American citizen, has lived in United States +for 30 years, has strong family ties and the support of friends and family residing in this country. +She wants nothing more than to remain in the United States under whatever conditions the Court +deems necessary so that she can effectively prepare for trial and vigorously defend against the +25-year-old charges in the Indictment. Ms. Maxwell has already proposed an expansive and, to +our knowledge, unprecedented set of bail conditions that would reasonably assure her +appearance. (See Dkt. 97.) In light of the Court's denial of that application (see Dkt. 106), Ms. +Maxwell now proposes two additional bail conditions to supplement the extraordinarily +restrictive bail package she has already offered. +• First, Ms. Maxwell will renounce her French and British citizenship to eliminate +any opportunity for her to seek refuge in those countries, if the Court so requires. +• Second, Ms. Maxwell will have her and her spouse's assets excluding funds +earmarked for living expenses, for legal fees and other expenses necessary to +defend her against the criminal charges in this case and related civil lawsuits and +for taxes—placed in a new account that will be monitored by a retired federal +District Court judge and former United States Attorney who will function as asset +monitor and will have co-signing authority over the account. +The former condition goes well beyond the extradition waivers that the Court deemed +insufficient and should satisfy any concerns the Court may have that Ms. Maxwell may try to +seek a safe haven in France or the United Kingdom. (See id. at 11-13). As a non-citizen, Ms. +Maxwell will not be able to avail herself of any protections against extradition that may apply to +2 + + +citizens of those countries. The latter condition will restrain Ms. Maxwell's assets so they +cannot be used for flight or harboring her outside of the jurisdiction of this Court. This should +satisfy the Court's concern that the proposed bond was not fully secured and left assets +unrestrained that could be used for such purposes. (See id. at 17-18). +In addition, since the last bail application, Ms. Maxwell has submitted twelve pretrial +motions that raise substantial legal and factual issues that may result in the dismissal of some or +all of the charges against her. Ms. Maxwell referenced some of these motions in her initial bail +application (see Dkt. 18 at 19) but was not in a position to fully articulate them until she had the +chance to review the discovery and research the legal issues in advance of the motion deadline of +January 25. These motions significantly call into question the strength of the government's case +against Ms. Maxwell and the underlying justification for continued detention. +Ms. Maxwell has already been denied a fair chance in the court of public opinion. She +has been maligned by the media, which has perpetuated a false narrative about her that has +poisoned any open-mindedness and impartiality of a potential jury. She has been relentlessly +attacked with vicious slurs, persistent lies, and blatant inaccuracies by spokespeople who have +neither met nor spoken to her. She has been depicted as a cartoon-character villain in an attempt +to turn her into a substitute replacement for Jeffrey Epstein. Yet, Ms. Maxwell is determined - +and welcomes the opportunity - to face her accusers at trial and clear her name. The additional +proposed bail conditions should quell any concerns that she would try to flee. The Court should +therefore grant bail under the proposed conditions so that Ms. Maxwell can adequately prepare +for trial. +3 + + +I. +The Proposed Additional Bail Conditions Will Reasonably Assure Ms. Maxwell's +Appearance in Court +As set forth above, Ms. Maxwell now proposes two additional restrictions that eliminate +any means or opportunity that she may have to leave the country. The Court should therefore +reconsider its earlier ruling and grant bail under the proposed conditions. See United States v. +Rowe, No. 02 CR. 756 LMM, 2003 WL 21196846, at *1 (S.D.N.Y. May 21, 2003) ("[A] release +order may be reconsidered even where the evidence proffered on reconsideration was known to +the movant at the time of the original hearing."); see also United States v. Petrov, No. 15-CR-66- +LTS, 2015 WL 11022886, at *3 (S.D.N.Y. Mar. 26, 2015) (noting "Court's inherent authority for +reconsideration of the Court's previous bail decision"). +A. Renunciation of Foreign Citizenship +To demonstrate her commitment to abide by her conditions of release and to provide +further assurance to the Court that she will not attempt to leave the country, Ms. Maxwell is +willing to formally renounce her foreign citizenships in France and the United Kingdom. Should +the Court feel this drastic condition is necessary, the required documents will be submitted to the +appropriate authorities. +Moreover, as a standard condition of bail, all of Ms. Maxwell's +passports will be surrendered to the government and no further application will be made. +If the Court deems it a necessary condition of release, Ms. Maxwell will formally +commence the procedure to renounce her foreign citizenship. The requisite paperwork is in the +process of being completed. Renunciation of UK citizenship can be accomplished immediately +upon granting of bail. The process of renouncing her French citizenship, while not immediate, +may be expedited. +Citizenship is a precious and priceless asset. Ms. Maxwell's decision to give up +citizenship from the county of her birth and the country of her upbringing demonstrates her +4 + + +earnestness to abide by the conditions of her release and underscores that she has no intention to +flee and reflects her deep need to communicate freely with counsel to prepare for her defense. +Her renunciation of foreign citizenship obviates the Court's concerns about the validity of +waivers of extradition. (See Dkt. 106 at 13). Ms. Maxwell will have no ability to contest +extradition from France or the United Kingdom on the basis of citizenship, which removes any +incentive the Court and government believe she may have to seek refuge in those countries. +B. +Restraint and Monitoring of Assets +In denying bail, the Court noted that the bond was not fully secured, and that Ms. +Maxwell and her spouse would still have several million dollars in unrestrained assets that could +be used to facilitate her flight from the country. (See id. at 17-18). To assuage any concerns that +those assets would be available to finance flight to and shelter in a foreign country, Ms. Maxwell +has taken steps to create a monitorship that will place meaningful restraints on the assets that are +not used to secure the bond, while still allowing Ms. Maxwell to pay for her legal defense, for +her spouse to pay for daily living expenditures and for payment of taxes. +1. +New Account +All assets of Ms. Maxwell and her spouse, with the exception of money currently held in +escrow for legal fees and related defense expenses and the funds contained in the bank account in +the name of Ms. Maxwell's spouse ("the Personal Account"), will be deposited in a newly +created account ("the New Account") to be overseen by an asset monitor appointed pursuant to +order of the Court. The New Account will contain all of Ms. Maxwell's and her spouse's +remaining cash and other liquid assets, including any proceeds that result from the pending sale +1 The Personal Account is identified as Account I on page 9 of the Financial Report annexed to Ms. Maxwell's +Renewed Bail Application. (See Dkt. 97, Exhibit O.) +5 + + +of Ms. Maxwell's London house and any other assets, excluding salary, hereinafter acquired. +The asset manager will approve the financial institution at which the New Account is created and +must approve and co-sign any expenditure from the New Account, with the exception of +disbursements for Ms. Maxwell's legal fees in connection with the ongoing criminal and civil +litigation and for payment of taxes, which will not require authorization. No illiquid assets may +be sold, conveyed or transferred without approval of the asset monitor. +Other Assets +The only funds that will not be included in the New Account are (1) the money currently +held in escrow by Ms. Maxwell's attorneys, which will be used exclusively for her defense; and +(2) the roughly $450,000 in the Personal Account which her spouse will use only for living +expenses. The asset monitor shall regularly receive information regarding activity of the Personal +Account, including the account balance, on a weekly basis. The asset monitor must also receive +five-day advance notice of any check, on-line payment, or transfer of funds in any amount +exceeding $5,000, and the reason for such payment. Ms. Maxwell's spouse agrees to be bound +by these restrictions and reporting requirements. +The asset monitor shall report to Pretrial Services any possible non-compliance or +disbursement in violation of the terms and conditions specified above. +3. +Selected Asset Monitor +The Honorable William S. Duffey, Jr., a retired federal District Court judge and the +former United States Attorney for the Northern District of Georgia, has agreed to undertake the +position of asset monitor. (Judge Duffey's bio is attached as Exhibit A.) Judge Duffey has +extensive experience evaluating and monitoring funds held in and disbursed from financial +6 + + +accounts and will be entrusted with the authority to oversee the assets of Ms. Maxwell and her +spouse, as described above. +Restraining Ms. Maxwell's assets that are not used to secure the bond and placing them under +the supervision of a former federal District Court judge eliminates any concern that such funds +could be used to violate the terms of release. +Il. +Ms. Maxwell's Pretrial Motions Raise Substantial Legal and Factual Issues +That Could Result in Dismissal of Some or All of the Charges Against Her +In addition to the new conditions proposed above, the numerous substantive pretrial +motions now before the Court amply challenge the purported strength of the government's case. +Ms. Maxwell's pretrial motions raise serious legal issues that could result in dismissal of +charges, if not the entire indictment. Among the dozen submissions are motions to dismiss the +superseding indictment for breach of the non-prosecution agreement, for pre-indictment delay, +and for being based on improperly obtained evidence in violation of Ms. Maxwell's +constitutional rights under the Fifth and Sixth the Amendments. Other motions seek dismissal of +the Mann Act charges as being time-barred and the perjury charges as based on non-perjurious +statements. These motions are substantial with a likelihood of success on the merits. These +motions cast substantial doubt on the alleged strength of the government's case and warrant +granting bail on the conditions proposed. +Ill. +The Court Should Grant Bail +Under the Bail Reform Act of 1984, a defendant must be released on personal +recognizance or unsecured personal bond unless the judicial officer determines "that such release +will not reasonably assure the appearance of the person as required or will endanger the safety of +any other person or the community." 18 U.S.C. § 3142(b). The enhanced bail package proposed +by Ms. Maxwell contains financial burdens and a combination of restrictions that reasonably +7 + + +assure her appearance as required. Before preventive detention may be ordered under § 3142(e), +the Court is obliged to determine both whether the defendant is likely to flee the jurisdiction if +released, and whether any conditions of release will be reasonably certain to guard against this +propensity to flee. The Court expressed concerns and denied bail without indicating what +conditions would be reasonably certain to assure Ms. Maxwell's appearance. Ms. Maxwell is no +danger to the community and not alleged to have been involved in ongoing criminal activity. To +say that there are absolutely no conditions flies in the face of cases where non-United States +citizens with no ties to the district, let alone the country, were released on lesser conditions for +alleged criminality ongoing up to or within hours of the time of arrest, in contrast to 26-year-old +claims alleged against Ms. Maxwell.2 +The additional conditions set forth above, which supplement the exceptional bail package +previously proposed, are sufficient to address the hypothetical risk of flight and secure Ms. +Maxwell's presence at trial. The financial magnitude of the proposed bonds, the collateral +pledged to secure the bonds, the stringent requirements of home detention, the renunciation of +foreign citizenship and monitoring of assets contained in a special account from which no funds +can be withdrawn without the approval and signature of a retired federal District Court judge and +former United States Attorney are conditions that amply satisfy the concerns expressed by the +government and the Court. These enditions are unique and unprecedented. They profoundly +' See Dkt. 97 at 34 (case-comparison chart in the Renewed Motion for Bail); cf. People v. Dominique Strauss-Kahn, +02526/2011(S.Ct. N.Y. County). Strauss-Kahn, a French citizen with no ties to the United States, was arrested on a +Paris-bound flight at JFK minutes before takeoff and later charged with several counts of sexual assault, including +felony charges punishable up to 25 years imprisonment, for sexual assault and attempted rape of a Manhattan hotel +housekeeper on the day of his arrest. The accusations were corroborated by semen containing Strauss-Kahn's DNA +on the accuser's uniform. The New York State Supreme Court granted bail in the amount of S1 million cash, 24- +hour home detention electronic monitoring ankle bracelet, and private 24/7 security guards. After surrendering his +French passport and posting an additional $5 million bail bond, Strauss-Kahn was placed under house arrest in a +residence in Manhattan. See https://www.theguardian.com/world/2011/ may/20/dominique-strauss-kahn-new-yorkapartment. +8 + + +affirm Ms. Maxwell's earnestness in seeking bail to properly prepare her defense, not to flee. +The Court should grant bail to Ghislaine Maxwell. +CONCLUSION +The proposed additional conditions of release +—renunciation of foreign citizenship and +restraint and monitoring of assets by a retired District Court judge enhance the already +extraordinarily restrictive bail conditions proposed in Ms. Maxwell's Renewed Motion for Bail. +In combination, these conditions satisfy the Bail Reform Act and reasonably assure Ms. +Maxwell's appearance at trial. To deny Ms. Maxwell bail when such extraordinary and +restrictive conditions are available would be a miscarriage of justice. +Dated: February 23, 2021 +Respectfully submitted, +Babbi C. Sternheim +Bobbi C. Sternheim +Law Offices of Bobbi C. Sternheim +Christian R. Everdell +COHEN & GRESSER LLP +Jeffrey S. Pagliuca +Laura A. Menninger +HADDON, MORGAN & FOREMAN P.C. +9 diff --git a/vision-fixhub/ds9-parsed-01/0c56b007331095899f02309f87299bdb3e03b525f518a3e9f6e87611e68d311e.receipt.json b/vision-fixhub/ds9-parsed-01/0c56b007331095899f02309f87299bdb3e03b525f518a3e9f6e87611e68d311e.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..add707d1d0b283e2c8f0981c66d66005115c2e22 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0c56b007331095899f02309f87299bdb3e03b525f518a3e9f6e87611e68d311e.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -110, + "dataset": "marble-joined", + "doc_id": "0c56b007331095899f02309f87299bdb3e03b525f518a3e9f6e87611e68d311e", + "engine": "marble-apple-vision", + "event_count": 10, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "c96accc2abcdb06d07d4169b85d312ca57c7e3b9e54b89d4180c1f6f3918c53e", + "output_sha256": "7888d57a7b1cb63daaae7e8859f3aeefe6ebccf90329cef03c14654902dd8f5c", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0c5baa40a124a472f685984f911437f097dd37b0a49a8521cae57d16e3f81c2c.md b/vision-fixhub/ds9-parsed-01/0c5baa40a124a472f685984f911437f097dd37b0a49a8521cae57d16e3f81c2c.md new file mode 100644 index 0000000000000000000000000000000000000000..b97b31c607b2c17df8cef16eeb01a0f658141449 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0c5baa40a124a472f685984f911437f097dd37b0a49a8521cae57d16e3f81c2c.md @@ -0,0 +1,64 @@ +From: +(USANYS)" < +To: +(USANYS)" +Subject: RE: Draft Indictment +Date: Fri, 14 Jun 2019 13:52:36 +0000 +Importance: Normal +I went to speak ti +Labout that and the option of charging it that way and superseding later - it is much preferable to +it this way if we can because we do not want to charge a single victim count - both not to put it all on +a and to not +suggest our case is that narrow. +gut is that we can, but in my comments I asked the team to do some research on the unit of prosecution. +From: +(USANYS) < +Sent: Friday, June 14, 2019 9:51 AM +To: +(USANYS) < +Subject: RE: Draft Indictment +Also, on Count 1, are we sure we can charge a single count covering all conduct? I presume we plan to supersede, so this +may be moot, but it'd be embarrassing to stumble out of the gate if we have to charge each person trafficked as a +separate substantive... +From: +To: +(USANYS) < +Sent: Thursday, June 13, 2019 10:57 PM +| (USANYS) < +Subject: Re: Draft Indictment +Good - you may have to be the one to help get it there. Will loop you in if chain continues. +Sent from my iPhone +On Jun 13, 2019, at 10:35 PM, +| (USANYS) { +> wrote: +I agree with this. +Sent from my iPhone +On Jun 13, 2019, at 10:19 PM, +I (USANYS) 4 +> wrote: +Sent from my iPhone +Begin forwarded message: +From: " +I (USANYS)" 4 +Date: June 13, 2019 at 10:19:35 PM EDT +To: "l +Cc: "' +Subject: Re: Draft Indictment + + +1. Let's chat tomorrow - I do think this is too sparse. I understand the concerns and they are right +ones, but more needs to be done to (i) instill public confidence in the significance and seriousness of this case in light +of the prior history: and (ii) relatedly, to give Geoff more to work with at a press conference to further that end. It is +a balance, and there are definitely steps we should take to protect the victims (esp those who remain truly +anonymous), but I think we'll need to bulk up a bit. +Sent from my iPhone +On Jun 13, 2019, at 9:47 PM, | +• wrote: +Attached is a draft indictment for your review. We tried to keep the facts sparse, both to protect the victims and to +avoid publicizing details that will help us vet new witnesses later on if the details remain confidential. +Thanks - +Assistant United States Attorney +Southern District of New York +One Saint Andrew's Plaza +New York, NY 10007 +<2019-06-13, Epstein Indictment.docx> diff --git a/vision-fixhub/ds9-parsed-01/0c5baa40a124a472f685984f911437f097dd37b0a49a8521cae57d16e3f81c2c.receipt.json b/vision-fixhub/ds9-parsed-01/0c5baa40a124a472f685984f911437f097dd37b0a49a8521cae57d16e3f81c2c.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..1a3408665d30da354bcd6c84a05d73aa553edc69 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0c5baa40a124a472f685984f911437f097dd37b0a49a8521cae57d16e3f81c2c.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "0c5baa40a124a472f685984f911437f097dd37b0a49a8521cae57d16e3f81c2c", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "8bb39ef2bd84df0439a0ee4f78aa28709f243c52114be95ef7661262cf368f3f", + "output_sha256": "a3f8eb36352d8b4b525e9f10c3a441de8b7b78d850f34826ff645a8529942d58", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0cd2507a719b7391e129b11338bd08e4afdae90fc9abc71af25a149c26a0e7a8.md b/vision-fixhub/ds9-parsed-01/0cd2507a719b7391e129b11338bd08e4afdae90fc9abc71af25a149c26a0e7a8.md new file mode 100644 index 0000000000000000000000000000000000000000..402fbd5b3dffe8d7876b758abf507cef95a26e8c --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0cd2507a719b7391e129b11338bd08e4afdae90fc9abc71af25a149c26a0e7a8.md @@ -0,0 +1,108 @@ +UNITED STATES ATTORNEY'S OFFICE +Southern District of New York +ACTING U.S. ATTORNEY AUDREY STRAUSS +FOR IMMEDIATE RELEASE +Thursday, July 2, 2020 +http://www.justice.gov/usao/nys +NYPD +CONTACT: U.S. ATTORNEY'S OFFICE +FBL +GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT +FOR CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE +MINORS +Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse +Additionally Charged With Perjury in Connection With 2016 Depositions +Audrey Strauss, the Acting United States Attorney for the Southern District of New +York, William F. Sweeney Jr., the Assistant Director-in-Charge of the New York Field Office of +the Federal Bureau of Investigation ("FBI"), and Dermot Shea, Commissioner of the New York +City Police Department ("NYPD"), announced that GHISLANE MAXWELL was arrested this +morning and charged with enticing a minor to travel to engage in criminal sexual activity. +transporting a minor with the intent to engage in criminal sexual activity, conspiracy to commit +conspirator Jeffrey Epstein exploited girls as young as 14, including by enticing them to travel +and transporting them for the purpose of engaging in illegal sex acts. As alleged, knowing that +Epstein had a preference for young girls, MAXWELL played a critical role in the grooming and +abuse of minor victims that took place in locations including New York, Florida, and New +Mexico. In addition, as alleged, MAXWELL made several false statements in sworn depositions +in 2016. MAXWELL is expected to be presented this afternoon in the in federal court in New +Hampshire. This case is assigned to U.S. District Judge Alison J. Nathan. +Acting U.S. Attorney Audrey Strauss said: "As alleged, Ghislaine Maxwell facilitated, +aided, and participated in acts of sexual abuse of minors. Maxwell enticed minor girls, got them +to trust her, and then delivered them into the trap that she and Jeffrey Epstein had set. She +pretended to be a woman they could trust. All the while, she was setting them up to be abused + + +sexually by Epstein and, in some cases, Maxwell herself. Today, after many years, Ghislaine +Maxwell finally stands charged for her role in these crimes." +FBI Assistant Director William F. Sweeney Jr. said: "Preserving the innocence of +children is among the most important responsibilities we carry as adults. Like Epstein, Ms. +Maxwell chose to blatantly disregard the law and her responsibility as an adult, using whatever +means she had at her disposal to lure vulnerable youth into behavior they should never have been +exposed to, creating the potential for lasting harm. We know the quest for justice has been met +with great disappointment for the victims, and that reliving these events is traumatic. The +example set by the women involved has been a powerful one. They persevered against the rich +and connected, and they did so without a badge, a gun, or a subpoena - and they stood together. I +have no doubt the bravery exhibited by the women involved here has empowered others to speak +up about the crimes of which they've been subjected." +NYPD Commissioner Dermot Shea said: "The heinous crimes these charges allege are, +and always will be abhorrent for the lasting trauma they inflict on victims. I commend our +investigators, and law enforcement partners, for their continuing commitment to bringing justice +to the survivors of sexual assault, everywhere." +If you believe you are a victim of the sexual abuse perpetrated by Jeffrey Epstein, +please contact the FBI at 1-800-CALL FBI, and reference this case. +According to the Indictment' unsealed today in Manhattan federal court: +From at least 1994 through at least 1997, GHISLAINE MAXWELL assisted, facilitated, +and participated in Jeffrey Epstein's abuse of minor girls by, among other things, helping Jeffrey +Epstein to recruit, groom, and ultimately abuse victims known to MAXWELL and Epstein to be +under the age of 18. The victims were as young as 14 years old when they were groomed and +abused by MAXWELL and Epstein, both of whom knew that their victims were in fact minors. +As a part and in furtherance of their scheme to abuse minor victims, MAXWELL and Epstein +enticed and caused minor victims to travel to Epstein's residences in different states, which +MAXWELL knew and intended would result in their grooming for and subjection to sexual +abuse. +As alleged, MAXWELL enticed and groomed minor girls to be abused in multiple ways. +For example, MAXWELL attempted to befriend certain victims by asking them about their lives, +taking them to the movies or taking them on shopping trips, and encouraging their interactions +with Epstein. MAXWELL also acclimated victims to Epstein's conduct simply by being present +for victim interactions with Epstein, which put victims at ease by providing the assurance and +comfort of an adult woman who seemingly approved of Epstein's behavior. Additionally, to +make victims feel indebted to Epstein, MAXWELL would encourage victims to accept offers of +financial assistance from Epstein, including offers to pay for travel or educational expenses. +' As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment +set forth herein, constitute only allegations, and every fact described therein should be treated as an allegation. The +defendant is presumed innocent unless and until proven guilty. +2 + + +MAXWELL also normalized and facilitated sexual abuse by discussing sexual topics with +victims, encouraging them to massage Epstein, and undressing in front of a victim. +As MAXWELL and Epstein intended, these grooming behaviors left minor victims +vulnerable and susceptible to sexual abuse by Epstein. MAXWELL was then present for certain +sexual encounters between minor victims and Epstein, such as interactions where a minor victim +was undressed, and ultimately MAXWELL was present for sex acts perpetrated by Epstein on +minor victims. +MAXWELL and Epstein's victims were groomed or abused at +Epstein's residences in New York, Florida, and New Mexico, as well as MAXWELL's residence +in London, England. +Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL +repeatedly made false statements, including about certain specific acts and events alleged in the +Indictment. +GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to +engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count +of conspiracy to entice a minor to travel to engage in illegal sex acts, which carries a maximum +sentence of five years in prison, one count of transporting a minor with the intent to engage in +criminal sexual activity, which carries a maximum sentence of 10 years in prison, one count of +conspiracy to transport a minor with the intent to engage in criminal sexual activity, which +carries a maximum sentence of five years in prison, and two counts of perjury, each of which +carries a maximum sentence of five years in prison. +The statutory maximum penalties are prescribed by Congress and are provided here for +informational purposes only, as any sentencing of the defendant would be determined by the +judge. +Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD. +This case is being handled by the Office's Public Corruption Unit. Assistant U.S. +Attorneys +are in charge of the prosecution. +The charges contained in the Indictment are merely accusations. The defendant is +presumed innocent unless and until proven guilty. +20-138 + +3 diff --git a/vision-fixhub/ds9-parsed-01/0cd2507a719b7391e129b11338bd08e4afdae90fc9abc71af25a149c26a0e7a8.receipt.json b/vision-fixhub/ds9-parsed-01/0cd2507a719b7391e129b11338bd08e4afdae90fc9abc71af25a149c26a0e7a8.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..215f07a2848343023b17624749b513d415713bc7 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0cd2507a719b7391e129b11338bd08e4afdae90fc9abc71af25a149c26a0e7a8.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -39, + "dataset": "marble-joined", + "doc_id": "0cd2507a719b7391e129b11338bd08e4afdae90fc9abc71af25a149c26a0e7a8", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.bare-h3\"]", + "idempotent": true, + "input_sha256": "81a1287b989f92e6643b3fc935b1e1ca4df2b3a99b19613b0a7c82b282678020", + "output_sha256": "4e7b1d5241b19e2af1f56b4b780b70fb938d32ad876972d9fc3939cab5c26787", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0cf5c27a524c4721bf3cfb88f8bc8816e14f95732cf147231c670f6657fdcdd2.md b/vision-fixhub/ds9-parsed-01/0cf5c27a524c4721bf3cfb88f8bc8816e14f95732cf147231c670f6657fdcdd2.md new file mode 100644 index 0000000000000000000000000000000000000000..b4764fb5fde9efd7b8209febf5b46ffd94169f09 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0cf5c27a524c4721bf3cfb88f8bc8816e14f95732cf147231c670f6657fdcdd2.md @@ -0,0 +1 @@ +No Images Produced diff --git a/vision-fixhub/ds9-parsed-01/0cf5c27a524c4721bf3cfb88f8bc8816e14f95732cf147231c670f6657fdcdd2.receipt.json b/vision-fixhub/ds9-parsed-01/0cf5c27a524c4721bf3cfb88f8bc8816e14f95732cf147231c670f6657fdcdd2.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..c6273dc6961a226e94bed72798e258974d164eaa --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0cf5c27a524c4721bf3cfb88f8bc8816e14f95732cf147231c670f6657fdcdd2.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "0cf5c27a524c4721bf3cfb88f8bc8816e14f95732cf147231c670f6657fdcdd2", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "f178af055e71420d37c174723973fc9d05e1b86b1a98bd61ef00cacd68eed5e3", + "output_sha256": "3874328764c818fba06683a6d5ddc2edc2d7850aaf4ba18646f81d3f8420a729", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0d190c6c3433c58b358d23a0afc64cf643710b10f2fde12a09ed310fc1042b00.md b/vision-fixhub/ds9-parsed-01/0d190c6c3433c58b358d23a0afc64cf643710b10f2fde12a09ed310fc1042b00.md new file mode 100644 index 0000000000000000000000000000000000000000..51a3f2d3d92533230356e9279c85d29eaa367725 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0d190c6c3433c58b358d23a0afc64cf643710b10f2fde12a09ed310fc1042b00.md @@ -0,0 +1,25 @@ +From: +Subject: +report images for GX +Date: Fri, 10 Sep 2021 04:22:56 +0000 +Attachments: Photos_for_GX_from +_export.xlsx +I pulled the photos from the +FBI exports and compiled the attached spreadsheet to keep track of the information +for these files and to use to ask the FBI to confirm where each of these was originally pulled from. Do you want to ask the +FBI to identify the source for all of these images now or after you pare down the set you originally flagged? +One thing I wanted to flag/ask, when you were reviewing these earlier, did you have any issues viewing any of the files? +The file types psd, "file," or girl do not appear viewable to me either from the export (in the browser window) or when I +downloaded the native file. I can check with our IT folks to see if they can help us figure out how to view these but also +wanted to ask if you had this issue in your review. +The pulled photos are here, and I added the index number to the start of the file name for ease of viewing at this point: +1Usa.doj.gov\cloud\NYS|StAndrews|Shared\USvEpstein-2018R01618\Trial\ Paralegal\AUSA GX Photo Review +Exports\|Pulled photos for GX +And a copy of the exports and original files you reviewed can be found on the shared here: +MUsa.doj gov\cloud NYS\StAndrews\Shared\USvEpstein-2018R01618\ Trial Paralegal\ AUSA GX Photo Review - +Exports +Let me know if you have any questions or want to chat about any of this. +Paralegal Specialist +U.S. Attorney's Office | SDNY +1 Saint Andrew's Plaza +New York, NY 10007 diff --git a/vision-fixhub/ds9-parsed-01/0d190c6c3433c58b358d23a0afc64cf643710b10f2fde12a09ed310fc1042b00.receipt.json b/vision-fixhub/ds9-parsed-01/0d190c6c3433c58b358d23a0afc64cf643710b10f2fde12a09ed310fc1042b00.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..cbf6f04857e1b8c3ae4b06d12df552fde11f6e49 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0d190c6c3433c58b358d23a0afc64cf643710b10f2fde12a09ed310fc1042b00.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "0d190c6c3433c58b358d23a0afc64cf643710b10f2fde12a09ed310fc1042b00", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "9d09eec95391bc51b9f355af090cdf4c3e84c34a71a4564031b8ec1337f922e1", + "output_sha256": "43178329788e9c04961b27854b415ef015fa83f2507ad4c32b9f55216d5f7436", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0d689045de08b89c488d1fc8a1f8370cd2cfa7bd0ed55f6ae0e52d78394dc190.md b/vision-fixhub/ds9-parsed-01/0d689045de08b89c488d1fc8a1f8370cd2cfa7bd0ed55f6ae0e52d78394dc190.md new file mode 100644 index 0000000000000000000000000000000000000000..32aee794f04e6cfeeb2c6e97f39ef2736fb53b70 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0d689045de08b89c488d1fc8a1f8370cd2cfa7bd0ed55f6ae0e52d78394dc190.md @@ -0,0 +1,308 @@ +6/17/21 +NYMFC +530.03 +PAGE' 001 +* +BUREAU OF PRISONS COUNT SHEET +NEW YORK MCC +OTRG EQ **** +OCTG EQ **** +M +08-10-2019 +00:35:17 +COUNT +AREA +B-A +C-A +E-N +E-S +G-N +G-S +H-A +I-N +K-N +K-S +R-A +Z-A +Z-B +TOTAL +COUNT +VERIFY +N +VERIFY +COUNT +COUNT +COUNT AREA +CENSUS +26 +10 +83 +79 +78 +88 +4 +86 +89 +137 +2 +1 +2 +1 +72 +5 +758 +26 +B-A +10 C-A +81 E-N +78 E-S +78 +88 +4 +86 +89 +136 +1 +72 +5 +754 +G-N +G-S +H-A +I-N +K-N +K-S +R-A +Z-A +Z-B +OFFICIAL PREPARING +COUN +OFFICIAL TAKING COUN +COUNT CABARED THE 2M +Good Verbol 31235 + + +METROPOLITAN CORRECTIONAL CENTER +NEW YORK, NY +OFFICIAL OUT COUNT +DATE: +FROM: +APPROVED: +REG # +08-10-19 +(Staff Member Preparing Out Count) +COUNT TIME: +12°AM +LOCATION: +Hosp +(operations Lien nant) +NAME +UNIT +REG # +NAME +UNIT +1. +2. +3. +4. +5. +6. +7. +8. +9. +10. +11. +12. +13. +OUT-COUNT BY UNIT +B-A +I-N +C-A +K-N +- Z-A +G-S +Z-B +H-A +Total Out-Counted: +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected count. +repare this form in ink. Group the inmates according to their respective housing units. This form is to be used only as ni +but-Count. No other form will be accepted in lieu of the Out-Count Form + + +NYMPC 530*05 * + +OPER CATG +CATEGORY: OCT +ASSIGNMENT: HOSP +ASSIGNMENT +OPER +NUM ASSIGNMENT REG NO +0001 HOSP +NAME +0002 +0003 +0004 +INMATE ROSTER +CATG ASSIGNMENT +* +08-09-2019 +22:52:23 +GROUP CODE: +FACILITY: NYM +OPER CATG ASSIGNMENT +OCT DATE +OTR +08-09-2019 E05-535L +08-09-2019 E07-555L +08-09-2019 E03-519L +08-09-2019 K12-064L +WRK +SUICIDE OR +UNASSG +ORD CCS +SUICIDE OR +SUICIDE OR +UNASSG +SUICIDE OR +UNASSG +G000O +TRANSACTION SUCCESSFULLY COMPLETED + + +Metropolitan Correctional Center +Deficial Charl 5 +- 8/18119 +Crane +Friet Ma +Signatur +Priot Hu +Seatur +Metropolians Correctional Center +Official Count SEp +- 8410/19 +- Time 1204fm +Coat: — +Priet Name_ +Sigrature: +Signatum +Unle +task +Count: +Meiropollins Correcting Center +(Mela| Coçat Slip +DAE 9710/19 +Time It de +Priat Namer +Signature: +Prim Name: +Signature: +Metropolitan Cornertional Center +official Coupt SEp +Un 56 +Print Name +Sigothere +Print Num +Senatur +_ Time, +201A +Metropolites Correcional Cater +Official Coust Sup +80/10/+9 +Time: +Print Name: +Signature: +Prist Namer +Signature: +Metropolitan Correctional Center +Offcial Coant 1 +Theme: + +12s(m +Unit: +Priet Nam +Spature +Priet Nam +відзат +Metropoliten Correcional Cente +Ofeat Cous Slip +-Date - 2 +hea 4 +Priat Him +Signature +Print Name +Metropellan Cornetiteal Cam +1 8/10/19 +Unic: +Count: _ +Priat Name: +Signalure: +Priat Name: +Signature: +Metropolitan Correctional Contes +Olical Coyot Slip +81109 +1V0/AM +Unit: +Count +Print Name: +Prial Name +Signatum _ + + +Metrepolina Corrersuaal Conter +Official Cousi Slip +Dalai +31191,7 +Time - +120/09 +Limi +Count +Priat Name: +Signelure: +Prial Namei +Sigaaturr: +Metroprlltan Correctionnl Center +New York, New Yark +OMcial Couit-Sle +RA +IaiE 8/10/A +Time: 1201AM +Unit: +Count: +1. Priot Nanse: +1. +Signature: +2. Priut Name: +2. +Signatare: +Meimspolitan Corrertiagal Centei +OMcial Coust Slip +Daihy +80)4 +Unil +Cosnl +Friat Name +Signature: +P'rint Name +5 gaalure +Metropolitan Correctional Center +New York, New York +Officlal Count-Slip +late 8-20-14 +Time X2 o/fr +Unit: +Const +I. Print Name +1. Signature: +1. P'rint Name +2. Signature: +Unle: +Coesl: +Prist Name: +Sigsatur +Pris Name: _ +Heautore +Metropolitan Correctiosal Cenie +OMcial Cowns 5lp- +De: s/1a/19 +Time: (ZiDy Atm diff --git a/vision-fixhub/ds9-parsed-01/0d689045de08b89c488d1fc8a1f8370cd2cfa7bd0ed55f6ae0e52d78394dc190.receipt.json b/vision-fixhub/ds9-parsed-01/0d689045de08b89c488d1fc8a1f8370cd2cfa7bd0ed55f6ae0e52d78394dc190.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..1420206de6d4f692564c720fa53d24a5378a77c5 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0d689045de08b89c488d1fc8a1f8370cd2cfa7bd0ed55f6ae0e52d78394dc190.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -82, + "dataset": "marble-joined", + "doc_id": "0d689045de08b89c488d1fc8a1f8370cd2cfa7bd0ed55f6ae0e52d78394dc190", + "engine": "marble-apple-vision", + "event_count": 7, + "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "2be849aee70a3def8da854668ede90f95131c9a8a77f345a1232e351b95f533c", + "output_sha256": "581f973a8288b898589954ddef1ca0b6cd8e020be4fe420b06b2a0fe766d5348", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0d74bfe2eeaa80312b5c521e1a8ccbc03a11397b329d9f5ea49806ec0b74b46f.md b/vision-fixhub/ds9-parsed-01/0d74bfe2eeaa80312b5c521e1a8ccbc03a11397b329d9f5ea49806ec0b74b46f.md new file mode 100644 index 0000000000000000000000000000000000000000..7ba8e5c4f5744ec483b10f245950585cc49c88d8 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0d74bfe2eeaa80312b5c521e1a8ccbc03a11397b329d9f5ea49806ec0b74b46f.md @@ -0,0 +1,703 @@ +MAXWELL +MAXWELL +MAXWELL +MAXWELL +MAXWELL +MAXWELL +MAXWELL +MAXWELL +MAXWELL +MAXWELL +MAXWELL +MAXWELL +MAXWELL +MAXWELL +MAXWELL +MAXWELL +MAXWELL +GHISLAINE +GHISLAINE +GHISLAINE +GHISLAINE +GHISLAINE +GHISLAINE +GHISLAINE +GHISLAINE +GHISLAINE +GHISLAINE +GHISLAINE +GHISLAINE +GHISLAINE +GHISLAINE +GHISLAINE +GHISLAINE +GHISLAINE +DOB +12/25/1961 +12/25/1961 +12/25/1961 +12/25/1961 +12/25/1961 +12/25/1961 P +12/25/1961 +12/25/1961 +12/25/1961 +12/25/1961 +12/25/1961 A +12/25/1961 +12/25/1961 +A +12/25/1961 +12/25/1961 P +12/25/1961 A +12/25/1961 +U.S. Customs and Border Protection +U.S. Department of Homeland Security +TECS - Person Encounter List +Generated By: +Doc +Type +Numbot t +Coder Car +Code +PV +P +Date - Time +(Eastern) +12/18/1999 +16:26 +10/02/1999 +18:00 +09/10/1999 +15:15 +0B/14/1999 +19:26 +BA +AF +08/01/1999 +12:42 +AA +07/15/1999 +BA +18:10 +4/28/199 +BA +R. 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Ms. Maxwell, through her attorneys of record, have not completed the +investigation of the facts relating to this case, have not completed discovery in this action, and +have not completed preparation for trial. Ms. Maxwell's responses to Plaintiff's requests are +based on information currently known to her and are given without waiving Ms. Maxwell's right +to use evidence of any subsequently discovered or identified facts, documents or +communications. Ms. Maxwell reserves the right to supplement this Response in accordance +with Fed. R. Civ. P. 26(e). +Ms. Maxwell objects to the Requests to the extent they attempt to impose any +requirement or discovery obligation greater than or different from those under the Federal Rules +of Civil Procedure, the local rules of this Court or any Orders of the Court. +3. +Ms. Maxwell objects to the Requests to the extent they seek documents or +information protected by the attorney/client privilege, the work-product doctrine, Rule 408 of the +Federal Rules of Evidence, any common interest privilege, joint defense agreement or any other +applicable privilege. +4. +Ms. Maxwell objects to the Requests to the extent they seek documents or +information outside of Ms. Maxwell's possession, custody or control. + + +Ms. Maxwell objects to the Requests to the extent they seek information which is +not relevant to the subject matter of the litigation and/or is not reasonably calculated to lead to +the discovery of admissible evidence. +Ms. Maxwell objects to the Requests to the extent they are overly broad, unduly +burdensome and/or propounded for the improper purpose of annoying, embarrassing, or +harassing Ms. Maxwell. +7. +or imprecise. +Ms. Maxwell objects to the Requests to the extent they are vague and ambiguous, +8. +Ms. Maxwell objects to the Requests to the extent they seek information that is +confidential and implicates Ms. Maxwell's privacy interests. +9. +Ms. Maxwell incorporates by reference every general objection set forth above +into each specific response set forth below. A specific response may repeat a general objection +for emphasis or for some other reason. The failure to include any general objection in any +specific response does not waive any general objection to that request. +10. +The Requests seek information that is confidential and implicates Ms. Maxwell's +privacy interests. To the extent such information is relevant and discoverable in this action, Ms. +Maxwell will produce such materials subject to an appropriate protective order pursuant to Fed. +R. Civ. P. 26(c) limiting their dissemination to the attorneys and their employees. +OBJECTIONS TO DEFINITIONS +11. Ms. Maxwell objects to Definition No. 1 regarding "Agent to the extent that it +purports to extend the meaning beyond those permissible by law. +12. Ms. Maxwell objects to Definition No. 3 regarding "Defendant." The Definition +is overly broad and unduly burdensome to the extent it attempts to extend the scope of the +Requests to documents in the possession, custody or control of individuals other than Ms. +Maxwell or her counsel. +13. Ms. Maxwell objects to Definition No. 5 regarding "Employee." Ms. Maxwell is +an individual, sued in an individual capacity, and therefore there is no "past or present officer, +director, agent or servant" of hers. Additionally, "attorneys" and "paralegals" are not +"employees" of Ms. Maxwell given that she herself is not an attorney and therefore cannot +"employ" attorneys. +14. +Ms. Maxwell objects to Definition No. 10 regarding "You" or "Your." The +Definition is overly broad and unduly burdensome to the extent it attempts to extend the scope of +the Requests to documents in the possession, custody or control of individuals other than Ms. +Maxwell or her counsel. +2 + + +OBJECTIONS TO INSTRUCTIONS +15. +Ms. Maxwell objects to Instruction No. 1, in particular the definition of the +"Relevant Period" to include July 1999 to the present, on the grounds that it is overly broad and +unduly burdensome and calls for the production of documents that are irrelevant to this action +and not reasonably calculated to lead to the discovery of admissible evidence. The Complaint at +paragraph 9 purports to describe events pertaining to Plaintiff and Defendant occurring in the +years 1999 - 2002. The Complaint also references statements attributed to Ms. Maxwell +occurring in January 2015. Defining the "Relevant Period" as "July 1999 to the present" is +vastly overbroad, irrelevant and not reasonably calculated to lead to the discovery of admissible +evidence, and as to certain of the Requests, is intended for the improper purpose of annoying or +harassing Ms. Maxwell and it implicates her privacy rights. Thus, Ms. Maxwell interprets the +Relevant Period to be limited to 1999-2002 and December 30, 2014 - January 31, 2015, except to +the extent that any the answers "relate to any activity of defendant with respect to the practice +which has been alleged and the duties alleged to be performed by Defendant, 'activities' being +defined as sexual abuse or trafficking of any female," in which case her answers reflect the +period 2000-today. Ms. Maxwell specifically objects to production of any documents outside +that period, except as specifically noted. +16. +Ms. Maxwell objects to Instruction No. 3 on the grounds that it is unduly +burdensome and is intended for the improper purpose of annoying or harassing Ms. Maxwell. +Ms. Maxwell cannot possibly recall the specific disposition of documents, particularly electronic +documents, dating back over 16 years. However, Ms. Maxwell, prior to this litigation has long +had a practice of deleting emails after they have been read. +17. +Ms. Maxwell objects to Instruction Nos. 5, 8, 9, 12, 17 to the extent they seek to +impose obligations to supply explanations for the presence or absence of such documents, to +specifically identify persons or documents, to provide information concerning who prepared +documents, the location of any copies of such documents, the identities and contact information +for persons who have custody or control of such documents, the reasons for inability to produce +portions of documents, and the "natural person in whose possession they were found," beyond +the requirements of Rule 34. This Instruction improperly seeks to propound Interrogatories +pursuant to Rule 33. +18. Ms. Maxwell objects to Instructions No. 13 on the grounds that it is unduly +burdensome and is intended for the improper purpose of annoying or harassing Ms. Maxwell. +Ms. Maxwell cannot possibly recall the specific circumstances upon which a document dating +back 16 years has ceased to exist. +19. Ms. Maxwell objects to Instruction No. 15 to the extent that it calls for documents +or information protected by the attorney/client privilege, the work-product doctrine, or any other +applicable privilege. +20. Ms. Maxwell objects to Instruction Nos. 18 & 19 to the extent they require +information on any privilege log above and beyond the requirements of Local Civil Rule 26.2. +3 + + +SPECIFIC OBJECTIONS AND RESPONSES TO PLAINTIFF'S SECOND REQUESTS +FOR PRODUCTION OF DOCUMENTS +DOCUMENT REQUEST NO. 1 +Produce all documents that Your attorneys reviewed and/or relied upon in the March 21, +2016, meet and confer discussion when Mr. Pagliuca stated that (1) Plaintiff made false +allegations concerning her sexual assault; (2) she made them in roughly the same time frame that +Plaintiff was abused by Jeffrey Epstein; (3) that the allegations were made against a number of +individuals in the area; and (4) that the allegations were found to be unfounded by local police. +RESPONSE: Ms. Maxwell has no knowledge of any statements made by Mr. Pagliuca +during the March 21, 2016 meet and confer and hence has no documents responsive to this +Request. Further, this Request inaceurately characterizes the statements of Ms. Maxwell's +counsel during the March 16, 2016 meet and confer. +Ms. Maxwell further objects to this Request to the extent it seeks documents or +information protected by the attorney/client privilege, the work-product doctrine, the common +interest privilege or any other applicable privilege. +Ms. Maxwell also objects to this Request to the extent it calls for information relating to +that exists within the public domain, the internet or in public court +records and which are equally available to both parties and can be obtained from some other +source that is more convenient, less burdensome, and less expensive. Subject to and without +waiver of the foregoing, Defendant refers to the public documents and news reports regarding +Plaintiff's allegations of sexual abuse and investigation of the same, which have been previously +produced, are available in the public domain, or referenced in court papers. Defendant also +refers Plaintiff to documents within the possession. custody and control of Plaintiff and her +counsel, including without limitation Mr. +. which were requested in +Defendant's First Set of Discovery Requests, but were not produced despite certification of +Plaintiff and Plaintiff's counsel that such Responses were truthful and complete. +Without waiver of any such objections, Ms. Maxwell has made available documents +related to some of Ms. +false allegations of sexual assaults in her Second Supplemental +Fed. R. Civ. P. 26(a)(1)(A) disclosures. +DOCUMENT REQUEST NO. 2 +Produce all documents concerning how any such police report, or how any such +recounting, retelling, summary, or description of any such police report (as referenced in +Interrogatory No. I), came into Your possession. This request includes, but is not limited to, all +documents concerning how, when, and by whom such reports (or descriptions of reports) were +obtained from a minor child's sealed juvenile records and files. +RESPONSE: Ms. Maxwell objects to this Request in that there is no "Interrogatory No. +1" to which the Request corresponds. She further objects to the Request in that it improperly +seeks to propound an Interrogatory in the form of a Request for Production of Documents and is +4 + + +a contention Interrogatory barred according to Plaintiff's interpretation of the Local Rules. The +Request embeds a number of assumptions that are not true and for which Plaintiff supplies no +basis for assertion of their veracity. +Ms. Maxwell likewise objects to this Request because it seeks documents or information +protected by the attorney/client privilege, the work-product doctrine, the common interest +privilege or any other applicable privilege. +Finally. Ms. Maxwell also objects to this Request to the extent it calls for information +relating to +that exists within the public domain, the internet or in public +court records and which are equally available to both parties and can be obtained from some +other source that is more convenient, less burdensome, and less expensive. Defendant refers to +the public documents and news reports regarding Plaintiff's allegations of sexual abuse and +investigation of the same, which have been previously produced, are available in the public +domain, or referenced in court papers. Defendant also refers Plaintiff to documents within the +possession, custody and control of Plaintiff and her counsel, including without limitation Mr. +, which were requested in Defendant's First Set of Discovery Requests, but +were not produced despite certification of Plaintiff and Plaintiff's counsel that such Responses +were truthful and complete. +Without waiver of any such objections, Ms. Maxwell has made available documents +related to some of Ms. +false allegations of sexual assaults in her Second Supplemental +Fed. R. Civ. P. 26(a)(1)(A) disclosures. Ms. Maxwell is withholding documents responsive to +this request on the basis of the attorney-client and work product privileges. +DOCUMENT REQUEST NO. 3 +Produce all documents concerning how information or knowledge of the local police's +findings or opinions concerning Ms. +allegations of sexual assault as a minor child came +into Your possession, including but not limited to documents concerning any statements made by +law enforcement or any state attorney, written or oral, concerning such allegations. +RESPONSE: Ms. Maxwell objects to this Request to the extent it seeks documents or +information protected by the attorney/client privilege, the work-product doctrine, the common +interest privilege or any other applicable privilege. +Ms. Maxwell also objects to this Request to the extent it calls for information relating to +that exists within the public domain, the internet or in public court +records and which are equally available to both parties and can be obtained from some other +source that is more convenient, less burdensome, and less expensive. Subject to and without +waiver of the foregoing, Defendant refers to the public documents and news reports regarding +Plaintiff's allegations of sexual abuse and investigation of the same, which have been previously +produced, are available in the public domain, or referenced in court papers. Defendant also +refers Plaintiff to documents within the possession, custody and control of Plaintiff and her +counsel, including without limitation Mr. +,. which were requested in +Defendant's First Set of Discovery Requests, but were not produced despite certification of +Plaintiff and Plaintiff's counsel that such Responses were truthful and complete. +5 + + +Without waiver of any such objections, Ms. Maxwell has made available documents +related to some of Ms. +false allegations of sexual assaults in her Second Supplemental +Fed. R. Civ. P. 26(a)(1)(A) disclosures. Ms. Maxwell is withholding documents responsive to +this request on the basis of the attorney-client and work product privileges. +DOCUMENT REQUEST NO. 4 +Produce all documents concerning any investigations, internal or otherwise, by any law +enforcement or governmental agency, regarding the illegal disclosure, illegal purchase, and/or +theft of sealed juvenile police records concerning Plaintiff. +RESPONSE: Ms. Maxwell objects to this Request to the extent it seeks documents or +information protected by the attorney/client privilege, the work-product doctrine, the common +interest privilege or any other applicable privilege. Ms. Maxwell also objects to this Request to +the extent it calls information relating to +that exists within the public +domain, the internet or in public court records and which are equally available to both parties and +can be obtained from some other source that is more convenient, less burdensome, and less +expensive. Defendant objects to this request to the extent that it characterizes the gathering of +public information as "illegal." +Subject to and without waiver of the foregoing, Defendant has been unable to locate any +documents responsive to this Request. +DOCUMENT REQUEST NO. 5 +Produce all documents concerning any rape, sexual assault, sexual intercourse, or other +sexual encounter involving Plaintiff. This Request includes, but is not limited to, (1) any +documents concerning any sexual assault of Plaintiff while a minor; (2) any police reports, or +or attorneys) by other individuals that reference any sexual assault of Plaintiff while a minor. +RESPONSE: Ms. Maxwell objects to this Request to the extent it seeks documents or +information protected by the attorney/client privilege, the work-product doctrine, the common +interest privilege or any other applicable privilege. +Ms. Maxwell also objects to this Request to the extent it calls for information relating to +that exists within the public domain, the internet or in public court +records and which are equally available to both parties and can be obtained from some other +source that is more convenient, less burdensome, and less expensive. Subject to and without +waiver of the foregoing, Defendant refers to the public documents and news reports regarding +Plaintiff's false allegations of sexual abuse and investigation of the same, which have been +previously produced, are available in the public domain, or referenced in court papers. +Defendant also refers Plaintiff to documents within the possession, custody and control of +Plaintiff and her counsel, including without limitation Mr. +| which were +requested in Defendant's First Set of Discovery Requests, but were not produced despite +certification of Plaintiff and Plaintiff's counsel that such Responses were truthful and complete. +6 + + +Defendant objects to the characterization of Plaintiff's documented false claims of sexual contact +as "rape" or "sexual assault." +Without waiver of any such objections, Ms. Maxwell has made available documents +related to some of Ms. +false allegations of sexual assault in her Second Supplemental +Fed. R. Civ. P. 26(a)(1)(A) disclosures. +DOCUMENT REQUEST NO. 6 +Produce any Joint Defense Agreement entered into between You and Jeffrey Epstein +from 1999 to the present. +RESPONSE: Ms. Maxwell objects to this Request to the extent it seeks documents or +information protected by the attorney/client privilege, the work-product doctrine, the common +interest privilege or any other applicable privilege. Defendant is withholding production of any +such agreement on the basis of such privileges. +DOCUMENT REQUEST NO. 7 +Produce any documents concerning any Joint Defense Agreement entered into between +You and Jeffrey Epstein from 1999 to the present. +RESPONSE: Ms. Maxwell objects to this Request to the extent it seeks documents or +information protected by the attorney/client privilege, the work-product doctrine, the common +interest privilege or any other applicable privilege. Defendant is withholding documents on the +basis of such privileges. +DOCUMENT REQUEST NO. 8 +Produce any documents concerning any of Your, or Your attorneys or agent's, +communications with Jeffrey Epstein's attorneys or agents from 1999 to the present relating to +the issue of sexual abuse of females, or any documents concerning any of Your, Your attorneys +or agent's, communications with Jeffrey Epstein's attorneys or agents from 1999 to the present +relating to the recruitment of any female under the age of 18 for any purpose, including +socializing or performing any type of work or services. +RESPONSE: Ms. Maxwell objects to this Request on the grounds that it is cumulative +and duplicative. Ms. Maxwell has already produced documents related to her communications +with Jeffrey Epstein in response to Plaintiff's First Requests for Production of Documents, all of +which document her denial that she did "recruit[] any female under the age of 18 for any +purpose." +Ms. Maxwell also objects to this Request to the extent it seeks documents or information +protected by the attorney/client privilege, the work-product doctrine, the common interest +privilege or any other applicable privilege. Subject to and without waiver of the foregoing, +Defendant has been unable to locate any additional documents responsive to this Request. +7 + + +DOCUMENT REQUEST NO. 9 +Produce any Joint Defense Agreement entered into between You and Alan Dershowitz +from 1999 to the present. +RESPONSE: Ms. Maxwell objects to this Request to the extent it seeks documents or +information protected by the attorney/client privilege, the work-product doctrine, the common +interest privilege or any other applicable privilege. Subject to and without waiver of the +foregoing, Defendant has been unable to locate any documents responsive to this Request. +DOCUMENT REQUEST NO. 10 +Produce any documents concerning any Joint Defense Agreement entered into between +You and Alan Dershowitz from 1999 to the present. +RESPONSE: Ms. Maxwell objects to this Request to the extent it seeks documents or +information protected by the attorney/client privilege, the work-product doctrine, the common +interest privilege or any other applicable privilege. Subject to and without waiver of the +foregoing, Defendant has been unable to locate any documents responsive to this Request. +DOCUMENT REQUEST NO. 11 +Produce any documents concerning any of Your attorneys' or agents' communications +with Alan Dershowitz's attorneys or agents from 1999 to the present +RESPONSE: Ms. Maxwell objects to this Request to the extent it seeks documents or +information protected by the attorney/client privilege, the work-product doctrine, the common +interest privilege or any other applicable privilege. Defendant is withholding communications +between Mr. Dershowitz's counsel and Defendant's counsel which contain work product and +concern joint defense or common interest matters. +DOCUMENT REQUEST NO. 12 +Produce all documents concerning L +D, whether or +not they reference her by name. This request includes, but is not limited to, all communications, +diaries, journals, calendars, blog posts (whether published or not), notes (handwritten or not), +memoranda, mobile phone agreements, wire transfer receipts, or any other document that +concerns Plaintiff in any way, whether or not they reference her by name. +RESPONSE: Ms. Maxwell objects to this Request as overly broad, unduly burdensome +and interposed for improper purposes. Response to this Request would literally entail defense +counsel reviewing for privilege every single document in their possession related to this case. +Ms. Maxwell further objects to this Request on the grounds that it is cumulative and +duplicative. Ms. Maxwell further objects to this request as exceeding the scope of this Court's +March 17, 2016 Order. Ms. Maxwell also objects to this Request to the extent it calls for +information relating to +that exists within the public domain, the internet +8 + + +or in publie court records and which are equally available to both parties and can be obtained +from some other source that is more convenient, less burdensome, and less expensive. Ms. +Maxwell further objects to this Request to the extent it seeks documents or information protected +by the attorney/client privilege, the work-product doctrine, the common interest privilege or any +other applicable privilege. Subject to the foregoing objections, Ms. Maxwell and her counsel are +not going to review every document in their possession for any additional documents responsive +to this Request. +DOCUMENT REQUEST NO. 13 +Produce all contracts, including but not limited to indemnification agreements and +employment agreements, between You and Jeffrey Epstein, or any entity associated with Jeffrey +Epstein, from 1999 to the present. +RESPONSE: Ms. Maxwell objects to this Request on the grounds that it is cumulative +and duplicative and is overly broad. Ms. Maxwell further objects to this Request to the extent it +seeks documents or information protected by the attorney/client privilege, the work-product +doctrine, the common interest privilege or any other applicable privilege. Subject to and without +waiver of the foregoing, Defendant has been unable to locate any such documents. +DOCUMENT REQUEST NO. 14 +Produce all documents concerning any contracts, including but not limited to +indemnification agreements and employment agreements, between You and Jeffrey Epstein, or +any entity associated with Jeffrey Epstein, from 1999 to the present. +RESPONSE: Ms. Maxwell objects to this Request on the grounds that it is cumulative +and duplicative and is overly broad. Ms. Maxwell further objects to this Request to the extent it +seeks documents or information protected by the attorney/client privilege, the work-product +doctrine, the common interest privilege or any other applicable privilege. Subject to and without +waiver of the foregoing, Defendant has been unable to locate any such documents. +DOCUMENT REQUEST NO. 15 +Produce all documents concerning the identity or identities of the individual(s) or entities +paying Your legal fees concerning the above-captioned action, and all documents concerning the +identity or identities of the individual(s) or entities paying Ross Gow, or any entities associated +with Ross Gow, for any work he performed on Your behalf. +RESPONSE: Ms. Maxwell objects to this Request on the grounds that it seeks multiple +categories of documents within a single request for production. Ms. Maxwell further objects to +this Request to the extent it seeks documents or information protected by the attorney/client +privilege, the work-product doctrine, the common interest privilege or any other applicable +privilege. Ms. Maxwell is producing her engagement letter with her counsel in this action. +Defendant has been unable to locate any additional documents responsive to this Request. +9 + + +DOCUMENT REQUEST NO. 16 +Produce all documents concerning any action or lawsuit brought against You from 1999 +to the present, including, but not limited to, actions or lawsuits brought in foreign jurisdictions. +RESPONSE: Ms. Maxwell objects to this Request on the grounds that it is over-broad +and unduly burdensome and calls for the production of documents that are irrelevant to this +action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. +Maxwell further objects to this Request to the extent it seeks documents or information protecte +y the attorney/client privilege, the work-product doctrine, or any other applicable privilege +Subject to and without waiving the above objections, Ms. Maxwell has been unable to locate any +documents responsive to this Request. +DOCUMENT REQUEST NO. 17 +Produce all documents concerning any statement made by You or on Your behalf to the +press or any other group or individual, including draft statements, concerning Ms. +by +You, Ross Gow, or any other individual, from 2005 to the present, including the dates of any +publications, and if published online, the Uniform Resource Identifier (URL) address. +RESPONSE: Ms. Maxwell objects to this Request on the grounds that it is cumulative +and duplicative. Ms. Maxwell also objects to this Request to the extent it calls for information +that exists within the public domain, the internet or in public court records and which are +equally available to both parties and can be obtained from some other source that is more +convenient, less burdensome, and less expensive. Ms. Maxwell further objects to this Request +to the extent it seeks documents or information protected by the attorney/client privilege, the +work-product doctrine, or any other applicable privilege. Ms. Maxwell is not producing +documents that are available in the public domain. Ms. Maxwell has been unable to locate any +additional documents responsive to this Request. +DOCUMENT REQUEST NO. 18 +Produce all documents concerning which individuals or entities You or Your agents +distributed or sent any statements concerning Ms. +referenced in Request No. 18 made by +You or on Your behalf. +RESPONSE: Ms. Maxwell objects to this Request on the grounds that it is cumulative +and duplicative. Ms. Maxwell also objects to this Request to the extent it calls for information +that exists within the public domain, the internet or in public court records and which are +equally available to both parties and can be obtained from some other source that is more +convenient, less burdensome, and less expensive. Ms. Maxwell further objects to this Request +to the extent it seeks documents or information protected by the attorney/client privilege, the +work-product doctrine, or any other applicable privilege. Ms. Maxwell is not producing +documents that are available in the public domain. Ms. Maxwell has been unable to locate any +additional documents responsive to this Request. +10 + + +DOCUMENT REQUEST NO. 19 Produce all documents concerning any alleged illegal +activity involving Plaintiff from the Relevant Period. This request includes, but is not limited to, +any documents concerning the Roadhouse Grill in Florida. +RESPONSE: Ms. Maxwell objects to this Request as vague and confusing. Ms. Maxwell +unaware of all illegal activities in which Plaintiff may have been engaged in during the stat +me period. and documents concerning those activities are uniquely within Plaintifi +possession, custody and control. +Ms. Maxwell further objects to this Request to the extent it seeks documents or +information protected by the attorney/client privilege, the work-product doctrine, the common +interest privilege or any other applicable privilege. +Ms. Maxwell also objects to this Request to the extent it calls for information relating to +that exists within the public domain, the internet or in public court +records and which are equally available to both parties and can be obtained from some other +source that is more convenient, less burdensome, and less expensive. Subject to and without +waiver of the foregoing, Defendant refers to the public documents and news reports regarding +Plaintiff's allegations of sexual abuse and investigation of the same, which have been previously +produced, are available in the public domain, or referenced in court papers. Defendant also +refers Plaintiff to documents within the possession, custody and control of Plaintiff and her +counsel, including without limitation Mr. +, which were requested in +Defendant's First Set of Discovery Requests, but were not produced despite certification of +Plaintiff and Plaintiff's counsel that such Responses were truthful and complete. +Without waiver of any such objections, Ms. Maxwell has made available documents +related to some of Ms. +contacts with law enforcement in her Second Supplemental Fed. +R. Civ. P. 26(a)(1)(A) disclosures. +DOCUMENT REQUEST NO. 20 +Produce all documents concerning any apartment or other dwelling occupied by Plaintiff +from 1999 to the present, including but not limited to, all documents concerning the acquisition +of, and payment for, such dwellings. This Request includes, but is not limited to, any dwelling +paid for -in whole or in part by Defendant or Jeffrey Epstein. +RESPONSE: Ms. Maxwell objects to this Request to the extent it calls for information +that exists within the public domain, the internet or in public court records and which are equally +available to both parties and can be obtained from some other source that is more convenient, +less burdensome, and less expensive. Ms. Maxwell is not producing documents that are available +in the public domain. Ms. Maxwell is not re-producing documents already produced by her and +produced by Plaintiff in this action, for example, in response to Defendant's First Set of +Discovery Requests to Plaintiff which requested inter alia documents related to Plaintiff's +residences since 1999. +Without waiver of any such objections, Ms. Maxwell has made available documents +related to some of Ms. +dwellings in her Second Supplemental Fed. R. Civ. P. +11 + + +26(a)(1)(A) disclosures. Ms. Maxwell has been unable to locate any additional documents +responsive to this Request. +DOCUMENT REQUESTS "CONCERNING PUNITIVE DAMAGES" +DOCUMENT REQUEST NO. 21 +Produce all copies of the complaints in any lawsuits that You have filed in any court in +which You seek damages or any other financial recovery from 2014 to the present. +RESPONSE: Ms. Maxwell objects to this Request on the grounds that it is overly broad +annoying or harassing Ms. Maxwell. Ms. Maxwell's personal financial information is not at +issue in this matter and information relating thereto is irrelevant. +Ms. Maxwell intends to move for a Protective Order regarding her personal financial +information and is refusing to respond and is withholding documents under the category of +"Document Requests Concerning Punitive Damages" until the motion is resolved. +Based on the May 16, 2016 conferral, counsel for Plaintiff has agreed to hold this +Request in abeyance pending either a finding of liability or resolution of dispositive motions. +Plaintiff's counsel will not file a Motion to Compel a Response to this Request, nor will +Defendant move for a Protective Order with regard to this Request, without further conferral. +DOCUMENT REQUEST NO. 22 +Produce all Financial Statements prepared for or submitted to any Lender or Investor for +the past three years by You personally or on Your behalf or on behalf of any entity in which You +hold or held a controlling interest from January 2015 to the Present. +RESPONSE: Ms. Maxwell objects to this Request on the grounds that it is overly broad +and unduly burdensome and calls for the production of documents that are irrelevant to this +action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. +Maxwell objects to this Request on the grounds that it is propounded for the improper purpose of +annoying or harassing Ms. Maxwell. Ms. Maxwell's personal financial information is not at +issue in this matter and information relating thereto is irrelevant. +Ms. Maxwell intends to move for a Protective Order regarding her personal financial +information and is refusing to respond and is withholding documents under the category of +"Document Requests Concerning Punitive Damages" until the motion is resolved. +Based on the May 16, 2016 conferral, counsel for Plaintiff has agreed to hold this +Request in abeyance pending either a finding of liability or resolution of dispositive motions. +Plaintiff's counsel will not file a Motion to Compel a Response to this Request, nor will +12 + + +Defendant move for a Protective Order with regard to this Request, without further conferral. +DOCUMENT REQUEST NO. 23 +Produce all W-2s, K-Is, and any other documents reflecting any income (including +salary, bonuses, dividends, profit distributions, royalties, advances, annuities, and any other form +of income), including all gross and net revenue received by You directly or indirectly from +January 2015 to the present. +ESPONSE: Ms. Maxwell objects to this Request on the grounds that it is overly broa +ind unduly burdensome and calls for the production of documents that are irrelevant to thi +action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. +Maxwell objects to this Request on the grounds that it is propounded for the improper purpose of +annoying or harassing Ms. Maxwell. Ms. Maxwell's personal financial information is not at +Ms. Maxwell intends to move for a Protective Order regarding her personal financial +information and is refusing to respond and is withholding documents under the category of +"Document Requests Concerning Punitive Damages" until the motion is resolved. +Based on the May 16, 2016 conferral, counsel for Plaintiff has agreed to hold this +Request in abeyance pending either a finding of liability or resolution of dispositive motions. +Plaintiff's counsel will not file a Motion to Compel a Response to this Request, nor will +Defendant move for a Protective Order with regard to this Request, without further conferral. +DOCUMENT REQUEST NO. 24 +Produce all tax returns filed with any taxing entity (either foreign or domestic) from +January 2015 to the present by You or on Your behalf, or on behalf of any entity in which You +hold or held a controlling interest at the time of filing. +RESPONSE: Ms. Maxwell objects to this Request on the grounds that it is overly broad +nd unduly burdensome and calls for the production of documents that are irrelevant to thi +ction and not reasonably calculated to lead to the discovery of admissible evidence. Ms +Maxwell objects to this Request on the grounds that it is propounded for the improper purpose of +annoying or harassing Ms. Maxwell. Ms. Maxwell's personal financial information is not at +issue in this matter and information relating thereto is irrelevant. +Ms. Maxwell intends to move for a Protective Order regarding her personal financial +information and is refusing to respond and is withholding documents under the category of +"Document Requests Concerning Punitive Damages" until the motion is resolved. +Based on the May 16, 2016 conferral, counsel for Plaintiff has agreed to hold this +Request in abeyance pending either a finding of hability or resolution of dispositive motions. +Plaintiff's counsel will not file a Motion to Compel a Response to this Request, nor will +Defendant move for a Protective Order with regard to this Request, without further conferral. +13 + + +DOCUMENT REQUEST NO. 25 +Produce all bank statements or other financial statements which were prepared by You, +on Your behalf or by or on behalf of any entity in which You held an ownership interest of 10% +or more at any time from January 2015 to the present. +RESPONSE: Ms. Maxwell objects to this Request on the grounds that it is overly broad +and unduly burdensome and calls for the production of documents that are irrelevant to this +Ms. Maxwell intends to move for a Protective Order regarding her personal financial +information and is refusing to respond and is withholding documents under the category of +"Document Requests Concerning Punitive Damages" until the motion is resolved. +Based on the May 16, 2016 conferral, counsel for Plaintiff has agreed to hold this +Request in abeyance pending either a finding of liability or resolution of dispositive motions. +Plaintiff's counsel will not file a Motion to Compel a Response to this Request, nor will +Defendant move for a Protective Order with regard to this Request, without further conferral. +DOCUMENT REQUEST NO. 26 +Produce all deeds and titles to all real property owned by You or held on Your behalf +either directly or indirectly at any time from January 2015 to the present. +RESPONSE: Ms. Maxwell objects to this Request on the grounds that it is overly broad +and unduly burdensome and calls for the production of documents that are irrelevant to this +action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. +Maxwell objects to this Request on the grounds that it is propounded for the improper purpose of +annoying or harassing Ms. Maxwell. Ms. Maxwell's personal financial information is not at +issue in this matter and information relating thereto is irrelevant. +Ms. Maxwell intends to move for a Protective Order regarding her personal financial +information and is refusing to respond and is withholding documents under the category of +"Document Requests Concerning Punitive Damages" until the motion is resolved. +Based on the May 16, 2016 conferral, counsel for Plaintiff has agreed to hold this +Kequest in abeyance pending either a finding of habilty or resolution of dispositive motions. +Plaintiff's counsel will not file a Motion to Compel a Response to this Request, nor will +Defendant move for a Protective Order with regard to this Request, without further conferral. +DOCUMENT REQUEST NO. 27 +Produce all passbooks (or other documents showing account balances) with respect to all +savings accounts, checking accounts, and savings and loan association share accounts owned by +14 + + +You or on which You hold a right or have held a right to withdraw funds at any time from +January 2015 to the present. +RESPONSE: Ms. Maxwell objects to this Request on the grounds that it is overly broad +and unduly burdensome and calls for the production of documents that are irrelevant to this +action and not reasonably calculated to lead to the discovery of admissible evidence. MS. +Maxwell objects to this Request on the grounds that it is propounded for the improper purpose of +annoying or harassing Ms. Maxwell. Ms. Maxwell's personal financial information is not at +issue in this matter and information relating thereto is irrelevant. +Ms. Maxwell intends to move for a Protective Order regarding her personal financial +information and is refusing to respond and is withholding documents under the category of +"Document Requests Concerning Punitive Damages" until the motion is resolved. +Based on the May 16, 2016 conferral, counsel for Plaintiff has agreed to hold this +Request in abeyance pending either a finding of liability or resolution of dispositive motions. +Plaintiff's counsel will not file a Motion to Compel a Response to this Request, nor will +Defendant move for a Protective Order with regard to this Request, without further conferral. +DOCUMENT REQUEST NO. 28 +Produce all passbooks (or other documents showing account balances) with respect to all +savings accounts, checking accounts and savings loan association share accounts, owned by You +in whole or in party jointly as co-owner, partner, or joint venture, in any business enterprise, or +owned by an entity in which You have or have had a controlling interest at any time from +January 2015 to the present. +RESPONSE: Ms. Maxwell objects to this Request on the grounds that it is overly broad +and unduly burdensome and calls for the production of documents that are irrelevant to this +action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. +Maxwell objects to this Request on the grounds that it is propounded for the improper purpose of +annoying or harassing Ms. Maxwell. Ms. Maxwell's personal financial information is not at +issue in this matter and information relating thereto is irrelevant. +Ms. Maxwell intends to move for a Protective Order regarding her personal financial +information and is refusing to respond and is withholding documents under the category of +"Document Requests Concerning Punitive Damages" until the motion is resolved. +Based on the May 16, 2016 conferral, counsel for Plaintiff has agreed to hold this +Request in abeyance pending either a finding of liability or resolution of dispositive motions. +Plaintiff's counsel will not file a Motion to Compel a Response to this Request, nor will +Defendant move for a Protective Order with regard to this Request, without further conferral. +DOCUMENT REQUEST NO. 29 +Produce all bank ledger sheets (from the internet or otherwise) concerning all bank +accounts in which You have a right to withdraw funds, reflecting the highest balance in said +15 + + +accounts from January 2015 to the present. . +RESPONSE: Ms. Maxwell objects to this Request on the grounds that it is overly broad +nd unduly burdensome and calls for the production of documents that are irrelevant to thi +ction and not reasonably calculated to lead to the discovery of admissible evidence. M +maying or harassing Ms. Maxwell Ms Max well s personal financial informaton is purpase o +issue in this matter and information relating thereto is irrelevant. +Ms. Maxwell intends to move for a Protective Order regarding her personal financial +informion and ieseline to respond and i amigolding documens nder she category of +Based on the May 16, 2016 conferral, counsel for Plaintiff has agreed to hold this +Request in abeyance pending either a finding of liability or resolution of dispositive motions. +Plaintiff's counsel will not file a Motion to Compel a Response to this Request, nor will +Defendant move for a Protective Order with regard to this Request, without further conferral. +DOCUMENT REQUEST NO. 30 +Produce all bank ledger sheets (from the internet or otherwise) concerning all bank +accounts owned by You solely, or jointly as co-owner, partner, or joint venture, in any business +enterprise, or any entity in which You have or have had a controlling interest from January 2015 +to the present, reflecting het highest balance in said accounts for each month from January 2015 +to the present. +RESPONSE: Ms. Maxwell objects to this Request on the grounds that it is overly broad +and unduly burdensome and calls for the production of documents that are irrelevant to this +action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. +Maxwell objects to this Request on the grounds that it is propounded for the improper purpose of +annoying or harassing Ms. Maxwell. Ms. Maxwell's personal financial information is not at +issue in this matter and information relating thereto is irrelevant. +Ms. Maxwell intends to move for a Protective Order regarding her personal financial +information and is refusing to respond and is withholding documents under the category of +"Document Requests Concerning Punitive Damages" until the motion is resolved. +Based on the May 16, 2016 conferral, counsel for Plaintiff has agreed to hold this +Request in abeyance pending either a finding of liability or resolution of dispositive motions. +Plaintiff's counsel will not file a Motion to Compel a Response to this Request, nor will +Defendant move for a Protective Order with regard to this Request, without further conferral. +DOCUMENT REQUEST NO. 31 +Produce all checkbooks for all accounts on which You were authorized to withdraw +funds from January 2015 to the present. +16 + + +RESPONSE: Ms. Maxwell objects to this Request on the grounds that it is overly broad +and unduly burdensome and calls for the production of documents that are irrelevant to this +action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. +Maxwell objects to this Request on the grounds that it is propounded for the improper purpose of +annoying or harassing Ms. Maxwell. Ms. Maxwell's personal financial information is not at +issue in this matter and information relating thereto is irrelevant. +Ms. Maxwell intends to move for a Protective Order regarding her personal financial +information and is refusing to respond and is withholding documents under the category of +"Document Requests Concerning Punitive Damages" until the motion is resolved. +Based on the May 16, 2016 conferral, counsel for Plaintiff has agreed to hold this +Request in abeyance pending either a finding of liability or resolution of dispositive motions. +Plaintiff's counsel will not file a Motion to Compel a Response to this Request, nor will +Defendant move for a Protective Order with regard to this Request, without further conferral. +DOCUMENT REQUEST NO. 32 +Produce the 2015 and 2016 balance sheets and other financial statements with respect to +any and all business enterprises of whatever nature (including not-for-profit enterprises), either +foreign or domestic, in which You possess any ownership interest of 10% or more, whether a +partner, joint venture, stockholder, or otherwise. +RESPONSE: Ms. Maxwell objects to this Request on the grounds that it is overly broad +and unduly burdensome and calls for the production of documents that are irrelevant to this +action and not reasonably calculated to lead to the discovery of admissible evidence. Ms +Max well objects to this Request on the grounds that it is propounded for the improper purpose o +annoving or harassing Ms. Maxwell. Ms. Maxwell's personal financial information is not a +issue in this matter and information relating thereto is irrelevant. +Ms. Maxwell intends to move for a Protective Order regarding her personal financial +information and is refusing to respond and is withholding documents under the category of +"Document Requests Concerning Punitive Damages" until the motion is resolved. +Based on the May 16, 2016 conferral, counsel for Plaintiff has agreed to hold this +Request in abeyance pending either a finding of liability or resolution of dispositive motions. +Plaintiff's counsel will not file a Motion to Compel a Response to this Request, nor will +Defendant move for a Protective Order with regard to this Request, without further conferral. +DOCUMENT REQUEST NO. 33 +Produce all corporate securities (stocks or bonds), foreign or domestic, directly or +indirectly held by You, or held on Your behalf or for Your benefit by another individual or +entity, including trusts from January 2015 to the Present. +RESPONSE: Ms. Maxwell objects to this Request on the grounds that it is overly broad +and unduly burdensome and calls for the production of documents that are irrelevant to this +17 + + +action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. +Maxwell objects to this Request on the grounds that it is propounded for the improper purpose of +annoying or harassing Ms. Maxwell. Ms. Maxwell's personal financial information is not at +issue in this matter and information relating thereto is irrelevant. +Ms. Maxwell intends to move for a Protective Order regarding her personal financial +information and is refusing to respond and is withholding documents under the category of +"Document Requests Concerning Punitive Damages until the motion is resolved. +Based on the May 16, 2016 conferral, counsel for Plaintiff has agreed to hold this +Request in abeyance pending either a finding of liability or resolution of dispositive motions. +Plaintiff's counsel will not file a Motion to Compel a Response to this Request, nor will +Defendant move for a Protective Order with regard to this Request, without further conferral. +DOCUMENT REQUEST NO. 34 +Produce all accounts receivable ledgers or other records which set forth the names and +addresses of all persons or business enterprises that are indebted to You and the amounts and +terms of such indebtedness from August 2016 to the Present. +RESPONSE: Ms. Maxwell objects to this Request on the grounds that it is overly broad +and unduly burdensome and calls for the production of documents that are irrelevant to this +action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. +Maxwell objects to this Request on the grounds that it is propounded for the improper purpose of +annoying or harassing Ms. Maxwell. Ms. Maxwell's personal financial information is not at +issue in this matter and information relating thereto is irrelevant. +Ms. Maxwell intends to move for a Protective Order regarding her personal financial +information and is refusing to respond and is withholding documents under the category of +"Document Requests Concerning Punitive Damages" until the motion is resolved. +Based on the May 16, 2016 conferral, counsel for Plaintiff has agreed to hold this +Request in abeyance pending either a finding of liability or resolution of dispositive motions. +Plaintiff's counsel will not file a Motion to Compel a Response to this Request, nor will +Defendant move for a Protective Order with regard to this Request, without further conferral. +DOCUMENT REQUEST NO. 35 +Produce all copies of the partnership or corporation Income Tax Returns for any +partnership or corporation, either foreign or domestic, in which You do possess or have +possessed any ownership interest of 4% or more whether as partner, joint venture, stockholder or +otherwise, from 2014 to the present. +RESPONSE: Ms. Maxwell objects to this Request on the grounds that it is overly broad +and unduly burdensome and calls for the production of documents that are irrelevant to this +action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. +Maxwell objects to this Request on the grounds that it is propounded for the improper purpose of +18 + + +annoying or harassing Ms. Maxwell. Ms. Maxwell's personal financial information is not at +issue in this matter and information relating thereto is irrelevant. +Ms. Maxwell intends to move for a Protective Order regarding her personal financial +information and is refusing to respond and is withholding documents under the category of +"Document Requests Concerning Punitive Damages" until the motion is resolved. +Based on the May 16, 2016 conferral, counsel for Plaintiff has agreed to hold this +equest in abeyance pending either a finding of liability or resolution of dispositive motion +laintiff's counsel will not file a Motion to Compel a Response to this Request, nor wi +Defendant move for a Protective Order with regard to this Request, without further conferral. +DOCUMENT REQUEST NO. 36 +Produce all title certificates, registration certificates, bills of sale, and other evidences of +ownership possessed by You or held for Your beneficial interest with respect to any of the +following described property owned by You or held directly or indirectly for Your beneficial +interest from January 2015 to the present: +a. Motor vehicles of any type, including trucks, other automobiles, and two or three-wheeled +vehicles (motorcycles, ATV, etc.). +b. Aircraft of any type, including jets, propeller planes, and helicopters +c. Boats, launches, cruisers, sailboats, or other vessels of any type +d. Real estate and real property +RESPONSE: Ms. Maxwell objects to this Request on the grounds that it is overly broad +and unduly burdensome and calls for the production of documents that are irrelevant to this +action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. +Maxwell objects to this Request on the grounds that it is propounded for the improper purpose of +annoying or harassing Ms. Maxwell. Ms. Maxwell's personal financial information is not at +Ms. Maxwell intends to move for a Protective Order regarding her personal financial +information and is refusing to respond and is withholding documents under the category of +"Document Requests Concerning Punitive Damages" until the motion is resolved. +Based on the May 16, 2016 conferral, counsel for Plaintiff has agreed to hold this +Request in abeyance pending either a finding of liability or resolution of dispositive motions. +Plaintiff's counsel will not file a Motion to Compel a Response to this Request, nor will +Defendant move for a Protective Order with regard to this Request, without further conferral. +DOCUMENT REQUEST NO. 37 +From January 2012 to the present, produce all documents concerning any source of +funding for the TarraMar Project or any other not-for-profit entities with which You are +19 + + +associated, including but not limited to, funding received from the Clinton Global Initiative, the +Clinton Foundation (a/k/a William J. Clinton Foundation, a/k/a/ the Bill, Hilary & Chelsea +Clinton Foundation), and the Clinton Foundation Climate Change Initiative. +RESPONSE: Ms. Maxwell objects to this Request on the grounds that it is overly broad +and unduly burdensome and calls for the production of documents that are irrelevant to this +action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. +Maxwell objects to this Request on the grounds that it is propounded for the improper purpose of +annoying or harassing Ms. Maxwell. Ms. Maxwell's personal financial information is not at +issue in this matter and information relating thereto is irrelevant. +Ms. Maxwell intends to move for a Protective Order regarding her personal financial +information and is refusing to respond and is withholding documents under the category of +"Document Requests Concerning Punitive Damages" until the motion is resolved. +Based on the May 16, 2016 conferral, counsel for Plaintiff has agreed to hold this +Request in abeyance pending either a finding of liability or resolution of dispositive motions. +Plaintiff's counsel will not file a Motion to Compel a Response to this Request, nor will +Defendant move for a Protective Order with regard to this Request, without further conferral. +DOCUMENT REQUEST NO. 38 +Produce all memoranda and/or bills evidencing the amount and terms of all of Your +current debts and obligations that exist presently. +RESPONSE: Ms. Maxwell objects to this Request on the grounds that it is overly broad +and unduly burdensome and calls for the production of documents that are irrelevant to this +action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. +Maxwell objects to this Request on the grounds that it is propounded for the improper purpose of +annoying or harassing Ms. Maxwell. Ms. Maxwell's personal financial information is not at +issue in this matter and information relating thereto is irrelevant. +Ms. Maxwell intends to move for a Protective Order regarding her personal financial +information and is refusing to respond and is withholding documents under the category of +"Document Requests Concerning Punitive Damages" until the motion is resolved. +Based on the May 16, 2016 conferral, counsel for Plaintiff has agreed to hold this +Request in abeyance pending either a finding of liability or resolution of dispositive motions. +Plaintiff's counsel will not file a Motion to Compel a Response to this Request, nor will +Defendant move for a Protective Order with regard to this Request, without further conferral. +DOCUMENT REQUEST NO. 39 +Produce all records indicating any and all income (whether taxable or not) received +by You from all sources from January 2015 to the present. +RESPONSE: Ms. Maxwell objects to this Request on the grounds that it is overly broad +20 + + +and unduly burdensome and calls for the production of documents that are irrelevant to this +action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. +Maxwell objects to this Request on the grounds that it is propounded for the improper purpose of +annoying or harassing Ms. Maxwell. Ms. Maxwell's personal financial information is not at +issue in this matter and information relating thereto is irrelevant. +Ms. Maxwell intends to move for a Protective Order regarding her personal financial +information and is refusing to respond and is withholding documents under the category of +"Document Requests Concerning Punitive Damages" until the motion is resolved. +Based on the May 16, 2016 conferral, counsel for Plaintiff has agreed to hold this +Request in abeyance pending either a finding of liability or resolution of dispositive motions. +Plaintiff's counsel will not file a Motion to Compel a Response to this Request, nor will +Defendant move for a Protective Order with regard to this Request, without further conferral. +DOCUMENT REQUEST NO. 40 +Produce all copies of any and all brokerage account statements or securities owned by +You individually, jointly with any person or entity or as trustee, guardian or custodian, from +January 2015 to the present, including in such records date of purchase and amounts paid for +such securities, and certificates of any such securities. +RESPONSE: Ms. Maxwell objects to this Request on the grounds that it is overly broad +and unduly burdensome and calls for the production of documents that are irrelevant to this +action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. +Maxwell objects to this Request on the grounds that it is propounded for the improper purpose of +annoying or harassing Ms. Maxwell. Ms. Maxwell's personal financial information is not at +issue in this matter and information relating thereto is irrelevant. +Ms. Maxwell intends to move for a Protective Order regarding her personal financial +information and is refusing to respond and is withholding documents under the category of +"Document Requests Concerning Punitive Damages" until the motion is resolved. +Based on the May 16, 2016 conferral, counsel for Plaintiff has agreed to hold this +Request in abeyance pending either a finding of liability or resolution of dispositive motions. +Plaintiff's counsel will not file a Motion to Compel a Response to this Request, nor will +Defendant move for a Protective Order with regard to this Request, without further conferral. +DOCUMENT REQUEST NO. 41 +Produce all records pertaining to the acquisition, transfer and sale of all securities by You +or on Your behalf from January 2015 to the present, such records to include any and all +information relative to gains or losses realized from transactions involving such securities. +RESPONSE: Ms. Maxwell objects to this Request on the grounds that it is overly broad +and unduly burdensome and calls for the production of documents that are irrelevant to this +action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. +21 + + +Maxwell objects to this Request on the grounds that it is propounded for the improper purpose of +annoying or harassing Ms. Maxwell. Ms. Maxwell's personal financial information is not at +issue in this matter and information relating thereto is irrelevant. +Ms. Maxwell intends to move for a Protective Order regarding her personal financial +information and is refusing to respond and is withholding documents under the category of +"Document Requests Concerning Punitive Damages" until the motion is resolved. +Based on the May 16, 2016 conferral, counsel for Plaintiff has agreed to hold this +Request in abeyance pending either a finding of liability or resolution of dispositive motions. +Plaintiff's counsel will not file a Motion to Compel a Response to this Request, nor will +Defendant move for a Protective Order with regard to this Request, without further conferral. +DOCUMENT REQUEST NO. 42 +Produce all policies of insurance having any cash value that exist or existed from January +2015 to the present, which policies You or any entity controlled by You is the owner or +beneficiary. +RESPONSE: Ms. Maxwell objects to this Request on the grounds that it is overly broad +and unduly burdensome and calls for the production of documents that are irrelevant to this +action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. +Maxwell objects to this Request on the grounds that it is propounded for the improper purpose of +annoying or harassing Ms. Maxwell. Ms. Maxwell's personal financial information is not at +issue in this matter and information relating thereto is irrelevant. +Ms. Maxwell intends to move for a Protective Order regarding her personal financial +information and is refusing to respond and is withholding documents under the category of +"Document Requests Concerning Punitive Damages" until the motion is resolved. +Based on the May 16, 2016 conferral, counsel for Plaintiff has agreed to hold this +Request in abeyance pending either a finding of liability or resolution of dispositive motions. +Plaintiff's counsel will not file a Motion to Compel a Response to this Request, nor will +Defendant move for a Protective Order with regard to this Request, without further conferral. +UN-NUMBERED REQUEST +Produce all copies of any and all trust agreements that exist or existed from January 2015 +to the present in which You are the settlor or beneficiary together with such documents necessary +and sufficient to identify the nature and current value of the trust. +RESPONSE: Ms. Maxwell objects to this Request on the grounds that it is overly broad +and unduly burdensome and calls for the production of documents that are irrelevant to this +action and not reasonably calculated to lead to the discovery of admissible evidence. MS. +Maxwell objects to this Request on the grounds that it is propounded for the improper purpose of +annoying or harassing Ms. Maxwell. Ms. Maxwell's personal financial information is not at +issue in this matter and information relating thereto is irrelevant. +22 + + +Ms. Maxwell intends to move for a Protective Order regarding her personal financial +information and is refusing to respond and is withholding documents under the category of +"Document Requests Concerning Punitive Damages" until the motion is resolved. +Based on the May 16, 2016 conferral, counsel for Plaintiff has agreed to hold this +Request in abeyance pending either a finding of liability or resolution of dispositive motions +Plaintiff's counsel will not file a Motion to Čompel a Response to this Request, nor will +Defendant move for a Protective Order with regard to this Request, without further conferral. +Dated: May 16, 2016 +Respectfully submitted, +s/Laura A.Menninger +Laura A. Menninger (LM-1374) +Jeffrey S. Pagliuca (pro hac vice) +HADDON, MORGAN AND FoReMAn, P.C. +Denver, CO 80203 +Phone: +Fax: +Attorneys for Ghislaine Maxwell +23 + + +CERTIFICATE OF SERVICE +I certify that on May 16, 2016, I served the attached document DEFENDANT +GHISLAINE MAXWELL'S RESPONSES AND OBJECTIONS TO PLAINTIFF'S SECOND +REQUEST FOR PRODUCTION OF DOCUMENTS via email to the following counsel of +record: +Sigrid S. McCawley +Meridith Schultz +BOIES. SCHILLER & FLEXNER. LLP +Paul G. Cassell +Salt Lake City. UT 84112 +Ft. Lauderdale, FL 33301 +FARMER, JAFFE, WEISSING, EDWARDS, +FISTOS & LEHRMAN, P.L. +Ft. Lauderdale. FL 33301 +s/ Laura A. Menninger +Laura A. Menninger +24 diff --git a/vision-fixhub/ds9-parsed-01/0d9131afe0a87c0ba8dacbfc6b7f721e4649c0b09dc1d0f759abfeaf7fe1a2ac.receipt.json b/vision-fixhub/ds9-parsed-01/0d9131afe0a87c0ba8dacbfc6b7f721e4649c0b09dc1d0f759abfeaf7fe1a2ac.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..812aa7ac902d7a889a8705193da874833c61b689 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0d9131afe0a87c0ba8dacbfc6b7f721e4649c0b09dc1d0f759abfeaf7fe1a2ac.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -288, + "dataset": "marble-joined", + "doc_id": "0d9131afe0a87c0ba8dacbfc6b7f721e4649c0b09dc1d0f759abfeaf7fe1a2ac", + "engine": "marble-apple-vision", + "event_count": 24, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "4019c1b76dc544843f528d80d2bb9fe54d1999a59e2e68ed661c058fa134d602", + "output_sha256": "84dd86db9232b7fbb0f6b9aa12303c52ae68b79ac3c00017f0bf776c85f6990c", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0da66ef4d2abb5956ef8cff1e7929f309f47fb3fd76e634be4bf296d7194c205.md b/vision-fixhub/ds9-parsed-01/0da66ef4d2abb5956ef8cff1e7929f309f47fb3fd76e634be4bf296d7194c205.md new file mode 100644 index 0000000000000000000000000000000000000000..1bf9648ca72d9f45f53a438259a0c8b763ed6841 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0da66ef4d2abb5956ef8cff1e7929f309f47fb3fd76e634be4bf296d7194c205.md @@ -0,0 +1,41 @@ +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +---- +UNITED STATES OF AMERICA +- V.- +GHISLAINE MAXWELL, +Defendant. +STIPULATION +S2 20 CR 330 (AJN) +---- +IT IS HEREBY STIPULATED AND AGREED by and among the United States +of America, by Damian Williams, United States Attorney for the Southern District of New York, +and +Assistant United +States Attorneys, of counsel, and defendant Ghislaine Maxwell, by and with the consent of her +attorneys, Christopher Everdell, Esq., Laura Menninger, Esq., Jeffrey Pagliuca, Esq., and Bobbi +Sternheim, Esq., that: +1. +The documents marked 3505-043 and 3505-044 are a true and accurate +copy of the transcript of the deposition taken on December 4, 2009 in West Palm Beach, Florida. + + +2. +IT IS FURTHER STIPULATED AND AGREED THAT this stipulation, +marked as Government Exhibit 1007, and the documents marked 3505-043 and 3505-044, may +be received in evidence as Government exhibits at trial subject to objections by the defense +based on relevance, hearsay, or under Rule 403. +Dated: +November_ +_ 2021 +New York, New York +DAMIAN WILLIAMS +United States Attorney for the +Southern District of New York +By: +Assistant United States Attorneys +Southern District of New York +Christopher Everdell, Esq. / Laura Menninger, Esq. +Jeffrey Pagliuca, Esq. / Bobbi Sternheim, Esq. +Attorneys for Defendant Ghislaine Maxwell +2 diff --git a/vision-fixhub/ds9-parsed-01/0da66ef4d2abb5956ef8cff1e7929f309f47fb3fd76e634be4bf296d7194c205.receipt.json b/vision-fixhub/ds9-parsed-01/0da66ef4d2abb5956ef8cff1e7929f309f47fb3fd76e634be4bf296d7194c205.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..32452965d7b8746837a7d84be89e1217f05b7e9e --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0da66ef4d2abb5956ef8cff1e7929f309f47fb3fd76e634be4bf296d7194c205.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "0da66ef4d2abb5956ef8cff1e7929f309f47fb3fd76e634be4bf296d7194c205", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "5db639372ef816d5cbd5ab7624b7f01b694fbca2b0dd8b932735e8dafbabfbe8", + "output_sha256": "b71f7442f8fa2beefb8894916798b84045a2a717152beca3bc5f318bed96be72", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0dc729ea8a5d8c9533e7d86c41c0e53c979a98465253128f98c5646ab012864b.md b/vision-fixhub/ds9-parsed-01/0dc729ea8a5d8c9533e7d86c41c0e53c979a98465253128f98c5646ab012864b.md new file mode 100644 index 0000000000000000000000000000000000000000..a8b4accf7ce271c07b61b45ae0256af535e3ec4f --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0dc729ea8a5d8c9533e7d86c41c0e53c979a98465253128f98c5646ab012864b.md @@ -0,0 +1,32 @@ +From: +(USANYS)" { +To: +(USANYS) [Contractor]" < +Subject: FW: Please see annexed +Date: Tue, 10 Nov 2020 17:34:19 +0000 +Attachments: 2020-11-10 +_-_Ltr_to_Audrey_Strauss.pdf +Inline-Images: image001 jpg +Pls review and advise me what this is +From: Jennifer Freeman < +Sent: Tuesday, November 10, 2020 12:27 PM +To: +| (USANYS) < +Subject: Please see annexed +Stay well, +Jennifer +Jennifer Freeman +Marsh Law Firm PLLC +Direct Dial +Skype for Business +Recipient 2019 PowerPlay Advocacy Award +Blog | Facebook | Iwitter | Linkedin +CONFIDENTIALITY NOTICE: The information contained in this message and any attachment is confidential +and may be subject to the attorney-client privilege, or otherwise protected from disclosure by applicable law. +Any disclosure, distribution, copying, or use of the information contained in this message or any attachment by +anyone other than the intended recipient, regardless of address or routing, is strictly prohibited. If you are not the +intended recipient, please telephone or email the sender and delete this message and any attachment from your +IF YOU ARE NOT A CLIENT: This material is general information of an educational nature and is not legal +advice. This communication does not establish or constitute the retention of Marsh Law Firm PLLC for the +provision of legal services, unless explicitly so stated herein. Any attached items, including the content of this e- +mail, are offered "as is" with no guarantee as to their accuracy, timeliness, or completeness. diff --git a/vision-fixhub/ds9-parsed-01/0dc729ea8a5d8c9533e7d86c41c0e53c979a98465253128f98c5646ab012864b.receipt.json b/vision-fixhub/ds9-parsed-01/0dc729ea8a5d8c9533e7d86c41c0e53c979a98465253128f98c5646ab012864b.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..b51fd8305b8bbb2deb583d1cbaa744ce79de6d21 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0dc729ea8a5d8c9533e7d86c41c0e53c979a98465253128f98c5646ab012864b.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "0dc729ea8a5d8c9533e7d86c41c0e53c979a98465253128f98c5646ab012864b", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "050ac7ea5bf63efa11954b840e644230875bde66e2816ec395841a3ef4628d2c", + "output_sha256": "af9c15170190fe339b03ded16b591ed57e7a6d21870e913c176846912d62e2d3", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0de589a3ef0c3c02f5f0c68e0bb248be64c0f09c04afbae584f6a500cdf5028b.md b/vision-fixhub/ds9-parsed-01/0de589a3ef0c3c02f5f0c68e0bb248be64c0f09c04afbae584f6a500cdf5028b.md new file mode 100644 index 0000000000000000000000000000000000000000..bf8f2efa7f20e0c88a57f56de6e66af5df7de095 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0de589a3ef0c3c02f5f0c68e0bb248be64c0f09c04afbae584f6a500cdf5028b.md @@ -0,0 +1,13 @@ +From: ' +To: " +D" d +Subject: RE: Screenshot 2019-08-10 at 2.42.56 PM +Date: Sat, 10 Aug 2019 18:45:41 +0000 +Attachments: Jeffrey_Epstein_Statementv2.pdf +Weird. Maybe our phones do that. It looks fine when I PDF it. +-----Original Message-...- +From: +Sent: Saturday, August 10, 2019 2:43 PM +To: / +Subject: Screenshot 2019-08-10 at 2.42.56 PM +This is what I see now diff --git a/vision-fixhub/ds9-parsed-01/0de589a3ef0c3c02f5f0c68e0bb248be64c0f09c04afbae584f6a500cdf5028b.receipt.json b/vision-fixhub/ds9-parsed-01/0de589a3ef0c3c02f5f0c68e0bb248be64c0f09c04afbae584f6a500cdf5028b.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..16c78aaa3cf98b00593cd7ce608b6e121cdea3e1 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0de589a3ef0c3c02f5f0c68e0bb248be64c0f09c04afbae584f6a500cdf5028b.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "0de589a3ef0c3c02f5f0c68e0bb248be64c0f09c04afbae584f6a500cdf5028b", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "e9fcfd8b9ed9f5ef7f2e7f933a5cf084d7683d6d7cf2e6af0839be8cb85487bd", + "output_sha256": "dff5db33ca54718639a6f819b3b13b5b6424f2eb3c6f86d5e277688b91c42f87", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0e16813c25779d7acc657421f7be18dcc60660a9d343ed8841bef7890549ae93.md b/vision-fixhub/ds9-parsed-01/0e16813c25779d7acc657421f7be18dcc60660a9d343ed8841bef7890549ae93.md new file mode 100644 index 0000000000000000000000000000000000000000..c5c496b5ba59f15f78f519b93a61473513b11d3a --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0e16813c25779d7acc657421f7be18dcc60660a9d343ed8841bef7890549ae93.md @@ -0,0 +1,12 @@ +From: +To: +(USANYS)" < +(USAFLS)" < +Subject: Epstein +Date: Wed, 17 Apr 2019 13:45:12 +0000 +Importance: Normal +I'm just following up on our conversation from last week about who might be the appropriate contact for me to speak to +about our grand jury request. You had thought it was probably someone at either MD Fl or ND Ga and were going to get +back to me. +Thanks, +United States Attorney's Office, SDNY diff --git a/vision-fixhub/ds9-parsed-01/0e16813c25779d7acc657421f7be18dcc60660a9d343ed8841bef7890549ae93.receipt.json b/vision-fixhub/ds9-parsed-01/0e16813c25779d7acc657421f7be18dcc60660a9d343ed8841bef7890549ae93.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..0e8691baf83848c725e2860175c7850d4396d133 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0e16813c25779d7acc657421f7be18dcc60660a9d343ed8841bef7890549ae93.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "0e16813c25779d7acc657421f7be18dcc60660a9d343ed8841bef7890549ae93", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "bd909a1e8e1ef6dbb26a69f9ac4a2e5c441409d9cfe7ba3bfaf58ac26b19bdee", + "output_sha256": "0e4de89371cfcaca85252f81712a9b0b1ec7068e6407de1d0ecb42e8cd7e9e06", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0e16a2a80cf3e578ceba2dca65b925a174612296ea69cbbbacabf749d0fd7cb9.md b/vision-fixhub/ds9-parsed-01/0e16a2a80cf3e578ceba2dca65b925a174612296ea69cbbbacabf749d0fd7cb9.md new file mode 100644 index 0000000000000000000000000000000000000000..9be0e628eecd0cc578f1e527d8c6ff47f3d616e5 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0e16a2a80cf3e578ceba2dca65b925a174612296ea69cbbbacabf749d0fd7cb9.md @@ -0,0 +1,30 @@ +To: +From: +Sent: +Wed 7/10/2019 2:16:36 PM +Subject: Wednesday AM Suicide Watch/Psych Observation Update +Wednesday AM Suicide Watch/Psych Observation Update +Inmate Epstein #76318-054 was removed from Psychological Observation and placed in the SHU. +Suicide Watch +None +Psych Observation +Very respectfully, +Ph.D. +Forensic Psychologist +LT, U.S. Public Health Service +U.S. Department of Justice +Federal Bureau of Prisons +Metropolitan Correctional Center +150 Park Row +New York, New York 10007 +Office: + +SDNY_00011818 + +Fax: +E-mail: +"This message is intended for official use and may contain SENSITIVE information. If this message +contains SENSITIVE information, it should be properly delivered, labeled, stored, and disposed of +according to policy." + +SDNY_00011819 \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/0e16a2a80cf3e578ceba2dca65b925a174612296ea69cbbbacabf749d0fd7cb9.receipt.json b/vision-fixhub/ds9-parsed-01/0e16a2a80cf3e578ceba2dca65b925a174612296ea69cbbbacabf749d0fd7cb9.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..394101ea3f3e3bac5ad6ebf9b82ebc55289ebfef --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0e16a2a80cf3e578ceba2dca65b925a174612296ea69cbbbacabf749d0fd7cb9.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "0e16a2a80cf3e578ceba2dca65b925a174612296ea69cbbbacabf749d0fd7cb9", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.stamp-stripping.confidential\"]", + "idempotent": true, + "input_sha256": "467a9bc6e7e7cde43ba57bbcac69be0887d430f4c08c99d086a26301aba649fc", + "output_sha256": "23bb5b2d29ba358d52d678683e2f80155cd7f40d873f038261ee37bd84d9b2c4", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0e1f09bbd658c6f8bf780257b32aa84299949b53406090a1bd17553a1fd9266b.md b/vision-fixhub/ds9-parsed-01/0e1f09bbd658c6f8bf780257b32aa84299949b53406090a1bd17553a1fd9266b.md new file mode 100644 index 0000000000000000000000000000000000000000..14895dab5b56e689ff0aed4151f2202c3ea000ab --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0e1f09bbd658c6f8bf780257b32aa84299949b53406090a1bd17553a1fd9266b.md @@ -0,0 +1,19 @@ +M-19-019432 +VIDENC +OCME +_M - 19-019432 Caso Ni +Dato of Collec +Collected By +Description of +on 15:20. +ah/ard thest codstial +Location of Collection Meteupolitar Curtation +Callat 220 +Cradle/Special Huusing unit/ Tierk/ +Type of Offense +Victim +JePfrey Epstein +Suspect +lecelved From +CHAIN OF CUSTODY +12LB. diff --git a/vision-fixhub/ds9-parsed-01/0e1f09bbd658c6f8bf780257b32aa84299949b53406090a1bd17553a1fd9266b.receipt.json b/vision-fixhub/ds9-parsed-01/0e1f09bbd658c6f8bf780257b32aa84299949b53406090a1bd17553a1fd9266b.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..0a164622aa30e3f467a56c1398604289f5017a41 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0e1f09bbd658c6f8bf780257b32aa84299949b53406090a1bd17553a1fd9266b.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "0e1f09bbd658c6f8bf780257b32aa84299949b53406090a1bd17553a1fd9266b", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "0608d16a3717f750aabb855a1edb9a49433e4e397d58008a55019c1b02fcb665", + "output_sha256": "063ce7b419d6e2a16437383e47bc0b855ec24e1ae1eff9744cafc59828db75e9", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0e3f583a7bcb27da8a831d14df0ae54005c71aa420987bd453001658796abdc7.md b/vision-fixhub/ds9-parsed-01/0e3f583a7bcb27da8a831d14df0ae54005c71aa420987bd453001658796abdc7.md new file mode 100644 index 0000000000000000000000000000000000000000..9b41da17434d7fbc2e7126bff5b001f34e6f6c20 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0e3f583a7bcb27da8a831d14df0ae54005c71aa420987bd453001658796abdc7.md @@ -0,0 +1,30 @@ +From: +To: +Subject: Re: +Date: Mon, 08 Dec 2008 14:57:47 +0000 +Importance: Normal +I would like to be a fly on that wall. Ok on +standards. +Meeting with I +-- Original Message -.... +Fro +To: +Sent: Mon Dec 08 09:53:02 2008 +Subject: RE: +It is this Friday at 3:00 before Judge Hurley. +By the way, I just talked to Spencer Kuvin, who represents +Sounds like +recruited her. He has Epstein set for deposition in +I now to review his case. Will forward a copy of chats if case meets +(the person we didn't find). She was 15 when she went. +case in January and they are videotaping it. +Assistant U.S. Attorney +Phone +Fax +•---Original Message-.. +From: +Sent: Monday, December 08, 2008 9:46 AM +To: +Subject: +What is the date and time of the +sentencing? diff --git a/vision-fixhub/ds9-parsed-01/0e3f583a7bcb27da8a831d14df0ae54005c71aa420987bd453001658796abdc7.receipt.json b/vision-fixhub/ds9-parsed-01/0e3f583a7bcb27da8a831d14df0ae54005c71aa420987bd453001658796abdc7.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..8c9d56dfac0de4e069309daf1af4f026121d0578 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0e3f583a7bcb27da8a831d14df0ae54005c71aa420987bd453001658796abdc7.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "0e3f583a7bcb27da8a831d14df0ae54005c71aa420987bd453001658796abdc7", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "df8cc8bbab6e4495dd29db97ce5cf65aabe7c2915c0a911911fba260566d8cc4", + "output_sha256": "f4ac84cdae231e3538cda0ab162c3cd2dbb2897c404eb18a977722da38d2b72e", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0e4c82729f637add3d22f50007a548a7490d776d4a84de2f2eee890cb0a09e51.md b/vision-fixhub/ds9-parsed-01/0e4c82729f637add3d22f50007a548a7490d776d4a84de2f2eee890cb0a09e51.md new file mode 100644 index 0000000000000000000000000000000000000000..a0856a27a64983c2264c5dc667af3faf97baf39e --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0e4c82729f637add3d22f50007a548a7490d776d4a84de2f2eee890cb0a09e51.md @@ -0,0 +1,21 @@ +10/6/21, 12:40 PM +I/FBI/State Delayed Response +Additional Inquiry Response +ORI: NYFBINYOO +Federal Bureau of Investigation - New York +New York State Division of Criminal Justice Services +Alfred E. Smith Building, 80 South Swan St. +Albany, New York 12210. Tel: 1-800-262-DCJS +Michael C.Green, Executive Deputy Commissioner of the NYS Division of Criminal Justice Services +• III Information +The following information is provided in response to your request for a search of the III based on: +NYFBINYO0 +THIS NCIC INTERSTATE IDENTISICATION INDEX RESPONSE IS THE RESULT DE-YOUR +INQUIRY ON +NAME +FBI NO. +INQUIRY DATE +THE RECORD(5) CAN BE OBTAINED THROUGH THE INTERSTATE IDENTIFICATION +INDEX BY USING THE APPROPRIATE NCIC TRANSACTION. +END +1/1 diff --git a/vision-fixhub/ds9-parsed-01/0e4c82729f637add3d22f50007a548a7490d776d4a84de2f2eee890cb0a09e51.receipt.json b/vision-fixhub/ds9-parsed-01/0e4c82729f637add3d22f50007a548a7490d776d4a84de2f2eee890cb0a09e51.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..b83fa15c3f08996a40dc9c1e0dc20dfc37f62c2b --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0e4c82729f637add3d22f50007a548a7490d776d4a84de2f2eee890cb0a09e51.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "0e4c82729f637add3d22f50007a548a7490d776d4a84de2f2eee890cb0a09e51", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "caf24bd0f3a2fbc76bf61399dfe480444871b45f68e1a788385697c4b00c6986", + "output_sha256": "8d10de65e4fe1548200f2237a127f8defce9501f79e21d0b7f0779d1158ebd63", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0e58245cf282ea123be711c8183c868148da219afe1fab283cf1f7db2ad18c65.md b/vision-fixhub/ds9-parsed-01/0e58245cf282ea123be711c8183c868148da219afe1fab283cf1f7db2ad18c65.md new file mode 100644 index 0000000000000000000000000000000000000000..6d591f8901e40e349fd2845e32b1f2d9eb80c2cc --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0e58245cf282ea123be711c8183c868148da219afe1fab283cf1f7db2ad18c65.md @@ -0,0 +1,16 @@ +From: ' +To: +Ce: " +Subject: RE: update for Epstein victim website +Date: Wed, 21 Aug 2019 14:40:13 +0000 +Could we please add the following to the Victim & Witnesses Services page for Epstein: +August 21, 2019 update: +On August 21, 2019, a hearing was ordered by the Court in the case of United States v. Jeffrey Epstein, 19 Cr. 490 (RMB). +The hearing is in connection with the nolle prosequi order proposed to the Court on August 19, 2019, by the United States +Attorney, following the death of defendant Jeffrey Epstein. At the hearing, counsel for the victims and the victims will be +heard, if they wish to be. The hearing is scheduled for Tuesday, August 27, 2019, at 10:30 a.m. before the Honorable +Richard M. Berman, United States District Judge for the Southern District of New York, Daniel Patrick Moynihan United +States Courthouse, 500 Pearl Street, New York, New York, in Courtroom 17B. +thanks, +Assistant U.S. Attorney +Southern District of New York diff --git a/vision-fixhub/ds9-parsed-01/0e58245cf282ea123be711c8183c868148da219afe1fab283cf1f7db2ad18c65.receipt.json b/vision-fixhub/ds9-parsed-01/0e58245cf282ea123be711c8183c868148da219afe1fab283cf1f7db2ad18c65.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..699f66109e41ba81b2c8b1542363f53d2f693069 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0e58245cf282ea123be711c8183c868148da219afe1fab283cf1f7db2ad18c65.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "0e58245cf282ea123be711c8183c868148da219afe1fab283cf1f7db2ad18c65", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "12dd13f0f3d866b53d0399a013dc0969fff334f33452328362153840be27e9eb", + "output_sha256": "afb416b597550efc1c59d427db7957f41921c60b752c29701440b420774f57fd", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0e5e7c3ffb21f39facf6356e4fffe6defece855bf02c5aeed11de316dceab763.md b/vision-fixhub/ds9-parsed-01/0e5e7c3ffb21f39facf6356e4fffe6defece855bf02c5aeed11de316dceab763.md new file mode 100644 index 0000000000000000000000000000000000000000..5370dd99d25d36eb9238c205e510b861c4bcd934 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0e5e7c3ffb21f39facf6356e4fffe6defece855bf02c5aeed11de316dceab763.md @@ -0,0 +1,58 @@ +From: +To: +(NY) (FBI)" < +Cc: " += +Subject: FW: Information from Norway - Epstein-case (EJ 376/19) +Date: Thu, 09 Jan 2020 21:11:40 +0000 +Attachments: 2019_12_17_at +_ 15h08m22s_JobID_28242.pdf +Inline-Images: image002.png +Consistent with passing along all tips that come to us directly, please see the email below (and attachment here) that I +received earlier today. I have responded to confirm receipt. +thanks, +From +(CRM) < +Sent: Thursday, January 09, 2020 05:51 +To: +Subject: FW: Information from Norway - Epstein-case (EJ 376/19) +I am our DOJ Liaison Prosecutor stationed in The Hague at Eurojust (and an AUSA from Baltimore on detail to OIA). I +received the information below, and attached, from our Norwegian partners here. I'm not sure what value add it has, but +I am following through on my promise to pass it on. +Let me know if you have any questions at all, or if I can be of further assistance here. +Thanks, +U.S. Department of Justice +Office of International Affairs Counsel +U.S. Liaison Prosecutor, Eurojust +The Hague, Netherlands +Mobile: +Email: +From: +Sent: Tuesday, December 17, 2019 4:45 PM + + +To +(CRM) < +Cc: Liaison Prosecutor Norway < +P: "LP United States +Subject: Information from Norway - Epstein-case (EJ 376/19) +Dearl +The Norwegian Director of Public Prosecution has on behalf of the Norwegian Ministry of Foreign Affairs sent me +information that might be of interest in the case against Mr. Epstein, and requested me to forward the information to +USA. +The letter concerns International Peace Institute in New York and donations from Jeffrey Epstein. +I would highly appreciate your kind assistance to forward the information to the competent authorities in USA conducting +the ongoing investigation. The information in the letter is provided by a woman to an employee in the Norwegian Ministry +of Foreign Affairs. Her identity will upon request be given to your HA. +Please let me know if I can be of any further assistance. +Kind regards +Liaison Prosecutor for Norway +EUROJUST +EUROJUST - Criminal justice across borders +The Hague, Netherlands +Mobile: +Eurojust supports national authorities in the efficient coordination of investigations and prosecutions of serious and organised cross-border +crime. +This message is confidential and may be legally privileged or otherwise protected from disclosure. If you are not the intended recipient, please +telephone or e-mail the sender and delete this message and any attachment from your system. You must not copy or disclose the contents of +this message or any attachment to any other person. diff --git a/vision-fixhub/ds9-parsed-01/0e5e7c3ffb21f39facf6356e4fffe6defece855bf02c5aeed11de316dceab763.receipt.json b/vision-fixhub/ds9-parsed-01/0e5e7c3ffb21f39facf6356e4fffe6defece855bf02c5aeed11de316dceab763.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..48298bbfdb9684f2b7696f531994bf7a31424b4f --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0e5e7c3ffb21f39facf6356e4fffe6defece855bf02c5aeed11de316dceab763.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "0e5e7c3ffb21f39facf6356e4fffe6defece855bf02c5aeed11de316dceab763", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "12cf194b6cdd20f3e1cacf8a0998744ebefe547092336dd625b1c5c2214c1e1d", + "output_sha256": "5e15a574605f7c0ae8fdc89486de8d3f280bce26c2896d5ab48797a189101b42", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0ec882e874b82d0189860146eb1d3c6e1cff9d2de56faa1376953a23edc9c279.md b/vision-fixhub/ds9-parsed-01/0ec882e874b82d0189860146eb1d3c6e1cff9d2de56faa1376953a23edc9c279.md new file mode 100644 index 0000000000000000000000000000000000000000..e93e97de0e79a07e2f5b8a9415dd53be9417dfdd --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0ec882e874b82d0189860146eb1d3c6e1cff9d2de56faa1376953a23edc9c279.md @@ -0,0 +1,6 @@ +Subject: FW: US V Maxwell +Date: Wed, 01 Dec 2021 02:15:24 +0000 +Attachments: LBUVMAXF.PDF; XLBUVMAXE.PDF; LBUVMAXF_4PP.PDF; +XLBUVMAXF_4PP.PDF +Transcripts from today attached. +Subject: [EXTERNAL] US V Maxwell diff --git a/vision-fixhub/ds9-parsed-01/0ec882e874b82d0189860146eb1d3c6e1cff9d2de56faa1376953a23edc9c279.receipt.json b/vision-fixhub/ds9-parsed-01/0ec882e874b82d0189860146eb1d3c6e1cff9d2de56faa1376953a23edc9c279.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..9893a7b57936553f795289551175b1cac13c8dd2 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0ec882e874b82d0189860146eb1d3c6e1cff9d2de56faa1376953a23edc9c279.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "0ec882e874b82d0189860146eb1d3c6e1cff9d2de56faa1376953a23edc9c279", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "7f1333d2b7122159c60fae6bf6d70e3344c332d5d0745533b2bc6fb8c7a14c4a", + "output_sha256": "ea21c85f67b18fa02eb8762330a27e59192033776322258d2ac23dc11c00e0e8", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0edcd6689d043529291da997106e8c9c66b233418bffa2e7823cec4e34a3913f.md b/vision-fixhub/ds9-parsed-01/0edcd6689d043529291da997106e8c9c66b233418bffa2e7823cec4e34a3913f.md new file mode 100644 index 0000000000000000000000000000000000000000..29661f28fdc271eba9d316773184f871a0242018 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0edcd6689d043529291da997106e8c9c66b233418bffa2e7823cec4e34a3913f.md @@ -0,0 +1,50 @@ +From: +To: " +Cc: " +(USANYS)" { +Contractor]" < +¡SANYS)" < +Subject: Re: updates +Date: Sat, 06 Jul 2019 22:30:44 +0000 +Importance: Normal +Not currently planning on it but very well could change. +Sent from my iPhone +On Jul 6, 2019, at 6:27 PM, Margolin, James (USANYS) [Contractor] < +Is the indictment going to be unsealed before Monday morning? +> wrote: +Chief Public Information Officer +U.S. Attorney's Office, SDNY +- +On Jul 6, 2019, at 6:05 PM, +(USANYS) 4 +> wrote: +Sent from my iPhone +Begin forwarded message: +From: "Berman, Geoffrey (USANYS)" { +Date: July 6, 2019 at 5:54:01 PM EDT +To: "l +1"'. +Ce: +USANYS)" ≤ +(USANYS)" < +(USANYS)" +JSANYS)" < +(USANYS)" < +I)". +Subject: Re: updates +Epstein is in custody. Search warrants being executed now. Geoff +On Jul 6, 2019, at 12:44 PM, Berman, Geoffrey (USANYS) < +• wrote: + + +tells me that he is confirmed on board. Wheels up. Geoff' +On Jul 6, 2019, at 11:10 AM, +> wrote: +Good morning allasked me to pass along two quick updates. First, Judge Moses signed the search warrant this morning. +Second, our case agent told us that FBI received a flight manifest from CBP last night. The passengers listed are +Epstein and two pilots. Of course, that is subject to change, and I'm told that FBI will try to get confirmation of +the passengers after the flight takes off. +Assistant United States Attorney +Southern District of New York +One Saint Andrew's Plaza +New York, NY 10007 diff --git a/vision-fixhub/ds9-parsed-01/0edcd6689d043529291da997106e8c9c66b233418bffa2e7823cec4e34a3913f.receipt.json b/vision-fixhub/ds9-parsed-01/0edcd6689d043529291da997106e8c9c66b233418bffa2e7823cec4e34a3913f.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..cf218c3dbbff32615c25e5b8df3058f054eb0b42 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0edcd6689d043529291da997106e8c9c66b233418bffa2e7823cec4e34a3913f.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -26, + "dataset": "marble-joined", + "doc_id": "0edcd6689d043529291da997106e8c9c66b233418bffa2e7823cec4e34a3913f", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "3547d55d9f1f29891d13f300652eecefdfd82334b0dbc76502abf20257ea02af", + "output_sha256": "6fc46b67d6cd29c12601ac38809fbb7d55cc6c4fa04467eadc1848f34bf36ddb", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0ee189299058b5b2463e2cda828a8904628f7c882adae11fb98d0f51babab1e6.md b/vision-fixhub/ds9-parsed-01/0ee189299058b5b2463e2cda828a8904628f7c882adae11fb98d0f51babab1e6.md new file mode 100644 index 0000000000000000000000000000000000000000..223f94ab53a1ffd53008ad08fecf7d35c1cc6d4c --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0ee189299058b5b2463e2cda828a8904628f7c882adae11fb98d0f51babab1e6.md @@ -0,0 +1,114 @@ +Fs|ll +FOY & SEPLOWITZ. +attorneys +at law +105 MAIN STREET +HACKENSACK, NJ 07601 +TEL: 201-457-0071 +FAX: 201-457-0072 +WWW.FOYSEPLOWITZ.COM +30 WALL STREET +8TH FLOOR +NEW YORK. NY 10005 +TEL: 212-709-8230 +January 29, 2020 +AUSA +AUSA +AUSA +US Attorney's Office - SDNY +One Saint Andrew's Plaza +New York, NY 10007 +Re: +US v. Tova Noel, et al +19 er 830 +Dear Counsel: +I acknowledge receipt of your January 24, 2020 correspondence regarding the +surveillance system at the MCC. Based on the information provided in your +correspondence and pursuant to Fed. R. Crim. P. 16, please provide the following +information and materials: +1. Documents and information related to the initial installation of the video +surveillance system at the MCC before and after August 10, 2019, including +the entity that was contracted to install it, the date it was installed, and a +description of how it operates at MCC; +2. The specific type and model of the video surveillance system before and after +August 10, 2019; +3. Rules and regulations regarding the maintenance of the video surveillance +systems before and after August 10, 2019; +4. All certifications, maintenance records and work orders, completed and +outstanding, for the video surveillance system that was in place on and before +August 10, 2019; +5. The work order and the contract with the entity that replaced the video +surveillance system on or about August 12, 2019; +6. Please confirm whether there are any concealed cameras in the SHU and +throughout MCC; +7. Whether any MCC corrections officers/employees were advised that the video + + +FOY & SEPLOWITZ Le +ATTORNEYS AT LAW +PAGE 2 +surveillance cameras were not operational or compromised in any way. If so, +who are the corrections officers/employees, when were they advised, and how +were they advised; +8. What is the difference between the new video surveillance system and the +video surveillance system that was previously in use for over 10 years; +9. Under the current video surveillance system, are the cameras installed in the +same locations as the cameras under the old video surveillance system? If not, +please specify which camera locations have changed and provide their prior +and current locations; +10. All reports, communications. and documentation related to the "system +failure" on or about July 29, 2019 and on or about August 8, 2019; +11. The identity and contact information to the technician employed by the MCC, +who was aware of the August 8th system failure on DVR-2 and attempted to fix +the problem; +12. All FBI reports and notes as it relates to its investigation of the destruction of +video surveillance evidence at the MCC; +13. Incident reports, maintenance records, and documentation for Camera-2, +Camera-3, and the Tier Cameras recorded to DVR-2 that were not recording +on August 9, 2019 and August 10, 2019; +14. The indictment alleges that the defendants spent substantial portions of their +shifts sitting at their desk, browsing the internet and moving around the +common area of the SHU. +. Which specific video files contain this alleged +conduct? For each video file, provide the date and time stamp of the alleged +conduct; +15. The file number with the date and time stamp of any video surveillance that +captures Jeffrey Epstein on the MCC video surveillance system; +16. All video surveillance seized by the Government as part of their investigation +into Jeffrey Epstein's alleged July 23, 2019 suicide attempt, including any +footage of Epstein from before or after the alleged suicide attempt; +17. As per paragraph #17 of the indictment, which specific video and time stamp +makes clear that defendant Noel and Officer - 1 did not perform the 4pm count; +18. As per paragraph #19 of the indictment, which specific video and time stamp +shows that defendant Noel did not perform the 10pm count; + + +FOY & SEPLOWITZ uc +ATTORNEYS AT LAW +PAGE 3 +19. As per paragraph #20 of the indictment, which video surveillance file contains +defendant Noel briefly walk up to and then walk back from the tier where +Epstein was housed; +20. As per paragraph #21 of the indictment, which specific video and time stamp +makes clear that defendant Noel did not perform the 12am count; +21. What video surveillance, if any, captures defendant Noel or defendant Thomas +speaking with +on August 10, 2019 after the discovery of Epstein's +body; +22. Advise which video surveillance files capture the defendants on the computer +induring the internet searches referenced in paragraph #24 of the +23. What is the two-hour period that allegedly shows defendant Noel and Thomas +sitting at their desk without moving and appearing to be asleep? Please +provide the video date and time stamp of the alleged conduct; +Given the volume of discovery, we are asking the Government to highlight where +exactly on the video surveillance system the alleged incriminating evidence is +contained. Doing so may assist in expediting the ability of the defense to be ready for +trial. +If you have any questions or concerns about the foregoing, please give me a call. +Thank you for your thoughtful consideration. +Sincerely, +FOY & SEPLOWITZ LLC +Jason E. Fay +JASON E. FOY +Cc: +Tova Noel diff --git a/vision-fixhub/ds9-parsed-01/0ee189299058b5b2463e2cda828a8904628f7c882adae11fb98d0f51babab1e6.receipt.json b/vision-fixhub/ds9-parsed-01/0ee189299058b5b2463e2cda828a8904628f7c882adae11fb98d0f51babab1e6.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..4d239f42fc462ecc5e7af032a622366b193d819d --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0ee189299058b5b2463e2cda828a8904628f7c882adae11fb98d0f51babab1e6.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -36, + "dataset": "marble-joined", + "doc_id": "0ee189299058b5b2463e2cda828a8904628f7c882adae11fb98d0f51babab1e6", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "981d21aa44a8c8f392a03f13c693630fb22c0c0f52124ef709638b6bf68d393e", + "output_sha256": "4f8c19bb2b6854f117fee9dddc1a5ff8922c74084c31f353598742e3c4d50235", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0eee5823f307de8a0398433e91e7fba4641efa6baded96416504fdb871ae5a53.md b/vision-fixhub/ds9-parsed-01/0eee5823f307de8a0398433e91e7fba4641efa6baded96416504fdb871ae5a53.md new file mode 100644 index 0000000000000000000000000000000000000000..d38b67033d182d5e75ff5bc9d83c9ff045806e00 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0eee5823f307de8a0398433e91e7fba4641efa6baded96416504fdb871ae5a53.md @@ -0,0 +1,471 @@ +From: ' +To: Robert Glassman +Ce: "l +D' E +P, Nathan Werksman +>, Kevin Boyle +Subject: RE: SDNY investigation +Date: Fri, 07 Feb 2020 23:07:31 +0000 +Robert, +We should be able to do any time Wednesday through Friday (26th-28th) of that week, with a preference for +Thursday the 27th if that would be convenient for you and +What's good on your end? +thanks, +-----Original Message----- +From: +Sent: Friday, February 07, 2020 15:52 +To: Robert Glassman < +Cc: l +Nathan Werksman +Subject: RE: SDNY investigation +Robert, +Kevin Boyle < +Thanks very much for getting back to us -- I left a voicemail just a few minutes ago, hadn't yet seen your emai +ut we'll figure out the team's schedule and get back to you very shortly. That should work, but let us confirm +thanks, +*--Original Message--. +From: Robert Glassman < +Sent: Friday, February 07, 2020 T3.4. +To: / +Cc: l +Nathan Werksman < +Subject: Re: SDNY investigation +2; Kevin Boyle < +how's the week of 2/24 instead? That's better for her. +Robert S. Glassman +Panish Shea & Boyle +psblaw.comi +> On Feb 6, 2020, at 11:08 AM, +P wrote: +> + + +> Robert, +> +> We're still hoping to try to schedule an interview with +on February 19 (or the following couple days), +per the below -- would that be a possibility? I'll give you a call tomorrow if we haven't connected by then but +wanted to bump this from last week. Thank you! +> +> +> +> ---Original Message--... +> From: +> Sent: Friday, January 31, 2020 14:01 +> To: 'Robert Glassman' < +> Cc: +'Nathan Werksman' +Pi +; 'Kevin Boyle' +> Subject: RE: SDNY investigation +> +> Robert, +> +> Wanted to follow up on the below in case it was still useful to chat -- some combination of the team will be +around next week if you want to have a call. +> +P: +family +February 19? Or if not the 19th, any availability on the 20th or 21st? +> thanks very much, +> +>----Original Message----- +> From: +> Sent: Friday, January 24, 2020 03:45 +> To: Robert Glassman < +> Cc: +Nathan Werksman +> Subject: RE: SDIT mavesuganom +> +> Robert, +> +> +> thanks, +V +; Kevin Boyle = +> Apologies for the belated reply, it's been a crazy week for us, but we'd be happy to talk. We should be generally +available tomorrow (Friday) until about 2 p.m. our time, or also early next week if that's easier. +-----Original Message----- +> From: Robert Glassman < +> Sent: Wednesday, January 22, 2020 15:39 +> To: +> Cc: +TEl +Nathan Werksman +P: +; Kevin Boyle < + + +> Subject: Re: SDNY investigation +> +> Thanks +I ended up seeing these too. +> +> Our judge is John Koeltl and the magistrate is Barbara Moses. +> +> Moskowitz already reached out to us. +> +> Is there a good time to chat? +> +> +> Robert S. Glassman +> Panish Shea & Boyle +> psblaw.com +> +>> On Jan 20, 2020, at 1:11 PM, +P wrote: +>> +>> Robert, +>> +>> Thanks very much for sending the complaint, we appreciate it. We'll try to keep an eye on the docket, but if +you wouldn't mind letting us know when a judge is assigned, that would also be helpful. In terms of media, it +was covered in the Daily News on Friday, here: +>> +>> https://www.nydailynews.com/new-york/ny-epstein-trump-victim-suit-20200118- +mosqsa2h7venpf5uewjrkvigo4-story.html +>> And then picked up by the Post and other outlets on Saturday: +>> +>> https://nypost.com/2020/01/18/new-jeffrey-epstein-accuser-says-he-molested-her-at-13-told-her-to-wearchildrens-underwear/ +>> https://www.the-sun.com/news/274369/jeffrey-epstein-first-vietim-kids-underwear/ +>> https://www.dailymail.co.uk/news/article-7901651/Woman-claiming-Jeffrey-Epsteins-victim-saysintroduced-Trump-age-14.html +>> thanks, +>> +>> +>> +>> ---Original Message--- +>> From: Robert Glassman < +>> Sent: Friday, January 17, 2020 22:18 +>> To: +>> Cc: +P; Nathan Werksman - +>> Subject: RE: SDNY investigation +>> +>> +>> +>> Robert Glassman, Esq. +>> Panish Shea & Boyle LLP +>> +>> +sorry for not giving you a heads up on this. That was not my intent. Just been really busy with a couple +of other big matters going on now. Please see attached. What media is picking it up? I don't see anything. +Los Angeles, CA 90025 + + +>> +>> +>> Web: www.psblaw.com +>> CONFIDENTIALITY NOTICE: +>> This e-mail may contain confidential and privileged material for the sole use of the intended recipients). Any +review, use, distribution or disclosure by others is strictly prohibited. If you are not the intended recipient (or +authorized to receive for the recipient), please contact the sender by reply e-mail or telephone, and delete all +copies of this message. +»> If you are a potential client, the information you disclose to us by email will be kept in strict confidence and +will be protected to the full extent of the law. Please be advised, however, that Panish Shea & Boyle LLP and its +lawyers do not represent you until you have signed a retainer agreement with the firm. Until that time, you are +responsible for any statutes of limitations or other deadlines for your case or potential case. +>> +>>---Original Message-.... +>> From: +>> Sent: Friday, January 17, 2020 4:52 PM +) [mailto: +>> To: Robert Glassman < +> +>> Cc: +P; Nathan Werksman • +>> Subject: RE: SDNY investigation +>> Robert, +>> Based on media reports today it looks like you filed the civil lawsuit? I don't think we realized that was +imminent -- could we ask you to please send us a copy of the filing? I don't yet see it on PACER. +>> thanks, +>>----Original Message-...- +>> From: +>> Sent: Monday, December 20 2019 22:28 +>> To: Robert Glassman < +>> Cc: +P; Nathan Werksman < +>> Subject: RE: SDNY investigation +>> +>> Great, thanks very much. We'll likely start with +and mother and then go from there. As soon as we +have a sense of when it would be productive for us to return for a follow-up meeting with | +vere able to scheite hede deesons. had ail vays, please din lit hesital to ust us pendi if an thing cocks ul +ve re able to schedule these discussions. And as always. t +in the meantime. +>> +----Original Message--- +>> From: Robert Glassman < +>> Sent: Monday, December 30, 2019 22:20 +>> To: +) < +> > Cc: +>; Nathan Werksman + + +»> Subject: Re: SDNY investigation +>> +>> +- yes, all good to contact those folks. Thanks for checking in. +>> Robert S. Glassman +>> Panish Shea & Boyle +>> psblaw.com +>> +>> +>>>> On Dec 30, 2019, at 1:10 PM, +wrote: +>>> +>>> Robert, +>>> +>>> Following up on our most recent meeting with you and +we wanted to confirm that it's alright +expect to contact +For us to begin reachin an. Pais week to the contact she identied for sea in particular ve could indialy +1 Jean-Paul, and +and then Howie Simon, +witness - I know +happened to have any contact with +mentioned that was a possibility so wanted to check. +>>> +>>> Thanks very much, and hope you're having a good holiday season. +>>> +>>> thanks again, +>>> +>>> +>>> +>>>----Original Message----- +>>> From: +>>> Sent: Friday, December 13, 2019 17:06 +>> > To: Robert Glassman < +>>> Ce: +since we last spoke - no problem at all'it not, but I think she +P; Nathan Werksman +>>> Subject: RE: SDNY investigation +>>> +>>> Totally understand, just wanted to ask. We'll see you Monday at 11:00. And thanks for that additional info as +well. +>>> +>>> +-----Original Message-... +>>> From: Robert Glassman < +>>> Sent: Friday, December 13, 2019 16:14 +>>> To: +>>> Ce: +P; Nathan Werksman < +>>> Subject: Re: SDNY investigation +>>> +>>> +stuft etc. +>>> Re the +unfortunately, we can't do earlier than 11. She just needs time to get to my office after taking care of +my understanding is that she is +somewhere. Pretty sure +I will find + + +out and we can chat about it on Monday. +>>> +>>> +>>> Robert S. Glassman +>>> Panish Shea & Boyle +>>> psblaw.com +>>> +>>> +>>>>> On Dec 12, 2019, at 1:30 PM, +wrote: +>>>> +>>>> Robert, +233> +>>>> We wanted to ask if it might be possible to start at 10:00 on Monday rather than 11:00? If not, we totally +understand (I think you may have wanted time to meet with her before starting with us) but wanted to check. +>>>> +>>>> Separately, I knowl +left you a message earlier, but since we're emailing about this we can just ask -- +we were wondering if it might be possible to tell us where +mother currently lives? Not her literal +address, but just city and/or state -- we don't have any intention of contacting her before we speak to you and +your client in person, but just for our longer-term logistical planning, we're wondering where we would be +headed if and when an interview of her were to be appropriate. +>>>> +>>>> thanks, +>>>> +>>>> +>>>>---Original Message-.... +>>>> From: +>>>> Sent: Wednesday, December 11, 2019 13:15 +>>>> To: Robert Glassman • +>>>> Cc: +P; Nathan Werksman < +>>>> Subject: RE: SDNY investigation +>>>> +>>>> Confirmed, thanks -- we'll see you then. And just on substance, I think we mentioned these topics when we +spoke on the phone earlier, but just to refresh, I expect we'll want to talk through some additional specifies on +travel, we'll talk more about other steps we'll be looking to take in our investigation for corroboration and what +the appropriate timing and format of that would be, and to start to talk about specific conduct by Epstein and/or +Maxwell to whatever extent Ms. +is comfortable with that at this stage. And we'll also likely refresh on +(musther topics as inell, bore ond yag Some of the more inmediate areas well expect to cover. Let us know i +t's usetul to chat again before Mondav. +>>>> +>>>> thanks again, +>>>> +>>>> +>>>>> +>>>>---Original Message-... +>>>> From: Robert Glassman 4 +>>>> Sent: Wednesday, December 11, 2019 12:38 +>>>> To: +>>>> Cc: +2: +P; Nathan Werksman < +>>>> Subject: RE: SDNY investigation +>>>> +>>>> Let's do 11 a.m. on Monday. + + +>>>> +>>>> Robert Glassman, Esq. +>>>> Panish Shea & Boyle LLP +>>>> +Los Angeles, CA 90025 +>>>> +>>>> +>>>> +>>>> Web: www.psblaw.com +>>>> +>>>> CONFIDENTIALITY NOTICE: +>>>> This e-mail may contain confidential and privileged material for the sole use of the intended recipient(s). +Any review, use, distribution or disclosure by others is strictly prohibited. If you are not the intended recipient +(or authorized to receive for the recipient), please contact the sender by reply e-mail or telephone, and delete all +copies of this message. +>>>>> +>>>> If you are a potential client, the information you disclose to us by email will be kept in strict confidence +and will be protected to the full extent of the law. Please be advised, however, that Panish Shea & Boyle LLP and +its lawyers do not represent you until you have signed a retainer agreement with the firm. Until that time, you are +responsible for any statutes of limitations or other deadlines for your case or potential case. +>>>> +>>>> +>>>>----Original Message----- +>>>> From: +) [mailto: +>>>> Sent: Wednesday, December 11, 2019 8:26 AM +>>>> To: Robert Glassman < +>>>> Cc: +P; Nathan Werksman < +>>>> Subject: RE: SDNY investigation +>>>> +>>>> Robert, +Tuesday if that ends up being useful as well. +>>>% +>>>> thanks, +>>>> +>>>> +>>>> +>>>>--Original Message-.-- +>>>> From: Robert Glassman < +>>>> Sent: Tuesday, December 10, 2019 20:59 +>>>> To: +>>>> Cc: +P; Nathan Werksman +>>>> Subject: Re: SDNY investigation +>>>> +>>>> Monday morning works at my office. Tuesday may also work too if you need more time. But confirm for +Monday. +>>>% +>>>> +>>>> Robert S. Glassman +>>>> Panish Shea & Boyle + + +>>>> psblaw.com +>>>> +>>>> +>>>>>> On Dec 10, 2019, at 9:35 AM, +wrote: +>>>>> +>>>>> Robert, +>>>>> +>>>>> Following up on our call, in terms of logistics, we can come to California to meet with +anytime this coming Sunday, Monday, or Tuesday, if any of those work? Also, if it's at all posstore to ciner set +aside a significant amount of time on one day or--possibly preferably--a few hours on two consecutive days (and +if so, we could do the second meeting on Wednesday if that's helpful), that will allow us to review relevant case +notes, do quick research, or anything else that would provide for helpful follow-up where we'd just need a little +time between discussion sessions. And as always, happy to discuss via phone if that's helpful. +>>>>> +>>>>> thanks, +>>>>> +>>>>> +>>>>>----Original Message-...- +>>>>> From: +>>>>> Sent: Monday, December 09, 2019 17:46 +>>>>> To: Robert Glassman < +>>>>> Cc: +≥; Nathan Werksman < +>>>>> Subject: RE: SDNY investigation +>>>>> +very much. +>>>>> +>>>>>----Original Message--- +>>>>> From: Robert Glassman < +>>>>> Sent: Monday, December 09, 2019 17:34 +>>>>>To: +>>>>> Cc: +>>>>> Thanks Robert -- we'll call you in 5-10 minutes, just gathering everybody up in the same place. Thanks +; Nathan Werksman < +>>>>> Subject: Re: SDNY investigation +>>>>> +>>>>> Yes. Call me on my cell today. +>>>>> +>>>>> +>>>>> Robert S. Glassman +>>>>> Panish Shea & Boyle +>>>>> psblaw.com +>>>>> +2223> +>>>>>>> On Dec 9, 2019, at 9:21 AM, +wrote: +>>>>>> +>>>>>> Robert, +>>>>>> +>>>>>> Checking in on the below -- is there a good time to chat this week? +>>>>>> +>>>>>> thanks, +>>>>>> + + +>>>>>> +>>>>>>----Original Message-.... +>>>>>> From: +>>>>>> Sent: Wednesday, December 04, 2019 13:06 +>>>>>> To: Robert Glassman < +>>>>>> Cc: +≥; Nathan Werksman < +>>>>>> Subject: RE: SDNY investigation +>>>>>> +>>>>>> Hi Robert, +>>>>>> +>>>>>> Following up on our discussion a couple weeks ago, would it make sense to have a quick call later this +week or early next to check in on current status? We also have one additional data point we'd like to convey as +well, at your convenience. +>>>>>> +>>>>>> thanks, + +>>>>>> + +>>>>>>---Original Message-..- +>>>>>> From: Robert Glassman < +>>>>>> Sent: Friday, November 22, 2019 13:31 +>>>>>> To: +>>>>>> Cc: +>>>>>> Subject: Re: SDNY investigation +>>>>>> +>>>>>> Thanks. Cell is best +>>>>>> +>>>>>> +>>>>>> Robert S. Glassman +>>>>>> Panish Shea & Boyle +>>>>>> psblaw.com + +>>>>>> +>>>>>>>> On Nov 22, 2019, at 10:14 AM, +> wrote: +>>>>>>> +>>>>>> diff --git a/vision-fixhub/ds9-parsed-01/0eee5823f307de8a0398433e91e7fba4641efa6baded96416504fdb871ae5a53.receipt.json b/vision-fixhub/ds9-parsed-01/0eee5823f307de8a0398433e91e7fba4641efa6baded96416504fdb871ae5a53.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..e0ef532df40aedc05bcf07b76593c9f82537b8bc --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0eee5823f307de8a0398433e91e7fba4641efa6baded96416504fdb871ae5a53.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -130, + "dataset": "marble-joined", + "doc_id": "0eee5823f307de8a0398433e91e7fba4641efa6baded96416504fdb871ae5a53", + "engine": "marble-apple-vision", + "event_count": 14, + "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "16365716cef0c111347dd3a378a23e09afc0f4f0cdd7e46b9cfbe8301f5b3c44", + "output_sha256": "c2f6e22a5c81193c1b4451df8b99d202e0958659146d706548eb5100dc4bd383", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0f09e644a6ab6ce1f3a8a48a519c7ebad6a9ae091a7d027eb140df9ee8478dd0.md b/vision-fixhub/ds9-parsed-01/0f09e644a6ab6ce1f3a8a48a519c7ebad6a9ae091a7d027eb140df9ee8478dd0.md new file mode 100644 index 0000000000000000000000000000000000000000..fadc3d71f0ae21602c6569bebc62398de58ad54a --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0f09e644a6ab6ce1f3a8a48a519c7ebad6a9ae091a7d027eb140df9ee8478dd0.md @@ -0,0 +1,61 @@ +RAY, MITEV & ASSOCIATES, LLP +New York Attorneys +MANHATTAN +New York. New York 10010 +Killer Bees +SUFFOLK COUNTY +Miller Place, New York 11764-1430 +SEND ALL MAIL TO: +MILLER PLACE, NEW YORK 11764-1117 +March 9, 2020 +VIA EMAIL: +US Attorney's Office +Central Islip, New York 11722-4454 +Re: +Jeffrey Epstein Investigation +Dear +Please allow me to convey to the US Attorney General and his investigation what +may be useful information regarding the investigation of Jeffrey Epstein's involvement +in the Justice Department for immediate consideration and action, if required. +Attorney General Barr several months ago indicated in public that his office +would be pursuing every person who assisted Jeffrey Epstein or conspired with him as to +his abuse of various young women. There is a woman who appears to have done so +repeatedly, who has remained until now out of the reach of the investigation. Her name +is +Ms. +is a +ational who maintained an apartment : +[YC until the Epstein investigation became public via AG Barr, whereupon she remove +herself to Sweden, out of reach of US authority.. However, she returns quietly to the US +today, to remain here for several days in NYC. +repeatedly procured young Swedish women for Jeffrey Epstein's +pleasures, through an operation called " +aka "BBB." This +shell organization is actually only +Over several years, Ms. +out to attractive, young Swedish females that they could be placed with major American +businesses as interns for at least a year, via BBB. This actually appears to have occurred, + + + +considerable sum of money for this (Parenthetically, Ms. +1 you suedes trail parence city pain paid Mis +a +also introduced a sof +›orn star to Swedish Prince Carl Philip, Duke of Värmland Crown Prince, whom he +marie media or this he keround into is awaits on social medi +postings and photos suddenly disappeared once AG Barr spoke on Epstein. To be sure +was a major player in the Epstein sickening saga. She is well connected in royal +and elite Swedish and NYC circles. +has been a Swedish ambassador +for many years. +Ms. +lands in NY/NJ today, 3/9/20. It may be that the US Attorney's +Office would wish to confront her before she slips back to Sweden. I am not sanguine +that she will easily be cooperative. We are trying to get a location where she will be +staying. +I am personally an acquaintance of Ms. +My life partner is as well. +Vertmulz vours +JR/etl + diff --git a/vision-fixhub/ds9-parsed-01/0f09e644a6ab6ce1f3a8a48a519c7ebad6a9ae091a7d027eb140df9ee8478dd0.receipt.json b/vision-fixhub/ds9-parsed-01/0f09e644a6ab6ce1f3a8a48a519c7ebad6a9ae091a7d027eb140df9ee8478dd0.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..3890c0c11a0f57058a04e24eaa33653ebcb640d6 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0f09e644a6ab6ce1f3a8a48a519c7ebad6a9ae091a7d027eb140df9ee8478dd0.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -46, + "dataset": "marble-joined", + "doc_id": "0f09e644a6ab6ce1f3a8a48a519c7ebad6a9ae091a7d027eb140df9ee8478dd0", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "5f3ba3213c245ef01fd916af12b1d6887fe8142c90aa848e7e6a17cebfa10f6a", + "output_sha256": "2efa210a36cf9f7d396bf4d2b26c5017a3810a5e53601a7153a30799d9b59d3d", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0f6cb6c40f7bb6714c2c0bf78048ade4bf4dd4b3c3a3c7c1677809d7d261e10f.md b/vision-fixhub/ds9-parsed-01/0f6cb6c40f7bb6714c2c0bf78048ade4bf4dd4b3c3a3c7c1677809d7d261e10f.md new file mode 100644 index 0000000000000000000000000000000000000000..cb8e1b3e5c679427fe4864066fece19bd9322f5f --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0f6cb6c40f7bb6714c2c0bf78048ade4bf4dd4b3c3a3c7c1677809d7d261e10f.md @@ -0,0 +1,36 @@ +FD-302 (Rev. 5-x-10) +- 1 of 1- +FEDERAL BUREAU OF INVESTIGATION +OFFICIAL RECORD +Date of entry +08/14/2019 +On August 10, 2019 at approximately 1430 hours, the reporting +investigator did interview BOP nurse/medic +on the 9th floor +outside of the "L" tier. +informed that he has been a nurse at the +BOP for approximately 18 months and that on the date of incident he was +working a 0600 × 1400 shift and assigned "medical duty". According to +he remembers getting the call regarding EPSTEIN at 0633 via an alarm +broadcast over the radios. +informed he arrived at the cell at 0635 +hours and observed BOP guards inside and administering CPR. +checked +EPSTEIN for vitals and detected no pulse and no sign of life. +attempted to shock EPSTEIN through an Automated External Defibrillator (AED) +and "no shock" was advised. EPSTEIN was transported via stretcher to the MCC +2nd floor medical ward where he was intubated, given oxygen, and given 3 +rounds of epinephrine. +again attempt to utilize an AED to shock +EPSTEIN, but "no shock" was advised. +stated that when he entered the +cell he observed EPSTEIN laying parallel to the bunk bed with his head +towards the wall the desk was affixed to and his feet towards opposite wall. +stated the ligature was still around EPSTEIN's neck. +Investigation on 08/10/2019 at New York, New York, United States (In Person) +File # 90A-NY-3151227 +Date dratted +08/13/2019 +by +This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your agency; it and its contents are not +to be distributed outside your agency. diff --git a/vision-fixhub/ds9-parsed-01/0f6cb6c40f7bb6714c2c0bf78048ade4bf4dd4b3c3a3c7c1677809d7d261e10f.receipt.json b/vision-fixhub/ds9-parsed-01/0f6cb6c40f7bb6714c2c0bf78048ade4bf4dd4b3c3a3c7c1677809d7d261e10f.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..e42bca309ac8f6c3daeec103b71d92f2d0bd341c --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0f6cb6c40f7bb6714c2c0bf78048ade4bf4dd4b3c3a3c7c1677809d7d261e10f.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "0f6cb6c40f7bb6714c2c0bf78048ade4bf4dd4b3c3a3c7c1677809d7d261e10f", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "f78b0d261db7e1e0cb3defbb835c4e93eba7675663a2a1213802f613a492aa18", + "output_sha256": "fe9ae2f1bee331a25bdf40dd8783e982b9ff8f38c955b207f36a5e51bac0bf93", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0f73e810a8b061027f2e93ed4058f7e236aebef2ae3769b7c73c7e40db0e4fdd.md b/vision-fixhub/ds9-parsed-01/0f73e810a8b061027f2e93ed4058f7e236aebef2ae3769b7c73c7e40db0e4fdd.md new file mode 100644 index 0000000000000000000000000000000000000000..96dab7387ede7d5430906aefc4f9029517bfee72 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0f73e810a8b061027f2e93ed4058f7e236aebef2ae3769b7c73c7e40db0e4fdd.md @@ -0,0 +1,14 @@ +0,0/21/21 +From: +To: +Subject: +Date: +Attachments: +Phone Record 104 +Saturday, August 10, 2019 3:04:24 PM +8.19.19.can +Communication Technician +US Department of Justice +MCC-New York +150 Park Row +New York, NY 10007-1704 diff --git a/vision-fixhub/ds9-parsed-01/0f73e810a8b061027f2e93ed4058f7e236aebef2ae3769b7c73c7e40db0e4fdd.receipt.json b/vision-fixhub/ds9-parsed-01/0f73e810a8b061027f2e93ed4058f7e236aebef2ae3769b7c73c7e40db0e4fdd.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..ec9b3d76b48b17f149627c7ab419d70965126967 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0f73e810a8b061027f2e93ed4058f7e236aebef2ae3769b7c73c7e40db0e4fdd.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "0f73e810a8b061027f2e93ed4058f7e236aebef2ae3769b7c73c7e40db0e4fdd", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "d9d9d1279cef51207c98f4f4c974f25caa1fd56b71f5b6c73bb0529a2e6d5b68", + "output_sha256": "fa83a3d6a8b659779106861c560b4d21ec3e179a5ca8b5d8310a1fe35c581bb0", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/0fb7c8cb18dd24a28b0374f6301c329f94ab4ccb71de30342af04e31d93d76d2.md b/vision-fixhub/ds9-parsed-01/0fb7c8cb18dd24a28b0374f6301c329f94ab4ccb71de30342af04e31d93d76d2.md new file mode 100644 index 0000000000000000000000000000000000000000..b6dad1d2fbd830b98663281559d11c21d2daffae --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0fb7c8cb18dd24a28b0374f6301c329f94ab4ccb71de30342af04e31d93d76d2.md @@ -0,0 +1,131 @@ +From: ' +To: ' +I)"< +|" ‹ +I)"< +Subject: FW: VNS +Date: Fri, 26 Jul 2019 14:27:10 +0000 +Attachments: US_v._Epstein_-_Updated_Victim_List.xlsx;] +20190726095441587_DRAFT.pdf +Good with you guys? +From: +Sent: Friday, July 26, 2019 10:20 AM +Subject: RE: VNS +Thanks +Attached is the updated version of the notification. Can it go out? +- +And when we get contact info for +, they will receive the same notice. +Thanks again! +From: +To: +Cc: +Sent: Friday, July 26, 2019 10:09 AM +Subject: RE: VNS +Hi +Thanks. The list looks good to me-| think +contact information looks up to date. Regarding +lis editing the text of the letters based on some comments, but the +we've been in touch with +them recently-I'm copying our case agents here so that they can connect with you about getting updated contact +information. +Once the letter is finalized, however, let's send it out quickly today, and we can send letters to +the agents are able to provide you with contact information. +as soon as +Thanks! +From: +Sent: Friday, July 26, 2019 10:00 AM +To: +Cc: +Subject: RE: VNS +Hil +attached is the updated victim list. There are 2 victims that are highlighted that we don't have contact info. +Another victim highlighted in blue looks like has opted out of notifications. + + +Can I send the letters out under these circumstances? +Thanks, +Victim-Witness Assistant +U.S. Attorney's Office - SDNY +From: +To: +Cc: +Subject: RE: VNS +Sent: Friday, July 26, 2019 9:38 AM +Just checking on the status of the letters— given the court conference next week, we wanted to make sure these went +out. FBI tells us that the info should be updated in VNS, if you're able to check. +Thanks! +From: +To: +Cc: +Sent: Tuesday, July 23, 2019 4:45 PM +Subject: RE: VNS +Thanks A +1. Let me contact FBI. I'Il get back to you. +P: +From: +To: B +Cc: +Sent: Tuesday, July 23, 2019 4:42 PM +(USANYS) < +Subject: RE: VNS +Hi +P; +Thanks for making those changes. Looks like you weren't able to get contact information for several of the victims. What +is the easiest way to accomplish that—do you want to touch base with our case agents? Or should we take certain steps? +Thanks. +From: +To: +Cc: +Sent: Tuesday, July 23, 2019 4:23 PM +Subject: RE: VNS + + +Hi n +attached is the updated victim list. Please look it over and let me know if it's accurate. +Also attached is the notification that will be sent to these victims. Can it go out? Thank you. +From: +Sent: Friday, July 19, 2019 5:25 PM +To: El +Cc: +Subject: RE: VNS +Apologies-there is one more victim who should be added: that's +, also represented by +Thanks. +From: +To: +Cc: +Subject: RE: VNS +Sent: Friday, July 19, 2019 5:21 PM +Hi +Thanks! I know everyone has been moving quickly on this, so understandably there are some errors in the system. Is it +possible to make the following corrections to the VNS system? In addition, I've listed below several victims who should be +added— are you able to coordinate with FBI to get their contact information, or should we ask them to add them to the +system? +Edits: +is represented by counsel. Letters should go to: +fis listed with a typo in her name (she's listed as +Victims to add: + + +From: +To: +Cc: +Subject: RE: VNS +Sent: Friday, July 19, 2019 5:05 PM +you're welcome! Please see attached. The list was pulled from VNS and I edited it the best I can. Let me know if +you want it in a Word version and I'Il work on that next week. +Victim-Witness Assistant +U.S. Attorney's Office - SDNY +From: +Sent: Friday, July 19, 2019 4:41 PM +To: +Ccil +Subject: VNS +(USANYS) < +Thanks for putting together the next round of notifications. Would it be possible to email us the list of victims you have +indexed (and their attorneys, for notification purposes)? Because of the volume of victims, it would be great if we could +double check that everything made it into the system, and also check some of the spellings. +Thanks! +Assistant United States Attorney +Southern District of New York diff --git a/vision-fixhub/ds9-parsed-01/0fb7c8cb18dd24a28b0374f6301c329f94ab4ccb71de30342af04e31d93d76d2.receipt.json b/vision-fixhub/ds9-parsed-01/0fb7c8cb18dd24a28b0374f6301c329f94ab4ccb71de30342af04e31d93d76d2.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..0d2113b73d076b4a787403096095809d4338d9f2 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/0fb7c8cb18dd24a28b0374f6301c329f94ab4ccb71de30342af04e31d93d76d2.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -48, + "dataset": "marble-joined", + "doc_id": "0fb7c8cb18dd24a28b0374f6301c329f94ab4ccb71de30342af04e31d93d76d2", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "54086e018a1453458a578087c781337b380b36a359da2938d651b15896e53cae", + "output_sha256": "b90b21cb77675fda883c388418c8a12f5c59ae47f0eb071dca95657259a189f7", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/103006b7f64a1a4352bb8862a0b7995222b883f9687ea4b38ba2164326aac1a8.md b/vision-fixhub/ds9-parsed-01/103006b7f64a1a4352bb8862a0b7995222b883f9687ea4b38ba2164326aac1a8.md new file mode 100644 index 0000000000000000000000000000000000000000..df0d9e81de48a3d5e11cc1af02f570a591822cd2 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/103006b7f64a1a4352bb8862a0b7995222b883f9687ea4b38ba2164326aac1a8.md @@ -0,0 +1,6 @@ +4248н3480 +Sp: 0.10010.100 +F +L +Zoom: 0% +G: 4096L: 2048 diff --git a/vision-fixhub/ds9-parsed-01/103006b7f64a1a4352bb8862a0b7995222b883f9687ea4b38ba2164326aac1a8.receipt.json b/vision-fixhub/ds9-parsed-01/103006b7f64a1a4352bb8862a0b7995222b883f9687ea4b38ba2164326aac1a8.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..d9e2b0ccf1489c361e613b3b55c4aab87f094ca0 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/103006b7f64a1a4352bb8862a0b7995222b883f9687ea4b38ba2164326aac1a8.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "103006b7f64a1a4352bb8862a0b7995222b883f9687ea4b38ba2164326aac1a8", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "113fa4f91f9ef335571fb479b63a0b2ce8430f3cabde03d6174099a330887ea0", + "output_sha256": "15c0aadc2b713c65f2b6dc3b798f075f401645811474fe85ab43d3d4cb29c1c9", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/105ee54872f30126f9794e6ae3323e91bf68db6fe85da1a8981ddde8aa6cf3b1.md b/vision-fixhub/ds9-parsed-01/105ee54872f30126f9794e6ae3323e91bf68db6fe85da1a8981ddde8aa6cf3b1.md new file mode 100644 index 0000000000000000000000000000000000000000..7b3990bf972250d08094ce3e7257bb1f61ce8bb5 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/105ee54872f30126f9794e6ae3323e91bf68db6fe85da1a8981ddde8aa6cf3b1.md @@ -0,0 +1,32 @@ +U.S. Department of Justice +United States Marshals Service +Prisoner Custody Alert Notice +Prisoner Name: +EPSTEIN, JEFFREY EDWARD +Prisoner Number: + +Origina +offense Cod +3699 +Original Offense +Description +Sex Offense +Remark +18 USC 371 SEX TRAFFICKING +CONSPIRACY +718/19 +Alerts: +Code +Description +MTL +Mental Concerns +Remark +Suicidal Tendencies +Prepared By: +Prepared Date: +Received By: +Received Date: +Copy 1 - Jail/Copy 2 - USMS +Page 1 +Form USM-130 +Rev. 12/16 diff --git a/vision-fixhub/ds9-parsed-01/105ee54872f30126f9794e6ae3323e91bf68db6fe85da1a8981ddde8aa6cf3b1.receipt.json b/vision-fixhub/ds9-parsed-01/105ee54872f30126f9794e6ae3323e91bf68db6fe85da1a8981ddde8aa6cf3b1.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..7a6ad8f78aa3338af1152988b2560f123a668740 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/105ee54872f30126f9794e6ae3323e91bf68db6fe85da1a8981ddde8aa6cf3b1.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -20, + "dataset": "marble-joined", + "doc_id": "105ee54872f30126f9794e6ae3323e91bf68db6fe85da1a8981ddde8aa6cf3b1", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "ad8599d1badd2365d4498977c9e3005fa159db948b0ebaa09f3c8fd62484c3ec", + "output_sha256": "065715cc2afa616341b8456d33f242808cd1629c9d57155071304a3a22ba9157", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/10661d28b585ff8ebb1d6ab0356b170aacf275dc28c700770c45474d08a7acf5.md b/vision-fixhub/ds9-parsed-01/10661d28b585ff8ebb1d6ab0356b170aacf275dc28c700770c45474d08a7acf5.md new file mode 100644 index 0000000000000000000000000000000000000000..b5890850ba6cf7970aefda7eb2e220c233cd0185 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/10661d28b585ff8ebb1d6ab0356b170aacf275dc28c700770c45474d08a7acf5.md @@ -0,0 +1,119 @@ +FEDERAL BUREAU OF INVESTIGATION +Title: (U//FOUO) TO DOCUMENT BUSINESS INFORMATION. +Approved By: +Drafted By: +Case ID #: 72-MM-113327 +(U) RODRIGUEZ, ALFREDO - SEE SUB +Date: 12/08/2009 +Details: +Precedence: ROUTINE Date: 12/09/2009 +To: Miami +From: Miami +Contact: +Approved By: +Drafted By: +Case ID #: 72B-MM-11327 (Pending) +188B-MM-105207-C (Pending) +Title: VICTIM NOTIFICATION FORM +Synopsis: To document business information. +Reference: 72B-MM-111327 Serial 1 +Details: +VnsCase#: 72B-MM-111327 +CAgtName: +PContact: Person + + +72-MM-113327, 12/08/2009 +BusName +: +BusEIN : +BusAcet +VicFirN : Bradley +VicMidN +: James +ViclastN: Edwards +SSAN : +ViDate : 20091023 +VicDOD : +VicMinor: N +DOB : +Race +: U +Sex : U +Addr +Addr2 : Ste 2 +City : Ft. Lauderdale +State +FL +Country : US +Zip +33301 +Email : +2 + + +72-MM-113327, 12/08/2009 +Phone : +Fax : +VWrkAddr : +VWrkadd2 : +VwrkCity: +VwrkSt : +VwrkCtry: +Vwrkzip +: +WEmail : +WPhone : +WFax +VicPager: +NOKF1IN : +NOKMidN +NOKLastN: +NOKRe1 : +NOKAddr : +NOKAddrZ : +NOKCity +NOKState: + + +72-MM-113327, 12/08/2009 +NOKCtry +: +NOKZip : +NOKHEmal : +NOKWEma1 : +NOKHPho +NOKWPhO : +NOKHFax : +NOKWFax +NOKPager: +GrdFiIN : +GrdMidN : +GrdLastN: +GrdRel +GrdAddr +GrdAddr2: +GrdCity : +GrdState: +GrdCtry : +GrdZip : +GrdHEmal: +4 + + +72-MM-113327, 12/08/2009 +GrdWEmal: +GrdHPho +GrdWPho +GrdHFax +GrdWFax +GrdPager: +PropRet +Totloss +: 000000000 +Lang. +: +Disable +: +** +5 \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/10661d28b585ff8ebb1d6ab0356b170aacf275dc28c700770c45474d08a7acf5.receipt.json b/vision-fixhub/ds9-parsed-01/10661d28b585ff8ebb1d6ab0356b170aacf275dc28c700770c45474d08a7acf5.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..846d9ad93857d117e2ecd8ea22b3e12497d9c78a --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/10661d28b585ff8ebb1d6ab0356b170aacf275dc28c700770c45474d08a7acf5.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -281, + "dataset": "marble-joined", + "doc_id": "10661d28b585ff8ebb1d6ab0356b170aacf275dc28c700770c45474d08a7acf5", + "engine": "marble-apple-vision", + "event_count": 6, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "cab95067da1e9df95d9a12f30cd92cf77aad0e2ca6e48674faf8165a2328274c", + "output_sha256": "9036839226c6df5e4f39eff9baebe8a2ba4be26c9d5421bcf045b63fdce490cd", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1068cf15ff102cc71434573ab43297d45bb519fa903d49b6f3fc9e41162edac8.md b/vision-fixhub/ds9-parsed-01/1068cf15ff102cc71434573ab43297d45bb519fa903d49b6f3fc9e41162edac8.md new file mode 100644 index 0000000000000000000000000000000000000000..f4b56df08e5fe3a64d52368622d99bb55f2befab --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1068cf15ff102cc71434573ab43297d45bb519fa903d49b6f3fc9e41162edac8.md @@ -0,0 +1,156 @@ +FD-302 (Rev: 5-8-10) +- 1 of 4- +FEDERAL BUREAU OF INVESTIGATION +, OFFICIAL RECORD +Cramerica come hagals sel +Date of entry +08/30/2019 +The following interview was conducted by Assistant United States Attorney +(AUSA) +(SA) +Investigation SA +and Office of the Inspector General Special Agent +also present for the interview was Federal Bureau of +, date of birth | +was interviewed at the +United States Attorney's Office, 1 Saint Andrews Plaza, New York, New York. +After being advised the nature of the interview and the identities of the +interviewing AUSA and SA's, +provided the following information; +approximately +worked for the +stated he had worked for the Bureau of Prisons (BOP) since +. Prior to employment with the BOP +promoted to +stated he joined the BOP as a Corrections Officer and was +•. He spent one year at the +when he first joined the BOP +and had spent the remainder of his tenure at the +• Captain +was his supervisor. +stated a GS9 Lieutenant's responsibilities depend largely on +which area of the prison he or she was assigned to, which rotated on a +quarterly basis. Those duties include operations, activities, solitary +housing, special investigations and administration as well as possible +collateral duties such as emergency protection. +stated he was assigned as the +activities lieutenant at the time +of the interview and worked the regular 2PM to 10PM shift. His regular days +off were +and +• He would on occasion work overtime hours of +switch shifts with other officers. As there were no activity lieutenants +assigned during the overnight hours, he had no relief officer. +Investigation on +08/21/2019 +at New York, New York, United States (In Person) +File # +Date drafted 08/30/2019 +by +This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your agency; it and its contents are not +to be distributed outside your agency. + + +, On +08/21/2019 +_, Page +2 of 4 +stated the responsibilities of an activities lieutenant include +making rounds and placing inmates in special housing. During rounds they +ensure officers are properly carrying out their job responsibilities and +give the inmates the opportunity to address them with any concerns. +stated he often attempted to walk all of the tiers based on time. +stated on weekdays the prison takes a count at 4PM. The +activities and operations lieutenants take a verbal count by speaking with +each unit and match that number with the count slips from internal, if +correct they clear the institutional count. They cannot clear a count until +they receive a good verbal count from every unit. He was not aware of any +instance in which the count was cleared without speaking with every unit. +stated he would attempt to watch the camera monitors as the +corrections officers performed the count to ensure officers were properly +counting, he could not monitor at all times due to the amount of activity in +the control room. +stated he was normally relieved before 10PM, prior to evening +count. He had heard of an instance where the count was not properly +completed, but it had been some time in the past. +stated as a lieutenant he worked to enforce policy through verbal +counseling and by example. Taking the count is one of the most important +duties corrections officers perform as professionals. +stated the special housing unit (SHU) is responsible for doing +rounds every thirty minutes. As a lieutenant he would sign round forms if +they were correct. He had never signed off on forms that were filled out in +advance and would report any instance of that to his supervisors if he was +aware of it. He trained officers to differ their round patterns so inmates +would not be aware of their timing. +stated he had heard stories of officers not completing their +thirty minute rounds in the SHU, other than the JEFFREY EPSTEIN death he had +not heard of any instances for approximately five to ten years. +stated he recalled suicides taking place in MCC in 2003 and +another several years later. + + +, On +08/21/2019 +_, Page +3 of 4 +stated he was on duty the night EPSTEIN was brought to MCC. He +was received at the rear gate and observed him being processed in. At the +time of his arrival EPSTEIN was deemed ok to go to general population, +was unaware of his high profile. +stated he knew EPSTEIN to be in visits often with his legal +counsel, often until 7-8 PM. Other than the intake questions EPSTEIN +answered on his arrival, +I had no other personal interaction with him. +stated he was not involved officially in regard to Epstein's +first alleged suicide attempt. His only other involvement with EPSTEIN was +to bring him food while in the SHU. +that he +stated he was aware EPSTEIN had been moved back to the SHU and +was required to have a +roommate per a mass email he had received. +stated he did not have any conversations with anyone regarding +Epstein's need for a roommate. +stated Lieutenant +was the SHU lieutenant. He believed It. +would have known EPSTEIN required a roommate as it is a regular +responsibility. He believed It. +would have enforced the roommate rule. +stated he had worked the 2PM to 10PM shift on August 9, 2019. He +was relieved around 9:50-9:55 PM that evening. He was not aware that EPSTEIN +did not have a roommate. He did not know +• EPSTEIN's former roommate, +had left MCC leaving EPSTEIN without a roommate. +found out the +following morning. He had been working as operations lieutenant that +evening, I. +had been working as activities lieutenant, she had made +the rounds. +stated if he had known EPSTEIN did not have a roommate he would +have ensured he did, as he knew him to be on the hot list. +stated the following morning, August 10, 2019, at approximately +6:30-6:45 AM he received a call from Lt. +, informing him that +EPSTEIN had attempted suicide and he should go straight to the hospital +instead of reporting to the jail for duty. +stated at the hospital the escorting staff informed him the +EPSTEIN had passed away. He saw his body and told his officers not to speak + + +., On +08/21/2019 +_ Page +4 of 4 +to anyone and direct any questions to the prison public relations officer. +He said the same to the hospital security. +stated Officers +were on scene at +the hospital. +stated he had not taken any photographs of EPSTEIN'S body and +advised his officers to stay with the body until they could be relieved. +stated back at the prison he resumed his activities as lieutenant +and was guided to collect 1og books and escort FBI Agents as part of the +death investigation. +stated he was not aware of the destruction of any records. +stated he knew Officer THOMAS for a few years and knew Officer +NOEL as a newer officer but had no personal relationship with +either. \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/1068cf15ff102cc71434573ab43297d45bb519fa903d49b6f3fc9e41162edac8.receipt.json b/vision-fixhub/ds9-parsed-01/1068cf15ff102cc71434573ab43297d45bb519fa903d49b6f3fc9e41162edac8.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..89df057917a3d5035b915e3ee98815fb185d2640 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1068cf15ff102cc71434573ab43297d45bb519fa903d49b6f3fc9e41162edac8.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -304, + "dataset": "marble-joined", + "doc_id": "1068cf15ff102cc71434573ab43297d45bb519fa903d49b6f3fc9e41162edac8", + "engine": "marble-apple-vision", + "event_count": 5, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "a09e78754509a3d4aca3afcdfb23375161707eac7ab2cd4a6329c652c03111f8", + "output_sha256": "4e950459e91748d16293e95995caebd06b1146728029cfb75732586301675a6d", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/10797496073575762d8f6bb1dfedbbca94e729cc5d5cc742a580cc265a4eda68.md b/vision-fixhub/ds9-parsed-01/10797496073575762d8f6bb1dfedbbca94e729cc5d5cc742a580cc265a4eda68.md new file mode 100644 index 0000000000000000000000000000000000000000..b68df840b6084468c0793738f541699858188a48 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/10797496073575762d8f6bb1dfedbbca94e729cc5d5cc742a580cc265a4eda68.md @@ -0,0 +1,257 @@ +lo: ' +Cc: +(NY) (FBI)" < +Subject: RE: Discovery questions +Date: Fri, 04 Sep 2020 02:49:28 +0000 +(USANYS)" < +Hi +Thanks again so much for getting these materials to us. I've got a few follow up questions on discovery issues below. Feel +free to give me a call to talk through these if that's easier. +• Any update on the status of the scanning and disc reviews? +• Any update from CART on the paperwork? +• I'ma bit confused about some of the files on the thumb drive you provided: +• None of the audio files in the folder entitled "Grand Jury Testimony 7.19.06" are playing for me. Are you +able to play them? +• In the folder entitled "Additional scans PBPD" and the folder entitled "Scans from reiter" - where did these +documents come from? +• In the folder entitled "Items from Reiter - disks" - There are a bunch of subfolders that seem empty or to +have files that have nothing to do with the Epstein investigation, or that won't open. Can you let me +know where these came from and what they are? +Thanks, +Assistant United States Attorney +Southern District of New York +1 St. Andrew's Plaza +New York, NY 10007 +I. (NY) (FBI) < +Sent: Thursday, August 20, 2020 6:17 PM +To: +(USANYS) < +Subject: RE: Discovery questions +Hey all, + + +Just wanted to send a quick email to detail what is being given today. There is a box of media, including VHS, cassette, +and microcassettes, and newspaper articles that were provided by Reiter. +On the thumbdrive is a spreadsheet outlining what is included; items highlighted in blue are included. You will notice a +comment "see disk tracking spreadsheet" in items not highlighted; this spreadsheet will be included in the disk copies we +send over that will detail how many images total and how many removed. +There are loose disks which include 1B evidence scans, 1D1-1D5 evidence items, LSJ 3D imaging, and the FBI file. +Separately, we will keep you updated as we continue to work on the redactions and will let you know as soon as we finish +with the disks. +Let us know you have any questions. +Special Agent +FBI New York Field Office +Child Exploitation/Human Trafficking +C: +Sent: Wednesday, August 19, 2020 8:43 PM +To: +Cc: +• (NY) (FBI) < +(USANYS) < +Subject: [EXTERNAL EMAIL] - Re: Discovery questions +I'll be in the office tomorrow. +Sent from my iPhone +On Aug 19, 2020, at 8:18 PM, +wrote: +Great, thanks very much. I'm not in the office right now, but hopefully someone from the team can grab these. If not, I +can find a paralegal to take them. +(NY) (FBI) 4| +Sent: Wednesday, August 19, 2020 7:24 PM +To: l +Cc:| +(USANYS) < +Subject: RE: Discovery questions +Sure no problem. I can bring those over tomorrow as well. +From: | +Sent: Wednesday, August 19, 2020 7:22 PM +To: 1 +• (NY) (FBI) 4| +V +Pi +Cc:| +| (USANYS) + + +Subject: [EXTERNAL EMAIL] - RE: Discovery questions +Perfect, thanks! Yes, I think we should take the vhs tapes and microcassettes to get them converted, if that's ok. +(NY) (FBI) < +Sent: Wednesday, August 19, 2020 7:20 PM +To: +P; +Cc: +I (USANYS) < +Subject: RE: Discovery questions +That sounds great. Thank you. We are definitely open to them scheduling a time if need be. +I will check in with CART again and get back to you. +As far as the paper evidence and case file, we can drop that off to your office sometime tomorrow evening. Just working +on putting it all on a disk/thumbdrive for you. Also, FYI, included in the boxes from Reiter are vhs tapes and +microcassettes. Would you like us to turn these over to you as well? Let me know your thoughts on this. +Thanks! +To: +Sent: Wednesday, August 19, 2020 7:01 PM +. (NY) (FBI) < +Cc: +(USANYS) +Subject: [EXTERNAL EMAIL] - RE: Discovery questions +Thank you so much for these — very helpful (and sorry I didn't realize the message pad scans also had the same pages +without post-its!) +On these: +• Yes, please send over the copy of the gi transcript disc when you can. +• Found the original scans from the FL file-thank you! +• Yes, please get us the paper evidence from NY, VI, and Reiter as soon as you can. +• We'll take the FBI file whenever you can get it to our office. +• My understanding from past FBI cases is that CART completes some sort of paperwork documenting the dates on +which they conduct data extractions. We need that for all of the extractions in this case, please (It may not be +3025). +• On the evidence from disks, understood. In order to give you more time, we are going to tell the defense +attorneys that the materials are available for them to review in-person if they want to schedule a time to come +down to the FBI office, but that in the meantime we are still working on getting copies of non-nude images to +produce to them. + + +To: +• (NY) (FBI) < +Sent: Wednesday, August 19, 2020 2:21 PM +Cc: +(USANYS) < +Subject: RE: Discovery questions +Hey all, below is a summary of the discovery items you've requested. +Message Pad Scans: The message pads were scanned with the post it notes on them and the very next page is the page +without the post it note, so the pages are back to back. +Papers from Miami case file (grand jury testimony): This is a disk - I can copy it and send it over to you. +Evidence scans: Are you referring to the scans from the FL file? We sent those over with the original message pad scan +last year. If you need that again, let us know and we can get another copy over to you. As far as paper evidence from +the NY and VI searches, and the paper provided by Reiter, we can get that over to you by the end of the week. +FBI file: We have that ready for you. +CART: There are no 302s regarding the extraction of devices. +Evidence from disks: This is a large volume and we've been working on this and removing nude/semi nude images. This +is the only thing that would be difficult to complete by Friday. If we could have a little more time to pull this together, +that would be very helpful. +If it's helpful to talk through some of this via phone, we are happy to do that as well. +Special Agent +FBI New York Field Office +Child Exploitation/Human Trafficking +C: | +To: +Cc: +Sent: Tuesday, August 18, 2020 6:41 PM +(NY) (FBI) < +(USANYS) < +Subject: [EXTERNAL EMAIL] - RE: Discovery questions +Thanks so much, +Really appreciate all the work you and | +to figure out the timeline for the discovery issues. +Sent: Tuesday, August 18, 2020 6:40 PM +To: / +Cc: +• (NY) (FBI) * +| (USANYS) < +Subject: Re: Discovery questions +_are putting in on this. Let's touch base tomorrow + + +Hey guys, +Apologies but today I was out In the field on surveillance and +was also out of the office so we've not +been able to connect on these discovery questions. We will be back in the office tomorrow and will dive into +this as best we can. We have several calls tomorrow, one of which is with Tony Figuero but well do our best to +get on this list. That being said I don't want to make you any promises that everything will be compiled by +tomorrow and that we will have an answer to all of your questions but we can jump on a call tomorrow if you +like to square some of this away. +| I did receive your "pages from Miami_case_docs" PDF. +Detective +NYPD / FBI +Child Exploitation Human Trafficking Task Force +Office: +Cell: +Fax: +Sent: Tuesday, August 18, 2020 6:03 PM +To: | +Cc:| +(NY) (FBI) < +Subject: RE: Discovery questions +Hi +and +Sorry to pester, but would you be able to let us know whether it is realistic to expect that you'll be able to get us these +materials tomorrow or Thursday? +Thanks, +Sent: Tuesday, August 18, 2020 4:41 PM +To: +Cc: +1. (NY) (FBI) < +(USANYS) < +Subject: RE: Discovery questions +Hi +and +P; +P: + + +The drive you provided us has some scans on it (looks like they're scans of the message pads). As I recall, there was a +larger scanning project, during which the FBI scanned all of the paper that was vouchered in evidence. Are you able to +provide us with all of those scans this week? +With respect to the message pads in particular, I think you mentioned that they were scanned both with post-it notes on +them and also without the post-it notes. The version on this drive just looks like it has the post-it note scans. +Thanks, +To: +Cc: +Sent: Tuesday, August 18, 2020 4:45 AM +• (NY) (FBI) < +Subject: RE: Discovery questions +Sorry, got a bounceback for l +will go through. +To: +Cc: +Sent: Tuesday, August 18, 2020 4:40 AM +(NY) (FBI) < +Subject: FW: Discovery questions +(USANYS) < +too. I'm just attaching the one page I referenced in my email below. Hopefully that +(USANYS) < +I got a bounceback from your account for the below email because the attachment was too big. Hopefully it went +through for +I so she can see it. If not, please let me know. +Thanks, +To: +Cc: +Sent: Tuesday, August 18, 2020 4:33 AM +• (NY) (FBI) < +P; +(USANYS) < +Subject: Discovery questions +Hi +and +Thanks so much for your help with the Maxwell discovery so far. I have some follow-up questions about the most recent +batch you provided, and wanted to check in on the longer term tasks we discussed last month. +Below are some questions regarding the discovery dropped off a few days ago with requests for additional items: +• The last page of the attached appears to be a photograph of a disc. The label on the disc seems to suggest it +contains grand jury transcripts. Have you given us those transcripts? +• The message pad scans you provided still have post-it notes on top of several of the message pad pages. I think +mentioned that each pad had been scanned twice, but I'm only seeing one copy of each pad-and those + + +copies all of post-its on them. That's true of nearly every "Notebook" pdf you provided in the "Message pad +scans" folder. Would you please get us a scans of these without post-its on them? +• It looks like we're still missing SW returns for the 20 mag 6719 warrant and for the NH premises warrant. +Would you please get us copies of those returns? +Following up on our conversation last month, I think we're still waiting on the below items from you guys. Would you +please be able to get us these this week? +• Full FBI sentinel file +• CART paperwork regarding the extraction of data from all devices seized during the investigation +• All 302s regarding the extraction of data from any seized devices and the review of images (both digital and +hard copy) seized during the investigation, including from Epstein's properties. +• Scans of the files Reiter provided to the FBI and provide us with all of those scanned materials +• Scans of all hard copy documents, including photos, in the possession of the FBI that have not yet been +scanned, including anything seized during any searches. Please produce to SDNY all of those scans, except any +nude or partially nude images. For nude or partially nude images, please provide us with a log detailing how +many such images were scanned, where they were from, and where they are being stored. +• Copies of the contents of all the discs that were seized and searched pursuant to search warrants to a platform +for review. Then please produce to SDNY a copy all of those materials, except any nude or partially nude +images. For nude or partially nude images, please provide us with a log detailing how many such images were +located, where they were from, and where they are being stored. +Please let me know if you have any questions or if it would be useful to hop on a call. +Thanks very much, +Assistant United States Attorney +Southern District of New York +1 St. Andrew's Plaza +New York, NY 10007 \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/10797496073575762d8f6bb1dfedbbca94e729cc5d5cc742a580cc265a4eda68.receipt.json b/vision-fixhub/ds9-parsed-01/10797496073575762d8f6bb1dfedbbca94e729cc5d5cc742a580cc265a4eda68.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..cdaa5efea3599359ac2c111d6c6846292842a38a --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/10797496073575762d8f6bb1dfedbbca94e729cc5d5cc742a580cc265a4eda68.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -169, + "dataset": "marble-joined", + "doc_id": "10797496073575762d8f6bb1dfedbbca94e729cc5d5cc742a580cc265a4eda68", + "engine": "marble-apple-vision", + "event_count": 8, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "e6cd77b17703bab2e79b656dde503e009acb7006561fe45241c38f587aecf3de", + "output_sha256": "b5b4347dbca1de9f51d344ab04c7b4e59295b65a0ccc42855b7a00d07968981d", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/107aca915179c9902675a89d47204d1b39830f9011f503860f38bca186d087d0.md b/vision-fixhub/ds9-parsed-01/107aca915179c9902675a89d47204d1b39830f9011f503860f38bca186d087d0.md new file mode 100644 index 0000000000000000000000000000000000000000..a04027d4b40adf0cc61ad9a32ba774de6634d2ed --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/107aca915179c9902675a89d47204d1b39830f9011f503860f38bca186d087d0.md @@ -0,0 +1,8 @@ +From: " +To: +Cc: +Subject: 302s +Date: Tue, 10 Dec 2019 18:05:38 +0000 +Attachments: Interview of +Interview of +on 2.19 2019, par diff --git a/vision-fixhub/ds9-parsed-01/107aca915179c9902675a89d47204d1b39830f9011f503860f38bca186d087d0.receipt.json b/vision-fixhub/ds9-parsed-01/107aca915179c9902675a89d47204d1b39830f9011f503860f38bca186d087d0.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..87e559c174734cb48dcaf8d8e255ec24df125ed5 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/107aca915179c9902675a89d47204d1b39830f9011f503860f38bca186d087d0.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "107aca915179c9902675a89d47204d1b39830f9011f503860f38bca186d087d0", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "cb260c044b979cc5213e255f059b5607959a39c06ce0067c3062b1497dc7d3ef", + "output_sha256": "4581fae446dfa5310a3fb431eac5962af797d00b9b06da5c82ebe1ddb7308722", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1092629be1bc2116a80725930603b2a9e7dadead73dc020a9cfc6bb51ae864ad.md b/vision-fixhub/ds9-parsed-01/1092629be1bc2116a80725930603b2a9e7dadead73dc020a9cfc6bb51ae864ad.md new file mode 100644 index 0000000000000000000000000000000000000000..29630b06aca22408bd3af80a2858d5bae2775119 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1092629be1bc2116a80725930603b2a9e7dadead73dc020a9cfc6bb51ae864ad.md @@ -0,0 +1,26 @@ +From: +To: ' +Subject: RE: Maxwell +Date: Tue, 07 Jul 2020 14:52:02 +0000 +Ha thanks man! Much appreciated, and yeah, we shall see ... +From: +Sent: Monday, July 06, 2020 08:38 +To: +Subject: FW: Maxwell +Belated congratulations, and my condolences on the wheel out. Good luck going forward. I hope AJN loves your case as +much as everyone else does. +From: +To: +Sent: Thursday, July 2, 2020 10:43 AM +Subject: Maxwell +PCU - Please join me in congratulating +on the arrest this morning of Ghislaine Maxwell. +spoke a bit about the case on our call on Tuesday and the truly remarkable job the team has done in bringing it. I won't +repeat all of that, buy you should know, as you read press coverage today that already is making it seem like these charges +were inevitable, that they were anything but, and that they are instead the result of an extraordinary amount of work and +perseverance and creativity by +I in building a case based on conduct that I'm pretty sure is older +than all of our paralegals. +will be holding a press conference at 12, and while it is sadly not possible for all of us to be there to join her given +current conditions, I hope we can all take a moment to remotely congratulate the team on a terrific accomplishment in +bringing an extremely important case against a woman very worthy of criminal prosecution. diff --git a/vision-fixhub/ds9-parsed-01/1092629be1bc2116a80725930603b2a9e7dadead73dc020a9cfc6bb51ae864ad.receipt.json b/vision-fixhub/ds9-parsed-01/1092629be1bc2116a80725930603b2a9e7dadead73dc020a9cfc6bb51ae864ad.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..95ce183ba64b7c9a3208ddda2f6a645aea650eae --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1092629be1bc2116a80725930603b2a9e7dadead73dc020a9cfc6bb51ae864ad.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "1092629be1bc2116a80725930603b2a9e7dadead73dc020a9cfc6bb51ae864ad", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "50ec34cc17737bc2b8fdd1bdc4b26c92f52ee248bc5d954c6422df08b2d37fcc", + "output_sha256": "2a734a903fc0cc0c75446eb017661fceb5615fc8864fd0e6847923302b3ed495", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1126b5c5cb9c11d17e0e3ae4f191acd43a924f133ba2529270bd1ea4536bfa83.md b/vision-fixhub/ds9-parsed-01/1126b5c5cb9c11d17e0e3ae4f191acd43a924f133ba2529270bd1ea4536bfa83.md new file mode 100644 index 0000000000000000000000000000000000000000..fc6f58276d4d3b3b7e931a4889b7d7b8193ce0c5 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1126b5c5cb9c11d17e0e3ae4f191acd43a924f133ba2529270bd1ea4536bfa83.md @@ -0,0 +1,104 @@ +From: +Cc: ' +Subject: FW: Maxwell Waxman Malenko Maine +Date: Mon, 06 Jul 2020 14:10:37 +0000 +Attachments: +(4) pdf; Maine_1991_Senator_Cohen_Article.pdf; +Waxman_Bedroom_Eyes_of_Child.pdf; Transcript_PFH_Against_Waxman_Vol_Il.pdf +Mandy and Paul, +Forwarding the below per our practice, +Thanks, +Maurene +From: [ +Sent: Monday, July 6, 2020 10:01 AM +To: +Subject: FW: Maxwell Waxman Malenko Maine +Another one. +From: +To: +Ccl +Sent: Sunday, July 5, 2020 2:03 PM +Subject: Maxwell Waxman Malenko Maine +Victim/Witness Coordinator +SDNY United States Attorney's Office +New York, New York 10007 +Dear Ms. +Regarding the SDNY press conference this past week announcing the arrest of Ghislaine Maxwell, 1 am +contacting you as SDNY encouraged the public to report concerns of potential child sex abuse and grooming-- +no matter how long ago. +• Michael Waxman and Igor Malenko may, or may not, be related to the Epstein case. Allegedly Maine US +Senator George Mitchell is, and he was, according to published flight records, on Epstein's plane. +• Michael Waxman's family is New England's largest corporate real estate family (Finard Properties) with +extensive real estate in New Hampshire, Maine and Massachusetts - including a family "summer estate" + + +Waxman used to take my two-year old daughter to for overnights. Transcript PFH Against Waxman Vol +II.pdf" at: https://documentcloud.adobe.com/link/track?uri=urn:aaid:scds:US:064b57d1-1994-430f-a613- +5a89de37b7e6 +• My 2-year-old daughter, | +l, was confirmed for sex abuse by her father by Maine's sexual assault +forensic examiners. Her father, Igor Malenko, was on an illegal green card at the time of this confirmation. +He was later given US citizenship although he was not legally able to receive US citizenship. Michel +Waxman has been his pro bono lawyer for more than a decade and has declared his "personal" interest in +my "beautiful" daughter. +• Igor Malenko, as a criminal alien on an illegally green card, is the only person to ever sue Portland +Maine's District Attorney, Stephanie Anderson, when she attempted to uphold the law and enforce a +judgement of joint custody that Igor Malenko had been violating for nearly two years—illegally +withholding and hiding my four-year-old daughter from me +https://www.pressherald.com/2012/02/08/man-sues-da-over-her-role-in-custody-dispute_2012-02-08/ +• Michael Waxman, despite 13 counts brought by Maine Overseers of the Bar for extreme stalking and +harassment of me and my young daughter, was protected by a judge who rule the Overseers of the Bar had +a "problem with reality." The same judge who protected Maine's former FBI bureau chief arrested and +convicted for raping a ten-year-old girl. +• Michael Waxman vowed, and this is detailed in under oath testimony in court transcripts and his own +emails, to use his "vast family fortune" to take my daughter from me because he loved and "cared for" my +"beautiful" daughter whom he wanted to "play games with." He posted on his Facebook account that he +wished he could be like "Men in Black" and erase my daughter's memory of her mother. I could go on. +This is the briefest of summaries. +• I am reporting Igor Malenko, a criminal alien, confirmed for sex assault of my two-year-old daughter has +been illegally protected by US government employees in Maine and provided a green card he was not +legally eligible for and citizenship he was not eligible for. I assume Michael Waxman used his "vast family +fortune" to purchase these. +SDNY say to report - no matter how long ago - child sex abuse and/or concerns about potential child sex abuse +and grooming. +My daughter was confirmed for rape by her father when she was two years old. Her father is not legal in +America. He has engaged in green card and citizenship fraud. He has lied, extensively, to the USG. My daughter +has been prevented from contact with me, her mother, for nine years. +No one has helped me or my daughter. The criminals have been totally protected by USG employees. +Brief overview of what is going on in Maine - +1. Maine State Police Chief (for 25 years) Andrew Demers went to jail for raping his own 4-year-old +granddaughter & is now a registered sex offender http://sor.informe.org/cgi-bin/sor/step3.pl? +id-9429&search=2&city=S&limiter= Every one of the cases that he shut down, including Bill Cohen's, +related to child sex abuse should have been re-opened. +2. Maine's most powerful US Senators Bill Cohen (Bill Clinton's Secretary of Defense) and George +Mitchell have been credibly named as child sex abusers/traffickers +https://theglobepost.com/2019/08/29/us-predator-database/ + + +3. Maine's former FBI Bureau Chief John Kenoyer went to jail for raping a 10-year-old girl +https://www.upi.com/Archives/1988/01/06/Ex-FBI-agent-wants-to-serve-jail-time-instyle/8989568443600/ The judge who protected Kenoyer is the same one protecting Michael Waxman +today-Donald Alexander +4. Maine Child Protection Senior Staffer Cynthia Wellman sued the State of Maine claiming Maine +government employees and UMO professors were running a child trafficking ring +https://medium.com/@LoriHandrahan2/government-employees-trafficking-children-in-maine- +303a8224ac37 +5. Maine's current Governor Janet Mills (who grew up with me-her mother was my high school English +teacher) has been instrumental in the crimes against my daughter and I and in protecting +Waxman/Malenko. She has also been credibly named as involved in cocaine trafficking +https://archive.bangordailynews.com/1992/05/05/report-clears-drug-agents-of-wrongdoing/and +https://www.pressherald.com/2014/04/25/maine_attorney_general_enters_fray_ over_divorce_case! +6. Michael Waxman has Epstein level wealth. We have already reported to federal law enforcement +concerning pictures Waxman posted on his public media account with a very young boy that Waxman +wrote had "bedroom eyes" while sitting on Waxman's lap at his family's 5 star, multi-million dollar resort, +Tryall in Jamaica. No one did anything. Please see attachted. Waxman said he would use his vast wealth +to take my daughter. And he did. +7. South Portland police, Steve Webster, who helped protect Waxman/Malenko, has retired and is now +presenting himself as an expert on child sex trafficking +https://www.newscentermaine.com/article/news/crime/surviving-the-life-survivors-of-sex-trafficking-say= +maines-system-is-broken/97-0817cc56-0204-4b90-ad58-9f78698f3ad7 +8. Brief overview of what Maine's Child Protection did to my daughter and I +https://medium.com/@LoriHandrahan2/maines-hhs-child-protection-staff-are-trafficking-children- +55fle492fc4f +Hoping and praying you will investigate and act. +Kindest, +Virus-free. www.avg.com diff --git a/vision-fixhub/ds9-parsed-01/1126b5c5cb9c11d17e0e3ae4f191acd43a924f133ba2529270bd1ea4536bfa83.receipt.json b/vision-fixhub/ds9-parsed-01/1126b5c5cb9c11d17e0e3ae4f191acd43a924f133ba2529270bd1ea4536bfa83.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..1f179a882f0983721df9d9f35cfbece65672576a --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1126b5c5cb9c11d17e0e3ae4f191acd43a924f133ba2529270bd1ea4536bfa83.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -38, + "dataset": "marble-joined", + "doc_id": "1126b5c5cb9c11d17e0e3ae4f191acd43a924f133ba2529270bd1ea4536bfa83", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "aa2c100744f2bbe9a0712800ba4a0decdadf43f708f85348f5063b42545408ed", + "output_sha256": "489b5fc4b9b8d63117c83265bfcb66a01c4824ae791b0e03d554f53b35c2f065", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/11318e0394db2d3aec791d7688f2b5becb0bac5451e6e2e2482aa2961b1409fc.md b/vision-fixhub/ds9-parsed-01/11318e0394db2d3aec791d7688f2b5becb0bac5451e6e2e2482aa2961b1409fc.md new file mode 100644 index 0000000000000000000000000000000000000000..c691ac2d31dc6565ae42ad9b81156875c7970fcc --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/11318e0394db2d3aec791d7688f2b5becb0bac5451e6e2e2482aa2961b1409fc.md @@ -0,0 +1,21 @@ +From: +To: +Cc: +(USANYS)" | +(USANYS) [Contractor]" +(USANYS)" +(USANYS)" +P. +Subject: Telephone calls about Jeffrey Epstein +Date: Wed, 10 Jul 2019 19:02:47 +0000 +Importance: Normal +(USANYS)" < +(USANYS)" +- +We need to get this info to all the SSOs who might answer the phone when +is gone for the day. ++++++++ +If we receive a call that sounds like it is from a victim of Jeffrey Epstein, or someone who says they have information, +please respond this way. +Tell the caller you are going to forward them to a special number for this where they should leave a message with a phone +number where we can call them. Tell them someone will definitely call them. Then forward them to 1-1030. diff --git a/vision-fixhub/ds9-parsed-01/11318e0394db2d3aec791d7688f2b5becb0bac5451e6e2e2482aa2961b1409fc.receipt.json b/vision-fixhub/ds9-parsed-01/11318e0394db2d3aec791d7688f2b5becb0bac5451e6e2e2482aa2961b1409fc.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..3898b02d80f8400b6aaaabaf0a47f070ebb097d8 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/11318e0394db2d3aec791d7688f2b5becb0bac5451e6e2e2482aa2961b1409fc.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "11318e0394db2d3aec791d7688f2b5becb0bac5451e6e2e2482aa2961b1409fc", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "8d6d57dbed53b9624e32ab35949a64632fe5b648ba5f17dcd0c6cefc1d87ebe9", + "output_sha256": "5f8672fd08a222d287a34519aa258012f40e5a032e6fd6c1e2c29bbecae5be81", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1134473507899ae16fb1eb18bc551558407ff6a127962b70c027fc5917a415ec.md b/vision-fixhub/ds9-parsed-01/1134473507899ae16fb1eb18bc551558407ff6a127962b70c027fc5917a415ec.md new file mode 100644 index 0000000000000000000000000000000000000000..395ea511a93502d6b67eded309737e08269d0f8d --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1134473507899ae16fb1eb18bc551558407ff6a127962b70c027fc5917a415ec.md @@ -0,0 +1,1107 @@ +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +-- X +UNITED STATES OF AMERICA, +V. +GHISLAINE MAXWELL, +Defendant. +20 Cr. 330 (AJN) +- X +REPLY MEMORANDUM OF GHISLAINE MAXWELL +IN SUPPORT OF HER MOTION UNDER THE DUE PROCESS CLAUSE TO +SUPPRESS ALL EVIDENCE OBTAINED FROM THE GOVERNMENT'S SUBPOENA +TO BOIES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX +Jeffrey S. Pagliuca +HADDON MORGAN & FOREMAN P.C. +150 East 10th Avenue +Denver, CO 80203 +Christian R. Everdell +COHEN & GRESSER LLP +800 Third Avenue +New York, NY 10022 +Bobbi C. Sternheim +Law Offices of Bobbi C. Sternheim +33 West 19th Street - 4th Floor +New York, NY 10011 +Attorneys for Ghislaine Maxwell + + +Table of Contents +Table of Contents. +Table of Authorities.. +ii +Table of Exhibits +. iv +Introduction and Summary of the Argument +1 +I. +The Facts +..2 +II. +The Government's Response to Maxwell's Motion. +..6 +III. +A. The Government's Defenses Are Not Credible. +B. +Assuming the Government's Defenses Are Worthy of Belief, the Government +Still Misled the Court... +The Materiality of the Government's False Statements. +7 +17 +18 +IV. +The Remedy for the Government's Misconduct.. +20 +A. Pursuant to its Inherent Power, this Court Should Suppress the Evidence Obtained +from Boies Schiller and Dismiss Counts Five and Six, which are the Fruits of that +Evidence. +20 +B. +At a Minimum, this Court Should Order a Hearing at which Maxwell May Inquire +into the Circumstances Surrounding the Government's Misrepresentation to +Judge McMahon +Conclusion +..26 +27 +Certificate of Service +29 + + +Table of Authorities +Cases +Abdell v. City of New York, No. 05 CIV. 8453 KMK JCF, 2006 WL 2664313 +(S.D.N.Y. Sept. 14, 2006).. +Berger v. United States, 295 U.S. 78 (1935) +Brady v. Maryland, 373 U.S. 83 (1963) .... +Brown v. Maxwel, 929 F.3d 4 (2d Cir. 2019) +Chemical Bank v. Affiliated FM Ins. Co., 154 F.R.D. 91 (S.D.N.Y. 1994). +Elkins v. United States, 364 U.S. 206 (1960). +Four Star Fin. Servs., LLC v. Commonwealth Mgmt. Assocs., 166 F. Supp. 2d 805 +(S.D.N.Y. 2001) +Franks v. Delaware, 438 U.S. 154 (1978).... +v. Marwell, 325 F. Supp. 3d 428 (S.D.N.Y. 2018) +Hampton v. United States, 425 U.S. 484 (1976).. +In re WinNet R CJSC, 2017 WL 1373918 (S.D.N.Y. No. 16MC484(DLC), Apr. 13, 2017) +Martindell v. Int'l Tel. & Tel. Corp., 594 F.2d 291 (2d Cir. 1979)... +McNabb v. United States, 318 U.S. 332 (1943) +Morales v. Portuondo, 165 F. Supp. 2d 601 (S.D.N.Y. 2001) ... +Rea v. United States, 350 U.S. 214 (1956) ... +United States v. Bout, 731 F.3d 233 (2d Cir. 2013). +United States v. Cortina, 630 F.2d 1207 (7th Cir. 1980). +United States v. Falso, 544 F.3d 110 (2d Cir. 2008)... +United States v. Lambus, 897 F.3d 368 (2d Cir. 2018).. +United States v. Ming He, 94 F.3d 782 (2d Cir. 1996). +United States v. Paredes-Cordova, No. S1 03 CR. 987DAB, 2009 WL 1585776 +(S.D.N.Y. June 8, 2009) +. 8 +24 +11 +19,20 +14, 18,19 +. 20 +25 +20,22 +8,15 +. 20 +..24 +18,21 +. 20 +24 +20 +..23 +20,22, 25,26 +22 +23,25 +20 +25 +ii + + +United States v. Payner, 447 U.S. 727 (1980). +United States v. Pena, 961 F.2d 333 (2d Cir. 1992) +United States v. Russell, 411 U.S. 423 (1973) +United States v. Schmidt, 105 F.3d 82 (2d Cir. 1997) +Wang v. Reno, 81 F.3d 808 (9th Cir. 1996).. +Young v. United States, 481 U.S. 787 (1987) +Other Authorities +Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and +Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020) +U.S. Dept. of Justice, JUSTICE ManuaL, JM § 9-11.151 +Rules +Fed. R. Civ. P. 5.2 +N.Y. Rules of Professional Conduct, Rule 3.3(d). +N.Y. Rules of Professional Conduct, Rule 3.8, cmt. [6A]. +Constitutional Provisions +U.S. CONST. amend. IV +U.S. CoNST. amend. V +U.S. CoNST. amend. VI +20 +, 25 +21 +. 23 +..2 +24 +11 +15 +19 +24 +16 +22 +. 21 +26 +iii + + +Table of Exhibits +EXHIBIT J: Notes of Feb. 11, 2021 Call with AUSA | +(Sealed) +ExHIBIT K: Handwritten Notes by AUSA L +of Meeting and Contacts with Peter Skinner, +Stan Pottinger, and Brad Edwards +EXHIBIT L: Email String Between Peter Skinner and AUSA | +, co'ing Stan Pottinger, Brad +Edwards, and Sigrid McCawley (Feb. 29, 2016-Mar. 5, 2016) (Sealed) +EXHIBIT M: Emails between AUSA +and Chief of the Criminal Division (Mar. 3, 2016) +(Sealed) +ExIIT N: Emails between AUSA +2018-Dec. 6, 2018) (Sealed) +and AUSA L +and other AUSAs (Nov. 30, +ExHIBIT O: Email from Stan Pottinger to AUSA | +_ cc'ing Brad Edwards and Sigrid +McCawley, re Daniel Siad (Mar. 3, 2016) (Sealed) +EXHIBIT P: +Supplemental Privilege Log, Apr. 4, 2016 +ExHIBIT Q: Defendant's Response in Opposition to Motion to Exceed Presumptive Ten +Deposition Limit, +v. Maxwell, No. 15-cv-07433-RWS (S.D.N.Y.) (June 16, 2016) +iv + + +Ghislaine Maxwell submits this reply in support of her Motion to suppress all evidence +the government obtained from a grand jury subpoena it issued to Boies Schiller Flexner LLP and +to dismiss Counts Five and Six, which are the fruits of that unlawful subpoena. +Introduction and Summary of the Argument +If the government meant to reassure this Court that nothing improper happened, its +Response was anything but reassuring. +The government now confesses that it had significant and substantial contact with +attorneys in 2016 —while the +_defamation suit against Maxwell was +on-going +—as part of an effort to instigate a criminal prosecution of Maxwell for allegedly +trafficking +and others and then lying under oath. Doubling down on an increasingly +farfetched story, however, the government insists that nothing improper occurred when it +misrepresented these contacts to the Chief Judge of the Southern District of New York. +Contrary to the government's portrayal of events, what happened here is that a prosecutor +from the public corruption unit of the United States Attorney's Office, in an ex parte proceeding, +affirmatively misled Chief Judge McMahon to circumvent a Protective Order entered by one of +her colleagues. The prosecutor then exploited the material he obtained to indict Maxwell. +Had the prosecutor not affirmatively misled Judge McMahon, the government would +never have obtained the 90,000 pages of material it now possesses, material that is centralindeed, essential-to its case against Maxwell. It would be the height of irony, not to mention +injustice, to allow the government to convict Maxwell of testifying falsely when the government +could not have indicted Maxwell but for the false statements it made to a federal judge. +"In a situation like this, the judiciary ... may exercise its supervisory power to make it +clear that the misconduct was serious, that the government's unwillingness to own up to it was +more serious still, and that steps must be taken to avoid a recurrence of this chain of events." +1 + + +Wang v. Reno, 81 F.3d 808, 821 (9th Cir. 1996). For the reasons given below, the exercise of this +Court's supervisory authority is called for here. +I. The Facts +Pressed into some minimal measure of candor, the government now admits the following +facts are true: +• On February 29, 2016, AUSA L +the Human Trafficking Coordinator and +Project Safe Childhood Coordinator for the U.S. Attorney's Office for the Southern +District of New York, Ex. J, p 1, met with Peter Skinner of Boies Schiller, Stan +Pottinger, and Brad Edwards, who represented +Ex. K, p 1. +• The meeting concerned +allegations of sexual abuse and trafficking by +Jeffrey Epstein and Maxwell. Ex. J, Pp 1-3. +• At the meeting, +attorneys told AUSA L +the following: +• That Maxwell was Epstein's "head recruiter" of underage victims. Id. at 2. +• That +was underage when she was brought to New York "for training +by Maxwell and Epstein [in] how to service men." Id. at 3. +• That +nad a pending civil lawsuit against Maxwell for defamation +alleging that Maxwell had recruited +to be trafficked and abused by +Epstein. Id. at 4, 7. +That Maxwell was asserting truth as a defense to +defamation claim. +Id. at 4, 7. +• That Maxwell had photos of naked underage girls on her computer. Id. at 6.' +' No such photos were found on or produced from any computers associated with Maxwell. +2 + + +• That Maxwell and Epstein-friend +"took sexually explicit +photos of L +regularly." Id. +• That, as a birthday present, Maxwell gave Epstein a sexually explicit photo of +taken when +was sixteen.? Id. +• That Epstein hung the photo on one of his walls.* Id. +• That +has a note in Maxwell's handwriting with the name of another +victim. Id. at 8.3 +o That +was "live in" sex slave from 2000-2002.° Id. at 3. +• That there were other vietims of Epstein and Maxwell, including | +, id. at 7, who is apparently Accuser-1 in this case, and another woman +whose description matches +id. at 9, who is apparently +Accuser-3. +• That Accuser-1 was "highly credible." Id. at 7. +• That Epstein and Maxwell used "the same MO with" Accuser-3 that they used +with +Id. at 7, 9. +• And that +wants [a] prosecution." Id. at 7. +of +2 Maxwell denies ever taking any photos of +in any of the civil or criminal document productions. +and we have seen no sexually explicit photo +3 Not only did Maxwell not meet +was seventeen years old, Maxwell never +provided any such photo to Epstein, nor, to our knowledge, has any such photo ever been produced, in the +civil or criminal cases. +"Again, we have not seen any such photo produced in any discovery, either in the civil or +criminal cases. +› We are aware of no note in Maxwell's handwriting being produced in the +action, or the +criminal discovery. +was in fact living with her fiancé at the time and held multiple other jobs, as later +confirmed through depositions and documents in the +action. + + +• The attorneys promised to send AUSA +"affidavits and depositions" to +support their request for a prosecution. Id. at 8. +• Calling the meeting "intriguing," AUSA +emailed the Chief of the Criminal +Division three days later and proposed to "talk over" the facts with him. Ex. M, pp 1- +2. He agreed. Id. at 1. +• In the days and weeks after the February 29 meeting, there were several emails +between +attorneys and AUSA +•. Exs. L & N. +• +There was also at least one phone call. Ex. K, at 4. +• +attorneys provided AUSA +with documents as promised. Id. at 2; see +also Ex. L, p 2. +Most importantly, the government now admits that AUSA | +the prosecutor in +charge of the case who appeared before Chief Judge McMahon on April 9, 2019, knew all of this +and still denied that Boies Schiller had any role in fomenting the investigation and claimed that +there had been no contacts between Boies Schiller and his office before November 2018, when +he claimed the investigation first began. +None of these statements by AUSA | +to Judge McMahon were true. +As described above, +attorneys pressed the U.S. Attorney's Office for the +Southern District of New York to investigate and prosecute Epstein and Maxwell. Ex. J. +Then, two months after the meeting with AUSA | +attorneys told Judge +Sweetwho was presiding over +defamation against Maxwell— that there was an +4 + + +"ongoing criminal investigation" into Maxwell, and they withheld from discovery 57 separate +documents, invoking the "law enforcement privilege." Ex. P.? +In late November 2018 and early December 2018—just two months before AUSA +filed the ex parte request before Judge McMahon seeking modification of the civil +Protective Order entered by Judge Sweet-AUSA +shared with AUSA +, as +well as one other member of the trial team and the heads of the Public Corruption Unit, +everything she learned from her contacts with +attorneys. Ex. N. +AUSA +gave AUSA +and his colleagues: (1) nine pages of detailed, +hand-written notes from the February 29 meeting; (2) the emails she received from +attorneys; and (3) all the documents provided to her by +attorneys. Id. Some of what she +gave AUSA +included material Boies Schiller attorneys designated a short time later +as "confidential" under Judge Sweet's Protective Order, including flight records and Palm Beach +Police Department Records. +AUSA +took an active role in gathering these materials from AUSA | +Copying AUSA +AUSA +had emailed AUSA | +on December 5, 2018, +to obtain all the records of the February 29 meeting with +attorneys. Id. at 1. In that +email, AUSA +also asked AUSA L +whether, after February 29, she met "again +with [Peter Skinner] or anyone else." Id. +Two other aspects to the privilege log are notable: (a) In the +meeting who also sent emails to AUSA | +privilege log, though the log purports to reflect all email communications about the "ongoing criminal +investigation" that Boies Schiller had tried to initiate just a couple of weeks earlier. +5 + + +Barely twelve hours later, when AUSA L +hadn't responded, AUSA +took it upon himself to follow up, emailing AUSA | +:: "Just quickly following up on this - +we're trying to get a complete handle on the landscape - thanks!" Id. +AUSA +responded one hour later: "Just went through my files and found a folder +w/ the notes I took and the documents they brought me." Id. She turned everything over to +AUSA +and other prosecutors in the office, including one other prosecutor on this trial +team. Id. AUSA +did not answer AUSA +• original question: "[D]id [she] meet +again with [Peter Skinner] or anyone else" after the February 29, 2016 meeting with +attorneys. Id. But AUSA | +certainly did not deny a second meeting or a subsequent phone +call occurred. Id. +By the end of the day on December 6, 2018, AUSA | +had in his possession +everything +and her attorneys provided to AUSA +, as well as AUSA +extensive hand-written notes. He also had access to AUSA L +questions. By the end of the day, AUSA | +herself for any follow up +had a "complete handle on the landscape," +just as he asked for a couple hours earlier. +When AUSA +appeared before Judge McMahon barely four months later, +however, he told her none of this, unequivocally and falsely disavowing any role by Boies +Schiller in fomenting the investigation and denying any contacts between Boies Schiller and his +office before November 2018. Even though AUSA +had a "complete handle on the +landscape," he painted an entirely different, false picture for Judge McMahon. +II. The Government's Response to Maxwell's Motion. +Confronted with evidence of AUSA +misrepresentations to Judge McMahon, +the government has filed a Response reluctantly admitting that the U.S. Attorney's Office had +sustained contact with Boies Schiller in 2016. Even so, the government tries its best to minimize +6 + + +the significance of those interactions and of AUSA +misrepresentations to an Article +III federal judge. This Court should not permit the government to whitewash its conduct. +The discovery provided to Maxwell in response to her Motion rebuts every defense the +government now offers of its conduct. And if that weren't enough, the government's defense +fails on its own terms, because if this Court were to assume its truth (an assumption the +government has not earned), AUSA +statements to Judge McMahon would still have +been demonstratively and materially false. +A. The Government's Defenses Are Not Credible. +Discovery provided to Maxwell in response to her Motion rebuts every defense the +government now offers of its conduct. +• Defense 1: The February 29, 2016 meeting was only about Epstein. +AUSA +contemporaneous hand-written notes entirely undermine the +government's claim that the February 29, 2016 meeting was about Epstein only and had nothing +to do with Maxwell. Resp. at 89 & n.39. See Ex. J. AUSA +notes refer to Maxwell as +Epstein's "head recruiter" of underage girls; they document allegations that Maxwell "regularly" +took sexually explicit photos of +| and other underage girls, which she kept on her +computer; they allege that Maxwell gave one such photo to Epstein as a birthday present, which +he hung on his wall; they claim that Maxwell, along with Epstein, brought +to New York +to personally "train|] [her] ... [in] how to service men;" and they assert that Maxwell used the +"same MO" to recruit other girls to the sex trafficking scheme. The contents of AUSA +notes belie any notion that +attorneys—who at that very moment were suing Maxwell +7 + + +for defamation for denying she had trafficked and abused +-were focused only on Epstein +and not on Maxwell. +Despite AUSA +contemporaneous notes showing that the meeting very much +concerned Maxwell, the government now claims that "the pitch was to investigate Epstein, not +Maxwell," and that the discussion included only "passing references to Maxwell." Resp. at 89 +n.39. The government bases this argument exclusively on a phone call prosecutors conducted +with AUSA +on February 11, 2021, five years after the February 29 meeting actually took +place. Ex. K. This Court should reject the government's revisionist history. +The best evidence of what happened on February 29, 2016 at least the best evidence the +government has produced so far—is AUSA +contemporaneous notes." Ex. J.; Abdell v. +City of New York, No. 05 CIV. 8453 KMK JCF, 2006 WL 2664313, at *7 (S.D.N. Y. Sept. 14, +2006) (denying motion to quash third-party subpoena because "contemporaneous statements of +witnesses constitute best evidence"). Although the government attached these notes to its +Response, Resp. Ex. 5, the government does not rely on them as part of its argument, choosing +instead to rely on AUSA +2021 recollection of what happened, Resp. at 62-66, 89 & +n.39, 92 (citing Ex. 4). +" It appears the government does not actually want to know anything beyond what AUSA | +remembers (or doesn't remember) of 2016. All the government did in response to Maxwell's Motion was +telephone AUSA L +1. The government apparently: (1) did not search its system for any and all emails +from, to, or about David Boies, Sigrid McCawley, Stan Pottinger, Brad Edwards, or Peter Skinner; and +(2) did not interview anyone other than AUSA | +. such as the other attendees of the meeting +(Pottinger, Edwards, and Skinner), or any of the other AUSAs whom AUSA | +talked to about her +Most conspicuous, of course, is the government's failure to interview AUSA | +an affidavit from him. If this Court does not grant Maxwell's Motion on the papers, only an evidentiary +hearing can address these issues. +8 + + +But in her 2021 interview, AUSA +mostly disclaimed a memory of what happened +in 2016. Ex. K. The phrases "does not recall," "does not remember," or some similar expression +of lack of memory appear at least thirty-two times in the notes of the government's 2021 call +with AUSA +Id. +Many of AUSA | +disclaimers, however, are simply not credible. For example, +AUSA | +claimed not to "have an independent memory of the +v. Maxwell +[defamation] lawsuit being mentioned" during the meeting, id. at 1, even though her notes are +replete with references to the lawsuit, Ex. J. After reviewing her notes, AUSA | +that they refreshed her memory. Ex. K, p 1. +denied +AUSA +similarly denied remembering whether +attorneys ever provided +her with documents, id. at 6, despite the email from Peter Skinner just hours after the February +29 meeting providing AUSA L +with numerous documents, Ex. L, p 1-2, and despite the +fact that AUSA +in 2018 personally delivered those documents to AUSA +AUSA +, and one member of the prosecution team in this case, Ex. N, p 1 (12/6/2018 +Email to AUSA +"Just went through my files and found a folder w/ the notes I took +and the documents they brought me. Want to come by?"). +When AUSA | +i did claim to remember what transpired, her memory was often +inconsistent with the contemporaneous evidence. Take just one example. "To [her] knowledge," +AUSA +said, she did "not receive[] any discovery materials from any civil case." Ex. K, p +6. That is not correct. The government admits that AUSA | +received from +attorneys, and turned over to AUSA +and others in the office, including flight records +and Palm Beach Police Department Records. Resp. at 66 & n.2. Both of these documents were +produced in discovery in the civil case. +9 + + +From any perspective, therefore, AUSA +• 2021 version of events is not worthy of +credence, nor is the government's Response to Maxwell's Motion, which adopts AUSA +version of events (to the extent she claims to remember them) while ignoring the +contemporaneous evidence of what actually happened. The record is surpassingly clear: In +February 2016 and the weeks and months after, +Maxwell and Epstein.° +attorneys "pitched" a prosecution of +• Defense 2: The government was not asked to consider a perjury charge +against Maxwell. +Noting that the February 29, 2016 meeting occurred before Maxwell's two depositions +(April and July 2016), the government insists that +| attorneys did not ask (indeed could +not have asked) the government to consider charging Maxwell with perjury. Resp. at 63. Again, +the documentary evidence belies this claim. +First, AUSA +contemporaneous notes say that "1 +wants prosecution." Ex. +J, p 7. AUSA +M. +knew what +attorneys were after, which is why she emailed the +Chief of the Criminal Division just days after the meeting to discuss the "intriguing" case, Ex. +Second, in the 2021 interview with prosecutors, AUSA | +did not deny that +attorneys asked her to consider a perjury prosecution. Ex. K, p 5. Instead, AUSA +said that she "does not remember one way or the other if any of the attorneys referenced +the possibility of perjury." Id. +° There are other indications as well that +attorneys pressed AUSA D +_ to investigate +Maxwell. For example, while AUSA +notes say +"is wanting to cooperate," Ex. +I, p 2, they say nothing of the sort about Maxwell, instead describing her as Epstein's "head recruiter," id. +See also Ex. O. +10 + + +Third, in the same interview, AUSA +admitted that she contemplated a perjury +prosecution, and she "recalls thinking that a perjury investigation would have ... challenges." +Ex. K, p 5. Left unexplained by the government in its Response to Maxwell's Motion is why +AUSA +would have contemplated a perjury prosecution if +attorneys had not +proposed one. +There are two possible explanations. Either (1) | +attorneys knew in February +2016 that they were going to set a perjury trap for Maxwell, and they discussed that plan with +AUSA +at the time, or (2) there were additional communications between AUSA +and +attorneys (phone calls or even a second meeting) after Maxwell was deposed. +Either way, the government contemplated a perjury charge against Maxwell in 2016, and the +Response's insistence otherwise is not credible. +• Defense 3: Maxwell's argument relies on nothing but the Daily News +article. +The government says that Maxwell's argument "is premised solely on her use of selective +snippets from a lone Daily News Article that is premised, in meaningful part, on anonymous +sources and hearsay." Resp. at 89. This claim is stunningly disingenuous, and it fails on its own +terms. +When Maxwell filed her Motion, she did not have access to the government's emails and +AUSA +contemporaneous notes, despite their obvious exculpatory value. See Brady v. +Maryland, 373 U.S. 83, 87-88 (1963). The government did not disclose these materials until +Maxwell challenged the government's candor and conduct before Judge McMahon. One +wonders whether the government would have provided them to Maxwell had she not filed this +Motion. +11 + + +The government's claim also fails on its own terms. The article is not meaningfully +anonymous. " Among others, the article quotes David Boies, who said: +We were saying to anyone who would listen: We've got clients who were abused. +Some of them were underage. We have the evidence. There's a whole record that's +been developed. We can establish beyond any reasonable doubt there was a massive +sex trafficking ring going on. +The article also quotes Brad Edwards, who describes in his self-published memoir the various +contacts +attorneys had with the U.S. Attorney's Office in 2016. +Finally, as detailed above, AUSA +article's substance." Ex. J. +contemporaneous notes confirm most of the +• Defense 4: There was only one meeting. +The government denies there was a second meeting between the U.S. Attorney's Office +and +| attorneys. Resp. at 92. This denial, though, is based solely on AUSA | +foggy memory and in the absence of any credible investigation. Contrary to the government's +claim, the evidence strongly suggests there was a second meeting or some further contact +between them. At the very least, this Court should hold an evidentiary hearing to find the truth. +1° Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and +Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020), +https://www.nydailynews.com/new-york/ny-jeffrey-epstein-maxwell-case-20201013- +jmzhl7zdrzdgrbbs7ycobfnszu-story.html. +To the extent the article relies on unnamed sources, there is no indication those sources are +anonymous in the sense that the author is unaware of their identity. In the 2021 call, the government +apparently did not ask AUSA +I whether she was one of the unnamed sources. See Ex. K. +" The government also says the article is hearsay. Resp. at 89. This is an odd claim for the +government to make while asking this Court to credit double hearsay: someone's notes of statements +made by AUSA L +during a phone call. The government's hearsay argument does nothing but +support Maxwell's request for an evidentiary hearing. +12 + + +Two of the sources in the Daily News article insisted there was a second meeting in the +summer of 2016.!2 +In addition, as described above, AUSA L +in 2021 said she recalls contemplating a +perjury prosecution of Maxwell. Ex. K, p 5. But if there were only the one meeting, it makes +little sense for AUSA +to have been thinking about a potential perjury prosecution in +February of 2016, before Maxwell had even been deposed (unless the plan was to set a perjury +trap for Maxwell). It is more likely that AUSA | +contemplated a perjury prosecution after +a second meeting with +attorneys, which took place after at least one of Maxwell's +depositions. As reported in the Daily News, "David [Boies] was particularly frustrated by the +failure to pursue a perjury charge."13 "We have her dead to rights," he said. '4 +This Court cannot accept without further inquiry the government's assertion that there +wasn't a second meeting or any further contact between the U.S. Attorney's Office and +attorneys. At a minimum, an evidentiary hearing is required. +• Defense 5: AUSA +had no idea what was in Boies Schiller's files. +The government stands by the claim that AUSA +had "either little or no +additional information than [Judge McMahon did] in terms of what materials there are [and] who +was deposed" and, for all the government knew, the deposition transcripts would show "page +after page of people taking the Fifth." See Resp. at 70. The government's Response is not +credible. +12 Supra Note 10. +' Supra Note 10. +1' Supra Note 10. +13 + + +For one thing, the government admits that +attorneys turned over several +documents in 2016, which were in the government's possession when AUSA +claimed +to Judge McMahon that he did not know what was in Boies Schiller's file. Moreover, by the time +AUSA +told Judge McMahon that, for all he knew, the deposition transcripts would +show "page after page of people taking the Fifth," it was already a matter of public record that +Maxwell had been deposed and that she had not invoked the Fifth Amendment. Ex. Q, p 1. +The government's argument also defies logic. The government was asking Judge +McMahon to authorize a subpoena of Boies Schiller's entire file. At a minimum, the government +had to have asked Boies Schiller about the size of the file and issues related to privilege to +determine if Boies Schiller would contest the subpoena or notify either the civil court or +Maxwell when the subpoena was issued and responsive documents produced. In fact, the +government issued two subpoenas to Boies Schiller: the first for material covered by the +Protective Order, and the second for material outside the Protective Order's reach. Clearly, the +government knew more about Boies Schiller's file than AUSA +let on. +• Defense 6: The "subject of your investigation" to whom Judge McMahon +referred was Jeffrey Epstein. +According to the government, when Judge McMahon asked AUSA +"about +contacts between the United States Attorney's Office and the Boies Schiller firm prior to the +issuance of the subpoena on the subject of your investigation," Mot. Ex. E, p 2, Judge McMahon +was referring only to Epstein. Resp. at 71. This is not a plausible reading of the transcript. +After his first appearance before her, Judge McMahon haled AUSA +back to +court for one reason. "I'll be very up-front with you," she said. Mot. Ex. E, p 2. +14 + + +I want to make sure I'm not in a Chemical Bank["] kind of situation, so I would +like to know about contacts between the United States Attorney's Office and the +Boies Schiller firm prior to the issuance of the subpoena on the subject of your +investigation. +Id. (emphasis added). +"Tellingly,"' Judge McMahon did not ask AUSA +about the "target" of his +investigation; she asked about its "subject." The "subject of [the] investigation" is much broader +than its "target." +"A "target' is a person as to whom the prosecutor or the grand jury has substantial +evidence linking him or her to the commission of a crime and who, in the judgment of the +prosecutor, is a putative defendant."|? "A 'subject' of an investigation is a person whose conduct +is within the scope of the grand jury's investigation."'" The scope of an investigation, in turn, +includes not only potential defendants and potential victims, but also the conduct at issue and the +locations involved. +Were there any doubt about Judge McMahon's meaning, she put that doubt to rest in her +written order authorizing the subpoena. Mot. Ex. G, p 21. The "subject of the investigation," she +explained, was "the matters that were the subject of the +[defamation] Action." Id. And +having asked AUSA +about his office's contacts with Boies Schiller about "the +15 Chemical Bank v. Affiliated FM Ins. Co., 154 F.R.D. 91 (S.D.N.Y. 1994). +16 "Tellingly," claims the government in the Response, "Maxwell omits [the phrase "subject of +your investigation'] of this question from her motion." Resp. at 70 n.34. Not true. On page 13 of +Maxwell's Motion, in arguing that AUSA | +mislead Judge McMahon, Maxwell fully and +completely quotes Judge McMahon's question, just as she does above. Mot. at 13 (quoting Ex. E, p 2). +1 United States Department of Justice, JUSTICE MANUAL, JM § 9-11.151, Grand Jury, Advice of +"Rights" of Grand Jury Witnesses (updated Jan. 2020), available at: https://www.justice.gov/jm/jm-9- +11000-grand-jury#9-11.151 (last accessed Mar. 11, 2021). +18 Id. +15 + + +matters that were the subject of the +[defamation] Action," and having been misled by +AUSA +response, Judge McMahon erroneously (though blamelessly) concluded that +[nJothing in this record suggests to me that +or Boies Schiller had anything +to do with the Government's decision to convene a grand jury to look into the +Action... There is no evidence of +"collusion," to invoke a term of the moment, and it is quite clear that Boies Schiller +did not foment the Government's investigation. +Id. (emphasis added). +For her part, AUSA +AUSA +shared the very concern Judge McMahon later expressed to +that Boies Schiller was trying to instigate an investigation of Maxwell to +leverage its position in the " +Action." Mot. Ex. K, p 3. In the 2021 call, AUSA | +recalled that the +pending CVRA civil case and other civil litigation ... gave [her] some pause +because she had other occasions where civil litigants have decided to report +something to the USAO because they think it will help them in their civil case. +AUSA +even mentioned this concern to the Chief of the Criminal Division. Id. If AUSA +and the Chief of the Criminal Division recognized what was going on, AUSA +can hardly feign ignorance.'° +If the government means to suggest that when Judge McMahon asked about any prior +contacts concerning "the subject of your investigation," she was somehow confining her inquiry +to the time period surrounding November 2018, see Resp. at 90-91, that too is an implausible +reading of the transcript. If Judge McMahon meant "subject" to be a term of art ("subject" of the +investigation as opposed to a "target" of the investigation), then the government should have +19 Of course, if AUSA +| honestly did not understand Chief Judge McMahon's question, +ince she issued her opinion there could no longer be any doubt. And at that point, AUSA | +vould have been duty-bound to correct the misimpression he had created. N.Y. Rules of Professiona +Conduct, Rule. 3.8, cmt. [6A] (*Like other lawyers, prosecutors are subject to Rule 3.3, which requires a +lawyer to take reasonable remedial measures to correct material evidence that the lawyer has offered +when the lawyer comes to know of its falsity."). +16 + + +disclosed the Boies Schiller contacts for the reasons given above. And if Judge McMahon meant +"subject" to have its everyday meaning, then she was asking about something even broader: +Whether the U.S. Attorney's Office had contacts with Boies Schiller about the "subject"- i.e., +the "conduct" being investigated. +Nothing about the transcript supports the government's overly narrow, hindsight-based +interpretation of Judge MeMahon's question. +*** +For these reasons, this Court should reject the government's attempt to rewrite the history +of its investigation and its affirmative misrepresentations to Judge McMahon. +B. Assuming the Government's Defenses Are Worthy of Belief, the +Government Still Misled the Court. +Even if the government's account were worthy of belief (which it is not), that doesn't get +the government off the hook +The government would like this Court to believe that: (1) the February 29 meeting +concerned a prosecution of Epstein only and not Maxwell; and (2) when Judge McMahon asked +AUSA +about his office's prior contacts with Boies Schiller concerning "the subject of +its investigation," Judge McMahon was referring to Epstein only and not Maxwell. +Even if those two assertions were true, however, then AUSA +still misled +Judge McMahon and misrepresented the origins of the investigation. Under the government's +version of events, "the pitch was to investigate Epstein, not Maxwell." Resp. at 89 n.39. If that's +true, AUSA +unquestionably should have told Judge MeMahon about the February +2016 meeting when she asked him "about contacts between the United States Attorney's Office +and the Boies Schiller firm prior to the issuance of the subpoena on the subject of your +investigation"- +-i.e., Epstein. AUSA +did not tell Chief Judge MeMahon about the +17 + + +contacts with Boies Schiller on the topic of Epstein any more than he shared the contacts on the +topic of Maxwell-he simply denied any contacts had occurred, something that is demonstrably +false. +Whether Boies Schiller "pitched" a prosecution of Epstein only or of Epstein and +Maxwell as a duo, AUSA +misled Judge McMahon by denying there was any "pitch" +whatsoever. +III. The Materiality of the Government's False Statements. +The government halfheartedly suggests that "there is no reason to believe that a +description of the February 2016 meeting would have been material to Chief Judge McMahon's +analysis of whether she was facing a 'Chemical Bank kind of situation."" Resp. at 91. Hardly. In +fact, there is every reason to believe Judge McMahon would have refused to authorize the +subpoena if AUSA +had not so misled her. +How do we know? Because Judge McMahon said so at least twice. +Judge McMahon first made this clear by haling AUSA +back in for one and +only one reason: To ask him about the contacts between Boies Schiller and his office before +November 2018. So crucial was this question to Judge McMahon's decision that the transcript of +the AUSA +second appearance before her is just three pages long. Mot. Ex. E. +Judge McMahon made her thinking even clearer in her written order authorizing the +subpoena. Mot. Ex. G. On page 12 of her opinion, when attempting to reconcile Chemical Bank +with Martindell, " Judge McMahon found that "nothing in the record suggests that the +Government's investigation in this case was occasioned by Boies Schiller—a point to which I +will return later in this opinion." Mot. Ex. G, p 12. +20 Martindell v. Int'l Tel. & Tel. Corp., 594 F.2d 291 (2d Cir. 1979). +18 + + +Judge McMahon "returned" to that point when discussing whether Maxwell could have +reasonably relied on the Protective Order: +[T]he only thing on which Maxwell or anyone else might reasonably have relied is +that +or her lawyers would not do what the defendant in Chemical Bank +did that is, forward discovery materials in their possession to prosecutors for the +purpose of fomenting an investigation. But I am not faced with that situation. +Nothing in this record suggests to me that +or Boies Schiller had anything to +o with the Government's decision to convene a grand jury to look into the matter +that were the subject of the +Action. On the contrary—the Government ha +advised the Court that it contacted Boies Schiller as part of its search for parties +who might have been victims in its investigation; and that Boies Schiller told the +Government that it could not consensually produce at least some documents in its +files because of the existence of the Protective Order. There is no evidence of +"collusion," to invoke a term of the moment, and it is quite clear that Boies Schiller +did not foment the Government's investigation. Moreover, the Assistant United +States Attorney has represented to this Court that he has no idea what is in Boies +Schiller's files, and that for all he knows every witness who was deposed stood on +his/her Fifth Amendment rights and refused to answer questions. +Id. at 21. +Contrary to Judge McMahon's understanding, Boies Schiller contacted the government +(not the other way around); there was ample evidence of "collusion"; it was "quite clear that +Boies Schiller did ... foment the Government's investigation"; and AUSA +knew +much more about what was in Boies Schiller's files than he let on. +The Chemical Bank situation Judge McMahon was worried about — when civil litigant +attempts to foment a criminal investigation of her opponent—is exactly what occurred. +Judge McMahon cannot be faulted for not knowing all the facts. AUSA +the other hand, had a "complete handle on the landscape," and he withheld the truth from Judge +McMahon. Had AUSA +not misled her, it is clear Judge McMahon would not have +authorized the subpoena.?1 +' It's notable that even without the benefit of truth from AUSA | +I, Judge McMahon +wrongly concluded that Maxwell could not have reasonably relied on the Protective Order. In fact, the +19 + + +IV. The Remedy for the Government's Misconduct. +A. Pursuant to its Inherent Power, this Court Should Suppress the Evidence +Obtained from Boies Schiller and Dismiss Counts Five and Six, which are +the Fruits of that Evidence. +This Court has inherent authority to regulate the administration of criminal justice among +the parties. McNabb v. United States, 318 U.S. 332, 340 (1943). "Judges have an obligation to +exercise supervision over the administration of criminal justice in federal courts, a responsibility +that implies the duty of establishing and maintaining civilized standards of procedure and +evidence."" United States v. Ming He, 94 F.3d 782, 789 (2d Cir. 1996) (quoting McNabb, 318 +U.S. at 340). As the Supreme Court held in United States v. Payner, "Federal courts may use +their supervisory power in some circumstances to exclude evidence taken from the defendant by +'willful disobedience of law."' 447 U.S. 727, 735 (1980) (quoting MeNabb, 318 U.S. at 345) +(citing Elkins v. United States, 364 U.S. 206, 223 (1960); Rea v. United States, 350 U.S. 214, +216-17 (1956); Hampton v. United States, 425 U.S. 484, 495 (1976) (Powell, J., concurring in +judgment)). A court should invoke its supervisory power of suppression when "there has been a +fraud upon the court in addition to a violation of the defendant's rights." United States v. +Cortina, 630 F.2d 1207, 1216 (7th Cir. 1980). +In United States v. Cortina, a magistrate issued a search warrant based upon an affidavit +subscribed by FBI Agent Linda Stewart, which itself was based on the reports and investigation +of FBI Agent William Brown. Id. at 1208. Unbeknownst to Agent Stewart, Agent Brown's +Second Circuit in Brown v. Maxwell held a few months after Judge McMahon's ruling that Maxwell had +reasonably relied on the Protective Order's guarantee of confidentiality in substantial part, and it therefore +redacted sua sponte from the summary judgment material those "deposition responses concerning +intimate matters where the questions were likely only permitted—and the responses only compelledbecause of a strong expectation of continued confidentiality. 929 F.3d 4, 48, n.22 (2d Cir. 2019) (citing +Fed. R. Civ. P. 5.2). So, too, has Judge Preska redacted substantial material from the documents she has +released on remand from the Second Circuit, again reflecting that Maxwell reasonably relied on the +Protective Order. +20 + + +reports were replete with misrepresentations and outright lies about the conversations he had +with, and information provided by, a confidential informant. Id. at 1212-13. The Court of +Appeals affirmed the district court's order suppressing the evidence obtained from the search +conducted under the warrant. Id. at 1213. "This search," said the Court, "never should have taken +place." Id +The Court offered two bases for its decision. It first invoked the Franks analysis to affirm +the district court's conclusion that Agent Brown intentionally or recklessly misrepresented +material information in Agent Stewart's affidavit. Id. But the Court went further, concluding that +suppression was independently required as a matter of inherent authority. Id. at 1214-17. +Because Agent Brown lied in the affidavit (in addition to lying at the Franks hearing), "[t]he call +for the court's supervisory power under the[] circumstances is at its strongest and most +defensible." Id. at 1214. +The Court recognized that the inherent authority doctrine is not a free pass for courts to +suppress evidence or "merely [to] disagree with the method[s] of law enforcement." Id. "[T]he +federal supervisory power does not give 'the federal judiciary a 'chancellor's foot' veto over law +enforcement practices of which it (does) not approve."" Id. (quoting United States v. Russell, 411 +U.S. 423, 435 (1973)). Even so, inherent authority is properly invoked to "prevent[] the court +from condoning a fraud perpetrated upon it." Id. Suppression serves both to deter unlawful +governmental conduct and to protect judicial integrity. Id. (weighing "the deterrent values of +preventing the incrimination of those whose rights the police have violated ... and the need to +protect the integrity of the federal courts against the cost to society of excluding "probative but +tainted evidence'"). +21 + + +Maxwell had a due process right to notice and an opportunity to be heard on the +government's request to modify the Protective Order and issue a subpoena to Boies Schiller. +Mot. Ex. A, 1 14 (permitting modification of the Protective Order only "for good cause shown +following notice to all parties and an opportunity to be heard"); Mot. Ex. H (Judge Netburn +denying the government's ex parte request to modify the Jane Doe 43 Protective Order in part +because the government was attempting to deprive Maxwell of notice and an opportunity to be +heard); Martindell, 594 F.2d at 294; see U.S. CONST. amend. V. Maxwell also had a privacy +interest in the materials subject to the subpoena, including most especially her deposition +transcripts. Mot. Ex. A (defining "confidential" material as that which "implicates common law +and statutory privacy interests of ... Ghislaine Maxwell"); see U.S. CONST. amend. IV. The +government violated these rights when it secured an ex parte modification of the Protective +Order based on materially false statements to Judge McMahon. In resisting any sanction for its +misconduct, and in denying that Maxwell should even be afforded a hearing, the government +asks this Court to "condon[e] a fraud perpetrated upon it." See Cortina, 630 F.2d at 1214. +To be sure, AUSA +misled Judge McMahon in answering the singular question +she posed, and he did so with full knowledge of the facts. AUSA +misrepresentations +were material to Judge McMahon's decision, because she would not have modified the +Protective Order if AUSA +had been candid about Boies Schiller's role in initiating +the investigation. As Judge McMahon put it, "the only thing on which Maxwell ... might +reasonably have relied is that +or her lawyers" would not approach prosecutors and +"foment the Government's investigation." Mot. Ex. G, p 21. I. That is, in fact, exactly what +happened. As in Cortina, the modification of the Protective Order "never should have taken +place." Id. When, as here, a prosecutor-from the public corruption unit no less-misrepresents +22 + + +material information to a federal judge in an ex parte proceeding, "It]he call for the court's +supervisory power ... is at its strongest and most defensible." Cortina, 630 F.2d at 1214. +Maxwell need not satisfy the standard of Franks v. Delaware, 438 U.S. 154 (1978) in +order to obtain relief. But even if Franks applies, Maxwell has easily met her burden. To obtain a +Franks hearing, a defendant must make a "substantial preliminary showing," United States v. +Falso, 544 F.3d 110, 125 (2d Cir. 2008) (quoting Franks, 438 U.S. at 155-56), that (1) there were +"inaccuracies or omissions" in the affidavit, (ii) "the alleged falsehoods or omissions were +necessary to the issuing judge's probable cause or necessity finding." and (iii) "the claimed +inaccuracies or omissions [were] the result of the affiant's deliberate falsehood or reckless +disregard for the truth." United States v. Lambus, 897 F.3d 368, 397 (2d Cir. 2018). Here, there +is no dispute that (i) AUSA +representations to Judge McMahon were false and +misleading, (ii) Judge McMahon would not have modified the Protective Order to authorize the +subpoena if AUSA +had been honest with her, and (3) AUSA +statements +were deliberately false, since he had a "complete handle on the landscape" months before he +appeared in front of and misled Judge McMahon. +Nor need Maxwell prove "outrageous government conduct" to obtain relief. Were that +her burden, however, Maxwell would have easily satisfied it. "The concept of fairness embodied +in the Fifth Amendment due process guarantee is violated by government action that is +fundamentally unfair or shocking to our traditional sense of justice." United States v. Schmidt, +105 F.3d 82, 91 (2d Cir. 1997). To prevail on an outrageous government conduct claim, "a +defendant must show that the government's conduct is "so outrageous that common notions of +fairness and decency would be offended were judicial processes invoked to obtain a +23 + + +conviction.'" United States v. Bout, 731 F.3d 233, 238 (2d Cir. 2013) (quoting United States v. +Schmidt, 105 F.3d 82, 91 (2d Cir. 1997)). +Here, it would "shock the conscience" to permit a prosecutor to make false statements to +a federal judge to circumvent another judge's duly-entered order, all in violation of the +defendant's due process, privacy, and Fourth and Fifth Amendment rights. The only way to +prevent Maxwell from suffering unconstitutional prejudice because of the government's +misconduct is to suppress the evidence the government unlawfully obtained and to dismiss +Counts 5 and 6. +*** +AUSA +breached two separate but equally consequential duties: The duty of a +public prosecutor and the duty of candor. +"[T]he responsibility of a public prosecutor differs from that of the usual advocate; his +duty is to seek justice, not merely to convict." Young v. United States, 481 U.S. 787, 803 (1987). +Prosecutors are held to a higher standard, and for good reason. "[The prosecutor] is in a peculiar +and very definite sense the servant of the law, the twofold aim of which is that guilt shall not +escape or innocence suffer." Berger v. United States, 295 U.S. 78, 88 (1935). +Moreover, "Tiln light of the prosecutor's public responsibilities, broad authority and +discretion, the prosecutor has a heightened duty of candor to the courts and in fulfilling other +professional obligations." ABA Criminal Justice Standards, Prosecution Function, Standard 3- +1.4 (4th ed. 2017). "While all lawyers owe a duty of honesty and candor to the Court, 'this +obligation lies most heavily upon [public prosecutors] who are not merely partisan advocates, but +public officials charged with administering justice honestly, fairly and impartially." Morales v. +Portuondo, 165 F. Supp. 2d 601, 612 (S.D.N.Y. 2001). +24 + + +In turn, this already high standard ratchets up even higher when a prosecutor appears +before the court ex parte. "The duty of candor is, if anything, more critical when ex parte +applications are made to a court." In re WinNet R CJSC, 2017 WL 1373918, at *9 (S.D.N.Y. No. +16MC484(DLC), Apr. 13, 2017); see N.Y. Rules of Professional Conduct, Rule 3.3(d) ("In an ex +parte proceeding, a lawyer shall inform the tribunal of all material facts known to the lawyer that +will enable the tribunal to make an informed decision, whether or not the facts are adverse."); see +also id. cmt. [14]. And it "is not a defense to claim that, while factual statements to the Court +were materially misleading, they were not literally false. Attorneys are officers of the Court, and +our system of justice cannot operate efficiently if the Court cannot rely on the candor of counsel +presenting an application for ex parte relief." Four Star Fin. Servs., LLC v. Commonwealth +Mgmt. Assocs., 166 F. Supp. 2d 805, 810 (S.D.N.Y. 2001). +AUSA +failed to live up to these standards. In an ex parte proceeding, AUSA +affirmatively misled Judge McMahon, with full knowledge of what issue concerned +Judge McMahon and what information would be material to her decision. When, as here, "there +has been a fraud upon the court," Cortina, 630 F.2d at 1216, "It]he court has inherent authority +to regulate the administration of criminal justice among the parties before the bar .... [by] +exclud[ing] evidence taken from the defendant by willful disobedience of law," id. at 1214. +United States v. Lambus, 897 F.3d 368, 386 (2d Cir. 2018) ("It is within the court's inherent +authority to suppress evidence gathered unlawfully in order to maintain the integrity of its own +proceedings. ..."). +25 + + +B. At a Minimum, this Court Should Order a Hearing at which Maxwell +May Inquire into the Circumstances Surrounding the Government's +Misrepresentation to Judge MeMahon. +"An evidentiary hearing is normally required to address motions to suppress where a +factual issue is in dispute." United States v. Paredes-Cordova, No. S1 03 CR. 987DAB, 2009 +WL 1585776, at *1 (S.D.N.Y. June 8, 2009); United States v. Pena, 961 F.2d 333, 339 (2d Cir. +1992) (*[A]n evidentiary hearing on a motion to suppress ordinarily is required if the moving +papers are sufficiently definite, specific, detailed, and nonconjectural to enable the court to +conclude that contested issues of fact going to the validity of the search are in question." +(quotation omitted))). Here, the government has confessed enough facts to demonstrate that +Maxwell at least is entitled to a hearing. +There is no merit to the government's assertion that Maxwell is not entitled to a hearing +because she has not submitted an affidavit in support of her Motion. An affidavit is not a +prerequisite to a hearing when the government has confessed the existence of facts sufficient to +entitle a defendant to an evidentiary hearing. +Nor is an affidavit required when information at issue is peculiarly within the possession +of the government (e.g., AUSA +and AUSA +D or others who are adverse to +Maxwell (e.g., Boies, Edwards, Skinner, Pottinger). See Cortina, 630 F.2d at 1216 ("The +violation here is particularly insidious because it is difficult to uncover misrepresentations in an +[ex parte submission]. The information needed to prove such assertions false is peculiarly within +the hands of the government."). Since Maxwell was not at the February 29 meeting or copied on +any of the emails or communications that followed, the Response does not explain how Maxwell +could possibly submit an affidavit attesting to the government's misrepresentations based on +personal knowledge. +26 + + +The government of course does not suggest that any of its agents, such as AUSA +would be willing to provide an affidavit to Maxwell or otherwise speak with defense +counsel absent compulsion from this Court. Indeed, the government conspicuously did not attach +to its Response any affidavits about its interactions with Boies Schiller. +It's plain, therefore, that this Court should hold an evidentiary hearing and effectuate +Maxwell's constitutional right to compulsory process because that is the only way to get to the +truth.? +Conclusion +For these reasons, as well as those given in the Motion, this Court should: (1) suppress all +evidence the government obtained from Boies Schiller and any other evidence derived +therefrom; or (2) suppress the April and July 2016 depositions and all evidence derived +therefrom; and (3) dismiss Counts Five and Six. Maxwell requests an evidentiary hearing on this +Motion. +Dated: March 15, 2021 +22 If this Court concludes an affidavit is required before it holds a hearing, Maxwell requests +leave, as she did in her Motion, to attempt to obtain such an affidavit. But if, as is likely, none of the +participants —e.g., AUSA L +, AUSA I +1. Boies, Edwards, Skinner, Pottinger—voluntarily +provides an affidavit, Maxwell invokes her constitutional right to compulsory process and this Court's +authority to compel testimony in support of her defense. U.S. CONST. amend. VI. +27 + + +Respectfully submitted, +s/ Jeffrey S. Pagliuca +HANDON, NORCAN & FOREMAN PC. +150 East 10th Avenue +Denver, CO 80203 +Christian R. Everdell +COHEN & GRESSER LLP +800 Third Avenue +New York, NY 10022 +Phone: +Bobbi C. Sternheim +Law Offices of Bobbi C. Sternheim +33 West 19th Street - 4th Floor +New York, NY 10011 +Phone: +Attorneys for Ghislaine Maxwell +28 + + +Certificate of Service +I hereby certify that on March 15, 2021, 1 served by email, pursuant Rule 2(B) of the +Court's individual practices in criminal cases, the Reply Memorandum of Ghislaine Maxwell in +Support of Her Motion Under the Due Process Clause to Suppress All Evidence Obtained from +the Government's Subpoena to Boies Schiller and to Dismiss Counts Five and Six upon the +following: +Alison Moe +Maurene Comey +Andrew Rohrbach +Lara Pomerantz +U.S. Attorney's Office, SDNY +One Saint Andrew's Plaza +New York, NY 10007 +s/ Christian R. Everdell +29 diff --git a/vision-fixhub/ds9-parsed-01/1134473507899ae16fb1eb18bc551558407ff6a127962b70c027fc5917a415ec.receipt.json b/vision-fixhub/ds9-parsed-01/1134473507899ae16fb1eb18bc551558407ff6a127962b70c027fc5917a415ec.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..d19e4674637a1f6365477c4c9324eec9f5b9cf03 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1134473507899ae16fb1eb18bc551558407ff6a127962b70c027fc5917a415ec.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -413, + "dataset": "marble-joined", + "doc_id": "1134473507899ae16fb1eb18bc551558407ff6a127962b70c027fc5917a415ec", + "engine": "marble-apple-vision", + "event_count": 38, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.flight-log-tables.normalize\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "a38f36e4ad94faeea0611296e2a70b00e64824e93bcf4b5440f62daba04d72b1", + "output_sha256": "02d555f166b00890dce079b41e7cbccf5bcf7c6d1f1320a6072480615b0c4b8e", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1176b672b22350de16c2f497eec935074d535e3e27cdbad6a029f31840ede3fd.md b/vision-fixhub/ds9-parsed-01/1176b672b22350de16c2f497eec935074d535e3e27cdbad6a029f31840ede3fd.md new file mode 100644 index 0000000000000000000000000000000000000000..d48d7621f279d03e3391fcf5b15342f18814447f --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1176b672b22350de16c2f497eec935074d535e3e27cdbad6a029f31840ede3fd.md @@ -0,0 +1,425 @@ +NYMB5 530.03 +PAGE 001 +A +BUREAU OF PRISONS COUNT SHEET +NEW YORK MCC +QTRG EQ **** +OCTG EQ**** +F +OUTCOUNT SECTION +F +N +F +H +M +R +S +S O +A +TR +N +E +F +N +Y +S +D +D +** +08-05-2019 +02:15:22 +oc +UO +TU +N +T +COUNT +AREA +B-A +C-A +E-N +E-S +G-N +G-S +H-A +I-N +K-N +K-S +R-A +Z-A +Z-B +TOTAL +COUNT +VERIFY +CENSUS +26 +10 +87 +78 +78 +82 +1 +87 +89 +142 +77 +5 +762 +1 +1 +VERIFY +COUNT +COUNT COUNT AREA +XXXXXX +26 B-A +10 C-A +86 E-N +77 B-S +78 +G-N +82 +1 +87 +I-N +89 +K-N +142 +K-S +0 +R-A +77 +Z-A +5 +Z-B +760 +1 +OFFICIAL PREPARING COUNT: +OFFICIAL TAKING COUNT: +COUNT CLEARED TIME: + + +METROPOLITAN CORRECTIONAL CENTER +NEW YORK, NY +OFFICIAL OUT COUNT +DATE: +: 88/5/19 +COUNT TIME: +LOCATION: +5.00AM +HOsP +FROM: +APPROVED: +(Staff Member Preparing Out Count) +(Opérations Lieutenant) +REG # +NAME +UNIT +1. 85918-054 GAmA-PiNEDA EN 13. +REG # +NAME +UNIT +3. +4. +5. +6. +7. +8. +9. +10. +11. +12. +15. +16. +17. +18. +19. +20. +21. +22. +23. +24. +B-A +I-N +C-A +K-N +E-N +K-S +OUT-COUNT BY UNIT +E-S +G-N +-R-A +G-S +Z-B +H-A +Total Out-Counted: +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected count. +Prepare this form in ink. Group the inmates according to their respective housing units. This form is to be used only as an +Out-Count. No other form will be accepted in lieu of the Out-Count Form. + + +NYMB5 530*05 * + +CATEGORY: OCT +ASSIGNMENT: HOSP +OPER CATG ASSIGNMENT +OPER +NUM ASSIGNMENT REG NO +NAME +0001 HOSP +85918-054 GAMA-PINEDA +INMATE ROSTER +CATG ASSIGNMENT +* +08-05-2019 +01: 55:02 +GROUP CODE: +FACILITY: NYM +OPER CATG ASSIGNMENT +OCT DATE +QTR +08-05-2019 E05-533U +WRK +SUICIDE OR +UNASSG +GO000 +TRANSACTION +• SUCCESSFULLY +COMPLETED + + +METROPOLITAN CORRECTIONAL CENTER +NEW YORK, NY +OFFICIAL OUT COUNT +DATE: +FROM: +APPROVED: +8-5-4 +COUNT TIME: +LOCATION: +508Mn +INWDVR +(Staff Member Preparing Out Count) +(Operations Lieutenant) +REG # +NAME +UNIT +157084-056 HARRISON ES +REG # +NAME +UNIT +3. +4. +5. +6. +7. +8. +9. +10. +11. +12. +13. +14. +15. +16. +17. +18. +19. +20. +21. +22. +23. +24. +B-A +I-N +C-A +K-N +E-N +K-S +OUT-COUNT BY UNIT +G-N +- R-A +- +Z-A +G-S +Z-B +H-A +Total Out-Counted: +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected count. +Prepare this form in ink. Group the inmates according to their respective housing units. This form is to be used only as an +Out-Count. No other form will be accepted in lieu of the Out-Count Form. + + +NYMB5 530*05* +INMATE ROSTER + +CATEGORY: OCT +ASSIGNMENT: TNWDVR +OPER CATG ASSIGNMENT +OPER CATG ASSIGNMENT +NUM ASSIGNMENT REG NO +NAME +0001 TNNDVR +57084-056 HARRISON +* +08-05-2019 +02:08:40 +GROUP CODE: +FACILITY: NYM +OPER CATG ASSIGNMENT +OCT DATE +QTR +08-05-2019 E08-561L +WRK +TWN DRIVER +GOO0O +TRANSACTION +SUCCESSPULLY +COMPLETED + + +Unit: +Count: +Signature: +Signature: +Metropolitan Correctional Center +Official Count Slip +Date: +8/5/9 +Time: +Unit: +Metropolitan Correctional Center +Official Count Slip +Hosp +Date: +81 +5/19. +Count: +Time: +Signature: +Signature: +Unit: +Metropolitan Correctional Center +Official. Count Slip +B14 +Date: +8/5/4 +Count: +Time: +Signature: +Signature: +Unit: +Count: +Metropolitan Correctional Center +Official Count Slip +ES/ +77 +Date +08/05/2019 +Time: _ +5:00 Am +Signature: +Signature +Metropolitan Correctional Center +Official Count Slip +Unit: - +EN +- Dato 8.5-19 +Count: +86. +00 +-Time 5am +Signature: +Signature +Unit: IN +Count: +Print Names +Signature: +Print Names +Signature +Metropolitan Correctional Center +Official Count Slip, +85/192 +Time: +i00. +Metropolitan Correctional Center +Official Count Slip +Date: +8/51192 +Time: +5Am +Unit: +Count: +Signature: +Signature: +Unit: +Metropolitan Correctional Center +Official Count Slip +CAL +Date: +8/5/9, +Count: +Time: +Signature: +Signature: +Unit: +Metropolitan Correctional Center +Official Count Slip +6-N +78 +Date +8/5/19 +Time: +5:00 AM +Count: +Signature: +Signature + + +Metropolitan Correctional Center +Official Count Slip +KN / Date - +82 +85/19 15 +Time: Jou +Unit: _ +Count: +Signature: +Signature +Unit: +Count: +Signature: +Signature: +Metropolitan Correctional Center +Official Count Slip +ZBL +Date: +5 +/5/19, +Unit: +2A +Count: _ +77 +Signature: - +Signature +Metropolitan Correctional Center +Official Count Slip +- Дан +8•5.19 +Time: 5 Am +Metropolitan Correctional Center +Official Count Slip +Unit: / WDUR +Date. +8/5/19. +Count: _ +Time: +Signature: +Signature +Metropolitan Correctional Center +Official Count Slip +brit: K-s pate +Count: +142-85.192 +Time: 5,00Am +Signature: +Signature \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/1176b672b22350de16c2f497eec935074d535e3e27cdbad6a029f31840ede3fd.receipt.json b/vision-fixhub/ds9-parsed-01/1176b672b22350de16c2f497eec935074d535e3e27cdbad6a029f31840ede3fd.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..7da21076dbe989a0fe2547d0832a94a50a913a04 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1176b672b22350de16c2f497eec935074d535e3e27cdbad6a029f31840ede3fd.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -427, + "dataset": "marble-joined", + "doc_id": "1176b672b22350de16c2f497eec935074d535e3e27cdbad6a029f31840ede3fd", + "engine": "marble-apple-vision", + "event_count": 10, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "b5b31d35187f2271a168e9cf8cfec346ab0a6d066d2ed772f7f84c8ef1897675", + "output_sha256": "a8d7cf43ee3c39f9f7b114ff5a46e67b36556328002f7c56b489fddd48f72d74", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/11772a69d3a5656431809e9f463806f4644549040806fb801e6df7201f98f337.md b/vision-fixhub/ds9-parsed-01/11772a69d3a5656431809e9f463806f4644549040806fb801e6df7201f98f337.md new file mode 100644 index 0000000000000000000000000000000000000000..12a33a23031776a6b3a386764ef2483c876e5186 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/11772a69d3a5656431809e9f463806f4644549040806fb801e6df7201f98f337.md @@ -0,0 +1,28 @@ +called "/2/21 +1835 +From +wants to clority (2) Statoments +-Conversation cartier +today +over +Nebet w/ +(1) The last time +drugs. +Was +cat +mushrooms @ +he +reselled +32 YO +(not "33 70) +a Bachelor Arty +(2) +and. +telling +is. +has +not godments that the +or Health insurance, +3521-004 + +SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 diff --git a/vision-fixhub/ds9-parsed-01/11772a69d3a5656431809e9f463806f4644549040806fb801e6df7201f98f337.receipt.json b/vision-fixhub/ds9-parsed-01/11772a69d3a5656431809e9f463806f4644549040806fb801e6df7201f98f337.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..90df80c63be70c14f470ea3dedb9768bc9452344 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/11772a69d3a5656431809e9f463806f4644549040806fb801e6df7201f98f337.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -23, + "dataset": "marble-joined", + "doc_id": "11772a69d3a5656431809e9f463806f4644549040806fb801e6df7201f98f337", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "f2e89f2ba8a6b5638d8f891c19e0eeb509166216b714a75649d689532654cafe", + "output_sha256": "8612c2246ad611ea0e73e7727cd8811728343ebe8e7db37746cec03983230ad4", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/11ac723aca63670e8e9b5d7e301fdf2790f4f935c8bb84117a213b4ec29d1a7e.md b/vision-fixhub/ds9-parsed-01/11ac723aca63670e8e9b5d7e301fdf2790f4f935c8bb84117a213b4ec29d1a7e.md new file mode 100644 index 0000000000000000000000000000000000000000..4e86e72d62d2a471cdf4f1087899c52dad6cbd7b --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/11ac723aca63670e8e9b5d7e301fdf2790f4f935c8bb84117a213b4ec29d1a7e.md @@ -0,0 +1,51 @@ +LAST WILL AND TESTAMENT +OF +JEFFREY E. EPSTEIN +a its en it ernest my scion to pay for my state alertem my +luly proven and allowed against my estate +compensation to each Executor for serving as stetor hereueer, the ura of two Hundred Frity +Thousand Dollars ($250,000) to each Executor upon the completion of probate of my estate. No +Executor shall receive any other compensation for serving as Executor hereunder; provided, however, +that my Executor shall be reimbursed from my estate for all reasonable costs, expenses, charges, and +liabilities incurred or paid in respect thereto, including fees and expenses of counsel or any other agents +hired by my Executor, and my Executor shall not be liable therefor individually. +I direct my Executor to pay from my estate the Federal +and state transfer taxes described in Paragraph B(1) of Article SEVENTH. +direct my Executor to pay from my estate all expens +i storing, insuring, packing, shipping and delivering my tangible personal property in accordance wit +Article SECOND. +SECOND: I give, bequeath and devise all of my property, real and personal, +wherever situated, which I won at my death or of which I have the power to dispose after the payments +and distributions provided in Article FIRST, to the then acting Trustees of The Jeffrey E. Epstein 2014 +Trust (the "Trust") created under that certain Trust Agreement (the "Trust Agreement") dated November +_ 2014, as the same may be amended from time to time, to be held in accordance with the provisions +comprising the Trust Agreement at the time of my death. +1 appoint DARREN K. INDYKE, DAVID MITCHELL and +JAMES E. STALEY to be the Executors of this Will. If any one or more of my Executors fails to qualify +or ceases to act, 1 appoint LAWRENCE H. SUMMERS as successor Executor. I authorize the last acting +Executor to designate his successor as Executor. +If my estate must be administered in whole or in part in +any jurisdiction other than the state or territory of my domicile at the date of my death and if my +Executor is unable or unwilling to serve in such jurisdiction, then I appoint the successor Executor of my +estate designated in Paragraph A of Article THIRD provided that he is able and willing to serve in such +jurisdiction. If no Executor or successor Executor is able and willing to serve in such jurisdiction, my +Executor shall designate a successor Executor to serve in such jurisdiction. Such designation shall be +made by written instrument delivered to such successor Executor. +2657367.1 +GJ_000159 + + + + + + + + + + + + + + + + diff --git a/vision-fixhub/ds9-parsed-01/11ac723aca63670e8e9b5d7e301fdf2790f4f935c8bb84117a213b4ec29d1a7e.receipt.json b/vision-fixhub/ds9-parsed-01/11ac723aca63670e8e9b5d7e301fdf2790f4f935c8bb84117a213b4ec29d1a7e.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..d5fd98ccd83aa017c6da8dc47e59a6db7e41adac --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/11ac723aca63670e8e9b5d7e301fdf2790f4f935c8bb84117a213b4ec29d1a7e.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -108, + "dataset": "marble-joined", + "doc_id": "11ac723aca63670e8e9b5d7e301fdf2790f4f935c8bb84117a213b4ec29d1a7e", + "engine": "marble-apple-vision", + "event_count": 9, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "a2d64a84ef603b234c280152ded2208232d86696dd70bab61cb7ce2a419e49b2", + "output_sha256": "2bda1a05c02d10a256c02f389ce957d14677fdb54dfcb30a7ed8801f4f51b2d1", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/11d1dd8abd7308a0c990798f6f81d24a0f82c0f9a8908d5f2394d59ab9e91efa.md b/vision-fixhub/ds9-parsed-01/11d1dd8abd7308a0c990798f6f81d24a0f82c0f9a8908d5f2394d59ab9e91efa.md new file mode 100644 index 0000000000000000000000000000000000000000..8ce5c6ad9224bb2ce21e78299b25aa44bd71e108 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/11d1dd8abd7308a0c990798f6f81d24a0f82c0f9a8908d5f2394d59ab9e91efa.md @@ -0,0 +1,14 @@ +From: +To: +Cc: +Subject: Re: Epstein Meeting +Date: Tue, 25 Feb 2020 16:45:41 +0000 +> On Feb 25, 2020, at 11:45 AM, +> +> +>---Original Message----- +> From: +> Sent: Tuesday, February 25, 2020 11:36 AM +> To: +> Subject: Epstein Meeting +• wrote: diff --git a/vision-fixhub/ds9-parsed-01/11d1dd8abd7308a0c990798f6f81d24a0f82c0f9a8908d5f2394d59ab9e91efa.receipt.json b/vision-fixhub/ds9-parsed-01/11d1dd8abd7308a0c990798f6f81d24a0f82c0f9a8908d5f2394d59ab9e91efa.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..c22069e8b994041cd6a64c6b3995d6f48768c70e --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/11d1dd8abd7308a0c990798f6f81d24a0f82c0f9a8908d5f2394d59ab9e91efa.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "11d1dd8abd7308a0c990798f6f81d24a0f82c0f9a8908d5f2394d59ab9e91efa", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "53e6a08be212f8f2e7fbfb6d032816d3fecbc63bad43ff165126af84e1acbce1", + "output_sha256": "51205c79ae893602fee2925388d8e4ceaa776326c0fc051a1464576133baa958", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/11eed7dd39728cc9d98a359c95c250fe2e9ad825782aed11cf43271cd506760f.md b/vision-fixhub/ds9-parsed-01/11eed7dd39728cc9d98a359c95c250fe2e9ad825782aed11cf43271cd506760f.md new file mode 100644 index 0000000000000000000000000000000000000000..96282415705e4f3890c33f032118fbee61de70cc --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/11eed7dd39728cc9d98a359c95c250fe2e9ad825782aed11cf43271cd506760f.md @@ -0,0 +1,920 @@ +Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 1 of 34 +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +USDC SDNY +DOCUMENT +ELECTRONICALLY FILED +DOC#:_ +DATE FILED: 4/16/21 +United States of America, +-V- +Ghislaine Maxwell, +20-cr-330 (AJN) +OPINION & ORDER +Defendant. +ALISON J. NATHAN, District Judge: +In June 2020, a grand jury returned a six-count indictment charging Ghislaine Maxwell +with facilitating the late financier Jeffrey Epstein's sexual abuse of minor victims from around +1994 to 1997. The Government filed a first (S1) superseding indictment shortly thereafter, +which contained only small, ministerial corrections. The S1 superseding indictment included +two counts of enticement or transportation of minors to engage in illegal sex acts in violation of +the Mann Act and two counts of conspiracy to commit those offenses. It also included two +counts of perjury in connection with Maxwell's testimony in a civil deposition. Trial is set to +begin on July 12, 2021. +Maxwell filed twelve pretrial motions seeking to dismiss portions of the S1 superseding +indictment, suppress evidence, and compel discovery. After the parties fully briefed those +motions, a grand jury returned a second (S2) superseding indictment adding a sex trafficking +count and another related conspiracy count. +This Opinion resolves all of Maxwell's currently pending pretrial motions other than +those seeking to suppress evidence, which the Court will resolve in due course. The motions, and +this Opinion, deal exclusively with the S1 superseding indictment and do not resolve any issues + + +Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 2 of 34 +related to the newly added sex trafficking charges. For the reasons that follow, the Court denies +Maxwell's motions to dismiss the S1 superseding indictment in whole or in part. It grants her +motion to sever the perjury charges for a separate trial. It denies her motion to further expedite +discovery. +The Court provides a brief summary of its conclusions here and its reasoning on the +pages that follow: +Maxwell moves to dismiss all counts based on a non-prosecution agreement between +Jeffrey Epstein and the U.S. Attorney for the Southern District of Florida. The Court +concludes that the agreement does not apply in this District or to the charged offenses. +• Maxwell moves to dismiss all counts as untimely. The Court concludes that the +Government brought the charges within the statute of limitations and did not unfairly +delay in bringing them. +• Maxwell moves to dismiss the Mann Act counts because they are too vague, or in the +alternative to require the Government to describe the charges in greater detail. The +Court concludes that the charges are specific enough. +• Maxwell moves to dismiss the perjury counts because, in her view, her testimony +responded to ambiguous questioning and was not material. The Court concludes that +these issues are best left for the jury. +• Maxwell moves to sever the perjury counts from the Mann Act counts so that they can +proceed in a separate trial. The Court concludes that severance is appropriate and will +try the perjury counts separately. +• Maxwell moves to strike language from the indictment that she believes is superfluous +and to dismiss conspiracy counts she believes are redundant. The Court concludes that +these motions are premature before trial. +Maxwell moves to compel the Government to immediately disclose certain categories +of evidence. The Court concludes that she is not entitled to do so, but the Court will +order Maxwell and the Government to confer on a discovery schedule. +Maxwell moves to dismiss all counts because a grand jury in White Plains, rather than +Manhattan, returned the S1 superseding indictment. Because a jury in Manhattan +returned the S2 superseding indictment, the motion appears moot. +2 + + +Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 3 of 34 +I. +Jeffrey Epstein's non-prosecution agreement does not bar this prosecution +In September 2007, under investigation by both federal and state authorities, Jeffrey +Epstein entered into a non-prosecution agreement ("NPA") with the Office of the United States +Attorney for the Southern District of Florida. Dkt. No. 142 at 1-2. Epstein agreed in the NPA to +plead guilty in Florida state court to soliciting minors for prostitution and to serve eighteen +months in a county jail. Id. In exchange, the U.S. Attorney's Office agreed not to charge him +with federal crimes in the Southern District of Florida stemming from its investigation of his +conduct between 2001 and 2007. Id. It also agreed not to bring criminal charges against any of +his "potential co-conspirators." Id. +As a recent report from the Department of Justice's Office of Professional Responsibility +observed, the NPA was unusual in many respects, including its breadth, leniency, and secrecy. +OPR Report, Gov. Ex. 3, Dkt. No. 204-3, at x, 80, 175, 179, 260-61. The U.S. Attorney's +promise not to prosecute unidentified co-conspirators marks a stark departure from normal +practice for federal plea agreements. This provision appears to have been added "with little +discussion or consideration by the prosecutors." Id. at 169, 185. The report concluded that the +U.S. Attorney's negotiation and approval of the NPA did not amount to professional misconduct, +but nonetheless reflected "poor judgment." Id. at 169. +Only the NPA's effect, and not its wisdom, is presently before the Court. Maxwell +contends that the NPA bars this prosecution, because she is charged as a co-conspirator of +Jeffrey Epstein and the NA's co-conspirator provision lacks any geographical or temporal +limitations. The Court disagrees for two independent reasons. First, under controlling Second +Circuit precedent, the NPA does not bind the U.S. Attorney for the Southern District of New +York. Second, it does not cover the offenses charged in the S1 superseding indictment. +3 + + +Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 4 of 34 +A. The non-prosecution agreement does not bind the U.S. Attorney for the +Southern District of New York +United States Attorneys speak for the United States. When a U.S. Attorney makes a +promise as part of a plea bargain, both contract principles and due process require the federal +government to fulfill it. See Santobello v. New York, 404 U.S. 257, 262 (1971); United States v. +Ready, 82 F.3d 551, 558 (2d Cir. 1996). The question here is not whether the U.S. Attorney for +the Southern District of Florida had the power to bind the U.S. Attorney for the Southern District +of New York. The question is whether the terms of the NPA did so. Applying Second Circuit +precedent and principles of contract interpretation, the Court concludes that they did not. +In United States v. Annabi, the Second Circuit held: "A plea agreement binds only the +office of the United States Attorney for the district in which the plea is entered unless it +affirmatively appears that the agreement contemplates a broader restriction." 771 F.2d 670, 672 +(2d Cir. 1985) (per curiam). This is something akin to a clear statement rule. Single-district plea +agreements are the norm. Nationwide, unlimited agreements are the rare exception. Applying +Annabi, panels of the Second Circuit have stated that courts cannot infer intent to depart from +this ordinary practice from an agreement's use of phrases like "the government" or "the United +States." United States v. Salameh, 152 F.3d 88, 120 (2d Cir. 1998) (per curiam); United States v. +Gonzalez, 93 F. App'x 268, 270 (2d Cir. 2004). Those are common shorthand. A plea +agreement need not painstakingly spell out "the Office of the United States Attorney for Suchand-Such District" in every instance to make clear that it applies only in the district where +signed. +Maxwell asks this Court to draw the opposite conclusion. The provision of the NPA +dealing with co-conspirators does not expressly state that it binds U.S. Attorneys in other +districts. It does not expressly state that it applies in other districts. The relevant language, in +4 + + +Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 5 of 34 +its entirety, reads as follows: "the United States also agrees that it will not institute any criminal +charges against any potential co-conspirators of Epstein." Dkt. No. 142-1 at 5. Under Annabi, +Salameh, and Gonzalez, a statement that "the United States" agrees not to prosecute implies no +restriction on prosecutions in other districts. +Two provisions of the NPA refer specifically to prosecution in the Southern District of +Florida. The first states that the U.S. Attorney for the Southern District of Florida will defer +"prosecution in this District" if Epstein complies with the agreement. Dkt. No. 142-1 at 2. The +second states that no prosecution "will be instituted in this District, and the charges against +Epstein if any, will be dismissed" after he fulfills the agreement's conditions. Maxwell contends +that the lack of similar language in the co-conspirator provision must mean that it lacks any +geographical limitation. If anything, that language reflects that the NA's scope was expressly +limited to the Southern District of Florida. It is not plausible-let alone "affirmatively +apparent", Annabi, 771 F.2d at 672, that the parties intended to drastically expand the +agreement's geographic scope in the single sentence on the prosecution of co-conspirators +without clearly so saying. +Without an affirmative statement in the NPA's text, Maxwell turns to its negotiation +history. Under Second Circuit precedent she may offer evidence that negotiations of the NPA +between the defendant and the prosecutors included a promise to bind other districts. See United +States v. Russo, 801 F.2d 624, 626 (2d Cir. 1986). She alleges that officials in the U.S. +Attorney's Office for the Southern District of Florida sought and obtained approval for the NPA +from the Office of the Deputy Attorney General and communicated with attorneys in other +districts. Any involvement of attorneys outside the Southern District of Florida appears to have +been minimal. Maxwell has already received access to an unusually large amount of information +5 + + +Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 6 of 34 +about the NPA's negotiation history in the form of the OPR report and yet identifies no evidence +that the Department of Justice made any promises not contained in the NPA. The OPR report +reflects that the Office of the Deputy Attorney General reviewed the NPA, but only after it was +signed when Epstein tried to get out of it. OPR Report at 103. Other documents show that +attorneys in the Southern District of Florida reached out to other districts for investigatory +assistance but not for help negotiating the NPA. Dkt. No. 204-2. Nor would direct approval of +the NPA by the Office of the Deputy Attorney General change the meaning of its terms. No +evidence suggests anyone promised Epstein that the NPA would bar the prosecution of his coconspirators in other districts. Absent such a promise, it does not matter who did or did not +approve it. +Second Circuit precedent creates a strong presumption that a plea agreement binds only +the U.S. Attorney's office for the district where it was signed. Maxwell identifies nothing in the +NA's text or negotiation history to disturb this presumption. The Court thus concludes that the +NPA does not bind the U.S. Attorney for the Southern District of New York. +B. The non-prosecution agreement does not cover the charged offenses +The NPA would provide Maxwell no defense to the charges in the S1 superseding +indictment even against an office bound to follow it. The NPA bars prosecution, following +Epstein's fulfillment of its conditions, only for three specific categories of offenses: +(1) "the offenses set out on pages 1 and 2" of the NPA; namely, "any offenses that +may have been committed by Epstein against the United States from in or around +2001 through in or around September 2007" including five enumerated offenses; +(2) "any other offenses that have been the subject of the joint investigation by the +Federal Bureau of Investigation and the United States Attorney's Office"; and +(3) "any offenses that arose from the Federal Grand Jury investigation." +6 + + +Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 7 of 34 +Dkt. No. 142-1 at 2. The NPA makes clear that the covered charges are those relating to +and deriving from a specific investigation of conduct that occurred between 2001 and 2007. +Maxwell contends that the NPA's co-conspirator provision lacks any limitation on the +offenses covered. The Court disagrees with this improbable interpretation. The phrase +"potential co-conspirator" means nothing without answering the question "co-conspirator in +what?" The most natural reading of the co-conspirator provision is that it covers those who +conspired with Epstein in the offenses covered by the NPA for their involvement in those +offenses. Thus, it would cover any involvement of Maxwell in offenses committed by Epstein +from 2001 to 2007, other offenses that were the subject of the FBI and U.S. Attorney's Office +investigation, and any offenses that arose from the related grand jury investigation. +The Court has no trouble concluding that the perjury counts are not covered by the NPA. +Those charges do not relate to conduct in which Maxwell conspired with Epstein and stem from +depositions in 2016, more than eight years after Epstein signed the NPA. Maxwell now +concedes as much, though her motion sought to dismiss the S1 superseding indictment in its +entirety, perjury counts and all. +The Mann Act counts, too, fall comfortably outside the NPA's scope. The S1 +superseding indictment charges conduct occurring exclusively between 1994 and 1997, some +four years before the period covered by the Southern District of Florida investigation and the +NPA. The NPA does not purport to immunize Epstein from liability for crimes committed +before the period that was the subject of the FBI and U.S. Attorney's Office investigation. +Maxwell's protection is no broader. The Court thus concludes that the NPA does not cover the +offenses charged in the S1 superseding indictment. +7 + + +Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 8 of 34 +C. Maxwell is not entitled to an evidentiary hearing +In the alternative to dismissing the indictment, Maxwell requests that the Court conduct +an evidentiary hearing as to the parties" intent in the NPA. The Court finds no basis to do so. +The cases Maxwell cites where courts held hearings on the scope of a plea agreement +mostly involved oral agreements where there was no written record of the full set of terms +reached by the parties. All of them involved defendants with first-hand knowledge of +negotiations who claimed prosecutors breached an oral promise. "An oral agreement greatly +increases the potential for disputes such as ... a failure to agree on the existence, let alone the +terms, of the deal." United States v. Aleman, 286 F.3d 86, 90 (2d Cir. 2002). Thus, an +evidentiary hearing may be necessary to determine the terms of an agreement never committed to +writing. This is no such case. The NPA's terms are clear. Beyond the NPA itself, an extensive +OPR report details its negotiation history. No record evidence suggests that prosecutors +promised Epstein anything beyond what was spelled out in writing. The Court agrees with the +Government that Maxwell's request for a hearing rests on mere conjecture. +For the same reason, the Court will not order the discovery on the NPA. In any case, it +appears that the Government has already produced two of the documents Maxwell seeks in her +motion the OPR report and notes mentioned in a privilege log. Of course, the Government's +disclosure obligations would require it to disclose to Maxwell any exculpatory evidence or +evidence material to preparing the defense, including any evidence supporting a defense under +the NPA. The Government shall confirm in writing within one week whether it views any +evidence supporting Maxwell's interpretation of the NPA as material it is required to disclose, +and, if so, whether it has disclosed any and all such evidence in its possession. +8 + + +Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 9 of 34 +I. The indictment is timely +A. The indictment complies with the statute of limitations +Federal law imposes a five-year limitations period for most non-capital offenses. 18 +U.S.C. § 3282(a). Recognizing the difficulty of promptly prosecuting crimes against children, +Congress has provided a longer limitations period for "offense[s] involving the sexual or +physical abuse, or kidnaping" of a minor. 18 U.S.C. § 3283. Until 2003, the operative version +of § 3283 allowed prosecution of these offenses until the victim reached the age of twenty-five. +Congress further extended the limitations period in the PROTECT Act of 2003, Pub. L. No. 108- +21, 117 Stat. 650, to allow prosecution any time during the life of the victim. +The parties agree that the Mann Act charges are timely if subject to the PROTECT Act, +but untimely under the general statute of limitations for non-capital offenses or the pre-2003 +version of § 3283. Maxwell contends that the charged offenses do not qualify as offenses +involving the sexual or physical abuse or kidnapping of a minor and are thus governed by the +general statute of limitations. Alternatively, she contends that the pre-2003 version of § 3283 +applies because the charged conduct occurred prior to 2003. The Court concludes that statute of +limitations in the PROTECT Act applies and that the charges are timely. +1. The Mann Act charges are offenses involving the sexual abuse of minors +Maxwell does not dispute that the facts alleged in the S1 superseding indictment involve +the sexual abuse of minors. The indictment charges that Epstein sexually abused each of the +alleged minor victims and that Maxwell allegedly enticed them to travel or transported them for +that purpose. Instead, Maxwell contends that charged offenses do not qualify as offenses +involving the sexual abuse of minors because sexual abuse is not an essential ingredient of each +statutory offense. See Bridges v. United States, 346 U.S. 209, 221 (1953). In Maxwell's view, +9 + + +Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 10 of 34 +for example, it is possible to transport a minor with intent to engage in criminal sexual activity +and not follow through with the planned sexual abuse, and so sexual abuse is not an essential +ingredient of the offense. Maxwell makes the same argument for the enticement and related +conspiracy charges. +This approach is analogous to the "categorical approach" employed by courts to evaluate +prior convictions for immigration and sentencing purposes. See Taylor v. United States, 495 +U.S. 575, 602 (1990). Generally speaking, the "categorical approach" requires that courts "look +only to the statutory definitions—i.e., the elements" of the relevant offense to determine if the +provision applies "and not to the particular facts underlying those convictions." Descamps v. +United States, 570 U.S. 254, 261 (2013) (internal quotation marks omitted). Whether a statute +requires a categorical or case-specific approach is a question of statutory interpretation. To +determine whether Congress used the word "offense" in a statute to refer to an offense in the +abstract or to the facts of each individual case, the Court must examine the statute's "text, +context, and history." United States v. Davis, 139 S. Ct. 2319, 2327 (2019). +Though it has not authoritatively settled the question, the Second Circuit has strongly +suggested that Maxwell's approach is the wrong one. In Weingarten v. United States, 865 F.3d +48, 58-60 (2d Cir. 2017), the Second Circuit discussed at length how the text, context, and +history of § 3283 show that Congress intended courts to apply the statute using a case-specific +approach. The Third Circuit reached the same conclusion in United States v. Schneider, 801 +F.3d 186, 196 (3d Cir. 2015). +The Court sees no reason to depart from the reasoning in Weingarten. First, "It]he +Supreme Court's modern categorical approach jurisprudence is confined to the post-conviction +contexts of criminal sentencing and immigration deportation cases." Weingarten, 865 F.3d at 58. +10 + + +Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 11 of 34 +To the extent that the categorical approach is ever appropriate in other contexts, it is +inappropriate here. +The Court begins with the statute's text. Statutes that call for application of the +categorical approach typically deal with the elements of an offense in a prior criminal conviction. +Id. at 59. "The language of § 3283, by contrast, reaches beyond the offense and its legal +elements to the conduct involved]' in the offense. That linguistic expansion indicates Congress +intended courts to look beyond the bare legal charges in deciding whether § 3283 applied." Id. at +59-60 (alteration in original) (quoting § 3283). Maxwell cites one case holding otherwise, but +that case involved a venue statute presenting significantly different concerns. See United States +v. Morgan, 393 F.3d 192, 200 (D.C. Cir. 2004). The Supreme Court has likewise held that a +statute which uses the language "an offense that ... involves fraud or deceit in which the loss to +the victim or victims exceeds $10,000" is "consistent with a circumstance-specific approach." +Nijhawan v. Holder, 557 U.S. 29, 32, 38 (2009) (emphasis added). Thus, the word "involves" +generally means that courts should look to the circumstances of an offense as committed in each +case. This reading accords with a robust legislative history indicating that Congress intended to +apply § 3283 to a wide range of crimes against children. See Weingarten, 865 F.3d at 60; +Schneider, 801 F.3d at 196. +The purposes underlying the categorical approach do not apply here either. For statutes +dealing with prior convictions, "[t]he categorical approach serves "practical' purposes: It +promotes judicial and administrative efficiency by precluding the relitigation of past convictions +in minitrials conducted long after the fact." Moncrieffe v. Holder, 569 U.S. 184, 200-01 (2013). +In the context of § 3283, there is no prior conviction to assess, and the jury will determine in the +first instance whether "the defendant engaged in the applicable abusive conduct." Weingarten, +11 + + +Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 12 of 34 +865 F.3d at 60. Maxwell nonetheless contends that using a case-specific approach for § 3283 +would be impractical because the Government would need to prove conduct beyond the elements +of the offense. It may be true that this approach requires the Government to prove some +additional facts, but any statute-of-limitations defense presents factual issues (including, at least, +when the alleged conduct took place. This is not a serious practical problem and does not +justify setting aside the statute's language and apparent purpose. +Maxwell relies primarily on Bridges v. United States, 346 U.S. 209 (1953), to urge this +Court to cast Weingarten aside. The Supreme Court in Bridges addressed a statute that extended +the limitations period for defrauding the United States during the Second World War. In that +case, the Supreme Court first concluded that making false statements at an immigration hearing +was not subject to the extended limitations period because it lacked any pecuniary element as +required by the statute. Id. at 221. Then, as an alternative basis for its holding, it explained that +the offense did not require fraud as an "essential ingredient." Id. at 222. It reached that +conclusion in large part because the statute's legislative history made clear that Congress +intended it to apply only to a narrow class of war frauds causing pecuniary loss. Id. at 216. +As the Second Circuit explained in Weingarten, Congress had the opposite intent in the +enacting in the PROTECT Act. Weingarten, 865 F.3d at 59 & n. 10. "In passing recent statutes +related to child sex abuse, including extensions of the § 3283 limitations period, Congress +"evinced a general intention to "cast a wide net to ensnare as many offenses against children as +possible."'" Id. at 60 (quoting Schneider, 801 F.3d at 196 (quoting United States v. Dodge, 597 +F.3d 1347, 1355 (11th Cir. 2010) (en bane))). The primary basis for Bridges' holding +legislative history supporting a narrow interpretation- +-does not exist here. Instead, both the +statute's plan meaning and its legislative history suggest it should apply more broadly. +12 + + +Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 13 of 34 +Based on the statute's text, context, and history, the Court follows Weingarten and +concludes that the appropriate inquiry is whether the charged offenses involved the sexual abuse +of a minor on the facts alleged in this case. There is no question that they did. The Court thus +concludes that § 3283 governs the limitations period for the charges here. +2. The 2003 amendment to the statute of limitations applies to these offenses +Maxwell next contends that because the charged conduct took place before the +PROTECT Act's enactment, that statute did not lengthen the statute of limitations applicable to +her alleged offenses. Here too, the Second Circuit has provided guidance in its decision in +Weingarten. Although the court did not provide a definitive answer there, it explained that the +view Maxwell now takes confliets with established principles of retroactivity and the decisions +of at least two other circuit courts. Weingarten, 865 F.3d at 58 & n.8; see Cruz v. Maypa, 773 +F.3d 138, 145 (4th Cir. 2014); United States v. Leo Sure Chief, 438 F.3d 920, 924 (9th Cir. +2006). +The Supreme Court has set out a two-step framework to determine whether a federal +statute applies to past conduct. See Landgraf v. USI Film Products, 511 U.S. 244, 280 (1994). +Courts look first to the language of the statute. If the statute states that it applies to past conduct, +courts must so apply it. Weingarten, 865 F.3d at 54. Otherwise, the statute applies to past +conduct unless doing so would create impermissible retroactive effects. Id. +The Court begins with Landgraf's first step. To assess a statute's meaning here, courts +must consider the text of the statute along with other indicia of congressional intent, including +the statute's history and structure. See Enter. Mortg. Acceptance Co., LLC, Sec. Litig. v. Enter: +Mortg. Acceptance Co., 391 F.3d 401, 406 (2d Cir. 2004). +13 + + +Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 14 of 34 +Section 3283, as amended by the PROTECT Act, broadly states that "[n]o statute of +limitations that would otherwise preclude prosecution for an offense involving the sexual or +physical abuse, or kidnaping, of a child under the age of 18 years shall preclude such prosecution +during the life of the child." The statute lacks an express retroactivity clause, but courts have +held that no such clause is necessary, including for this particular statute. See Leo Sure Chief, +438 F.3d at 923. The statute's plain language unambiguously requires that it apply to +prosecutions for offenses committed before the date of enactment. Instead of simply providing a +new limitations period for future conduct, Congress stated that no statute of limitations that +would otherwise preclude prosecution of these offenses will apply. That is, it prevents the +application of any statute of limitations that would otherwise apply to past conduct. +Courts have reached the same conclusion for other statutes employing similar language. +The Eighth Circuit has held that the 1994 amendments to § 3283, which allowed prosecution of +sex crimes against children until the victim reached age twenty-five, applied to past conduct. See +United States v. Jeffries, 405 F.3d 682, 684-85 (8th Cir. 2005). The Second Circuit has observed +that the Higher Education Technical Amendments of 1991, Pub. L. No. 102-26, 105 Stat. 123, +illustrates language that requires a statute's application to past conduct. See Enter. Mortg. +Acceptance Co., LLC, Sec. Litig., 391 F.3d at 407. That statute eliminated the statute of +limitations for claims on defaulted student loans by stating that "no limitation shall terminate the +period within which suit may be filed." Id. The PROTECT Act's language is quite similar. +The history of § 3283 confirms Congress's intent to apply the extended limitations period +as broadly as the Constitution allows. With each successive amendment to the statute, Congress +further extended the limitations period, recognizing that sex crimes against children "may be +difficult to detect quickly" because children often delay or decline to report sexual abuse. +14 + + +Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 15 of 34 +Weingarten, 865 F.3d at 54. Congress enacted the limitations provision of the PROTECT Act +because it found the prior statute of limitations was "inadequate in many cases." H.R. Conf. +Rep. No. 108-63, at 54 (2003). For example, a person who abducted and raped a child could not +be prosecuted beyond this extended limit even if DNA matching conclusively identified him as +the perpetrator one day after the victim turned 25." Id. +Maxwell makes no argument based on the statute's text. Instead, she contends that +because the House version of the bill included an express retroactivity provision absent from its +final form, the Court should infer that Congress did not intend the statute to apply to past +conduct. However, the legislative history makes clear that Congress abandoned the retroactivity +provision in the House bill only because it would have produced unconstitutional results. The +Supreme Court has explained that a law that revives a time-barred prosecution violates the Ex +Post Facto Clause of the Constitution, but a law that extends an un-expired statute of limitations +does not. Stogner v. California, 539 U.S. 607, 632-33 (2003). Senator Leahy, who cosponsored the PROTECT Act, expressed concerns in a committee report that the proposed +retroactivity provision was "of doubtful constitutionality" because it "would have revived the +government's authority to prosecute crimes that were previously time-barred." 149 Cong. Rec. +S5137, S5147 (Apr. 10, 2003) (statement of Sen. Leahy). Congress removed the provision +shortly thereafter for this reason. The removal of the express retroactivity provision shows only +that Congress intended to limit the PROTECT Act to its constitutional applications, including +past conduct-like Maxwell's- +—on which the statute of limitations had not yet expired. +Both the text and history of the PROTECT Act's amendment to § 3283 reflect that it +applies Maxwell's conduct charged in the S1 superseding indictment. The Court could stop here. +15 + + +Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 16 of 34 +However, it also concludes that even if the statute were ambiguous, it would properly apply to +these charges. +At Lanfgraf's second step, the Court asks whether application of the statute to past +conduct would have impermissible retroactive effects. "[A] statute has presumptively +impermissible retroactive effects when it "takes away or impairs vested rights acquired under +existing laws, or creates a new obligation, imposes a new duty, or attaches a new disability, in +respect to transactions or considerations already past."" Weingarten, 865 F.3d at 56 (quoting +Landgraf, 511 U.S. at 290). Thus, applying a new statute of limitations to previously timebarred claims has an impermissible retroactive effect. Enter. Mortg. Acceptance Co., LLC, Sec. +Litig., 391 F.3d at 407. Applying it to conduet for which the statute of limitations has not yet +expired does not. Vernon v. Cassadaga Valley Cent. Sch. Dist., 49 F.3d 886, 890 (2d Cir. 1995). +Maxwell concedes that these offenses were within the statute of limitations when +Congress enacted the PROTECT Act. Thus, the Act did not deprive her of any vested rights. +Maxwell contends that it is unfair to allow the Government to prosecute her now for conduct that +occurred more than twenty years ago, but there is no dispute that Congress has the power to set a +lengthy limitations period or no limitations period at all. It has done so here, judging that the +difficulty of prosecuting these offenses and the harm they work on children outweighs a +defendant's interest in repose. Maxwell's fairness argument is a gripe with Congress's policy +judgment, not an impermissibly retroactive application of the statute. The Court concludes that +$ 3283 allows her prosecution now. +B. The Government's delay in bringing charges did not violate due process +"As the Supreme Court stated in United States v. Marion, the statute of limitations is the +primary guarantee against bringing overly stale criminal charges."" United States v. Cornielle, +16 + + +Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 17 of 34 +171 F.3d 748, 751 (2d Cir. 1999) (cleaned up) (quoting United States v. Marion, 404 U.S. 307, +322 (1971)). There is a strong presumption that an indictment filed within the statute of +limitations is valid. To prevail on a claim that pre-indictment delay violates due process, a +defendant must show both that the Government intentionally delayed bringing charges for an +improper purpose and that the delay seriously damaged the defendant's ability defend against the +charges. See id. This is a stringent standard. "Thus, while the [Supreme] Court may not have +shut the door firmly on a contention that at some point the Due Process Clause forecloses +prosecution of a claim because it is too old, at most the door is barely ajar." DeMichele v. +Greenburgh Cent. Sch. Dist. No. 7, 167 F.3d 784, 790-91 (2d Cir. 1999). +The Court sees no evidence that the Government's delay in bringing these charges was +designed to thwart Maxwell's ability to prepare a defense. However, it is enough to say that +Maxwell does not make the strong showing of prejudice required to support this sort of claim. +Maxwell contends that the Government's delay in bringing charges has prejudiced her interests +because potential witnesses have died, others have forgotten, and records have been lost or +destroyed. It is highly speculative that any of these factors would make a substantial difference +in her case. +Maxwell first points to several potential witnesses who have passed away. These include +Jeffrey Epstein and his mother, one individual Maxwell believes worked with one of the alleged +victims in this case, and a police detective who investigated Epstein in Florida. She contends +they all would have provided exculpatory testimony were they alive today. Courts have +generally found that vague assertions that a deceased witness might have provided favorable +testimony do not justify dismissing an indictment for delay. See, e.g., United States v. Scala, 388 +F. Supp. 2d 396, 399-400 (S.D.N.Y. 2005). The Court agrees with this approach. Maxwell +17 + + +Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 18 of 34 +provides no indication of what many of these potential witnesses might have testified to. The +testimony she suggests the detective might have offered that witnesses in the Palm Beach +investigation did not identify Maxwell by name—is propensity evidence that does nothing to +establish her innocence of the charged offenses. There are also serious doubts under all of the +relevant circumstances that a jury would have found testimony from Epstein credible even if he +had waived his right against self-incrimination and testified on her behalf. See United States v. +Spears, 159 F.3d 1081, 1085 (7th Cir. 1999). +Maxwell's arguments that the indictment should be dismissed because of the possibility +of missing witnesses, failing memories, or lost records fail for similar reasons. These are +difficulties that arise in any case where there is extended delay in bringing a prosecution, and +they do not justify dismissing an indictment. United States v. Marion, 404 U.S. 307, 325-26 +(1971); see United States v. Elsbery, 602 F.2d 1054, 1059 (2d Cir. 1979). +Finally, the Court finds no substantial prejudice from the pretrial publicity this case has +garnered. Maxwell contends that lengthy public interest in this case has transformed her +reputation from that of Epstein's friend to a co-conspirator. And she also alleges without +evidence that her accusers fabricated their stories based on media allegations. The Court will +not dismiss the indictment on Maxwell's bare assertion that numerous witnesses are engaged in a +perjurious conspiracy against her. And the Court will take all appropriate steps to ensure that the +pretrial publicity in this case does not compromise Maxwell's right to a fair and impartial jury. +The Court thus concludes that Maxwell has failed to establish actual prejudice from the +Government's delay in bringing charges. She may renew her motion if the factual record at trial +shows otherwise. On the present record, neither the applicable statute of limitations nor due +process bars the charges here. +18 + + +Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 19 of 34 +III. The indictment describes the charged offenses with specificity +Maxwell seeks to dismiss the Mann Act counts for lack of specificity or in the alternative +to compel the Government to submit a bill of particulars providing greater detail of the charges. +The Court concludes that the charges in the S1 superseding indictment are clear enough. +Under Federal Rule of Criminal Procedure 7, an indictment must contain "a plain, +concise, and definite written statement of the essential facts constituting the offense charged." +The indictment must be specific enough to inform the defendant of the charges and allow the +defendant to plead double jeopardy in a later prosecution based on the same events. United +States v. Stavroulakis, 952 F.2d 686, 693 (2d Cir. 1992). 'Under this test, an indictment need do +little more than to track the language of the statute charged and state the time and place (in +approximate terms) of the alleged crime." United States. v. Tramunti, 513 F.2d 1087, 1113 (2d +Cir. 1975). In addition to dismissal, "Rule 7(f) of the Federal Rules of Criminal Procedure +permits a defendant to seek a bill of particulars in order to identify with sufficient particularity +the nature of the charge pending against him, thereby enabling defendant to prepare for trial, to +prevent surprise, and to interpose a plea of double jeopardy should he be prosecuted a second +time for the same offense." United States v. Bortnovsky, 820 F.2d 572, 574 (2d Cir. 1987). +The S1 superseding indictment sets out the elements of each charged crime and the facts +supporting each element. Nonetheless, Maxwell contends that the indictment is too vague +because it refers to open-ended time periods, describes conduct like "grooming" and +"befriending" that is not inherently criminal, and does not identify the alleged victims by name. +Maxwell's first argument fails because the Government need only describe the time and +place of charged conduct "in approximate terms." Tramunti, 513 F.2d at 1113. The details are +subject to proof at trial. "[T]he Second Circuit routinely upholds the 'on or about' language used +19 + + +Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 20 of 34 +to describe the window of when a violation occurred." United States v. Kidd, 386 F. Supp. 3d +364, 369 (S.D.N.Y. 2019) (quoting United States v. Nersesian, 824 F.2d 1294, 1323 (2d Cir. +1987)). "This is especially true in cases of sexual abuse of children: allegations of sexual abuse +of underage victims often proceed without specific dates of the offenses." United States v. +Young, No. 08-cr-285 (KMK), 2008 WL 4178190, at *2 (S.D.N.Y. Sept. 4, 2008) (collecting +cases). As here, these cases frequently involve alleged abuse spanning a lengthy period of time, +and witnesses who were victimized as children may struggle to recall the precise dates when +abuse occurred. The indictment adequately describes the time and place of the charged conduct. +Maxwell next contends that allegations of noncriminal conduct render the charges +impermissibly vague. The Court disagrees. Rule 7 requires only that the language of the +indictment track the language of the statute and provide a rough account of the time and place of +the crime. Tramunti, 513 F.2d at 1113. The language of the S1 superseding indictment does so. +The Government's decision to provide more details than those strictly required does not hamper +Maxwell's ability to prepare a defense. Maxwell's argument that some of the conduct alleged is +not inherently criminal goes to the merits of the Government's case, not the specificity of the +charges. +Finally, Maxwell argues that the indictment is vague because the government does not +provide the names of the alleged victims. The Court sees no basis to require that the alleged +victims' names be included the indictment. The names of victims, even if important, generally +need not appear there unless their omission would seriously prejudice the defendant. See United +States v. Stringer, 730 F.3d 120, 127 (2d Cir. 2013); United States v. Kidd, 386 F. Supp. 3d 364, +369 (S.D.N.Y. 2019). Maxwell likely knows the identity of the alleged victims described in the +indictment at this point because the Government has provided extensive discovery on them. +20 + + +Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 21 of 34 +Moreover, the Government has agreed to disclose their names in advance of trial. There is thus +no unfairness here. See Stringer, 730 F.3d at 126. As discussed below, the Court will require +the parties to negotiate and propose a full schedule for all remaining pretrial disclosures. +IV. The perjury charges are legally tenable +The Court turns next to Maxwell's motion to dismiss the perjury counts stemming from +her answers to questions in a deposition in a civil case. She contends that these charges are +legally deficient because the questions posed were fundamentally ambiguous and the questions +were not material to the subject of the deposition. The Court concludes that the charges are +legally tenable and Maxwell's defenses are appropriately left to the jury. +The applicable perjury statute imposes criminal penalties on anyone who "in any +proceeding before or ancillary to any court... knowingly makes any false material declaration." +18 U.S.C. § 1623(a). Testimony is perjurious only if it is knowingly false and is material to the +proceeding in which the defendant offered it. +A. The questions posed were not too ambiguous to support a perjury charge +The requirement of knowing falsity requires that a witness believe that their testimony is +false. United States v. Lighte, 782 F.2d 367, 372 (2d Cir. 1986). As a general matter, "[a] jury is +best equipped to determine the meaning that a defendant assigns to a specific question." Id. +Courts have acknowledged a narrow exception for questions that are so fundamentally +ambiguous or imprecise that the answer to them cannot legally be false. Id. at 372, 375; see also +United States v. Wolfson, 437 F.2d 862, 878 (2d Cir. 1970). A question is fundamentally +ambiguous only if reasonable people could not agree on its meaning in context. Lighte, 782 F.2d +at 375. The existence of some arguable ambiguity does not foreclose a perjury charge against a +witness who understood the question. +21 + + +Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 22 of 34 +At a minimum, Maxwell's motion is premature. Courts typically evaluate whether a +question was fundamentally ambiguous only after the development of a full factual record at +trial. See, e.g., United States v. Markiewicz, 978 F.2d 786, 808 (2d Cir. 1992). The evidence at +trial may shed further light on whether the questions posed were objectively ambiguous in +context or whether Maxwell subjectively understood them. In any event, the Court has closely +considered each of the categories of questions that Maxwell argues are ambiguous. None of the +alleged ambiguities Maxwell identifies rise to the level supporting dismissal of the charges. The +context of the questions and answers, in conjunction with the Government's evidence, could lead +a reasonable juror to conclude that the statements were perjurious. Truth and falsity are +questions for the jury in all but the most extreme cases. The Court declines to usurp the jury's +role on the limited pretrial record. +B. A reasonable juror could conclude that Maxwell's statements were material +Maxwell also argues that the perjury counts should be dismissed because none of the +allegedly false statements were material to the defamation action. In a civil deposition, a +statement is material if it has a natural tendency to influence the court or if a truthful answer +might reasonably lead to the discovery of admissible evidence. United States v. Gaudin, 515 +U.S. 506, 509 (1995); United States v. Kross, 14 F.3d 751, 753-54 (2d Cir. 1994). Like knowing +falsity, materiality is an element of the offense and thus ordinarily must be "decided by the jury, +not the court." Johnson v. United States, 520 U.S. 461, 465 (1997). Only the most extraordinary +circumstances justify departure from this general rule. United States v. Forde, 740 F. Supp. 2d +406, 412 (S.D.N.Y. 2010) (citing Gaudin, 515 U.S. at 522-23). +The charged statements do not fall within this narrow exception. Maxwell contends that +the questions did not relate to the sex trafficking and sexual abuse allegations at the center of the +22 + + +Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 23 of 34 +civil case, but that is not the legal standard. The Government may prevail if it proves that +Maxwell's answers could have led to the discovery of other evidence or could influence the +factfinder in the civil case. See Gaudin, 515 U.S. at 509; Kross, 14 F.3d at 753-54. At trial, a +reasonable juror could conclude that truthful answers to the questions may have permitted the +plaintiff to locate other victims or witnesses who could have corroborated the plaintiff's +testimony. The factual disputes relating to materiality are at least enough to preclude pretrial +resolution. In criminal cases, courts must guard against 'invading the "inviolable function of the +jury® in our criminal justice system," and if the "defense raises a factual dispute that is +inextricably intertwined with a defendant's potential culpability, a judge cannot resolve that +dispute on a Rule 12(b) motion." United States v. Sampson, 898 F.3d 270, 281 (2d Cir. 2018). +The Court concludes that the perjury charges are legally tenable and appropriately +presented to the jury. +V. The perjury charges must be severed and tried separately +Although the perjury charges are legally tenable, the Court concludes that the interests of +justice require severing those counts and trying them separately. Trying the perjury counts +together with the Mann Act counts would require admitting evidence of other acts likely to be +unduly prejudicial. It would also risk disqualifying Maxwell's chosen counsel based on their +involvement in the earlier civil case. +Rule 14(a) of the Federal Rules of Criminal Procedure allows a court to order separate +trials if joining all offenses in a single trial would prejudice the defendant. A defendant seeking +severance must show significant unfairness to outweigh the burden on the court of conducting +multiple trials. United States v. Walker, 142 F.3d 103, 110 (2d Cir. 1998). The harm to the +defendant must be more than "solely the adverse effect of being tried for two crimes rather than +23 + + +Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 24 of 34 +one." United States v. Werner, 620 F.2d 922, 929 (2d Cir. 1980). Though this standard is +demanding, the Court concludes that, due to unique features of the perjury counts, Maxwell +meets it here. Trying all counts together would compromise Maxwell's right to the counsel of +her choice and risk an unfair trial. +Trying the perjury counts together with the Mann Act counts would risk an unfair trial on +each set of counts. First, it would introduce unrelated allegations of sexual abuse, which would +potentially expose the jury to evidence that might otherwise not be admissible. In particular, a +joint trial would potentially expose the jury to a wider swath of information regarding civil +litigation against Epstein that is remote from Maxwell's charged conduct. This presents a +significant risk that the jury will cumulate the evidence of the various crimes charged and find +guilt when, if considered separately, it would not do so. See United States v. Halper, 590 F.2d +422, 430 (2d Cir. 1978). Second, the evidence presented on the Mann Act counts may prejudice +the jury's ability to fairly evaluate Maxwell's truthfulness in her deposition, a critical element of +the perjury counts. The Court has concerns that a limiting instruction may be inadequate to +mitigate these risks given the nature of the allegations involved. +Importantly, a joint trial is also likely to require disqualification of at least one of +Maxwell's attorneys from participating as an advocate on her behalf. The perjury counts likely +implicate the performance and credibility of her lawyers in the civil action- +—two of whom +represent her in this case. The New York Rules of Professional Conduct generally forbid a +lawyer from representing a client in a proceeding in which the lawyer is likely also to be a +witness. N.Y. R. Prof'l Conduct § 3.7(a). Maxwell's counsel in the civil action and the +deposition may be important fact witnesses on the perjury counts. Even if counsel were not +required to testify, trying all counts together could force Maxwell to choose between having her +24 + + +Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 25 of 34 +counsel testify on her behalf on the perjury charges and having them assist her in defending the +Mann Act charges. +The Second Circuit has recognized that witness testimony offered by a party's attorney +presents serious risks to the fairness of a trial. See Murray v. Metro. Life Ins. Co., 583 F.3d 173, +178 (2d Cir. 2009). The lawyer might appear to vouch for their own credibility, jurors might +perceive the lawyer as distorting the truth to benefit their client, and blurred lines between +argument and evidence might confuse the jury. Id. Disqualification of counsel also implicates +Maxwell's Sixth Amendment right to be represented by the counsel of her choice. See, e.g., +United States v. Kincade, No. 15-cr-00071 (JAD) (GWF), 2016 WL 6154901, at *6 (D. Nev. +Oct. 21, 2016). The prejudice to Maxwell is especially pronounced because the attorneys who +represented her in the civil case have worked with her for years and are particularly familiar with +the facts surrounding the criminal prosecution. See United States v. Cunningham, 672 F.2d +1064, 1070-71 (2d Cir. 1982). +The Court is of course cognizant of the burden separate trials may impose on all trial +participants. But much of the proof relevant to the perjury counts and the Mann Act counts does +not overlap. In particular, materiality for statements made in a civil deposition is broad, and +evidence on that question is unlikely to bear on the other charges here. See Kross, 14 F.3d at +753-54; Gaudin, 515 U.S. at 509. Although some allegations of sexual abuse are relevant to +both sets of charges, many are not. At a minimum, this will expand the scope of the trial far +beyond the narrower issues presented. And while the Court agrees with the Government that at +least some of Maxwell's concerns are overstated, there is little question that the jury's +consideration of the nature of the defamation action will require a significant investment of time +and resources to provide the requisite context. +25 + + +Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 26 of 34 +The balance of these considerations favors severance. "Motions to sever are committed +to the sound discretion of the trial judge." United States v. Casamento, 887 F.2d 1141, 1149 (2d +Cir. 1989). In its discretion, the Court concludes that trying the perjury counts separately will +best ensure a fair and expeditious resolution of all charges in this case. +VI. Maxwell's motion to strike surplusage is premature +Maxwell moves to strike allegations related to one of the alleged victims from the S1 +superseding indictment as surplusage. The Court declines to do so at this juncture. +Federal Rule of Criminal Procedure 7(d) allows a court to strike surplusage from an +indictment on a defendant's motion. "Motions to strike surplusage from an indictment will be +granted only where the challenged allegations are not relevant to the crime charged and are +inflammatory and prejudicial." United States v. Hernandez, 85 F.3d 1023, 1030 (2d Cir. 1996) +(cleaned up). Courts in this District generally delay ruling on any motion to strike until after the +presentation of the Government's evidence at trial, because that evidence may affect how +specific allegations relate to the overall charges. See, e.g., United States v. Nejad, No. 18-cr-224 +(AJN), 2019 WL 6702361, at *18 (S.D.N.Y. Dec. 6, 2019); United States v. Mostafa, 965 F. +Supp. 2d 451, 467 (S.D.N.Y. 2013). +Maxwell contends that the allegations related to "Minor Vietim-3" are surplusage +because the indictment does not charge that Minor Vietim-3 traveled in interstate commerce or +was below the age of consent in England where the alleged activities took place. Thus, she +argues, these allegations do not relate to the charged conspiracy and instead reflect an attempt to +introduce Minor Victim-3's testimony for impermissible purposes. +The Court will not strike any language from the S1 superseding indictment at this +juncture. The standard under Rule 7(d) is "exacting" and requires the defendant to demonstrate +26 + + +Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 27 of 34 +clearly that the allegations are irrelevant to the crimes charged. United States v. Napolitano, 552 +F. Supp. 465, 480 (S.D.N.Y. 1982). The indictment does not allege that the alleged victim +traveled in interstate commerce or was underage during sexual encounters with Epstein. But the +Court cannot rule out that the allegations may reflect conduct undertaken in furtherance of the +charged conspiracy or be relevant to prove facts such as Maxwell's state of mind. See United +States v. Concepcion, 983 F.2d 369, 392 (2d Cir. 1992). The Court will follow the well-worn +path of others in this District and reserve the issue for trial. Maxwell may renew her motion +then. +VII. Maxwell's motion to dismiss multiplicitous charges is premature +Maxwell's motion to dismiss either the first or third count of the S1 superseding +indictment as multiplicitous is also premature. Maxwell contends that the Government has +alleged the same conspiracy twice in the indictment. "An indictment is multiplicitous when it +charges a single offense as an offense multiple times, in separate counts, when, in law and fact, +only one crime has been committed." United States v. Chacko, 169 F.3d 140, 145 (2d Cir. 1999). +"The multiplicity doctrine is based upon the double jeopardy clause of the Fifth Amendment, +which assures that the court does not exceed its legislative authorization by imposing multiple +punishments for the same offense." United States v. Nakashian, 820 F.2d 549, 552 (2d Cir. 1987) +(cleaned up). +"Where there has been no prior conviction or acquittal, the Double Jeopardy Clause does +not protect against simultaneous prosecutions for the same offense, so long as no more than one +punishment is eventually imposed." United States v. Josephberg, 459 F.3d 350, 355 (2d Cir. +2006). "Since Josephberg, courts in this Circuit have routinely denied pre-trial motions to +dismiss potentially multiplicitous counts as premature." United States v. Medina, No. 13-cr-272 +27 + + +Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 28 of 34 +(PGG), 2014 WL 3057917, at *3 (S.D.N. Y. July 7, 2014) (collecting cases). The Court therefore +denies Maxwell's motion to dismiss multiplicitous counts without prejudice. +VIII. The parties shall negotiate all remaining disclosures +Maxwell moves to compel the Government to produce certain documents she believes it +has in its possession and has failed to produce. She also seeks accelerated disclosure of the +Government's witness list, Jencks Act material, Brady and Giglio material, co-conspirator +statements, and Rule 404(b) material. Based on the Government's response in briefing and +letters the parties have since submitted to the Court, it appears that most of these requests have +been overtaken by events. Accordingly, although the Court concludes that Maxwell is not +entitled to expedite this discovery based on the arguments in her motion papers, the Court will +require the parties to confer on an overall schedule for all remaining pretrial disclosures. +A. The Court accepts the Government's representations that it has disclosed all +Brady and Giglio Material +The Supreme Court's decisions in Brady v. Maryland, 373 U.S. 83 (1963) and Giglio v. +United States, 405 U.S. 150 (1972) require the Government to disclose to defendants certain +evidence that will aid their defense. Brady requires disclosure of exculpatory evidence. Under +Giglio, the Government has a duty to produce "not only exculpatory material, but also +information that could be used to impeach a key government witness." United States v. Coppa, +267 F.3d 132, 135 (2d Cir. 2001) (citing Giglio, 405 U.S. at 154). As a general rule, "Brady and +its progeny do not require immediate disclosure of all exculpatory and impeachment material +upon request by a defendant." Id. at 146. "[A]s long as a defendant possesses Brady evidence in +time for its effective use, the government has not deprived the defendant of due process of law +simply because it did not produce the evidence sooner." Id. at 144. +28 + + +Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 29 of 34 +Maxwell requests an order directing immediate disclosure of all Brady and Giglio +material and also requests a few specific documents she contends the Government has failed to +disclose. The Court begins with the specific requests. The requested materials include (1) +records of witness interviews in connection with an ex parte declaration in support of a response +to a motion to quash subpoenas; (2) an unredacted copy of two FBI reports; (3) pages from a +personal diary that is in the custody of a civilian third party; and (4) copies of all subpoenas the +Government has issued for Maxwell's records as part of its investigation in this case. +The Government represents that it is cognizant of its Brady obligations, that is has +reviewed the witness interviews and one of the FBI reports, and that neither set of documents +includes exculpatory information not previously disclosed. The Court has no reason to doubt the +Government's representation in this case that it is aware of its Brady obligations and that it has +complied and will continue to comply with them. And because the witness statements are +covered by the Jencks Act, the Court cannot compel production of such statements under the +terms of the statute. See 18 U.S.C. § 3500; Coppa, 267 F.3d at 145. Next, the Government +represents that it has already produced an unredacted copy of the other requested FBI report, and +so that request is moot. The diary pages she requests are within the control of a civilian third +party, not the Government, and so the Government need not (and perhaps cannot) produce them. +See United States v. Collins, 409 F. Supp. 3d 228, 239 (S.D.N.Y. 2019). Finally, Maxwell's +request for copies of all subpoenas the Government has issued is overly broad and lacks a legal +basis. Maxwell is not entitled to compel production of these documents. +The Court also will not issue an order requiring the immediate disclosure of Brady and +Giglio material. The Government has represented that it recognizes its obligations under Brady +and that it has complied, and will continue to comply, with such obligations. The Court has no +29 + + +Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 30 of 34 +reason to doubt these representations given its expansive approach to document production thus +far in this case. The Government has agreed in its recent letter to produce Giglio material six +weeks in advance of trial. The parties shall negotiate the specific timing, but assuming a +schedule along those lines is met, the Court concludes that Maxwell will be able to effectively +prepare for trial. See Coppa, 267 F.3d at 144. +B. Jencks Act material and co-conspirator statements +Maxwell also seeks to expedite discovery of Jencks Act material and non-exculpatory +statements of co-conspirators that the government may offer at trial. The Jencks Act, 18 U.S.C. +§ 3500, "provides that no prior statement made by a government witness shall be the subject of +discovery until that witness has testified on direct examination." Coppa, 267 F.3d at 145. The +statute therefore prohibits a district court in most cases from ordering the pretrial disclosure of +witness statements unless those statements are exculpatory. "A coconspirator who testifies on +behalf of the government is a witness under the Act." In re United States, 834 F.2d 283, 286 (2d +Cir. 1987). The Court therefore lacks the inherent power to expedite these disclosures. In any +case, the Government has agreed to produce all Jencks Act material at least six weeks in advance +of trial. +The Court also rejects Maxwell's alternative request for a hearing to determine the +admissibility of co-conspirator declarations. Co-conspirator statements may often be admitted at +trial on a conditional basis. If the Court determines that the Government has not met its burden +to show that the conditionally admitted statements were made in furtherance of the charged +conspiracy, the Court should provide a limiting instruction or, in extreme cases declare a +mistrial. United States v. Tracy, 12 F.3d 1186, 1199 (2d Cir. 1993). Although conditional +admissions can pose a problem, a pretrial hearing is unnecessary here because the Government +30 + + +Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 31 of 34 +has committed to producing co-conspirator statements at least six weeks in advance of trial to +allow Maxwell to raise any objections. Maxwell will have adequate time to object to any +proffered co-conspirator testimony following the Government's Jencks Act disclosures. +C. Witness list +As a general matter, "district courts have authority to compel pretrial disclosure of the +identity of government witnesses." United States v. Cannone, 528 F.2d 296, 300 (2d Cir. 1975). +In deciding whether to order accelerated disclosure of a witness list, courts consider whether a +defendant has made a specific showing that disclosure is "both material to the preparation of the +defense and reasonable in light of the circumstances surrounding the case." United States v. +Bejasa, 904 F.2d 137, 139-140 (2d Cir. 1990) (cleaned up). +Maxwell has made a particularized showing that the Government must produce a witness +list reasonably in advance of trial. The nature of the allegations in this case decades-old +allegations spanning multiple locations present considerable challenges for the preparation of +the defense. However, the Government's proposed disclosure schedule —which will afford +Maxwell at least six weeks to investigate testifying witness statements-allows Maxwell +significantly more time to review disclosures than schedules adopted in most cases in this +District. See, e.g., United States v. Rueb, No. 00-CR-91 (RWS), 2001 WL 96177, at *9 +(S.D.N.Y. Feb. 5, 2001) (thirty days before trial); United States v. Nachamie, 91 F. Supp. 2d 565, +580 (S.D.N.Y. 2000) (fourteen days before trial). In addition, on April 13, 2021, the +Government produced over 20,000 pages of interview notes, reports and other materials related +to non-testifying witnesses. After considering the circumstances, including the complexity of the +issues in this case and what the defense has already received and likely learned in the course of +discovery, the Court concludes that the Government's proposal is generally reasonable. +31 + + +Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 32 of 34 +D. Rule 404(b) material +Maxwell's final discovery request is for early disclosure of evidence the Government +seeks to offer under Federal Rule of Evidence 404(b). Under Rule 404(b), if the prosecutor in a +criminal case intends to use "evidence of a crime, wrong, or other act" against a defendant, the +prosecutor must "provide reasonable notice of the general nature of any such evidence that the +prosecutor intends to offer at trial" and must "do so in writing before trial—or in any form +during trial if the court, for good cause, excuses lack of pretrial notice." The Government +represents that it will notify the defense of its intent to use 404(b) evidence at least 45 days in +advance of trial to allow Maxwell to file any motions in limine to be considered at the final +pretrial conference. The Government's proposal will give Maxwell an opportunity to challenge +admission of that evidence and to bring to the Court's attention any issues that require resolution +before trial. "This is all that Rule 404(b) requires." United States v. Thompson, No. 13-cr-378 +(AJN), 2013 WL 6246489, at *9 (S.D.N.Y. Dec. 3, 2013). The Court concludes this schedule is +generally reasonable, although additional time to enable briefing and resolution in advance of +trial is strongly encouraged. +The Court's denial of Maxwell's requests to compel pretrial disclosures does not preclude +the parties from negotiating in good faith for an expedited discovery timeline that will account +for Maxwell's specific concerns. "[I]n most criminal cases, pretrial disclosure will redound to +the benefit of all parties, counsel, and the court." United States v. Percevault, 490 F.2d 126, 132 +(2d Cir. 1974). In general, the Court will require the parties to negotiate a final, omnibus +schedule to propose to the Court. The Court concludes that the disclosure of all of the above +materials approximately six to eight weeks in advance of trial is appropriate and sufficient. +32 + + +Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 33 of 34 +Given the complexities of the case and the addition of two counts via the S2 indictment, the +Court encourages the parties to agree to approximately eight weeks. +IX. The S2 superseding indictment moots Maxwell's grand jury challenge +The Court has not received supplemental briefing on the motions in light of the return of +the S2 superseding indictment and so does resolve any such issues here.' However, Maxwell's +motion seeking to dismiss the S1 superseding indictment because it was returned by a grand jury +sitting at the White Plains courthouse appears moot. Maxwell argued that the use of a grand jury +drawn from the White Plains Division in this District did not represent a fair cross-section of the +community, because her trial would proceed in the Manhattan Division. A grand jury sitting in +Manhattan returned the S2 superseding indictment. By April 21, 2021, Maxwell shall show +cause why her grand jury motion should not be dismissed on that basis. +Conclusion +The Court DENIES Maxwell's motions to dismiss the indictment as barred by Epstein's +non-prosecution agreement (Dkt. No. 141), to dismiss the Mann Act counts as barred by the +statute of limitations (Dkt. No. 143), to dismiss the indictment for pre-indictment delay (Dkt. No. +137), to dismiss the Mann Act counts for lack of specificity (Dkt. No. 123), to dismiss the +perjury counts as legally untenable (Dkt. No. 135), to strike surplusage (Dkt. No. 145), to +dismiss count one or count three as multiplicitous (Dkt. No. 121), and to expedite pretrial +disclosures (Dkt. No. 147). The Court GRANTS Maxwell's motion to sever the perjury counts +for a separate trial (Dkt. No. 119). +' The parties shall negotiate and propose a schedule for any available additional or supplement rulings in +light of the filing of the S2 indictment. +33 + + +Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 34 of 34 +The Court ORDERS the Government to confirm within one week whether it considers +any evidence related to negotiation of the non-prosecution agreement to constitute Brady or Rule +16 material and, if so, to confirm that it has or will disclose such evidence. +The Court further ORDERS the parties to negotiate a final schedule for all pretrial +disclosures that remain outstanding, including: Brady, Giglio, and Jenks Act materials, including +co-conspirator statements; non-testifying witness statements; testifying witness statements; the +identity of victims alleged in the indictment; 404(b) material; and the Government's witness list. +The Court also requires the parties to negotiate a schedule for any additional or supplemental +motions briefing in light of the S2 indietment. The Court ORDERS a joint proposal to be +submitted by April 21, 2021. If agreement is not reached, the parties shall submit their +respective proposals. +The Court further ORDERS Maxwell to show cause by April 21, 2021 why her motion to +dismiss the S1 superseding indictment under the Sixth Amendment (Dkt. No. 125) should not be +denied as moot. +SO ORDERED. +Dated: April 16, 2021 +New York, New York +Alie O. Notto +ALISON J. NATHAN +United States District Judge diff --git a/vision-fixhub/ds9-parsed-01/11eed7dd39728cc9d98a359c95c250fe2e9ad825782aed11cf43271cd506760f.receipt.json b/vision-fixhub/ds9-parsed-01/11eed7dd39728cc9d98a359c95c250fe2e9ad825782aed11cf43271cd506760f.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..c3a3d6945bc6ce58d84e737860fbd6430d7f8d79 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/11eed7dd39728cc9d98a359c95c250fe2e9ad825782aed11cf43271cd506760f.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -416, + "dataset": "marble-joined", + "doc_id": "11eed7dd39728cc9d98a359c95c250fe2e9ad825782aed11cf43271cd506760f", + "engine": "marble-apple-vision", + "event_count": 38, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "795049d4a4772a4d1aff7d0585db98d52a3fedccacbc973b6075263b4ae4f467", + "output_sha256": "481edd3954f562af1a8221424d34ba036444ca8ea927e937aa2cb781b5ab4c99", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/11fd246fa558d8b7a8e90137c3e4bd0c40f33bc8999f984c96469428b2cd57e3.md b/vision-fixhub/ds9-parsed-01/11fd246fa558d8b7a8e90137c3e4bd0c40f33bc8999f984c96469428b2cd57e3.md new file mode 100644 index 0000000000000000000000000000000000000000..ee0ee2d3ee2e965359e1ce908d5a802fb1e14283 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/11fd246fa558d8b7a8e90137c3e4bd0c40f33bc8999f984c96469428b2cd57e3.md @@ -0,0 +1,110 @@ +U.S. Customs and Border Protection +U.S. Department of Homeland Security +TECS - Person Query +Generated By: +09/23/2019 15:13 PM EDT +TECS RECORD ID: P9206925800C90 +IMAGE INFORMATION - PART I (0) +PERSON SUBJECT QUERY DETAILS INFORMATION +Tecs Record ID +P9206925800C90 +Record Status +NP - NON-SUSPECT. +PRIVATE AIRCRAFT INSPECTION +Query Notification +0 - No notification +Primary Action +0 - NOT ON PRIMARY +Last Name +MAXWELL +Alias (0) +Approval Status +Entry Date +|03/1B/1992 +Start Date +First Name +GHISLAINE +Date of Birth (1) +1) +(57 years old) +No Fly Indicator +REMARKS INFORMATION (1) +No +Date +1 +03/18/1992 +Race (0) +Remarks +PRIVATE AIRCRAFT ENFORCEMENT +SYSTEM +PERSONAL DATA INFORMATION +Nickname (0) +Height +Weight +PERSONAL IDENTIFICATION INFORMATION +Citizenship (1) +1) GBR - UNITED KINGDOM +BIRTH PLACE INFORMATION (0) +ALIEN INFORMATION (O) +EXCLUSION INFORMATION (0) +PASSPORT INFORMATION (0) + +Update Date +|07/14/1998 +Category +Stop Date +Middle Name +Hispanic Indicator +U - UNKNOWN +Selectee Indicator +N +Gender (0) +Hair (0) +Eyes (0) +Scars/Marks/Tattoos +Units +ENGLISH +SSN (0) +Residency Status +For Official Use Only / Law Enforcement Sensitive + + +U.S. Customs and Border Protection +U.S. Department of Homeland Security +TECS - Person Query +Generated By: +09/23/2019 15:13 PM EDT +ADDRESS INFORMATION (0) +DRIVERS' LICENSE INFORMATION (0) +PHONE INFORMATION (0) +ALTERNATE COMMUNICATION INFORMATION (0) +MISCELLANEOUS INFORMATION (0) +CRIMINAL AFFILIATION INFORMATION (0) +CONTACT INFORMATION +Organization +CBP FIELD OPS - HO, PRIVATE AIRCRAFT OPS +CASE NUMBER INFORMATION (O) +FINGER PRINT INFORMATION +No +Left +Code +Description +1 +2 +4 +5 +SPOUSE INFORMATION (D) +WARRANT INFORMATION (0) +ATF PROFILE INFORMATION (O) +BAGGAGE DECLARATION (CF6059) INFORMATION (0) +FINANCIAL INFORMATION (0) +EMPLOYMENT INFORMATION (0) +PILOT LICENSE INFORMATION (0) +IMAGE INFORMATION - PART II (0) +Full Name +Telephone +Right +Code +Description +For Official Use Only / Law Enforcement Sensitive + diff --git a/vision-fixhub/ds9-parsed-01/11fd246fa558d8b7a8e90137c3e4bd0c40f33bc8999f984c96469428b2cd57e3.receipt.json b/vision-fixhub/ds9-parsed-01/11fd246fa558d8b7a8e90137c3e4bd0c40f33bc8999f984c96469428b2cd57e3.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..7b0a706f9c8d86e26608fafc1623143a44a7e4ea --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/11fd246fa558d8b7a8e90137c3e4bd0c40f33bc8999f984c96469428b2cd57e3.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -46, + "dataset": "marble-joined", + "doc_id": "11fd246fa558d8b7a8e90137c3e4bd0c40f33bc8999f984c96469428b2cd57e3", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "c46de612fed9da842896a51d04dd29d0ae42630eef203e2a77477b8ae00047cd", + "output_sha256": "b0f890cd2138440754260f1bc6dd7d697a6cebc4ce17222aaf95dbe30b24da7f", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1206c79ac112be8a67d5330078e2eb65bc10676ecb3666ae4655bf33cb272f9a.md b/vision-fixhub/ds9-parsed-01/1206c79ac112be8a67d5330078e2eb65bc10676ecb3666ae4655bf33cb272f9a.md new file mode 100644 index 0000000000000000000000000000000000000000..63ca1456a274631bc820ce575d175f64dafc509e --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1206c79ac112be8a67d5330078e2eb65bc10676ecb3666ae4655bf33cb272f9a.md @@ -0,0 +1,409 @@ +UNITED STATES GOVERNMENT +MEMORANDUM +METROPOLITAN CORRECTIONAL CENTER +New York, NX 10007 +August 11, 2019 +REPLY TO +ATTN OF: +M/w Operations Lieutenant +SUBJECT: Daily Activity Report +TO: +Warden +• Associate Warden (0) +, Associate Warden (P) +• Executive Assistant +• Captain +Lieutenants +Departments Heads +Daily Activity as communicated or documented by the Operations +Lieutenant for August 10, 2019, was received and/or reviewed. The +following information was noted. +Morning Watch Shift: +It. G. Anderson reported Correctional assignment Sanitation +vacated, due to, a shortage of staff. Control Center Fire Panel +remains inoperative. +Day Watch Shift: +S. Jean reported I/M Epstein #76318-054 found unresponsive in +Special Housing escorted to the outside hospital for treatment. +Evening Watch Shift: + +SDNY_00008864 + + +INMATES IN OUTSIDE HOSPITAL/SUICIDE WATCH/FURLOUGH/DRY CELL: +on Suicide Watch w/inmate companion +on Suicide Watch w/inmate companion +NEW ADMISSIONS TO MCC New York: +NONE +RELEASED FROM MCC NEW YORK: +NONE +ANOMESSTONS TO THE SPECIAL HOUSING UNIT: +TOTAL. NUMBER OF CELAS IN SHU THAT ARE PRESENTLY TRTPLE BUNKED. +MISSING FIRE AND SECURITY REPORT: +NONE +MISSING EQUIPMENT INVENTORY FORM: +NONE + +SDNY_00008865 + + +THE FOLLOWING LEAVE WAS UTILIZED: +FURLOUGH: 00 +ANNUAL LEAVE: 05 +SICK LEAVE: 12 +OFFICIAL TIME: 00 +SUSPENSION: 00 +FFLA: 00 +EMLA: 00 +COP: 02 +AWOL: 00 +ADVANCE LEAVE: 00 +IWOP: 00 +ADMIN LEAVE: 00 +COMP TIME: 00 +TRAINING: 00 +GLYNCO: 00 +IWOP (M) : 00 +TOA: 00 +EPO: 00 +TRAVEL: 00 +THE FOLLOWING OVERTIMES WERE HIRED: +E-1 OVERTIME: +Number of staff = 34 +- 1 COMPTIME +lumber of staff = 0 +Hours = 263.00 +Hours = 00.00 +Hours = 00.00 + +SDNY_00008866 + + +B-2 OVERTIME: +Number of Statt = 00 +O9D OVERTIME (SPECIAL) : +Number of Staff = 00 +XXX OVERTIME (AIRLIFT) : +Number of Staff = 00 +87S OVERTIME (TREATY TRANS) : +Number of Staff = 03 +Hours = 00.00 +Hours = 00.00 +Hours = 00.00 +Hours = 00.00 +INSTITUTION TOTALS AT THE BEGINNING OF THE MORNING WATCH SHIFT: +08-10-2019 / 12:00 AM +UNIT B-A: +26 +UNIT E-N: 87 +UNIT E-S: 81 +UNIT G-N: 79 +UNIT G-S: 80 +UNIT H-A: 03 +UNIT I-N: 85 +UNIT K-N: 88 +UNIT K-S: 138 +UNIT Z-A: 77 +UNIT Z-B: +05 +TOTAL: +759 + +SDNY_00008867 + +METROPOLITAN CORRECTIONAL CENTER, NEW YORK, NY +Shift-Day-Date: M/W Saturday, August 10, 2019 +Daily Sensitive Information: +M/W +Beginning Count: 758 +SHU: 73/5 +TIME +CHRONOLOGICAL EVENTS +BC +12:00 AM Lieutenant +assumes duties as the Morning Watch +| 758 +operations +Lieutenant. The fire alarm and sprinkler system are +w/exception of Control Center +Fire +PREA +announcement conducted via the Institution Public Address System +and/or Radio. Restraint Equipment +Cage inventory conducted. All +equipment +accounted for. Metal +Detector +checks +conducted. All +operative w/the exception of +Rear +Gate/Facilities/R&D. +Roof +Check completed. All secure. +Temporary Chit +Inventory: #1:2; +#2:5; #3:5; #4:6; #5:5; #6:0; Hosp:0 +Institution Count in progress +12:00 +AM +12:00 +AM +12:15 +AM +12:23 +AM +12:30 +AM +12:35 +AM +12:36 +AM +12:49 +AM +3:00 AM +3:19 AM +3:24 AM +5:00 AM +5:29 AM +5:30 AM +6:33 AM +6:35 AM +AM +7:10 +AM +NYPD Phone Check #1283 +Body Alarm testing in progress +Body alarm testing completed +Watch Calls cont. +-1 SHU (correction): Fernandez #86824-054 (DRY CELL R-A) +Good Verbal count announced +Clear Institution count announced +758 +Institution Count in progress +Good Verbal count announced +Clear Institution count announced +Institution Count in progress +Good Verbal count announced +Clear Institution count announced +Lieutenant +on Board at approximately 5:30am relieving Lt +of duty. +Medical +emergency announced for +Unit +9 South inmate Epstein +#76318-054 found unresponsive in cell Z06-220 CPR in progress +911 Emergency service notified +E.M.S ambulance arrives to the Health Service Area, continued CPR +in progress by E.M.T. +E.M.S/BOP staff +depart with inmate +Epstein +ambulance to local hospital continuation of +#76318-054 +CPR +is +still +progress by EMT. +758 +758 +via| 757 +in +SHU +73/5 +71/5 + +SDNY_00008868 + + +UNITED +STATES +DEPARTME +NT OF +JUSTICE +METROPOL +ITAN +CORRECTI +ONAL +CENTER, +NEW +YORK, NY +DAILY +LIEUTENA +NT'S LOG +7:36 +Bop staff called to notify institution that inmate Epstein # +AM +STG International Terrorist phone calls monitored: +WITSEC inquiry (s) was/were received during my tour of duty: +The following Inmate(s) were placed in Administrative Detention: +Reg: Number +Ops It. S. Jean +Time +Ending Count: 758 SHU: 71; 10-South: 05; SHU OBS: 00; +Local Hosp: 00; H/A OBS: 04; B/A OBS: 00; Dry Cell: 01; +H/A (PBS) : 00; H/A (PCLAS): 00 +AD Order +SHIFT-DAY-DATE: D/W - Friday, August 09, 2019 +D/W Paily Sensitive Information: +ARARANTONd +| Beginning Count: 757 +SHU: 71/5 +8:00 AM +8:00 AM +8:00 AM +8:20 AM +10:00 AM +11:22 AM +11:24 AM +3:45 PM +3:57 PM +3:58 PM +Lieutenant S. Jean assumes duties as the Day Watch Operations +Lieutenant. The fire alarm and +pump system is inoperable at this +time. Fire +Watch is in Progress. Unable to conduct PREA +announcement over the Institution Public Address System, due to, +system malfunction. Restraint Equipment Cage inventory conducted. +All equipment accounted +| for. Metal Detector checks conducted. +All operative w/the exception of Rear Gate. +completed. All secure. Temporary Chit Inventory: #1:0; #2:5; +* Temporary hit favent ory: 1:0; 42:53 +#3:5; #4:6; #5:6; #6:5; Hosp: 0 +Daily Hand Stamp : DJBE/LEFT HAND +NYPD Phone Check #3371 +Body Alarm Test Initiated. +Body Alarm Testing Complete. +Institutional count in progress +Good verbal count announced +Clear institutional count +Institutional lockdown for count. ++1; I/M Mutimura #76329-054 +I/M Fernandez #86824-054 transferred to special housing (dry +cell) +757 | 71/5 +757 +71/5 +757 +| 71/5 +757 | 71/5 +757 + +SDNY_00008869 + + +METROPOLITAN CORRECTIONAL CENTER, NEW YORK, NX +3:59 PM -1 Bail Bond; Carreon-Macias #82858-198 +4:00 PM Relieved of duties by It. M. Cannata E/W Operations Lieutenant. +Visitation: CANCELLED +Inmates +Adults +Children +ION SCANNING TESTED HITS: 0 +TG/High Alert phone calls monitored: +VITSEC inquiry (s) was/were received during my tour of duty: +The following Inmate (5) were placed in Administrative Detention: O +Name +Reg Number +Reason +Unit +TIME +Ops It S. Jean +Act It M. Canatta +Ending Count: 756 ; SHU:72 ; 10-South: 05; SHU OBS: 00; +Local Hosp: 00; H/A OBS: 02; B/A OBS: 00; Drv Cell: 0( +756| 72/5 +Total +A/D Order + +SDNY_00008870 + +METROPOLITAN CORRECTIONAL CENTER, NEW YORK, NY +SHIFT-DAY-DATE: E/W - Saturday, August 10, 2019 +Daily Sensitive +Information. +Beginning Count: 756 +E/W +TIME +4:00 PM +4:00 PM +4:01 PM +4:16 +i PM +4:32 PM +5:02 PM +5:13 PM +6:00 PM +7:24 PM +CHRONOLOGICAL EVENTS +Lieutenant +assumes duties as the Evening Watch +Operations Lieutenant. Unable to conduct PREA announcement over +he Institution Public Address System, due to, system malfunction. +Restraint Equipment Cage inventory conducted. All equipment +accounted for. Metal Detector checks conducted. +w/the exception of Rear Gate. Roof Check completed. All secure. +Temporary Chit Inventory: #1:4; #2:4; #3:5; #4:5; #5:5; #6:3; +Institution count in progress. +NYPD Phone Check #1980 +Body alarm testing in progress. +Body alarm testing completed +Good verbal count +Clear institutional count. +Watch call in progress +transferred to +7:45 PM +8:42 PM +10:00 +PM +special housing (psych observation) +Trash run in progress +Trash run complete +Institutional count in progress. +10:21 +PM +10:38 +PM +12:00 +AM +Good verbal count announced. +Clear institutional count announced. +Relieved of duties by G. Anderson as the M/W Lieutenant. +INMATES +VISITING: +ADULTS +CHILDREN +STG/High Alert phone calls monitored: +WITSEC inquiry (s) was/were received during my tour of duty: 0 +The following Inmate (s) were placed in Administrative Detention: O +NAME +REG NUMBER +REASON +UNIT +TIME +SHU: 72/ +5 +в/с +SHU +756 72/5 +756 +756| 74/5 +756| 74/5 +TOTAL +A/D ORDER +Ops. It. +Act. It. +Ending Count: 756 ; SHU: 74; 10-South: 05; SHU OBS: 00; +Local Hosp: 00; H/A OBS: 02; B/A OBS: 00; Dry Cell: 00; +B/A SHU: 00 + +SDNY_00008871 + + +METROPOLITAN CORRECTIONAL CENTER, NEW +YORK, NY + +SDNY_00008872 \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/1206c79ac112be8a67d5330078e2eb65bc10676ecb3666ae4655bf33cb272f9a.receipt.json b/vision-fixhub/ds9-parsed-01/1206c79ac112be8a67d5330078e2eb65bc10676ecb3666ae4655bf33cb272f9a.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..8f0fb681170fbdc0cb67d497c8b29d0c6d4bf598 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1206c79ac112be8a67d5330078e2eb65bc10676ecb3666ae4655bf33cb272f9a.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -446, + "dataset": "marble-joined", + "doc_id": "1206c79ac112be8a67d5330078e2eb65bc10676ecb3666ae4655bf33cb272f9a", + "engine": "marble-apple-vision", + "event_count": 16, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "b7d3f7e180a7a58f220d6232ac0457358789820652389f31bc61dcac873be055", + "output_sha256": "57f1de60cd65cc3f4908924e2c387a099c25c9108d46d86f6d8beaf5870f4645", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/120d2b5235946a951d4fd9dcbe38c3572b49d79b20311c100e5e3508016a9a4e.md b/vision-fixhub/ds9-parsed-01/120d2b5235946a951d4fd9dcbe38c3572b49d79b20311c100e5e3508016a9a4e.md new file mode 100644 index 0000000000000000000000000000000000000000..a5601941177c904ef1dd1eb01c697c28a4ed3077 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/120d2b5235946a951d4fd9dcbe38c3572b49d79b20311c100e5e3508016a9a4e.md @@ -0,0 +1,78 @@ +From: +To: +Ce: +Subject: RE: Epstein - Additional Request +Date: Tue, 13 Aug 2019 16:16:47 +0000 +I am waiting on a call back from MCC. I will ask that status of that report. It is my understanding that the cell was to be +secured and not entered, but I will confirm for you. +U.S. Department of Justice +Office of the Inspector General +New York Field Office +One Battery Park Plaza, 29th Floor +New York, NY 10004 +From: +Sent: Tuesday, August 13, 2019 12:13 PM +Subject: RE: Epstein - Additional Request +Do we have any initial reports conducted by the BOP regarding the finding of Epstein, position of the body, etc. OCME is +requesting for anything that would assist them while they await findings or reports from the first on scene. And just to +confirm, that cell is still secured as requested correct, OCME may want to re-visit. +From: +Sent: Tuesday, August 13, 2019 11:34 AM +Subject: RE: Epstein - Additional Requests/ Interviews +Yes, that is my understanding that all union-represented employees want their union rep. present during the interviews. +I will call MCC to see if the Lt. +is available +U.S. Department of Justice +Office of the Inspector General +New York Field Office +One Battery Park Plaza, 29th Floor +New York, NY 10004 + + +From: +Sent: Tuesday, August 13, 2019 11:31 AM +Subject: RE: Epstein - Additional Requests/ Interviews +Thanks. To confirm, are all of the union-represented officers refusing to speak with us without their rep? +and | are free between 2-4, and we can do it at our office. +From: +Sent: Tuesday, August 13, 2019 11:30 AM +Subject: RE: Epstein - Additional Requests/ Interviews +I will work on getting physical descriptions of Thomas and Noel. +I spoke to +at MCC, all but +I have union representation. +If +is available to talk with us today, is there a time, location, ect. That works best? +U.S. Department of Justice +Office of the Inspector General +New York Field Office +One Battery Park Plaza, 29th Floor +New York, NY 10004 +From: +Sent: Tuesday, August 13, 2019 10:38 AM +Subject: Epstein - Additional Requests/ Interviews +We just spoke with OCME, and they would like (i) the responding ambulance reports; and (ii) physical descriptions (height +and weight) for Noel and Thomas. Could you please get us this information? +Second, below are the people that we would like to set up voluntary interviews with in the next few days. • +, can you +please reach out to +to set these up: +Name +Position +OPS Lt. +Shift +8/10 from 12-8 + + +Control +Control +Control +8/10 from 12-8 +8/9 from 4-12 +8/9 from 4-12 +8/10 from 12-8 +8/9 from 4-12 +8/9 from 2-10 +Thanks, +Assistant United States Attorney +Southern District of New York \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/120d2b5235946a951d4fd9dcbe38c3572b49d79b20311c100e5e3508016a9a4e.receipt.json b/vision-fixhub/ds9-parsed-01/120d2b5235946a951d4fd9dcbe38c3572b49d79b20311c100e5e3508016a9a4e.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..080f805104ff3fba1726fa41fe6b0642ffa25073 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/120d2b5235946a951d4fd9dcbe38c3572b49d79b20311c100e5e3508016a9a4e.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -64, + "dataset": "marble-joined", + "doc_id": "120d2b5235946a951d4fd9dcbe38c3572b49d79b20311c100e5e3508016a9a4e", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "a5513f65aac5ee3448d7781e2e48dc5459396b392dd9c526cdbb8b45ec9d9aea", + "output_sha256": "c59bd8d1ea313015bcd67ad8df6aa9d6d6d7efb65cae1b2d6d8dae1d476c0cfd", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/122199790f44822f44db56c51d9ec3bb8dc7e67750b1872350f25684945fd9cd.md b/vision-fixhub/ds9-parsed-01/122199790f44822f44db56c51d9ec3bb8dc7e67750b1872350f25684945fd9cd.md new file mode 100644 index 0000000000000000000000000000000000000000..972f7e7eb5a2cb5312da8fc0fb09ac056fc8a460 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/122199790f44822f44db56c51d9ec3bb8dc7e67750b1872350f25684945fd9cd.md @@ -0,0 +1,12 @@ +AP SKULL +CR30 +Se: 17 +Im: 1 +3480×4248 +NYC OCME Brons +Epstein Jettery +M-19-019432 +L +Sp: 0.10040.100 +Zoom: 0% +W: 4096 L: 2048 diff --git a/vision-fixhub/ds9-parsed-01/122199790f44822f44db56c51d9ec3bb8dc7e67750b1872350f25684945fd9cd.receipt.json b/vision-fixhub/ds9-parsed-01/122199790f44822f44db56c51d9ec3bb8dc7e67750b1872350f25684945fd9cd.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..550ce688220967b88e931458160d9cadb0dfc2d9 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/122199790f44822f44db56c51d9ec3bb8dc7e67750b1872350f25684945fd9cd.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "122199790f44822f44db56c51d9ec3bb8dc7e67750b1872350f25684945fd9cd", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "38d7211a2f221a6da58b133626c3b2e1fda88a878d899f59734961cab6d5d6df", + "output_sha256": "47324d833ac4b0d24ac73af76fc176dd77009e91aecb0a76af19113cbf6f74c9", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/12321caa1d9bc156b61f38b41b26d2244d8a76743a394720640886cf2dc8728d.md b/vision-fixhub/ds9-parsed-01/12321caa1d9bc156b61f38b41b26d2244d8a76743a394720640886cf2dc8728d.md new file mode 100644 index 0000000000000000000000000000000000000000..5336ff77ce7c5b2ae8176fc4f1d4bf62c3d72cb6 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/12321caa1d9bc156b61f38b41b26d2244d8a76743a394720640886cf2dc8728d.md @@ -0,0 +1,28 @@ +ANIXTER TP120240 & SIGNET TECH TP120150 +From +To +Date +Subject: +Attachments: +2019/04/01 14:11 +ANIXTER TP120240 & SIGNET TECH TP120150 +TEXT.htm +Good afternoon, +Ms. +after reviewing my CORS report for the Central Office Samples; I went ahead and asked +our Comp. Tech on the status of these particular POs and he advised me that they haven't been able to +receive the Fiber Cable and without the cable they can't proceed with the Camera Systems. He mentioned +that the company is requiring some sort of documentation and he should be able to provide you with the +details. +Sincerely, +Financial Program Specialist +United States Department of Justice +Federal Bureau of Prisons +Metropolitan Correctional CTR +150 Park Row New York, NY 10007 +Phone (g +Fax +Email: +SENSITIVE/PRIVILEGED COMMUNICATION +The information contained in this electronic message and any and al accompanying documents constitutes sensitive information. This information is the property of the U.5. Department of Justice. If you are not thi +intended recipient of this information, any disclosures, copying, distribution, or the saking of any action in relance on this information is strictly prohibited. diff --git a/vision-fixhub/ds9-parsed-01/12321caa1d9bc156b61f38b41b26d2244d8a76743a394720640886cf2dc8728d.receipt.json b/vision-fixhub/ds9-parsed-01/12321caa1d9bc156b61f38b41b26d2244d8a76743a394720640886cf2dc8728d.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..c8aebea1b63aedb36290e6c4a33d3bf1a3e237b0 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/12321caa1d9bc156b61f38b41b26d2244d8a76743a394720640886cf2dc8728d.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "12321caa1d9bc156b61f38b41b26d2244d8a76743a394720640886cf2dc8728d", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "ec58e7b08d8ce7566c72976e1151b839cf0fc83889d0e85ffa82930f01ac8585", + "output_sha256": "be2a206cef4aa605406a5177ef3b3535a00582e2304297b877d924ab6cc344c3", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1236f0391af1d2cd77bb015876a52beec8c5e5219a5c75728c1f9bdb989fd3ee.md b/vision-fixhub/ds9-parsed-01/1236f0391af1d2cd77bb015876a52beec8c5e5219a5c75728c1f9bdb989fd3ee.md new file mode 100644 index 0000000000000000000000000000000000000000..06949f8ec2419b1dce648b2a6dbe8cb2b326485c --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1236f0391af1d2cd77bb015876a52beec8c5e5219a5c75728c1f9bdb989fd3ee.md @@ -0,0 +1,44 @@ +Related Accounts +Cardhumer rafarmation, +Vame +Cardholder Idantificati +Address: +Customer No +Tome Phone: +Business +Phone: +Cell Phone: +Card Information +Prefixtion ID: 94823 +xpires +Prefix + +ast Usec +COMMERCE CONSUMER CHECK +Chip Card: +Description: +CARD +Related Accounts and Balances +Demand Deposit Account (DDA) +Account Number +Status +AVAILABLE +JOHN P MARRUGO +Card Information Cardholder Identitication +ACTIVE +1000) 000-0000 +0626/2013 +Station: +late or Maden Nai +SN/Taxpayer ID +Bad Address: +Carency:ged: +NO +0403/2019 +Description +PR CHECK +Primary +YES +(Toral Anorization Balances +https://cmse.metavante.org/main/cmse/RelatedBalView +8/26/2019 diff --git a/vision-fixhub/ds9-parsed-01/1236f0391af1d2cd77bb015876a52beec8c5e5219a5c75728c1f9bdb989fd3ee.receipt.json b/vision-fixhub/ds9-parsed-01/1236f0391af1d2cd77bb015876a52beec8c5e5219a5c75728c1f9bdb989fd3ee.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..d89b15b69ccb25f6a6afee1cb666779cf3fc83b5 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1236f0391af1d2cd77bb015876a52beec8c5e5219a5c75728c1f9bdb989fd3ee.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -18, + "dataset": "marble-joined", + "doc_id": "1236f0391af1d2cd77bb015876a52beec8c5e5219a5c75728c1f9bdb989fd3ee", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "eff481bc57895347688000e05e70dc967d1a2b1a8c867bd87c9478f3ff990463", + "output_sha256": "473003127485603ccb57cddf1c761a37558b3bd70f49ac667e8efee6b8c429b2", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/12469deb5d3da8e7dab905ce2764ec77e725abbf3818ada901e5c008ebbe96a0.md b/vision-fixhub/ds9-parsed-01/12469deb5d3da8e7dab905ce2764ec77e725abbf3818ada901e5c008ebbe96a0.md new file mode 100644 index 0000000000000000000000000000000000000000..38b64a72c23554b9d7e2500dcf29b39579436642 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/12469deb5d3da8e7dab905ce2764ec77e725abbf3818ada901e5c008ebbe96a0.md @@ -0,0 +1,51 @@ +FD-1023 +UNCLASSIFIED +FEDERAL BUREAU OF INVESTIGATION +CHS REPORTING DOCUMENT +HEADER +Source ID: +Date: +Case Agent Name: +Field Office/Division: +Squad: +11/23/2021 +1. +San Francisco +H1 +SOURCE REPORTING +Date of Contact: +11/23/2021 +ist all present including yourself (do not include the CHS) +A Merrin Mors +Type of Contact: +In Person +Country: +City: +State: +UNITED STATES +SF +California +Date of Report: +11/23/2021 +OFFICIAL RECORD +Substantive Case File Number +272-SJ-3262541 +Check here if additional reporting is in Echo +No +Source Reporting: +(U//FOUO) Boris Nikolic, ww.crunchbase.com/person/boris-nikolic, Managing Director of "bng0" and +Biomatics Capital, MD Zagreb Medical School is interesting in investing in a known US-based +Artificial Intelligence company. This US Al company is interested in pursuing funding from US +DARPA, Defense Advance Research Projects Agency, www.darpa.mil and other US Government funding +sources. Nikolic was designated a executor of Jeffrey Epstein's estate. +Synopsis: +CHS reports on Boris Nikolic. +SIGNATURE +Submitted By +First Level Approved By +Wed, 1 Dec 2021 17:34:08-08:00 +Tue, 7 Dec 2021 19:03:42 -08:00 +FD-1023 + +UNCLASSIFIED +FEDERAL BUREAU OF INVESTIGATION diff --git a/vision-fixhub/ds9-parsed-01/12469deb5d3da8e7dab905ce2764ec77e725abbf3818ada901e5c008ebbe96a0.receipt.json b/vision-fixhub/ds9-parsed-01/12469deb5d3da8e7dab905ce2764ec77e725abbf3818ada901e5c008ebbe96a0.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..23c16ba8f89feeae3446d908deedac1cb9cf4b97 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/12469deb5d3da8e7dab905ce2764ec77e725abbf3818ada901e5c008ebbe96a0.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -23, + "dataset": "marble-joined", + "doc_id": "12469deb5d3da8e7dab905ce2764ec77e725abbf3818ada901e5c008ebbe96a0", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "11832977eb272f7bbc62ea372ca8d2237c683335a948d04b150f2d40247a088f", + "output_sha256": "b88e268979ae96e6dfdc2d55aa9fc678f520e276c1e53045a4c7a926304b1a72", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/124bd90927ecc876d5d86685504b4b336298626ca6ef930aad073c6eb70a3c62.md b/vision-fixhub/ds9-parsed-01/124bd90927ecc876d5d86685504b4b336298626ca6ef930aad073c6eb70a3c62.md new file mode 100644 index 0000000000000000000000000000000000000000..77d4e7d7a02b3344013339ec95b920e58872ce4a --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/124bd90927ecc876d5d86685504b4b336298626ca6ef930aad073c6eb70a3c62.md @@ -0,0 +1,60 @@ +To: +From: +Sent: +G. Max o +Sat 1/1/4501 5:00:00 AM (UTC) +Subject: I rang her to see if she had seen anyone for you - this is her reply - want to do anything w/it /her + +
+‹blockquote type=cite class=cite cite>lo: +From: "G. Max" <] +agt;
+Subject: Re: see you in new york
+ +At 03:50 PM 2/7/2004 -0600, you wrote:
+‹blockquote type=cite class=cite cite›hi ghislaine, +it was good to hear from you the other day anbsp; i thought i'd fill you in on my situation and see how +we can work together.
+
+i am still dancing, anbsp; pilates-ing and teaching. i am very interested to keep training jeffery as we +work well together and i enjoy working with him.
+
+i understand he likes to work with a variety of beautiful, talented young women and i think that training +with lots of people can be a very good thing. anbsp; i understand what i am looking for in other people to +train / work with him, +and it's quite a tall order, which is why i know that you need some help you find +people. anbsp; they don't come along every day.
+ +i need to use my time effectively; to continue with my dance classes, learning, training and also earning +money to pay for it all, «br> +if 1 am looking for girls i will need to go to a wide variety of classes, whereas at the moment i tend to +stick to the one's i like. (not necessarily the one's to find suitable girls).
+
+so if you want me to be actively looking, then we will need to reach a financial arrangement as this will +be my job. or if you just want me to let you know if i come across someone suitable on my travels, then +what will you pay me for this? as +i am effectively 'doing myself out of a job'.
+
+i would just like to have a good idea of where i stand, and if i will be getting more work from you, or +if you can put me in touch with other people who may want a trainer. or if i can make 'looking for other +people' my main source of income. +as i am here properly now, i have bills and rent to pay, i need to find something somewhat stable.
+
+i can be available to travel, but if i am 'on call' i need to know and be paid accordingly,
+
+i have a couple of girls in mind, so let me know what arrangement we will have, and i will do my +best to help.
+i am appreciative of any work you can throw my way.
+i look forward to seeing +you +you're back in nyc. give my best to rainy england!
+
+love +
+X + +
+..s. do you want a lesson? wrote: +Per the attachment, should this document be assigned to ODAG for handling? +Thanks, +U.S. Department of Justice +Office of the Deputy Attorney General +From: +To: +Cc: +Sent: Thursday, September 05, 2019 11:37 AM +Subject: WF 4319870 +Per +assign to ODAG for assignment guidance. +Correspondence Management Analyst +https://iqapp.justapps.doj.gov/iq/StreamDownloader.aspx?path=&filename=1092019_1219.. 10/9/2019 + + + +U.S. Department of Justice +Executive Secretariat + +P; Darlene A. Alleyne +Subject: RE: travel approval request +Ed, +Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request +permission to travel next week for an interview in West Palm Beach on November 4. It will just be me and +, and +we'll travel some combination of the 3rd to the 5th. And also same as last time, we'd like to ask permission to reserve a +conference room at the hotel on that Monday for the interview, please. +thanks very much, +From: +Sent: Wednesday, June 12, 2019 14:51 +To: Tyrrell, Edward (USANYS) < +Cc: Duncan, Michele (USANYS) ‹ +Subject: RE: travel approval request +Ed, +Again in connection with the Epstein investigation (2018R01618), we'd like to please request permission to travel next +week for a victim interview in Los Angeles. As of now we tentatively expect to fly down Wednesday and return no later +than Friday (and will keep the timeframe as short as scheduling allows). The trip will be some combination of me, I +and/or +as previously. And also same as last time, we'd like to ask permission to reserve a conference room at +the hotel on Thursday for the interview, please. +thanks very much, + + +From: +Sent: Friday, May 24, 2019 14:57 +To: Tyrrell, Edward (USANYS) ‹ +Cc: Duncan, Michele (USANYS) < +> +Subject: RE: travel approval request +Ed, +Again in connection with the Epstein investigation, we'd like to please request permission to travel for approximately +three days next week for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly +down Tuesday night and return on Wednesday or Thursday (and will keep the timeframe as short as scheduling allows). +Unfortunately we're still trying to pin down timing for interviewing the victims, so depending on the timing it will either +be me and I +or +and +1, but we wanted to ask for permission now either way so we weren't doing it +super last minute after the holiday on Tuesday. And also same as last time, we'd like to ask permission to reserve a +conference room at the hotel for the interviews, please. +thanks very much, +From: | +Sent: Wednesday, April 03, 2019 20:57 +To: Tyrrell, Edward (USANYS) 4 +Subject: RE: travel approval request +Thank you +From: Tyrrell, Edward (USANYS) ‹| +Sent: Wednesday, April 03, 2019 20:46 +To:/ +Cc: +Subject: Re: travel approval request +Approved +Sent from my iPad +On Apr 3, 2019, at 8:02 PM, +Ed, +P; Duncan, Michele (USANYS) < +> wrote: +For the same case as below, United States v. Epstein, 2018R01618, an investigation relating to enticement of minors for +sexual activity, +and I would like to please request permission to travel for approximately three days next week for +meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly down Tuesday night and +return on Friday, though we will shorten the timeframe if scheduling allows. +Please let us know if any other information would be helpful, and thanks very much. + + +From: | +Sent: Thursday, March 14, 2019 18:32 +To: Tyrrell, Edward (USANYS) ‹ +Subject: travel approval request +Ed, +and I would like to please request permission for travel for United States v. Epstein, 2018R01618, an +investigation relating to enticement of minors for sexual activity, for two days of meetings and interviews in West Palm +Beach and/or Fort Lauderdale, Florida. As of now we're hoping to fly down next Wednesday night and return on +Saturday. +Please let us know if any other information would be helpful, and thanks as always. +Assistant U.S. Attorney +Southern District of New York diff --git a/vision-fixhub/ds9-parsed-01/1419a91f72e169d30fce7c11a03f0d07d764455958688358c914493c5d6ea773.receipt.json b/vision-fixhub/ds9-parsed-01/1419a91f72e169d30fce7c11a03f0d07d764455958688358c914493c5d6ea773.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..2a919a3d57edea29b7a20e0bdfc63025fb2a04b6 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1419a91f72e169d30fce7c11a03f0d07d764455958688358c914493c5d6ea773.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -48, + "dataset": "marble-joined", + "doc_id": "1419a91f72e169d30fce7c11a03f0d07d764455958688358c914493c5d6ea773", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "8d90db974168bc9bfd6fe188ce1f07f3fce526b6ac7a4ecdbd791d65908d9b7e", + "output_sha256": "4eaf7e86552c7c082a5157e7db351b958791ee2faa6aced1acf07ebe1ce60484", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/141b5b1dfecaf2e4a5465c1d8e01f5110b1e1ae05a7b9b58d6c45e9c3085cd41.md b/vision-fixhub/ds9-parsed-01/141b5b1dfecaf2e4a5465c1d8e01f5110b1e1ae05a7b9b58d6c45e9c3085cd41.md new file mode 100644 index 0000000000000000000000000000000000000000..f541f75a906990dfad8a1b17ae7d827d388511b3 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/141b5b1dfecaf2e4a5465c1d8e01f5110b1e1ae05a7b9b58d6c45e9c3085cd41.md @@ -0,0 +1,61 @@ +USDC SDNY +DOCUMENT +ELECTRONICALLY FILED +DOC#:_ +DATE FILED: 11/15/21 +Smith Villazor LLP +New York, New York 10019 +www.smithvillazor.com +Patrick J. Smith +_ may file a motion to quash +SMITH VILLAZOR +the subpoena on or before Friday, +November 19, 2021. The motion should +not repeat arguments made in the +November 15, 2021 +BY E-MAIL to +The Honorable Alison J. Nathan +Jnited States District Judge +Southern District of New York +Government's motion to quash, which is +due on Thursday, November 18, 2021. +The Defense shall respond to both +motions on or before Monday, +November 22, 2021. This memo +endorsement is filed temporarily under +New York, New York 10007 +seal to allow the parties to propose +redactions. Any redactions to this letter +Re: +United States v. Maxwell, No. 20 Cr. 330 +and the Defendant's motion must be +filed on the docket by November 21, +Dear Judge Nathan: +2021. SO ORDERED. +We represent +the independent administrator of the Epstein Victims" +Compensation Program, the litigation-alternative program established to confidentially resolve +f. Misto +11/15/21 +claims of sexual abuse against Jeffrey Epstein, his Estate, and other related individuals and +entities. This afternoon we were informed by counsel for the government that the defendant has +sought, and the Court intends to authorize, a subpoena directed to +under Federal +Rule of Criminal Procedure 17(c) for certain documents. We write to (i) inform the Court that +we are authorized to accept service of the subpoena on behalf of +and (ii) request a +briefing schedule for +anticipated motion to quash the subpoena. +We understand that the government intends to file a motion to quash the subpoena, with a +deadline of this Wednesday, November 17, 2021. Given that we have just learned of the +subpoena today, the issues it presents, and mindful of the impending start date of trial, we +respectfully request until November 23, 2021 to file a motion to quash on +behalf. +We are available should the Court have any questions. +Respectfully submitted, +/s/ Patrick J. Smith +Patrick J. Smith +Smith Villazor LLP +cc: +Christian R. Everdell, Esq., Jeffrey S. Pagliuca, Esq., Laura A. Menninger, +Esq., Mark Stewart Cohen, Esq., Bobbi C. Sternheim, Esq. (by e-mail) diff --git a/vision-fixhub/ds9-parsed-01/141b5b1dfecaf2e4a5465c1d8e01f5110b1e1ae05a7b9b58d6c45e9c3085cd41.receipt.json b/vision-fixhub/ds9-parsed-01/141b5b1dfecaf2e4a5465c1d8e01f5110b1e1ae05a7b9b58d6c45e9c3085cd41.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..58c154635651d48a5412d2dac133378ad329bdf1 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/141b5b1dfecaf2e4a5465c1d8e01f5110b1e1ae05a7b9b58d6c45e9c3085cd41.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "141b5b1dfecaf2e4a5465c1d8e01f5110b1e1ae05a7b9b58d6c45e9c3085cd41", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "b4a1ce4ff1e3944ed478187cea776e072838539f4c636a0eeb2a136c002f69a8", + "output_sha256": "01607a51f11c1f22173941d525db90a50f1bf8d8d83dbca6d2f797e9b7c4125a", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/144bee44aeb50869b7d211e0e69461c94dce644354709ba3cd54f1bb707904a7.md b/vision-fixhub/ds9-parsed-01/144bee44aeb50869b7d211e0e69461c94dce644354709ba3cd54f1bb707904a7.md new file mode 100644 index 0000000000000000000000000000000000000000..cefbfd33597a2de5bf03871b2c5799c926ca8476 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/144bee44aeb50869b7d211e0e69461c94dce644354709ba3cd54f1bb707904a7.md @@ -0,0 +1,14 @@ +Event: Epstein records w SDNY +Start Date: 2019-08-27 17:30:00 +0000 +End Date: 2019-08-27 18:30:00 +0000 +Organizer: +Location: OCME, 421 E. 26th St +Class: X-PERSONAL +Date Created: 2019-08-27 13:38:09 +0000 +Date Modified: 2019-08-27 13:38:09 +0000 +Priority: 5 +DTSTAMP: 2019-08-27 13:26:57 +0000 +Attendee: +(USANYS) +Alarm: Display the following message 15m before start +Reminder diff --git a/vision-fixhub/ds9-parsed-01/144bee44aeb50869b7d211e0e69461c94dce644354709ba3cd54f1bb707904a7.receipt.json b/vision-fixhub/ds9-parsed-01/144bee44aeb50869b7d211e0e69461c94dce644354709ba3cd54f1bb707904a7.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..49a52a93d8cfb31baaa3b39f8dcd917d713b0f78 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/144bee44aeb50869b7d211e0e69461c94dce644354709ba3cd54f1bb707904a7.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "144bee44aeb50869b7d211e0e69461c94dce644354709ba3cd54f1bb707904a7", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "f4bad352eb4a356947b78149905c1d40e0bf667ccfcb58f7475c02bd21feb4a4", + "output_sha256": "4be7042ee45a53dfef35dcf49f67de7ba46d3411435cf95b24655232e0724614", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/145c5cc7065f624c879e7e103e7fa99505bf9c60454835f5996178237f6dea3c.md b/vision-fixhub/ds9-parsed-01/145c5cc7065f624c879e7e103e7fa99505bf9c60454835f5996178237f6dea3c.md new file mode 100644 index 0000000000000000000000000000000000000000..102ea75a838b475da87b75e7f5070448f54b9f52 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/145c5cc7065f624c879e7e103e7fa99505bf9c60454835f5996178237f6dea3c.md @@ -0,0 +1,54 @@ +Service Request #25630 +Programming Profiles and Users in NICE Vision +Status: Closed +Priority: P3 (Next Day) +Type: Service Contract +Assigned To: +Customer: FBOP MCC New York MS0109 (130104.001) +Contact: +Date Created: Sep 24, 2019 +Next Appt.: +Service Location: Main Location +NEW YORK, NY 10007 +Bill To: FBOP MCC New York MS0109 (130104.001) +NEW YORK, NY 10007 +PO#: +Additional Information & Custom Fields: +Is this a emergency request: Yes. You must call +Is the system in question under +any warranty: +What is the system in question : +When was the problem first +discovered: +Today +PO Number: +Who reported the problem initally: +s this a consistent problem o +ntermitten +CONSISTENT +Is this problem effecting all users: YES +Is there power to the device in +question: +YES +Do you have a spare device te: Unknown +Can you send a picture of the No +device: +Has any work been done in the No +area involved: +Can you describe what is or is not Installation of new Nice Vision system. +happening: +Material Required For Request: PHONE SUPPORT +Who Requested the service call : +Detailed Description: +needs assistance in creating users and profiles. +Schedule + + +When +Sep 24, 2019, all-day +Assigned To +Comment +is working on this. +Equipment - No Equipment +No Comments +Details - No Detail Items diff --git a/vision-fixhub/ds9-parsed-01/145c5cc7065f624c879e7e103e7fa99505bf9c60454835f5996178237f6dea3c.receipt.json b/vision-fixhub/ds9-parsed-01/145c5cc7065f624c879e7e103e7fa99505bf9c60454835f5996178237f6dea3c.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..89695c95b85eeb17ee1374eebea5dcde1f2bc225 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/145c5cc7065f624c879e7e103e7fa99505bf9c60454835f5996178237f6dea3c.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "145c5cc7065f624c879e7e103e7fa99505bf9c60454835f5996178237f6dea3c", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "ee1976b087775d151659597120b157d90f762d9bdf0c8980ca435d91418c08f9", + "output_sha256": "9df0d2fcea6ac0c144eb96c6a09ffb85126ee054daf3cf28f9556e9ad896f9de", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/14808836b4bfba5126af0ef6e49de9c53917778831b690cd242f1713f14e7c78.md b/vision-fixhub/ds9-parsed-01/14808836b4bfba5126af0ef6e49de9c53917778831b690cd242f1713f14e7c78.md new file mode 100644 index 0000000000000000000000000000000000000000..b4764fb5fde9efd7b8209febf5b46ffd94169f09 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/14808836b4bfba5126af0ef6e49de9c53917778831b690cd242f1713f14e7c78.md @@ -0,0 +1 @@ +No Images Produced diff --git a/vision-fixhub/ds9-parsed-01/14808836b4bfba5126af0ef6e49de9c53917778831b690cd242f1713f14e7c78.receipt.json b/vision-fixhub/ds9-parsed-01/14808836b4bfba5126af0ef6e49de9c53917778831b690cd242f1713f14e7c78.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..4ca39dcd0e42a29a592979957b96c75cb89e4ba6 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/14808836b4bfba5126af0ef6e49de9c53917778831b690cd242f1713f14e7c78.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "14808836b4bfba5126af0ef6e49de9c53917778831b690cd242f1713f14e7c78", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "18f01a01657d3027f7493e22663c6b7b35da8efde10d29f8b57b9b8694511eb2", + "output_sha256": "3874328764c818fba06683a6d5ddc2edc2d7850aaf4ba18646f81d3f8420a729", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1495663a398844690eff4775f334d89c00d19de15349a6f92736ae640700681c.md b/vision-fixhub/ds9-parsed-01/1495663a398844690eff4775f334d89c00d19de15349a6f92736ae640700681c.md new file mode 100644 index 0000000000000000000000000000000000000000..fb97bbb7b7fa301a96072dda6d7cfc101fbb3f5b --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1495663a398844690eff4775f334d89c00d19de15349a6f92736ae640700681c.md @@ -0,0 +1,22 @@ +From: "Stoddart, Allison" +To: +NY) (FBI)" < +Subject: FW: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) +Date: Sat, 20 Nov 2021 16:35:56 +0000 +Importance: Normal +Attachments: unnamed +-----Original Appointment.... +From: Stoddart, Allison 4 +Sent: Friday, November 19, 2021 11:52 AM +To: Stoddart, Allison; Sahni, Anjan; +Cc: +| (USANYS); +Subject: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) +When: Monday, November 22, 2021 6:00 PM-7:00 PM (UTC-05:00) Eastern Time (US & Canada). +Where: Zoom Meeting - Meeting ID Below +I'm using Zoom for my meetings. +Meeting ID: 3127323168 or ryankusmin +Join from PC, Mac, iOS or Android: https://jpmchase.zoom.us/my/ryankusmin +Visit http://go/zoominfo for everything you need to know. If you're sharing your remote workspace with a family member, a +roommate or others, please ensure your work conversation stays private. You can try to take your meetings in a private space and use +your headphones. Read more at http://go/zoomcalls about protecting the firm's data while working remotely. diff --git a/vision-fixhub/ds9-parsed-01/1495663a398844690eff4775f334d89c00d19de15349a6f92736ae640700681c.receipt.json b/vision-fixhub/ds9-parsed-01/1495663a398844690eff4775f334d89c00d19de15349a6f92736ae640700681c.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..7504fae462a8b7a325b05119e594185c92cde694 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1495663a398844690eff4775f334d89c00d19de15349a6f92736ae640700681c.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "1495663a398844690eff4775f334d89c00d19de15349a6f92736ae640700681c", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "69c072804cd7d80b70b7f21f9353180b7494684bc7cd9eb083f670024144386b", + "output_sha256": "fc9578f26859bbe08379043091093eebedc5f0888a4594e40018aeb308e3a58f", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/149680a28bd6d86710a4aa8988c11733de3849fbe9f04ce45beb44a1248e7468.md b/vision-fixhub/ds9-parsed-01/149680a28bd6d86710a4aa8988c11733de3849fbe9f04ce45beb44a1248e7468.md new file mode 100644 index 0000000000000000000000000000000000000000..576e43da953ba66bd9b196153d6fe3d5ff48ef12 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/149680a28bd6d86710a4aa8988c11733de3849fbe9f04ce45beb44a1248e7468.md @@ -0,0 +1,294 @@ +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +lated October 23, Subpoenato Google, Inc +lated October 23, : +2018R01618 +Application for § 2705(b) +Grand Jury Non-Disclosure +Order to Service Provider +SEALED +'STATE OF NEW YORK +) +) SS. +19 MAG +COUNTY OF NEW YORK) +9975 +MA: pursuant to Title 28, United States Code, Section 1746, hereby +affirms under penalty of perjury the truth of the facts set forth herein: +1. +I am an Assistant United States Attorney in the Office of the United States +Attorney for the Southern District of New York and am familiar with the investigation +underlying this request. I respectfully submit this application under 18 U.S.C. § 2705(b) for an +order to Google, Inc., (the "Service Provider"), headquartered at 1600 Amphitheatre Parkway, +Mountain View, CA 94043, not to notify any person (including the subscribers or customers of +the account(s) listed in the attached subpoena) of the existence of the attached subpoena for a +period of 180 days from the date of the non-disclosure order herein requested. +The Service Provider is a provider of an electronic communication service or a +remote computing service within the meaning of 18 U.S.C. $$ 2510(15) & 2711(2). Section +2703(c)(2) of Title 18 authorizes the Government to obtain enumerated subscriber information +and certain other non-content information from a provider of an electronic communication +service or a remote computing service via grand jury subpoena. The Government is preparing to +serve a grand jury subpoena, in the form attached to the accompanying proposed Non-Disclosure +Order, on the Service Provider directing it to disclose information within those categories. + + +3. +When the Government seeks such information via grand jury subpoena, 18 U.S.C. +§ 2705(b) authorizes the Court to issue an order commanding a provider of electronic +communications service or remote computing service to whom a warrant, subpoena, or court +order is directed, for such period as the court deems appropriate, not to notify any other person of +the existence of the warrant, subpoena, or court order. The court shall enter such an order if it +determines that there is reason to believe that notification of the existence of the warrant, +subpoena, or court order will result in-- +(1) endangering the life or physical safety of an individual; +(2) flight from prosecution; +(3) destruction of or tampering with evidence; +(4) intimidation of potential witnesses; or +(5) otherwise seriously jeopardizing an investigation or unduly delaying a +trial. +In this case, such an order would be appropriate because the attached subpoena +relates to an ongoing criminal investigation that is neither public nor otherwise known to all +targets of the investigation, the account holder is suspected of being involved in or associated +with persons involved in the conduct under investigation, and disclosure of the subpoena to the +account owner or to any other person may alert subjects or targets of the ongoing investigation. +Accordingly, there is reason to believe that notification of the existence of the attached subpoena +will seriously jeopardize the investigation, including by giving targets an opportunity to flee or +avoid prosecution, or tamper with evidence, including electronically stored information that is +easily tampered with. The Government anticipates that these circumstances will continue for the +next 180 days. Accordingly, the Government believes that 180 days is an appropriate delay of +notice period for the Court to order, subject to extension upon further application if necessary. +2 + + +For the reasons set forth above, the Government further requests that the Court +order that this Application and any resulting order be sealed until further order of the Court, +except that the Government may provide copies of the application and order as need be to +personnel assisting the Government in the investigation and prosecution of this matter, and may +disclose these materials as necessary to comply with discovery and disclosure obligations in any +prosecutions related to this matter. +6. +No prior request for the relief set forth herein has been made. +WHEREFORE the Government respectfully requests the Court to enter the +accompanying proposed 2705(b) Non-Disclosure Order. +Dated: +New York, New York +October 22, 2019 +Assistaht United States Attorney +3 + + +U.S. Department of Justice +United States Attorney +Southern District of New York +he Silvia J. Nollo Building +October 23, 2019 +VIA EMAIL +Google, Inc. +Attn: Legal Department +1600 Amphitheatre Parkway +Mountain View, CA 94043 +uslawenforcement@google.com +19 MAG 9975 +To whom it may concern: +Please be advised that the accompanying grand jury subpoena has been issued in +connection with an official criminal investigation of a suspected felony being conducted by a +federal grand jury. Pursuant to the accompanying non-disclosure order issued under 18 +V.S.C. § 2705(b), you are prohibited from notifying any subscriber or other third-party of +the existence of this subpoena for a period of 180 days from the date of the order. If you +ever plan to notify the relevant subscriber(s) of the existence of this subpoena, even after +the 180-day period, please advise me before you do so, in case the investigation remains +ongoing and the order needs to be renewed. +You are hereby directed to preserve, under the provisions of 18 U.S.C. § 2703(f)(1) +any and all information, including, if applicable, all emails/attachments or other content +information, as well as any backup copies of such data or data designated for deletion, +pertaining to the domain(s) and accounts) referenced in the accompanying subpoena, for a +period of 90 days. This letter applies only retrospectively; it does not obligate you to capture +and preserve new information that arises after the date of this letter. +Thank you for your cooperation in this matter. +Sincerely, +GEOFFREY S. BERMAN +United States Attorney +By: +Assistant United States Attorney +Southern District of New York + + +Grand Jury Subpoena +United States District Onut +SOUTHERN DISTRICT OF New YorK +TO: +Google, Inc. +Attn: Legal Department +1600 Amphitheatre Parkway +Mountain View, CA 94043 +GREETINGS: +WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend +before the GRAND JURY of the people of the United States for the Southern District of New York, at +the United States Courthouse, 40 Foley Square, Room 220, in the Borough of Manhattan, City of New +York, New York, in the Southern District of New York, at the following date, time and place: +Appearance Date: +November 7, 2019 +Appearance Time: +10:00 a.m. +to testify and give evidence in regard to an alleged violation of : +18 U.S.C. §§ 1591, 371 +and not to depart the Grand Jury without leave thereof, or of the United States Attorney, and that you +bring with you and produce at the above time and place the following: +See Attached Rider +SEE ATTACHED RIDER. Personal appearance is not required if the requested records are (1) +produced by on or before the return date to Special Agent +at: Federal Bureau of +Investigation, 26 Federal Plaza, VCAC/Human Trafficking, New York, NY 10278, telephone: +, or via email at +; and (2) accompanied by an executed copy of the attached +Declaration of Custodian of Records. PLEASE PROVIDE IN ELECTRONIC FORMAT IF +POSSIBLE. +Failure to attend and produce any items hereby demanded will constitute contempt of court and will +subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law. +DATED: +New York, New York +October 23, 2019 +GSB. +GEOFFREY S. BERMAR +Uniled States Altorney for the +Southern District of New York +Assistant United States Attorney +One St. Andrew's Plaza +New York, New York 10007 +Telephone: +rev. 02.01.12 + + +RIDER +(Grand Jury Subpoena to Google, Inc., dated October 23, 2019) +Please provide all records for any accounts registered to or associated with the following +identifiers: +• Name: Ghislaine Maxwell +• Phone numbers: +• Email addresses: +All records should include, but are not limited to, the following: +2. +4. +All subscriber identifying information, including, but not limited to: +a. +name +b. +username or other subscriber identity or number +C. +address +d. +primary and alternate telephone numbers +pain or and alternate email adresses +social security number +any temporarily assigned network address +1. +j. +MAC address +Browser and operating system information +Records of session times and durations and any IP addresses used by the subscriber at +the beginning, end, and at any time during these sessions; +Length of service (including start date) and types of service utilized; +Means and source of payment for services (including any credit card or bank account +number; +Account notes and logs, including any customer-service communications or other +correspondence with the subscriber; and +Investigative files or user complaints concerning the subscriber, account, or phone +number. + + +7. +Any and all call records, including, but not limited to, incoming and outgoing calls +with any call details, local and long distance usage details, all subscriber opening +and/or registration documents, all subscriber identification and contact information, +all subscriber billing and payment information, SMS/text messaging records, IP +history and login records, associated email addresses and/or screen names, and any +additional accounts associated with any of the below-listed names, identifiers, +addresses, phone numbers, and accounts listed and associated records for those +accounts, from the date of registration of the phone number to present. +8. +Provide the phone number(s) and subscriber information for any other phone +number(s) listed to the same account as the above listed number(s) and for any other +accounts billed to any subscriber at the same address as the listed number(s), or using +the same name, email address, phone number, mailing address, or payment +information, and the associated information as described above. +N.B.: Personal appearance is not required if the requested records are (1) produced by on +or before the return date to Special Agent +]at: Federal Bureau of +Investigation, 26 Federal Plaza, VCAC/Human Trafficking, New York, NY 10278, +telephone: +,, or via email at +; and (2) accompanied by an +executed copy of the attached Declaration of Custodian of Records. PLEASE PROVIDE +IN ELECTRONIC FORMAT IF POSSIBLE. +IMPORTANT: REQUEST FOR NON-DISCLOSURE +Due to the ongoing nature of the investigation, it is requested that you do not +disclose any information relating to this Grand Jury subpoena request to any third party. + + +Declaration of Custodian of Records +Pursuant to 28 U.S.C. § 1746, I, the undersigned, hereby declare: +My name is +(name of declarant) +I am a United States citizen and I am over eighteen years of age. I am the custodian of +records of the business named below, or I am otherwise qualified as a result of my position with +the business named below to make this declaration. +I am in receipt of a Grand Jury Subpoena, dated October 23, 2019, and signed by +Assistant United States Attorney +,, requesting specified records of the business +named below. Pursuant to Rules 902(11) and 803(6) of the Federal Rules of Evidence, I hereby +certify that the records provided herewith and in response to the Subpoena: +1) were made at or near the time of the occurrence of the matters set forth in the records +›y, or from information transmitted by, a person with knowledge of those matters +(2) were kept in the course of regularly conducted business activity; and +(3) were made by the regularly conducted business activity as a regular practice. +I declare under penalty of perjury that the foregoing is true and correct. +Executed on +(date) +(signature of declarant) +(name and title of declarant) +(name of business) +(business address) +Definitions of terms used above: +As defined in Fed. R. Evid. 803(6), "record" includes a memorandum, report, record, or data +compilation, in any form, of acts, events, conditions, opinions, or diagnoses, The term, +"business" as used in Fed. R. Evid. 803(6) and the above declaration includes business, +institution, association, profession, occupation, and calling of every kind, whether or not +conducted for profit. + + +19 MAt +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +In Re Grand Jury Subpoena to Google, Inc.., +dated October 23, 2019, USAO Reference +No. 2018R01618 +9975 +§ 2705(b) +Non-Disclosure Order +to Service Provider +SEALED +Upon the application of the United States pursuant to 18 U.S.C. § 2705(b): +1. The Court hereby determines that there is reason to believe that notification of the +existence of the attached subpoena will result in one or more of the following consequences, +namely, endangering the life or physical safety of an individual; flight from prosecution; +destruction of or tampering with evidence; intimidation of potential witnesses; or otherwise +seriously jeopardizing an investigation or unduly delaying a trial. +Accordingly, it is hereby ORDERED: +2. Google, Inc. (the "Service Provider") shall not, for a period of 180 days from the date +of this Order (and any extensions thereof), disclose the existence of this Order or the attached +subpoena, to the listed subscriber of the accounts referenced in the subpoena, or to any other +person, except that the Service Provider may disclose the attached subpoena to an attorney for +the Service Provider for the purpose of receiving legal advice. +3. This Order and the Application upon which it was granted are to be filed under seal +until otherwise ordered by the Court, except that the Government may without further order +provide copies of the Application and Order as need be to personnel assisting the Government in +the investigation and prosecution of this matter, and disclose these materials as necessary to +comply with discovery and disclosure obligations in any prosecutions rélated to this matter. +Dated: +New York, New York +OCT 2 3 2019 +S/Debra Freeman +UNITED STATES MAGISTRATE JUDGE +Debra Freemar +United States Magistrate Judge +Soulhern District of New York diff --git a/vision-fixhub/ds9-parsed-01/149680a28bd6d86710a4aa8988c11733de3849fbe9f04ce45beb44a1248e7468.receipt.json b/vision-fixhub/ds9-parsed-01/149680a28bd6d86710a4aa8988c11733de3849fbe9f04ce45beb44a1248e7468.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..c98677bb90b6aad1a3a89a28ab5dc173602a1589 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/149680a28bd6d86710a4aa8988c11733de3849fbe9f04ce45beb44a1248e7468.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -108, + "dataset": "marble-joined", + "doc_id": "149680a28bd6d86710a4aa8988c11733de3849fbe9f04ce45beb44a1248e7468", + "engine": "marble-apple-vision", + "event_count": 9, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "8648ce6f62e6a0ad05a83948c32a441a272c53a5158941b199d0dcebc074048d", + "output_sha256": "a967e85204d9563ea0652f61f05077a0c3ec081e324bf9d97f45fac92fab1c40", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/14a46cca3c2d53b81d6ae9d5e4158dd44f7657a1ee31facb15a0edd0ed3f0146.md b/vision-fixhub/ds9-parsed-01/14a46cca3c2d53b81d6ae9d5e4158dd44f7657a1ee31facb15a0edd0ed3f0146.md new file mode 100644 index 0000000000000000000000000000000000000000..208ddc5e027b906f98006245d2d14fd1b765afc7 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/14a46cca3c2d53b81d6ae9d5e4158dd44f7657a1ee31facb15a0edd0ed3f0146.md @@ -0,0 +1,46 @@ +From: +To: "Moyer, Thomas" +Ce: "Moyne, Parvin" +I"< +"Benjamin, James" +, Andrew Stemmer +Subject: RE: Deutsche Bank Production +Date: Thu, 01 Aug 2019 00:34:46 +0000 +Tom, +Received, thanks. Following up on our previous conversation (and copying Andrew since I think we discussed this with +him), could you please let us know the current status on us being able to meet with someone (or someones) who can talk +with us in general terms about the nature of Epstein's accounts and their activities? Also, do you have a sense - or if not, +do you know when you'll have a sense - of what the overall production volume is likely to be, and the approximate +timeline for complete production? The answer may be that you're not sure yet, which would be understandable, but we +wanted to check. +thanks, +From: Moyer, Thomas • +Sent: Tuesday, July 30, 2019 15:49 +To: +Cc: Moyne, Parvin +Subject: Deutsche Bank Production +; Benjamin, James < +On behalf of our client, Deutsche Bank, the link below contains an additional production of documents in response to +your July 11, 2019 subpoena. Also attached is the accompanying cover letter for today's production. The password to +access these materials is the same as it was for the previous submissions. For your convenience, I will recirculate it +momentarily under separate cover. +Please do not hesitate to reach out if you have any questions. +Regards, +Tom +Citrix Attachments +DB-SDNY-Prod004.zip +Expires January 26, 2020 +67.4 MB +Download Attachments +Thomas Moyer uses Citrix Files to share documents securely. + + +Tom Moyer +AKIN GUMP STRAUSS HAUER & FELD LuP +2001 K Street N.W. Washington, DC 20006 | USA | Direct +Fax: +akingump.com +Internal: +The information contained in this e-mail message is intended only for the personal and confidential use of the +recipient(s) named above. If you have received this communication in error, please notify us immediately by e- +mail, and delete the original message. diff --git a/vision-fixhub/ds9-parsed-01/14a46cca3c2d53b81d6ae9d5e4158dd44f7657a1ee31facb15a0edd0ed3f0146.receipt.json b/vision-fixhub/ds9-parsed-01/14a46cca3c2d53b81d6ae9d5e4158dd44f7657a1ee31facb15a0edd0ed3f0146.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..932b355081cbdf74ac841469e21f9f32f7b9fbce --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/14a46cca3c2d53b81d6ae9d5e4158dd44f7657a1ee31facb15a0edd0ed3f0146.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "14a46cca3c2d53b81d6ae9d5e4158dd44f7657a1ee31facb15a0edd0ed3f0146", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "92753b961d085f9d2d4bd3083e60fbaa092a38208697f5075551457444f5e40b", + "output_sha256": "32041f3243fd2d6738a9faba3d0f1e4d590b9529c3053cec7956d2d1650be8a8", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/14ac1ebb94aa18dda176bbb51edb0fe6c5f02c9641ff3a6e2b21cd9515a5c40c.md b/vision-fixhub/ds9-parsed-01/14ac1ebb94aa18dda176bbb51edb0fe6c5f02c9641ff3a6e2b21cd9515a5c40c.md new file mode 100644 index 0000000000000000000000000000000000000000..951c60bf66f8f6682417d875fffee06f307fa783 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/14ac1ebb94aa18dda176bbb51edb0fe6c5f02c9641ff3a6e2b21cd9515a5c40c.md @@ -0,0 +1,20 @@ +From: +Sent: +To: +Subject: +Attachments: +Sunday, August 18, 2019 1:09 PM +WELLNESS CHECK +TEXT.htm +Good Afternoon, +On 08-17-2019 called Officer Thomas at 2:00 pm no answer, left a message. +On 08-17-2019 called Officer Noel at 2:02 pm no answer, left a message. +On 08-18-2019 called Officer Thomas at 1:00 pm no answer, left a message. +On D8-18-2019 called Officer Noel at 1:03 pm, phone went to voice mail left a message. +Thank you, +SCSS (Duty Officer) +Correctional Systems Officer +ECC. Butner +Butner. NC 27509 +"This message is intended for official use and may contain SENSITIVE information. If this message contains +SENSITIVE information, it should be properly delivered, labeled, stored, and disposed of according to policy." diff --git a/vision-fixhub/ds9-parsed-01/14ac1ebb94aa18dda176bbb51edb0fe6c5f02c9641ff3a6e2b21cd9515a5c40c.receipt.json b/vision-fixhub/ds9-parsed-01/14ac1ebb94aa18dda176bbb51edb0fe6c5f02c9641ff3a6e2b21cd9515a5c40c.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..c27e787b8d9a742bd5420bf9bc8a7ebc468462a9 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/14ac1ebb94aa18dda176bbb51edb0fe6c5f02c9641ff3a6e2b21cd9515a5c40c.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "14ac1ebb94aa18dda176bbb51edb0fe6c5f02c9641ff3a6e2b21cd9515a5c40c", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "0e0a11796bd310df71f1dcf4f1125e14ebc0e137b894335a4c3416231cbac211", + "output_sha256": "d13f094afe79afba2ced529e86eb403fbe89c09f9d42a8cc15aac4d3331f9178", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/14e211e574f1697cd4b6273bd7be25eec7934c4b4586828c86f1752a801a7130.md b/vision-fixhub/ds9-parsed-01/14e211e574f1697cd4b6273bd7be25eec7934c4b4586828c86f1752a801a7130.md new file mode 100644 index 0000000000000000000000000000000000000000..1fdf67445f5bb87905e91f5d6b12a6d1091be8f7 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/14e211e574f1697cd4b6273bd7be25eec7934c4b4586828c86f1752a801a7130.md @@ -0,0 +1,42 @@ +From: " +(USANYS)" { +To: " +(USANYS)" < +Subject: FW: U.S. v. Maxwell, Case No. 20 Cr. 330 (AJN) [Ms. Maxwell's Response to Government's +Omnibus Motions in Limine] +Date: Tue, 26 Oct 2021 13:08:29 +0000 +Attachments: 2021.10.25_Maxwell's_Respons_to_Government's_Omnibus_Motions_in_Limine.zip; +Govt_Omnibus_Opp_[Unredacted] pdf; Govt _Exhibit_A.pdf; Govt_Exhibit_B.pdf +Inline-Images: image001 jpg +From: +Sent: Tuesday, October 26, 2021 12:00 AM +To: +| (USANYS) < +Cc:| +(USANYS) < +(USANYS) < +Subject: FW: U.S. v. Maxwell, Case No. 20 Cr. 330 (AJN) [Ms. Maxwell's Response to Government's Omnibus Motions in +Limine] +Hi Chiefs, +Attached are their motions and the final version of ours, in case you'd like to see that. +Thanks, +From: Nicole Simmons < +Sent: Monday, October 25, 2021 11:50 PM +To: 'Nathan NYSD Chambers' ‹ +Cc: Jeff Pagliuca < +P; Laura Menninger < +(USANYS) +Subject: [EXTERNAL] U.S. v. Maxwell, Case No. 20 Cr. 330 (AJN) [Ms. Maxwell's Response to Government's Omnibus +Motions in Limine] +Dear Judge Nathan: +At the request of Jeffrey Pagliuca, please see attached Ms. Maxwell's Response to the Government's Omnibus Motions in +Limine and supporting documents. +Regards, +Nicole Simmons +Nicole Simmons +Haddon, Morgan and +Foreman, P.C. +Denver, Colorado +- + + diff --git a/vision-fixhub/ds9-parsed-01/14e211e574f1697cd4b6273bd7be25eec7934c4b4586828c86f1752a801a7130.receipt.json b/vision-fixhub/ds9-parsed-01/14e211e574f1697cd4b6273bd7be25eec7934c4b4586828c86f1752a801a7130.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..cf950ece2566ba3bbb5e086b1ecfdc9f0f9d1574 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/14e211e574f1697cd4b6273bd7be25eec7934c4b4586828c86f1752a801a7130.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "14e211e574f1697cd4b6273bd7be25eec7934c4b4586828c86f1752a801a7130", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "62cdac5211676022814411144fcbce4d9b62838c840c8565aab913bfabf5a135", + "output_sha256": "65b9066b205c30c459129d68a8efdd9027eb1de9cc19933a76b1a0032c7178a1", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/14f223615c79877a14994d1dca333fa2b9781a986f9e674ba5bfb36840ff0ec3.md b/vision-fixhub/ds9-parsed-01/14f223615c79877a14994d1dca333fa2b9781a986f9e674ba5bfb36840ff0ec3.md new file mode 100644 index 0000000000000000000000000000000000000000..613c1bee3256c54140ae7fc1de6a9e2d91fc061d --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/14f223615c79877a14994d1dca333fa2b9781a986f9e674ba5bfb36840ff0ec3.md @@ -0,0 +1,15 @@ +From: +To: +Subject: Re: Epstein, Jeffrey Edward, Reg. No. 73618-054 +Date: Mon, 12 Aug 2019 20:03:00 +0000 +Importance: Normal +Attachments: TEXT.htm +Thank you! +>>> +8/12/2019 4:02 PM >>> +FYL...S/W and Psych Ops docs +Associate Warden +MCC New York +150 Park Row +New York, NY 10007 +NYM/AW-Programs~ @bop.gov diff --git a/vision-fixhub/ds9-parsed-01/14f223615c79877a14994d1dca333fa2b9781a986f9e674ba5bfb36840ff0ec3.receipt.json b/vision-fixhub/ds9-parsed-01/14f223615c79877a14994d1dca333fa2b9781a986f9e674ba5bfb36840ff0ec3.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..83a1f25bdea9ca84cb7b2bb6e8265571e15dfc52 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/14f223615c79877a14994d1dca333fa2b9781a986f9e674ba5bfb36840ff0ec3.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "14f223615c79877a14994d1dca333fa2b9781a986f9e674ba5bfb36840ff0ec3", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "c7468675c66d3694a3415ad9aaa14ba2a6d9004518cfbbf8f54cacf1f3b48ef9", + "output_sha256": "9f540926d0a010e7f8e13b1b106f3a26939fee334827e723200ee0d1790306bf", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1507d7d98169dd1c6c46a24404babd8e94f181476c6dc2c2aa4bbb804cf1807c.md b/vision-fixhub/ds9-parsed-01/1507d7d98169dd1c6c46a24404babd8e94f181476c6dc2c2aa4bbb804cf1807c.md new file mode 100644 index 0000000000000000000000000000000000000000..5e41acb43565d38febb24e7513778a8e6dcd74b6 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1507d7d98169dd1c6c46a24404babd8e94f181476c6dc2c2aa4bbb804cf1807c.md @@ -0,0 +1,75 @@ +U.S. Department of Justice +United States Attorney +Southern District of New York +86 Chambers Street +New York, New York 10007 +May 4, 2021 +By Hand Delivery and ECF +The Honorable Paul A. Engelmayer +United States District Judge +Southern District of New York +40 Foley Square +New York, NY 10007 +Re: +The New York Times Co. v. Federal Bureau of Prisons, 20 Civ. 833 (PAE) +Dear Judge Engelmayer: +This Office represents defendant the Federal Bureau of Prisons ("BOP**) in this Freedom of +Information Act ("FOIA"), 5 U.S.C. § 552, action brought by plaintiff the New York Times +Company (the "Times") seeking the release of certain records related to Jeffrey Epstein. +Enclosed please find the Government's first in camera production. As directed by the Court, this +production consists of certain records identified in Exhibit 1 to the supplemental Christenson +declaration. +The production consists of 986 pages, including 375 pages of non-email documents and 611 +pages of emails. In connection with this production, the Government reviewed certain records in +the production and determined that they could be released with appropriate redactions. Pursuant +to the Court's directions, the Government has, for each page, indicated which portions of the +page are withheld under which FOIA Exemption and, if a portion or the entire page is withheld +under FOIA Exemption 7(A), indicated which criminal case, United States v. Tartaglione, 16-cr- +832 (KMK), or United States v. Noel, 19-cr-830 (AT), is the basis for the exemption. +Because of technological and other constraints, the Government used two systems to mark +the redactions on the pages. Under one system, a redaction is marked out by a pink box, and the +associated exemption is noted next to or within the box. Under the second system, the +Government highlighted redacted material as follows: material withheld under Exemption 7(A) +on the basis of Noel is highlighted red, material withheld under Exemption 7(A) on the basis of +Tartaglione is highlighted goldenrod yellow, material withheld under Exemptions 6 and 7(C) is +highlighted green, material withheld under FOIA Exemption 5 and the deliberative process +privilege is highlighted blue, and material withheld under FOIA Exemption 7(E) is highlighted +purple.' Under this second system, pages withheld in full are marked as such by a box in the +color corresponding to the exemption, with text noting the withholding in full. On certain pages, +both systems are used, with some redactions marked out using pink boxes, and other redactions +marked out with highlighting. +' If the entirety of a paragraph on a given page is withheld, then parallel lines in the appropriate +color have placed on either side that paragraph to indicate redaction. + + +Page 2 +The Government notes that upon compiling this submission, it identified and removed some +duplicate pages from the production. In addition, it re-ordered the documents, roughly by type +and content such that the Bates numbers on the documents are no longer strictly in order. These +steps were taken to facilitate the Court's review. +The production includes emails between Tartaglione's defense counsel and the Bureau of +Prisons, which typically discuss the conditions of Tartaglione's confinement and have been +withheld in full under Exemption 7(A) on the basis of Tartaglione. The Government believes +that many of these emails are not directly responsive to the Times's FOIA requests, but were +collected by BOP pursuant to electronic search terms generally because Jeffrey Epstein may be +mentioned at some point in a chain of emails and also possibly because Tartaglione's defense +counsel, Bruce Barket, is associated with the firm Barket, Epstein, Kearon, Aldea & LoTurco, +LLP, and so the name "Epstein" typically appears in the signature block of his emails. If the +Court would benefit from further submissions on why release of these emails in the context of a +FOIA request about Jeffrey Epstein could reasonably be expected to interfere with Tartaglione, +the Government is prepared to provide such submissions. However, upon re-reviewing these +materials and in light of representations by the Times as to its area of greatest interest, the +Government does not believe that these emails are of central concern in this matter and could be +fairly described as non-responsive to the Times's requests. +I thank the Court for its consideration of this submission. +Respectfully submitted, +By: +AUDREY STRAUSS +United States Attorney +/s/ Steven J. Kochevar +Steven J. Kochevar +Assistant United States Attorney +300 Quarropas Street +White Plains, NY 10007 +Telephone: (914) 993-1928 +Email: steven.kochevar@usdoj.gov diff --git a/vision-fixhub/ds9-parsed-01/1507d7d98169dd1c6c46a24404babd8e94f181476c6dc2c2aa4bbb804cf1807c.receipt.json b/vision-fixhub/ds9-parsed-01/1507d7d98169dd1c6c46a24404babd8e94f181476c6dc2c2aa4bbb804cf1807c.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..6a8f37066df31a35f2303bb429a3cca904eae3fc --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1507d7d98169dd1c6c46a24404babd8e94f181476c6dc2c2aa4bbb804cf1807c.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "1507d7d98169dd1c6c46a24404babd8e94f181476c6dc2c2aa4bbb804cf1807c", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "2986efb481040fc00a4e3ad9c4809ce2a8d6042587ee835ca53428695400ed27", + "output_sha256": "bf30405fa2424f05d1ba5792ff507916023f44c237cd996dfc2b9a38c8ce03ac", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1529483c1714d51fdf66ed46fcae126a788b620de929535b83ed5ee04053f6cf.md b/vision-fixhub/ds9-parsed-01/1529483c1714d51fdf66ed46fcae126a788b620de929535b83ed5ee04053f6cf.md new file mode 100644 index 0000000000000000000000000000000000000000..6a44aca594b6f71f95bcb5a7b0c7525343e3e486 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1529483c1714d51fdf66ed46fcae126a788b620de929535b83ed5ee04053f6cf.md @@ -0,0 +1,635 @@ +MOO NEW TORH +SPECIAL HOURNG WRIT +FRAME +12:00-12:30 AM +12:30-1:00 AM +1:00-1:30 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00-5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +OPERATIONS +LIEUTENANT +ICO NEW YORK +MCC NEW YORK +SPECIAL HOUSING UNIT +30 MINUTE CHECK SHEET +ZA +TIER-G +DATE: 08/10/2019 +START +END +SIGNATURE +SPECIALHOUSING URIT +START +1209 +11241 +1" +134 +20°7 +241 +2304 +313 +414 +K140 +508 +END +12'° +242 +112 +138 +209 +245 +308 +34 +47 +ste +542 +U" +SIGNATURE +TIME FRAME +8:00-8:30 AM +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30- 1:00 PM +1:00-1:30 PM +1:30-2:00 PM +2.00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +TIME FRAME +4:00-4:30 PM +4:30-5:00 PM +5:00 - 5:30 PM +5:30-6:00 PM +6:00-6:30 PM +6:30-7:00 PM +7:00-7:30 PM +7:30-8:00 PM +8:00-8:30 PM +8:30-9:00 PM +9:00-9:30 PM +9:30-10:00 PM +10:00-10:30 PM +10:30-11:00 PM +11:00-11:30 PM +11:30-12:00 PM +START +END +SIGNATURE +DAY WATCH +OPERATIONS +LIEUTENANT +EVENING WATCH +OPERATIONS +LIEUTENANT +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, 12:30 +am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be condueted +on an irregular schedule and no more than 40 minutes apart. All observations must be documented. + + +MCG NEW TORK +EGG DEW TORR +SPECIAL HOUSING UNIT +MCC NEW YORK +SPECIAL HOUSING UNIT +30 MINUTE CHECK SHEET +ZA +TIER-H +DATE:_08/10/2019 +STAR: +END +SIGNATURE +SPECIALHOUFING UNIT +FRAME +12:00-12:30 AM +12:30-1:00 AM +1:00-1:30 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00 -5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +OPERATIONS +LIEUTENANT +START +12"' +1246 +113 +1:37 +2" +24 +END +SIGNATURE +TIME FRAME +124 +114 +343 +414 +140 +1,510 +543 +344 +44 +5" +8:00-8:30 AM +8:30-8:00 AM +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30-1:00 PM +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +DAY WATCH +OPERATIONS +LIEUTENANT +TIME FRAME +STAR +4:00-4:30 PM +4:30-5:00 PM +5:00 - 5:30 PM +5:30-6:00 PM +6:00-6:30 PM +6:30-7:00 PM +7:00-7:30 PM +7:30-8:00 PM +8:00-8:30 PM +8:30-9:00 PM +9:00-9:30 PM +9:30-10:00 PM +10:00-10:30 PM +10:30-11:00 PM +11:00-11:30 PM +11:30-12:00 PM +EVENING WATCH +OPERATIONS +LIEUTENANT +A staff member must observe all inmates ‹ infined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at le: st once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another roun 1 in the second 30 minutes period of the same hour (example, 12:30 +am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be conducted +on an irregular schedule and no more than • 0 minutes apart. All observations must be documented. +SIGNATURE + + +MOG NEW YORK +SPECIM HOWANG WAIT +FRAME +12:00-12:30 AM +12:30- 1:00 AM +1:00-1:30 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00-5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +OPERATIONS +LIEUTENANT +START +END +SIGNATURE +1205 |201 +123ª |93 +107 +108 +135 +136 +205 +2° +301 +2 +249 +305 +339 +3Ole +3410 +112 +43 +4340 +A +504 +5° +B3t +538 +MCC NEW YORK +SPECIAL HOUSING UNIT +30 MINUTE CHECK SHEET +ZA +TIER-J +DATE:_08/10/2019 +TIME FRAME +START +END +SIGNATURE +8:00-8:30 AM +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30-1:00 PM +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +ROO NEW YORK +SPECIAL HOUSING UNIT +TIME FRAME +START +SIGNATURE +4:00-4:30 PM +430-5:00 PM +5:00-5:30 PM +5:30-6:00 PM +6:00-6:30 PM +6:30-7:00 PM +7:00-7:30 PM +7:30-8:00 PM +8:00-8:30 PM +8:30-9:00 PM +9:00-9:30 PM +9:30-10:00 PM +10:00-10:30 PM +10:30-11:00 PM +11:00-11:30 PM +11:30-12:00 PM +DAY WATCH +OPERATIONS +LIEUTENANT +EVENING WATCH +LOPERATIONS +LIEUTENANT +A sun member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, 12:30 +am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour, These rounds are to be conducted +on an irregular schedule and no more than 40 minutes apart. All observations must be documented. + + +MCG NEW TORN +SPECIAL HOUSING DAIT +FRAME +12:00-12:30 AM +12:30-1:00 AM +1:00-1:30 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00-5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +OPERATIONS +LIEUTENANT +SIGNATURE +START +END +1207 +1239 +12° +IDEN +109 +137 +267 +209 +241 +24 +207 30₴ +341 Bad +44 +<38 +4 +4 +3 +504 +0339 +5° +109 +MCC NEW YORK +SPECIAL HOUSING UNIT +30 MINUTE CHECK SHEET +ZA +TIER-K +DATE: 08/10/2019 +TIME FRAME +START +SIGNATURE +8:00-8:30 AM +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30-1:00 PM +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +MCC NEW YORK +SPECIA HOUSING UNIT +TIME FRAME +4:00-4:30 PM +4:30-5:00 PM +5:00 - 5:30 PM +5:30-6:00 PM +6:00-6:30 PM +6:30-7:00 PM +7:00-7:30 PM +7:30-8:00 PM +8:00-8:30 PM +8:30-9:00 PM +9:00-9:30 PM +9:30-10:00 PM +10:00-10:30 PM +10:30-11:00 PM +11:00-11:30 PM +11:30-12:00 PM +START +END +SIGNATURE +DAY WATCH +OPERATIONS +LIEUTENANT +VENING WATC +PERATION +LIEUTENANT +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +. m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, 12:3 +m - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be conducte +on an irregular schedule and no more than 40 minutes apart. All observations must be documented. + + +ROG NEW YORK +SPECIM HOUSInG WAIT +FRAME +12:00-12:30 AM +12:30-1:00 AM +1:00-1:30 AM +1:30-2:00 AM +2:00•2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00 -5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +OPERATIONS +LIEUTENANT +BOO NEW TORK +MCC NEW YORK +SPECIAL HOUSING UNIT +30 MINUTE CHECK SHEET +ZA +TIER- L +DATE: 08/10/2019 +SPECIAL HOUSING UNIT +START +1201 +1233 +103 +131 +201 +Q35 +3o1 +333 +408 +430 +500 +533 +402 +END +SIGNATURE +TIME FRAME +STARTE +END +SIGNATURE +TIME FRAME +START +ENSE +12°4 +12* +104 +132 +202 +234 +30? +334 +110? +43 +534 +8:00-8:30 AM +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30 - 1:00 PM +1:00-1:30 PM +1:30-2:00 PM +2.00-2:30 PM +2:30-3:00 PM +3.00-3:30 PM +3:30-4:00 PM +DAY WATCH +OPERATIONS +LIEUTENANT +4:00-4:30 PM +4:30-5:00 PM +5:00-6:30 PM +5:30-6:00 PM +6:00-6:30 PM +6:30-7:00 PM +7:00-7:30 PM +7:30-8:00 PM +8:00-8:30 PM +8:30.9:00 PM +9.00-9:30 PM +9:30-10:00 PM +10:00-10:30 PM +10:30-11:00 PM +11:00-11:30 PM +11:30-12:00 PM +EVENING WATCH +OPERATIONS +LIEUTENANT +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, 12:30 +am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be conducted +on an irregular schedule and no more than 40 minutes apart. All observations must be documented. +SIGNATURE + + +DOG NEW YORK +SPECIAL HOUSING WAIT +FRAME +12:00-12:30 AM +12:30-1:00 AM +1:00-1:30 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00 -5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +OPERATION +LIEUTENANT +BOO DEW YORK +MCC NEW YORK +SPECIAL HOUSING UNIT +30 MINUTE CHECK SHEET +ZA +TIER-M +DATE:_08/10/2019 +STAR +SIGNATURE +SPECIAL HOUSING UNIT +START +END +203 +1235 +1234 +105 +1060 +133 +134 +203 +204 +287 +238 +303 +333 +304 +334 +408 +409 +434 +1135 +6502 +503 +535 534 +484 405 +SIGNATURE +TIME FRAME +8:00-8:30 AM +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30-1:00 PM +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +TIME FRAME +4:00-4:30 PM +430-5:00 PM +5:00-5:30 PM +5:30-6:00 PM +6:00-6:30 PM +6:30-7:00 PM +7:00-7:30 PM +7:30-8:00 PM +8:00-8:30 PM +8:30-9:00 PM +9:00-9:30 PM +9:30-10:00 PM +10:00-10:30 PM +10:30-11:00 PM +11:00-11:30 PM +11:30-12:00 PM +START +SIGNATURE +DAY WATCH +OPERATIONS +LIEUTENANT +EVENING WATCH +PERATION +IEUTENAN +A staff member must observe all inmates confined in a continuous locked down status, such as administrative \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/1529483c1714d51fdf66ed46fcae126a788b620de929535b83ed5ee04053f6cf.receipt.json b/vision-fixhub/ds9-parsed-01/1529483c1714d51fdf66ed46fcae126a788b620de929535b83ed5ee04053f6cf.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..08952b42d7591b3aba7ac782828f38d2791ae79e --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1529483c1714d51fdf66ed46fcae126a788b620de929535b83ed5ee04053f6cf.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -508, + "dataset": "marble-joined", + "doc_id": "1529483c1714d51fdf66ed46fcae126a788b620de929535b83ed5ee04053f6cf", + "engine": "marble-apple-vision", + "event_count": 7, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "776d0b1adf37d32dec656ae18c248f45a12b6d262f332c108546fccd6e37a03d", + "output_sha256": "e12689659d0647cc2229288932b51cec6a2acc746724ad246a4ca92545a3506a", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1530f29af577503bb488231cc127de7c8f0b210b394b583841dddf43e3375a39.md b/vision-fixhub/ds9-parsed-01/1530f29af577503bb488231cc127de7c8f0b210b394b583841dddf43e3375a39.md new file mode 100644 index 0000000000000000000000000000000000000000..a83339f6b48604ffbe860c949257d8bdcc5e8857 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1530f29af577503bb488231cc127de7c8f0b210b394b583841dddf43e3375a39.md @@ -0,0 +1,72 @@ +FD-1087 (Rev. 5-8-10) +90A-NY-3151227 Serial 24 +FEDERAL BUREAU OF INVESTIGATION +Collected Item Log +Event Title: +(U) Seizure of DVR Controller and +DVR System #1 +Date: +08/15/2019 +Approved By: +Drafted By: +Case ID #: 90A-NY-3151227 +(U) UNSUB (S) ; +JEFFREY EPSTEIN - VICTIM; +DEATH INVESTIGATION +Collected From: +(U) Electronics Technition| +Metropolitan Corrections Center +150 Park Lane +New York, New York +Receipt Given?: No +Holding Office: NEW YORK +Details: +On August 15, 2019, Special Agent +seized a Dell +Powerridge R420 DVR Controller and DVR System #1, a NICE VISION PRO +Digital Video & Audio Recorder from the Metropolitan Corrections Center +(MCC), located at 150 Park Row, New York, NY. +Dell Powerridge R420 DVR Controller, barcode# 5BMQ212, Express service +Code #: 11587249622, Manufacturer date: 20140829 +DVR System #1 consists of the following items: +Disk Array Chassis containing 16 hard Drives; Model#: Premium 8600, SN: + +Disk Array Controller; Model#: NP-2000, SN: 43144901 +This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your agency; it and its +contents are not to be distributed outside your agency. +SDNY_00013359 + + + +Title: +Re: +90A-NY-3151227 Serial 24 +(U) Seizure of DVR Controller and DVR System #1 +90A-NY-3151227, 08/15/2019 +Item Type +1B Digital +1B Digital +Description +(U) Dell Powerridge R420 DVR Controller, Barcode# +5BMQ212, Express +service Code #: 11587249622, +Manufacturer date: 20140829 +Collected On: +08/15/2019 02:30 PM EDT +Receipt Number: 1 +Seizing Individual: +Collected By: +Device Type: Digital Video Recorder (DVR) +Number of Devices Collected: +(U) DVR System #1 consists of the following items: +1. Disk Array Chassis containing 16 hard Drives; Model#: +Premium 8600, +SN: 232476 +2. Disk Array Controller; Model#: NP-2000, SN: 43144901 +Collected On: 08/15/2019 02:30 PM EDT +Seizing Individual: +Collected By: +Device Type: Digital Video Recorder (DVR) +Number of Devices Collected: 1 +2 +SDNY_00013360 diff --git a/vision-fixhub/ds9-parsed-01/1530f29af577503bb488231cc127de7c8f0b210b394b583841dddf43e3375a39.receipt.json b/vision-fixhub/ds9-parsed-01/1530f29af577503bb488231cc127de7c8f0b210b394b583841dddf43e3375a39.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..3ac7e95a4703217b09d036c92b4d3a31efd8ce91 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1530f29af577503bb488231cc127de7c8f0b210b394b583841dddf43e3375a39.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -107, + "dataset": "marble-joined", + "doc_id": "1530f29af577503bb488231cc127de7c8f0b210b394b583841dddf43e3375a39", + "engine": "marble-apple-vision", + "event_count": 6, + "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "9728e40d93d05a511da6780b9648ee9d49cbd37d516d507fb09764e5df7d66b4", + "output_sha256": "c1055bb3aa90dac68a2cd7b14cbcdd6250fe0fef9e6cd81b3b871f86a8f45678", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/156873670e33be293ef8997789e66f6e06f45cc9b3a537eed4eb9293f36baaa3.md b/vision-fixhub/ds9-parsed-01/156873670e33be293ef8997789e66f6e06f45cc9b3a537eed4eb9293f36baaa3.md new file mode 100644 index 0000000000000000000000000000000000000000..fb0a8aadd1311a9595cc22ad43b59e5f6dbb014d --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/156873670e33be293ef8997789e66f6e06f45cc9b3a537eed4eb9293f36baaa3.md @@ -0,0 +1,380 @@ +PAGE 001 +: +07-18-2019 +07:56:08 +'UNCTION. +ON START DATE: 07-06 - 20L +SELECTION CATEGORY: ARS EQ ALL +FACL..: NYM +NEXT/PRIOR: +ACT/FUT/HIS: A +FORMAT: I +LOG END DATE..: 07-18-2019 +ALL FACILS?: N +- --EFFECTIVE- - - - - ENTRY - - - +DATE REG NO +NAME +DATE +TIME TID +TIME +07-06 76254-054 BURNETT +L HOSP USM A-PRE +07-06-2019 0039 NYMD4 0039 ++7-06-76318-054 BPSTEIN +07-06-2019-2124 NYMG3 2127 +07-07 76319-054 WILLIAMS +07-07-2019 0318 NYMD4 0319 +07-08 11608-082 BENJAMIN +RELRASE +07-08-2019 1800 NYMGZ 1801 +ADM CHANGE +07-08-2019 1827 NYMGZ 1827 +ADM CHANGE A-DES +07-08-2019 1828 NYMGZ 1828 +07-08 86159-054 BIGNON +07-08-2019 1832 NYMGZ 1832 +07-08 70786-050 BROWN +RELEASE +07-08-2019 1025 NYMCM 1026 +07-08 57297-083 BUCHANAN +RELEASE +07-08-2019 1422 NYMGZ 1422 +07-08 65759-050 CABRERA +07-08-2019 1423 NYMGZ 1423 +07-08 76218-054 CHERRY +L HOSP USM A-PRE +07-08-2019 1539 NYMGZ 1539 +07-08 79251-054 DELACRUZ +07-08-2019 1424 NYMGZ 1425 +07-08 77202-112 DELGADO +HLD REMOVE 07-08-2019 0831 NYMCM 0832 +07-08 76318-054 EPSTEIN +07-08-2019 0920 NYMCM 0921 +07-08-2019 1749 NYMGZ 1749 +07-08 86290-054 GARCIA +HLD REMOVE +07-08-2019 0833 NYMCM 0833 +07-08-2019 1418 NYMGZ 1418 +07-08 76287-054 HERNANDEZ +ADM CHANGE +07-08-2019 1842 NYMAM 1842 +07-08-2019 1843 NYMAM 1843 +07-08 86202-054 KIM +07-08-2019 0834 NYMCM 0834 +07-08 24988-014 MAHMOOD +LOCAL HOSP +07-08-2019 1017 NYMCM 1018 +LOCAL HOSP A-DES +07-08-2019 1538 NYMGZ 1538 +07-08 11867-087 MARSHALL +RELEASE +A-DES +07-08-2019 1020 NYMCM 1021 +07-08 86913-054 MENDOZA +A - 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Lieutenant +COPY" + + +Special Investigative Section +Type of Incident +Date and Time of Incident +Inmate Name/Register Number +Location of Incident +Photographs) by +Date and Time of Photo +Possible Suicide Attempt +07/23/19 - 1:27 AM +Epstein, Jeffrey #76318-054 +Special Housing Unit +07/23/19 - 1:55 AM +72314 + + +D +Special Investigative Section +Type of Incident +Date and Time of Incident +Inmate Name/Register Number +Location of Incident +Photographs) by +Date and Time of Photo +Possible Suicide Attempt +07/23/19 - 1:27 AM +Epstein, Jeffrey #76318-054 +Special Housing Unit +07/23/19-1:55 AM \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/158098eebe027241b69f480c012c79c2bb663d362a60982273f74b3934727515.receipt.json b/vision-fixhub/ds9-parsed-01/158098eebe027241b69f480c012c79c2bb663d362a60982273f74b3934727515.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..cd1aeef0fdf5f3c95b0473e1c091da278d1b3b1a --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/158098eebe027241b69f480c012c79c2bb663d362a60982273f74b3934727515.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -1842, + "dataset": "marble-joined", + "doc_id": "158098eebe027241b69f480c012c79c2bb663d362a60982273f74b3934727515", + "engine": "marble-apple-vision", + "event_count": 17, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "c2638be15da6553c9dd890c98d4068056dd0fddcd90a6f904ed3a35b0b3b1e8d", + "output_sha256": "84f0244727d64ba9d76bf7529a61692aeb7d924237b9ad517a313d56bbf0a6ae", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/158d6959b073b847e58f885093617501bad6d12d132bd18a35e87ca129199536.md b/vision-fixhub/ds9-parsed-01/158d6959b073b847e58f885093617501bad6d12d132bd18a35e87ca129199536.md new file mode 100644 index 0000000000000000000000000000000000000000..dbbecc614ab9c9fb35ed64fe47c036482e2a4118 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/158d6959b073b847e58f885093617501bad6d12d132bd18a35e87ca129199536.md @@ -0,0 +1,177 @@ +From: " +To: " +Ce: " +(USANYS)" < +(USANYS)" < +(USANYS)" +Subject: RE: Jeffrey Epstein-Related Touhy Requests - Times FOIA Action +Date: Mon, 10 Feb 2020 18:01:37 +0000 +(USANYS)" +I don't have the underlying FOIA requests yet. The Times did not attach them to the Complaint, and BOP hasn't sent them +to me. I will circulate once I have them. Thanks. +From: +To: +Cc: +(USANYS) < +Sent: Monday, February 10, 2020 12:35 PM +(USANYS) < +| (USANYS) < +P; +Subject: RE: Jeffrey Epstein-Related Touhy Requests - Times FOIA Action +I (USANYS) < +Thanks - could you send us the request? +From: +(USANYS) < +Sent: Monday, February 10, 2020 12:28 PM +To: +Cc: +(USANYS) +P: +I (USANYS) 4 +(USANYS) < +(USANYS) +(USANYS) +Subject: RE: Jeffrey Epstein-Related Touhy Requests - Times FOIA Action +Thanks, +and +please let me know if you'd like to discuss or have any particular concerns here. +From: +To: +Cc: +Sent: Monday, February 10, 2020 12:19 PM +(USANYS) +(USANYS) < +P; +_(USANYS) < +(USANYS) < +Subject: RE: Jeffrey Epstein-Related Touhy Requests - Times FOIA Action +I think the AUSAs you'd particularly want to check with are the ones doing that prosecution - +Copying them here. +|(USANYS) +(USANYS) +and +From: | +(USANYS) < +Sent: Monday, February 10, 2020 12:00 +To: +Cc: +(USANYS) < +P; +| (USANYS) < +Subject: RE: Jeffrey Epstein-Related Touhy Requests - Times FOIA Action +(USANYS) + + +All, +FYI, the New York Times has filed the attached FOIA complaint challenging BOP's response (or lack thereof) to the Times's +FOIA requests for records related to Jeffrey Epstein. I've contacted +to see who at BOP will be handling +this. Our Answer date is currently March 4, 2020. Please let me know if you have any particular concerns here or would +like to discuss. +Thanks, +From: +To: +Cc: +Sent: Thursday, January 2, 2020 7:10 PM +(USANYS) ‹ +(USANYS) < +P; +I (USANYS) < +(USANYS) +Subject: RE: Jeffrey Epstein-Related Touhy Requests +Thanks for talking with me this evening about this, we appreciate it. To briefly memorialize our discussion, and to loop in +everybody on the case on the criminal side, you'll be the point person for requests from civil plaintiffs / victims in +connection with Epstein lawsuits, and we'll work with you on those requests given our knowledge of the relevant facts +and materials. +In terms of this first question from the plaintiff, which was essentially presented as a question of how they should go +about making a request for certain materials possibly in the possession of the Government, we'll plan to take a look at the +letter you draft that will essentially set forth the requirements for making a Touhy request (e.g., similar to, or including. +the kind of information in | +example below), and separately sometime early next week I'll let plaintiff's counsel +(Robbie Kaplan at Kaplan & Hecker) know that they can expect to hear from someone in our Civil Division, within +approximately a week or so (of when that conversation occurs), and that we anticipate that communication will include +the relevant requirements of making such a request. +Please let me know if I'm forgetting anything, thanks again, and talk soon. +From: +(USANYS) < +Sent: Thursday, January 02, 2020 10:01 +To: +Subject: Jeffrey Epstein-Related Touhy Requests +(USANYS) < +I spoke to +about continuing to use +as the POC to outsiders for Touhy requests for information +relating to Jeffrey Epstein. (Thank you +• please give l +a call. +markup of a "please give us a Touhy statement" email that I have used in the past. | +. FWIW, following is a +anticipates that we will +be getting additional requests stemming from civil litigation by alleged vietims, so it would be useful to have +some consistency here. +knows that the criminal AUSAs will have to do all the work digging for any +pertinent information, but it will be useful to have another AUSA handle the actual communications, particularly +since the criminal AUSAs may be dealing with the alleged victims as victim-witnesses in ongoing criminal +matters. Thanks again, + + +Here's some draft language you may or may not find useful: +Dear XXX: +I am the Assistant U.S. Attorney who will be handling the request that you made to AUSA +for certain +information relating to Jeffrey Epstein. To assist us in evaluating your request, we ask that you provide us with a +detailed written statement of the litigation for which you seek this information; the pertinence of the information +sought to your litigation; and the availability (or absence) of means in that litigation, including discovery, to +obtain the information in question. This statement should be relatively thorough—i.e., it should not assume that +the persons reviewing your request will have any particular familiarity with the litigation in question. +For your information, following are the general principles that govern disclosure, in unrelated litigation, of +information obtained during the course of our official duties. Specifically, the response of federal agencies to +subpoenas and other third-party discovery demands is largely governed by Department of Justice regulations, +commonly referred to as Touhy regulations. See generally 5 U.S.C.A. § 301; United States ex rel. Touhy v. +Ragen, 340 U.S. 462 (1951) (authorizing such regulations). These regulations dictate the procedure for obtaining +a government employee's testimony or government records in state or federal proceedings. The Department of +Justice has its own Touhy regulations that set out the procedure it follows in responding to demands for +"production or disclosure" of information from the Department and its employees for use in state or federal court +proceedings. See 28 C.F.R. §§ 16.21-16.29. These Touhy regulations channel review of such demands to the +responsible United States Attorney, and then provide a set of procedures for the United States Attorney to follow +when considering such demands. See id. §§ 16.22(b), 16.24. These regulations apply to both current and former +Government employees. See id. §§ 16.21(a), 16.22(a), 16.28. The Department's Touhy regulations prohibit any +Department employee from testifying or producing documents in a case in which the Government is not a party, +even in response to a subpoena, "without prior approval of the proper Department official in accordance with §$ +16.24 and 16.25 of this part." Id. § 16.22(a). For matters concerning our Office, the proper official is the United +States Attorney for the Southern District of New York. Id. § 16.22(b). To facilitate the process of determining +whether such approval will be given, a party seeking such information must provide this Office with an affidavit +or written statement setting forth the testimony sought and its relevance to the proceeding for which it is sought. +See id. § 16.22(c), (d). We will then evaluate the request in light of governing rules of procedure in the case for +which the information is sought, substantive law, and privilege; specific statutory prohibitions such as may apply +to federal tax information, grand jury matters, or classified information; and the requirement of Deputy or +Associate Attorney General approval where the disclosure would identify a confidential source over the +objection of the agency or source, would interfere with enforcement proceedings or reveal sensitive investigative +techniques, or would reveal trade secrets without the owner's consent. See 28 C.F.R. § 16.26. To the extent +information sought derives from a criminal investigation, such information may be subject to, inter alia, the law +enforcement privilege. The law enforcement privilege protects against the disclosure of information that would +"reveal a confidential source or informant, ... reveal investigatory records compiled for law enforcement +purposes ... interfere with enforcement proceedings[,] or disclose investigative techniques and procedures ...." +Id. § 16.26(b)(4)-(5); see also In re City of New York, 607 F.3d 923 (2d Cir. 2010); In re Dept of Investigation of +the City of New York, 856 F.2d 481, 484 (2d Cir. 1988); Tuite v. Henry, 181 F.R.D. 175, 176 (D.D.C. 1998) ("The +federal law enforcement privilege is a qualified privilege designed to prevent disclosure of information that +would be contrary to the public interest in the effective functioning of law enforcement"), aff'd, 203 F.3d 53 +(D.C. Cir. 1999). The Government's privilege not to disclose material contained in the files of criminal +investigations is well-recognized. See In re Department of Investigation of the City of New York, 856 F.2d at 483; +Friedman v. Bache Halsey Stuart Shields, Inc., 738 F.2d 1336, 1341 (D.C. Cir. 1984); Kinoy v. Mitchell, 67 +F.R.D. 1, 11 (S.D.N.Y. 1975) (discussing privilege for files compiled in connection with a criminal +investigation). To the extent documents are sought for use in state court proceedings, note that the Department's +decision whether to authorize testimony or produce documents is not reviewable in state court. Review of the +agency's decision may only be had pursuant to the federal Administrative Procedure Act in federal court. See US. +EPA v. Gen. Elec. Co., 197 F.3d 592, 598-99 (2d Cir. 1999) (review pursuant to Administrative Procedure Act), +modified in part, 212 F.3d 689 (2d Cir. 2000); 5 U.S.C. § 702 (sovereign immunity waived to permit +Administrative Procedure Act only in "a court of the United States"). Federal sovereign immunity bars any +proceeding in state court to enforce a subpoena or otherwise compel testimony or production of documents. See + + +Louisiana v. Sparks, 978 F.2d 226, 234-36 (5th Cir. 1992); Boron Oil Co., 873 F.2d at 69-71; see also, e.g., +People v. Rodriguez, 546 N.Y.S.2d 861, 862-63 (Ist Dep't 1989) (holding that "state courts are without authority +to compel production of such files without the federal government's consent"); People v. Carbonaro, 427 +N.Y.S.2d 701, 702-03 (Kings Co. Sup. Ct. 1980) (quashing subpoena served on federal employee where +Department of Justice ordered him not to comply); Jacoby v. Delfiner, 51 N.Y.S.2d 478, 479 (N.Y. Co. Sup. Ct. +1944), aff d, 63 N. 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MAXWELL'S +MOTION TO DISMISS COUNTS FIVE AND SIX OF THE SUPERSEDING +INDICTMENT BECAUSE THE ALLEGED MISSTATEMENTS ARE NOT +PERJURIOUS AS A MATTER OF LAW +Jeffrey S. Pagliuca +Laura A. Menninger +HADDON, MORGAN & FOREMAN P.C. +Christian R. Everdell +Bobbi C. Sternheim +Law Offices of Bobbi C. Sternheim +Attorneys for Ghislaine Maxwell + + +TABLE OF CONTENTS +TABLE OF CONTENTS +TABLE OF AUTHORITIES +TABLE OF EXHIBITS +I. +The Defamation Action +II. +The Questions Were Fundamentally, and Fatally, Ambiguous... +III. +The Questions and Answers Were Immaterial +CONCLUSION +Certificate of Service ... +..i +.. ii +. ili +.. 1 +..6 +.. 10 +.... 10 +.. 12 + + +TABLE OF AUTHORITIES +Cases +Bronston v. United States, 409 U.S. 352 (1973). +v. Maxwell, 325 F. Supp. 3d 428 (S.D.N.Y. 2018) +United States v. Bonacorsa, 528 F.2d 1218 (2d Cir. 1976) +United States v. Bonds, 580 F. Supp. 2d 925 (N.D. Cal. 2008). +United States v. Chujoy, 207 F. Supp. 3d 626 (W.D. Va. 2016) +United States v. Cicalese, 863 F. Supp. 2d 231 (E.D.N.Y. 2012) +United States v. Earp, 812 F.2d 917 (4th Cir. 1987) .. +United States v. Edlind, 887 F.3d 166 (4th Cir. 2018). +United States v. Landau, 737 F. Supp. 778 (S.D.N.Y. 1990). +United States v. Lighte, 782 F.2d 367 (2d Cir.1986).. +United States v. Litvak, 808 F.3d 160 (2d Cir. 2015) +United States v. Manapat, 928 F.2d 1097 (11th Cir.1991). +United States v. Naegele, 341 B.R. 349 (D.D.C. 2006). +United States v. Reveron Martinez, 836 F.2d 684 (1st Cir. 1988). +United States v. Ruedlinger, 990 F. Supp. 1295 (D. Kan. 1997) +Rules +Fed. R. Civ. P. 32(1)(b).. +ii +.. 6, 7,10 +1 +.. 6 +9 +8 +7,9 +. 8 +8 +.. 7 +. 6 +10 +. 7 +8 +8 +..9 +... 6 + + +TABLE OF EXHIBITS +EXHIBIT L: Order Denying Motion to Join Under Rule 21 Doe v. United States, No. 08-80736- +Civ-Marra/Johnson (S.D. Fla. Apr. 7, 2016) +EXHIBIT M: Motion for Joinder Doe v. United States, No. 08-80736-Civ-Marra/Johnson (S.D. +Fla. Jan. 2, 2015) +EXHIBIT N: Ross Gow Email re. statement on behalf of Ghislaine Maxwell dated Jan. 2, 2015 +iii + + +The government misunderstands both the law and the facts related to the +V. +Maxwell defamation litigation. Although the government aspires to present "a more streamlined +presentation" at trial (Resp. 118 fin. 46), it is unlikely to meet this goal. What follows is a very +truncated discussion of some of the facts to place the questions and answers in Ms. Maxwell's +depositions from that civil action in context: +I. The Defamation Action +In 2008, two alleged Epstein victims brought an action under the Crime Victims' Rights +Act (CVRA) against the United States government purporting to challenge Epstein's plea +agreement. They alleged the government violated their CVRA rights by entering into the +agreement. +Seven years later, on December 30, 2014, Ms. +moved to join the CVRA action, +claiming she too had her CVRA rights violated by the government. On January 1, 2015, Ms. +filed a "corrected" joinder motion. The issue presented in her joinder motion was +narrow: whether she should be permitted to join the CVRA action as a party under Federal Rule +of Civil Procedure 21, specifically, whether she was a "known victim|] of Mr. Epstein and the +Government owed them CVRA duties," Ex. L at 5. Yet, the court noted, "the bulk of the +[motion] consists of copious factual details that +] and [her co-movant] would prove... +if allowed to join."" Id. (brackets omitted). Ms. +gratuitously included provocative and +"lurid details" of her alleged sexual activities as an alleged victim of sexual trafficking. Id. +At the time they filed the motion, Ms. +and her lawyers knew that the media had +been following the Epstein criminal case and the CVRA action. While they deliberately filed the +motion without disclosing Ms. +name, claiming the need for privacy and secrecy, they +made no attempt to file the motion under seal. Quite the contrary, they filed the motion publicly. +As the district court noted in ruling on the joinder motion, Ms. +"name[d] several +1 + + +individuals, and she offers details about the type of sex acts performed and where they took +place." Ex. L at 5. The court ruled the lurid details are unnecessary": "The factual details +regarding whom and where the Jane Does engaged in sexual activities are immaterial and +impertinent..., especially considering that these details involve non-parties who are not related +to the respondent Government." Id. Accordingly, "[t]hese unnecessary details shall be stricken." +Id. The court then struck all Ms. +factual allegations relating to her alleged sexual +activities and her allegations of misconduct by non-parties. Id. at 5-6. The court said the striking +of the "lurid details" was a sanction for Ms. +improper inclusion of them in her motion. +See id. at 6-7. The district court found not only that the "lurid details" were unnecessary but also +that the entire joinder motion was "entirely unnecessary." Id. at 7. +Ms. +and her lawyers knew the motion with all its "lurid details" was unnecessary +because, as the court pointed out, the motion itself recognized that she would be able to +participate as a fact witness to achieve the same result she sought as a party. See id. at 7-8; see +also id. at 8 (noting that in the motion, Ms. +lawyers said that "regardless of whether +this Court grants the ... Motion, 'they will call [her] as a witness at any trial"'). The court +denied +joinder motion. Id. at 10. One of the non-parties Ms. +"named" +repeatedly in the joinder motion was Ms. Maxwell. Ex. M, at 3-6. According to the "lurid +details" Ms. +included in the motion, Ms. Maxwell personally was involved in a "sexual +abuse and sex trafficking scheme" created by Epstein: +Ms. Maxwell "approached" +in 1999 when +was "fifteen years old" to +recruit her into the scheme. Id. at 3. +Ms. Maxwell was "one of the main women" Epstein used to "procure under-aged +girls for sexual activities." Id. +Ms. Maxwell was a "primary co-conspirator" with Epstein in his scheme. Id. +2 + + +• +She "persuaded" +to go to Epstein's mansion "in a fashion very similar to the +manner in which Epstein and his other co-conspirators coerced dozens of other +children." Id +• +Ms. Maxwell "appreciated the immunity" she acquired under Epstein's plea +agreement, because the immunity protected her from prosecution "for the crimes she +committed in Florida." Id. +• +Ms. Maxwell "assist[ed] in internationally trafficking" +and "numerous other +young girls for sexual purposes." Id. +• +was "forced" to watch Epstein, Ms. Maxwell and others "engage in illegal +sexual acts with dozens of underage girls." Id. +In the joinder motion, +also alleged she was "forced" to have sex with Harvard law +professor Alan Dershowitz, "model scout" Jean Luc Brunel, and "many other powerful men, +including numerous prominent American politicians, powerful business executives, foreign +presidents, a well-known Prime Minister, and other world leaders." Id. at 4-6. +said after serving for four years as a "sex slave," she "managed to escape to a +foreign country and hide out from Epstein and his co-conspirators for years." Id. at 3. +suggested the government was part of Epstein's "conspiracy" when it "secretly" +negotiated a non-prosecution agreement with Epstein precluding federal prosecution of Epstein +and his "co-conspirators." Id. at 6. The government's secrecy, +alleged, was motivated by +its fear that +would raise "powerful objections" to the agreement that would have "shed +tremendous public light on Epstein and other powerful individuals." Id. at 6-7. +As +and her lawyers expected, before District Judge Marra in the CVRA action +could strike the "lurid details" of +allegations in the joinder motion, members of the +media obtained copies of the motion, printed the "lurid" details in tabloid news publications, and +sought comment from Ms. Maxwell, Professor Dershowitz and others. +On January 2, 2015, UK lawyers for Ms. Maxwell sent representatives of British media +organizations an email containing "a quotable statement on behalf of Ms. Maxwell." The email +3 + + +was sent to more than 6 and probably less than 30 media representatives. The email to the media +members read: +To Whom It May Concern, +Please find attached a quotable statement on behalf of Ms. Maxwell. No further +communication will be provided by her on this matter. +Thanks for your understanding. +Best +Ross +Ross Gow +ACUITY Reputation +Jane Doe 3 is +- so not a new individual. The allegations made by +against Ghislaine Maxwell are untrue. The original allegations +are not new and have been fully responded to and shown to be untrue. +Each time the story is re told [sic] it changes with new salacious details about +public figures and world leaders and now it is alleged by Ms I +I [sic] that +Alan Derschowitz [sic] is involved in having sexual relations with her, which he +denies. +Ms +claims are obvious lies and should be treated as such and not +publicised as news, as they are defamatory. +Ghislaine Maxwell's original response to the lies and defamatory claims remains +the same. Maxwell strongly denies allegations of an unsavoury nature, which +have appeared in the British press and elsewhere and reserves her right to seek +redress at the repetition of such old defamatory claims. +Ex. N +Eight years after Epstein's guilty plea, +brought the defamation action, repeating +many of the allegations she made in her CVRA joinder motion. The complaint alleged that the +January 2015 statement "contained the following deliberate falsehoods": +(a) That +sworn allegations "against Ghislaine Maxwell are untrue." +(b) That the allegations have been "shown to be untrue." +(c) That +"claims are obvious lies." +4 + + +The defamation litigation was legally very complicated and New York law afforded +many statutory, common law, and constitutional defenses to Ms. Maxwell (which may become +relevant at another time). In addition to strong legal defenses Ms. Maxwell's defense of truth was +exceptional. It was clear that given the wording of Mr. Gow's statement, proof of falsity of one +or more of +claims would be enough to defeat the civil action. Very quickly there were +many provable "obvious lies." A few examples: +• Contrary to her claim of "slavery," I +lived independently from her parents with her +fiancé long before meeting Epstein or Ms. Maxwell and held a number of jobs in 2001 +and 2002. +employment at the Mar-a-Lago spa began in fall 2000 when she was 17, not 15. +(This falsity was important to +story for many reasons.) +Palm Beach Police investigation revealed no evidence that Ms. Maxwell was involved in +sexual abuse of minors, sexual trafficking or production or possession of child +pornography. +• No nude photograph of +was displayed in Epstein's home. +tales about foreign presidents and prime ministers were untrue. +• All of the famous people +_ claimed to have been sexually trafficked to denied these +claims, which were completely implausible. +Importantly, +post-dates the allegations contained in the superseding indictment +("Indictment") by three years. By her claims, and admissions, she did not meet Epstein until +2000, long after the accusers named in the Indictment. Her strong connection with these accusers +developed through her lawyers who likely represent at least two of the accusers and some of the +witnesses. +Virtually every issue in the defamation action was contested. A review of the docket, +unfortunately, reflects over one-thousand entries. The parties disagreed about the scope and +meaning of virtually all of Judge Sweet's discovery orders, including those related to Ms. +Maxwell's depositions. Significantly, Judge Sweet's Order prefaced all the listed categories with +the words "sexual activity" an "sexual activities." +5 + + +As expected, both depositions were hostile. The questions posed to Ms. Maxwell were +poorly phrased without regard to the rules of evidence. Accordingly, counsel for Ms. Maxwell +was required to object many times. As this court knows, civil litigants are limited to three types +of objections: form, foundation, and privilege. When those objections are posed, the examiner +has the opportunity to ask for the basis of the objection. It is not incumbent, indeed it is not +permitted, for the objecting lawyer to expound on the basis for the objection unless asked. +Virtually all of the questions that form the basis of Counts Five and Six were the subjeet +of valid objections. A prerequisite to use of deposition testimony at trial is that the testimony +must be admissible under the Federal Rules of Evidence as if the deponent were present and +testifying. Fed. R. Civ. P. 32(1)(b). The form and foundation of the questions asked were +improper and largely not relevant in the context of the defamation action. It is unlikely that any +of the answers would have been admitted at any trial. +II. The Questions Were Fundamentally, and Fatally, Ambiguous +In addition to being poorly phrased, the questions were unquestionably ambiguous. +"[W]hen a line of questioning is so vague as to be 'fundamentally ambiguous,' the answers +associated with the questions posed may be insufficient as a matter of law to support +[a] perjury conviction." United States v. Lighte, 782 F.2d 367 (2d Cir. 1986); see also United +States v. Bonacorsa, 528 F.2d 1218, +, 1221 (2d Cir. 1976). "Precise questioning is imperative as a +predicate for the offense of perjury." Bronston v. United States, 409 U.S. 352, 362 (1973). "A +question is fundamentally ambiguous when it is not a phrase with a meaning about which men of +ordinary intellect could agree, nor one which could be used with mutual understanding by a +questioner and answerer unless it were defined at the time it were sought and offered as +testimony." Lighte, 782 F.2d at 375 (cleaned up). Here, the questions were "fundamentally +ambiguous," containing particular undefined terms, "scheme" and "recruit" for example. +6 + + +The government complains that Ms. Maxwell has not cited any cases where a perjury +count was dismissed pretrial for "fundamental ambiguity." Resp. 120. Of course, the government +must know that myriad examples exist. United States v. Cicalese, 863 F. Supp. 2d 231, 236-37 +(E.D.N.Y. 2012), is instructive: +Succinctly, the prosecutor did not fulfill her obligation to "pin the witness down to +the specific object of [her] inquiry." Bronston, 409 U.S. at 360. Any number of +straightforward follow-up questions could have clarified the object of inquiry. For +example, in addition to the "attempt" question mentioned earlier, the government +could have cured the ambiguity by supplying the date, time or location of the target +meeting. +focusing Cicalese's attention on +the specific events at +issue. See Razzaia, 370 F.Supp. at 578-79. Left naked, the government's imprecise +question did not meet the standard set in Bronston. It cannot provide a jury with +a sufficient basis to reasonably conclude that Cicalese willfully lied by answering +as he did. Id. at 579. Asking simple follow-up questions could have resolved the +imprecision and fulfilled the government's obligation under Bronston. Whether by +strategy or inadvertence, the government did not do so. +The Court granted Cicalese's motion to dismiss the charges against him. Id. at 232. +Similarly, in United States v. Landau, 737 F. Supp. 778 (S.D.N.Y. 1990), the court +dismissed a perjury indictment, holding "the context of all the preceding questions and Landau's +grand jury testimony as a whole, the prosecutor's questions here are fundamentally ambiguous +and cannot as a matter of law to support a perjury conviction. Landau's motion is therefore +granted and the indictment is dismissed." Id. at 784 85 (emphasis added). The same is true +here. In the context of the questions preceding the selectively quoted testimony in Counts Five +and Six and the transcripts as a whole, the selected questions were fundamentally ambiguous. +In United States v. Manapat, 928 F.2d 1097 (11th Cir. 1991), the Eleventh Circuit +affirmed an acquittal on the grounds of fundamental ambiguity as a result of the content of the +form that was the basis of the prosecution. There, the defendant applied for an Airman Medical +Certificate to the Federal Aviation Administration. The application included a section entitled +"Medical History" that contained twenty-four questions regarding "conditions." The first twenty- +7 + + +one "conditions" questions were all medical in nature. The twenty-second and twenty-third +questions, however, inquired about convictions (one about "traffic convictions," the other about +"other convictions"). Manapat answered in the negative to both question twenty-two and +question twenty-three, and these answers became the basis for his prosecution for "knowingly +and willfully" making false statements to any department or agency of the United States. In +affirming the district court's decision to dismiss the indictment, the Eleventh Circuit stated: +Although the single statements "Record of traffic convictions," or "Record of other +convictions" may not be ambiguous standing alone, they become quite confusing +when buried in a list headed "Medical History" and purportedly concerned with +medical conditions.... In order to successfully prosecute an indictment for making +a false statement, the government must not remove questions from the context in +which their answers were given in an attempt to prove their clarity. +Id. at 1101. +Also helpful is United States v. Chujoy, 207 F. Supp. 3d 626, 654-55 (W.D. Va. +2016), aff'd sub nom. United States v. Edlind, 887 F.3d 166 (4th Cir. 2018), and aff'd, 770 F. +App'x 33 (4th Cir. 2019), where the court dismissed multiple perjury and false statement claims, +holding: +Moreover, it is not perjurious for [the defendant] to give an evasive answer to a +broadly-worded question, so long as her response was not false. See United States +v. Reveron Martinez, 836 F.2d 684, 689 (Ist Cir. 1988) ("In order to sustain a +perjury charge, evasions are not enough. The government must show more than that +the interdicted statement was unresponsive or guarded. At a bare minimum, the +remark must have been literally false."); United States v. Earp, 812 F.2d 917, 919 +(4th Cir. 1987) ("The burden is on the questioner to pin the witness down to the +specific object of the questioner's inquiry."); United States v. Naegele, 341 B.R. +349, 359 (D.D.C. 2006) ("[I]n the context of perjury charges based on adversarial +questioning, it is not the declarant's burden to provide candid answers.") +Accordingly, the government failed to offer sufficient evidence that Edlind's first +two answers that she had dinner with Kwiatkowski in April—were false. No +reasonable juror could conclude otherwise. +In United States v. Ruedlinger, 990 F. Supp. 1295, 1303-04 (D. Kan. 1997), the court after +"carefully review[ing] the allegations" found that the perjury charge must be dismissed. The +8 + + +court held that the ambiguity of both questions rendered the answers insufficient as a matter of +law to support a perjury conviction. The courts holding is equally applicable here: +Precise questioning is imperative as a predicate for the offense of perjury. A perjury +conviction cannot be based upon evasive answers or even upon misleading answers +so long as they are literally true. In the face of evasion or misleading answers, it is +the lawyer's duty to bring the witness back to the mark, to flush out the whole truth +with the tools of adversary examination. When a line of questioning is so vague as +to be fundamentally ambiguous, the answers associated with the questions posed +may be insufficient as a matter of law to support a perjury conviction (cleaned up). +And, finally, although there are more, in United States v. Bonds, 580 F. Supp. 2d 925, 931 (N.D. +Cal. 2008), the court ruled that using the terms "anything like" in connection with a perjury +prosecution in a professional baseball steroid investigation created a serious problem. The +government argued, similar to the claims here that, in context, this phrase refers to "anything like +steroids that could have led to a positive steroid test." According to the court, the use of the +qualifier made the question fundamentally ambiguous requiring dismissal of the count. +The government, at page 133 of its Response, incorrectly suggests that the burden was on +Ms. Maxwell or her counsel to clarify the confused questions, particularly regarding the infinite +time span. First, that is simply wrong. The questioner has the responsibility to ask clear +questions and to "pin down" the witness. Cicalese, 863 F. Supp. 2d 231, 236-37. It is the +government, not Ms. Maxwell who is engaging in post-hoc definitions about undefined terms +"scheme" and "interact with" (Count Five); and about the "presence" of certain items, or +Epstein's possession of "items" used in "activities," her "awareness" of what Epstein was doing +when she wasn't with him in a "millennium" and giving a "massage." (Count Six). Because the +questions were so bad, the government spends significant energy trying to rationalize what the +questioner meant. +The answers to the bad, ambiguous, objectionable questions were also "literally +true." Bronston v. United States, 409 U.S. 352 (1973), makes clear that an individual cannot be +9 + + +convicted of perjury for an answer given under oath that is literally true, even if it is +unresponsive and intended to mislead. The Court noted that "[t]he burden is on the questioner to +pin the witness down to the specific object of the questioner's inquiry." Id. at 360. The answers +to the questions in Counts Five and Six are "literally true" as discussed in detail in Ms. +Maxwell's moving brief. +Ill. The Questions and Answers Were Immaterial +The government is confusing arguable "relevance" and "materiality" which "are not +synonymous." United States v. Litvak, 808 F.3d 160, 174 (2d Cir. 2015). It is not enough that any +alleged "misrepresentation" concern "a variable that mattered to the" recipient of the +information. The government must prove that alleged misstatements were "capable of +influencing a decision" of the intended recipient. Id. It remains unclear how the government will +argue this issue. However, the questions were improper and could not have produced admissible +evidence for a jury to consider. There was nothing "influenced" on the part of the questioners +who would not have accepted any answer from Ms. Maxwell as true. Moreover, the questions +were not calculated to lead to discoverable evidence. +CONCLUSION +The Court has the necessary transcripts to decide this issue in Ms. Maxwell's favor, +pretrial. Accordingly, Ms. Maxwell requests that the Court dismiss Counts Five and Six. +Dated: March 15, 2021 +10 + + +Respectfully submitted, +s/ Jeffrey S. Pagliuca +Jeffrey S. Pagliuca +Laura A. Menninger +HADDON, MORGAN & FOREMAN P.C. +Christian R. Everdell +COHEN & GRESSER LLP +Bobbi C. Sternheim +Law Offices of Bobbi C. Sternheim +Attorneys for Ghislaine Maxwell +11 + + +Certificate of Service +I hereby certify that on March 15, 2021, I served by email, pursuant Rule 2(B) of the +Court's individual practices in criminal cases, the Reply Memorandum of Law in Support of Ms. +Maxwell's Motion to Dismiss Counts Five and Six of the Superseding Indictment Because the +Alleged Misstatements are not Perjurious as a Matter of Law upon the following: +U.S. Attorney's Office, SDNY +s/ Christian R. Everdell +12 diff --git a/vision-fixhub/ds9-parsed-01/15996c7cb084de86dc326cc48cf0d2fbc4a06b664e5202c7ff61c8326dc55ae9.receipt.json b/vision-fixhub/ds9-parsed-01/15996c7cb084de86dc326cc48cf0d2fbc4a06b664e5202c7ff61c8326dc55ae9.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..1aa2dacbb1ccecffeb5adf02815cff9aceb77cb3 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/15996c7cb084de86dc326cc48cf0d2fbc4a06b664e5202c7ff61c8326dc55ae9.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -192, + "dataset": "marble-joined", + "doc_id": "15996c7cb084de86dc326cc48cf0d2fbc4a06b664e5202c7ff61c8326dc55ae9", + "engine": "marble-apple-vision", + "event_count": 16, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "94e09f3c5a5e38aec85df55a25e87774772eae0f33dcdb5a58155eb14f0b8e34", + "output_sha256": "3c52ed1257e3dd23eb64be026d56e515ec87c8fcca37a587a8501032458a6b6b", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/15a548db1482cfb0375e57d6d56566e2ca4d7195fa008734e3797c28f79774a5.md b/vision-fixhub/ds9-parsed-01/15a548db1482cfb0375e57d6d56566e2ca4d7195fa008734e3797c28f79774a5.md new file mode 100644 index 0000000000000000000000000000000000000000..c3a334e1bda5c16cf31d321530420c6457c0c470 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/15a548db1482cfb0375e57d6d56566e2ca4d7195fa008734e3797c28f79774a5.md @@ -0,0 +1,33 @@ +From: +To: +Ce: "l +(USANYS) [Contractor]" < +¡USANYS)" < +(USANYS)" < +(USANYS)" +USANYS)" { +Subject: Re: Jeffrey Epstein, Blackmail and a Lucrative 'Hot List' - The New York Times +Date: Sun, 01 Dec 2019 16:08:21 +0000 +The story sure makes it seem like the guy (Kessler) is a scammer. +U.S. Attorney's Office, SDNY +> On Dec 1, 2019, at 9:42 AM +(USANYS) ‹ +> wrote: +> I spoke to Julie Brown about this guy. Even she was skeptical. +> Sent from my iPhone +> +>> On Dec 1, 2019, at 8:26 AM. +USANYS) [Contractor] < +> wrote: +>> +>> Lengthy tale about the apparent con man Patrick Kessler and his attempts to convince David Boies and +Stanley Pottinger he had video evidence of sexual abuse by well known figures associated with Jeffrey Epstein. +>> +>> https://www.nytimes.com/2019/11/30/business/david-boies-pottinger-jeffrey-epstein-videos.html +>> +>> Chief Public Information Officer +>> U.S. Attorney's Office, SDNY +>> +@usdoj.gov +office) +cell) diff --git a/vision-fixhub/ds9-parsed-01/15a548db1482cfb0375e57d6d56566e2ca4d7195fa008734e3797c28f79774a5.receipt.json b/vision-fixhub/ds9-parsed-01/15a548db1482cfb0375e57d6d56566e2ca4d7195fa008734e3797c28f79774a5.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..4f93cce5d5fef963935e77ee1f2da0521598a4b7 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/15a548db1482cfb0375e57d6d56566e2ca4d7195fa008734e3797c28f79774a5.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "15a548db1482cfb0375e57d6d56566e2ca4d7195fa008734e3797c28f79774a5", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "4784413e51fb56d422fc4366017306f3d27d2dacea120a050984c1f0168fae81", + "output_sha256": "1a46f1e135fbdd424a6467e6436295607032584ccdf87b9fbcfc25c42ee6afd9", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/15ab523b59918fe1a8be767c25b63084f70e95c171f4b16ebbf520c5680191ef.md b/vision-fixhub/ds9-parsed-01/15ab523b59918fe1a8be767c25b63084f70e95c171f4b16ebbf520c5680191ef.md new file mode 100644 index 0000000000000000000000000000000000000000..c416c9ddfb53e4a59779a2eacc6a8602bd6dd1e1 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/15ab523b59918fe1a8be767c25b63084f70e95c171f4b16ebbf520c5680191ef.md @@ -0,0 +1,8376 @@ +1 +DIGITALLY RECORDED +SWORN STATEMENT +OF +TERIAL +OIG CASE #: +TED MA +PROTEC +OFF +'ICE +DEPARTMENT OF JUSTICE +OF THE INSPECTOR GENERAL +AUGUST 12, 2019 +FENTON TRANSCRIPTION +28720 Roadside Drive, Suite 250 +Agoura Hills, CA 91301 +Phone: +SDNY _00007896 + + + +2 +APPEARANCES: +OFFICE OF THE +INSPECTOR +GENERAL +BY: +BY: +WITNESS: +OTHER +APPEARANCE +PROTECTED MATERIAL +IS : +PROTECTED +SDNY_00007897 + + + +1 +Today is Monday, August +2 12. The following will be a voluntary +3 interview of BOP I +in +4 furtherance of OIG investigation to be +5 determined, for the purpose of transcription, +6 will now identify all present in the interview. +7 I'll ask everyone to say and spell their last +8 name, as well as identify their working title +9 and employer. +10 +I am Special Agent +11 +• Office of the Inspector General. +12 +: Special Agent +13 +14 +• with the FBI. +EMPLOYEE 22, warden, +15 +Federal Bureau of Prisons. +16 +17 +18 +19 +Thank you. +20 +-- +21 +22 +-- you have reviewed and +23 signed Department of Justice OIG Form 226-2 +24 which is Warnings and Assurances of Employees +25 Request to Provide Information on a Voluntary +SDNY _00007898 + + + +4 +1 Basis. +Do you have any questions about this +2 form? +3 +4 +AM2023322 +No. +Would you like time to +5 review it with an attorney, or would you like +6 an attorney here? +7 +For now, I don't need an +8 attorney. +9 +: Okay. Are you currently +10 under the influence of any substances, or is +11 there any reason to prevent you from fully +12 understanding my questions and answering +13 truthfully today? +14 +No. +15 +• I'll now swear you to the +16 statements you're about to make. Please raise +17 your hand and repeat after me. +18 +I EMPLOYEE 22 +19 +EMPLOYDE 22 +I, EMPLOYEE 22 +20 +Hereby solemnly swear or +21 +affirm. +22 +Hereby solemnly swear or +23 +affirm. +24 +That the statements +• that +25 I'm about to make. +SDNY _00007899 + + + +2 +5 +1 +That the statements I'm +2 about to make. +3 +4 whole truth. +5 +6 whole truth. +7 +8 +9 +Shall be the truth and the +Shall be the truth and the +Thank you, sir. +Warden would you mind +ERIAL +10 telling us a little bit about your career with +11 +BOP? +When you started, how you became a +12 +Warden? +13 +Uh -- +14 +How you moved up the +15 ranks. +16 +I started out as a +17 Correctional Officer, and I was promoted to a +18 Lieutenant. +From there, I went to Special +19 +Investigative Agent at our regional office, and +20 then I went from there, I was promoted to +21 Captain, and then I was Associate Warden, and +22 then from there I went to DC as a Chief +23 Internal Affairs, and now in my present +24 position. +25 +Great. How long have you +SDNY _00007900 + + + +6 +1 been the Warden? +2 +I've been here since May of +3 2018. +4 +Okay, great. Just, your +5 role, you've done a lot of internal +6 investigations with the prison and you've +7 worked with the Department of Justice +for +8 +9 +: -- moving forward, just as +10 a note for the record, you're aware that +11 failure to be honest with us today would be +12 considered a criminal offense; correct? +13 +Yes. +14 +: Okay, great. Let's talk a +15 little bit about some overall policies at the +16 prison to +start with. +17 +Okay. +18 +: So, actually let me back +19 +up. +We're here today to talk about, +20 specifically Jeffrey Epstein. +21 +BELOVED 22 +22 +The inmate. +23 +EMPLOYEE +22 +24 +Would you mind just +25 telling us a little bit about when, your +SDNY _00007901 + + + +7 +1 understanding of when he arrived and that type +2 of, when he arrived, how he was placed, where +3 he was placed, and the reasons behind that? +4 +I don't remember the +5 specific date he arrived, but we didn't, what +6 happened was, we weren't told that he was going +7 to be coming to the institution. +8 +Okay. +9 +When he initially came, he +was dropped off on the weekend, and we didn't +11 find out until Monday, myself, that he had been +12 placed at the institution. And from then on, +13 we, you know, went through the whole process of +14 the screening, his medical stuff. Just normal +15 procedures that we follow and (Indiscernible +16 *00:04:04). +17 +: Okay. Now when you say +18 +"he was dropped off over the weekend", when +19 somebody arrives at the facility, what's the +20 normal -- +I mean typically if +somebody's that high profile -- +23 +24 +EMPLOYEE 22E +-- we should've been +25 +notified and +said hey, he's coming in. +We +SDNY _00007902 + + + +8 +1 weren't. +2 +Okay. +3 +You know, I mean, we saw it +4 on the news, but it didn't say. They just said +5 they had him in custody, but we didn't get any +6 formal, I didn't get any formal notice that he +7 had been brought into the institution. +8 +So, he was dropped off, and you know, +the +9 Lieutenant on shift processed him in and +10 brought him into the institution. We didn't +11 +find out or realize it until Monday. +12 +: So, it was Monday that you +13 +first were +officially made aware of it? +14 +That I was made aware. You +15 know, we found out, and I don't remember if it +was from looking at the news reports, we put it +17 together that he had been brought into the +18 institution. +We went through our Monday +19 morning meeting that we went through. So, +20 that's when -- +When he first arrived, was +22 he placed in general population? Do you know +23 where he was placed? +24 +EMPLOYEE 22 I don't recall where he was +25 placed when he came in. +SDNY _00007903 + + + +9 +1 +At some point, he was +2 placed in Special Housing Unit? +3 +EMPLOYEE 2 +Yes. +4 +Known as the SHU. +5 +6 +how did he end up there? +7 +EMPLOTEE 22 +Well, he was +a new +8 commitment. +He was high profile. +So, we +9 placed him in the Special Housing Unit so we +10 can further evaluate, you know, his status. Is +11 he ready for general population? +And we do +12 that with all inmates, but -- +13 +: Okay. +14 +-- and then to see, okay, +15 any separation issues. Any threats to him, +16 before we +put him out there in general +17 population. +18 +Was he ever in general +19 population? +20 +EMPLOYDE 22 +I don't recall. I don't, +21 +I'm not sure if it might've been the first day +22 +when he came in. +23 +24 +But I'm not sure, so I mean, +25 I would have to look at the 37 to confirm. +SDNY _00007904 + + + +10 +1 +But as +far as you know, +2 that Monday, the first business day after the +3 weekend he was initially dropped off. +4 +5 +From that point forward, +6 was he ever in general population? +7 +NO. +8 +What are the +9 policies in terms of, or is there policy that +BERIAL +10 dictates when somebody goes into general +11 +population from the SHU after the first +12 arrival? +13 +Well, what we do is we +evaluate the individual to see if they're ready +15 for general population, if they can hang, you +16 know -- +17 +18 +- if they can populate. +19 +Okay. +20 +And it's a number of +21 +factors. It depends. +I mean, if I have a gang +22 +member coming in, I'm taking into consideration +23 separation issues on it. If it's, you know, +24 somebody that might've been fraud or bank +25 fraud, then we determine if it's any issues of +SDNY _00007905 + + + +2 +11 +1 them going into the general population. +Sor +2 it's a case-by-case basis on how we determine +3 it. +4 +Okay. +What are the +5 policies in terms of when you're notified if +6 someone enters Special Housing Unit or is +7 discharged from Special Housing Unit? +8 +Well what it is is, it's +9 routed the individual, it's called a Release +10 Form. +SOr +several people sign it. They review +11 it. I believe psychology, CMC, the Captain, +12 and it goes to the Associate Warden and then +13 they sign what we call is a Kick-Out. Meaning +14 everybody's reviewed it and said, okay, this +15 person is appropriate for general population. +16 +: Okay. For Mr. Epstein, +17 after that, +he was never put in general +18 population; correct? +19 +No. +20 +Was the determination to +keep him +in Special Housing? What was the +22 +communication that goes on there? +23 +Well we, now initially when +24 he came in, it's the goal to determine, okay, +25 can they go to general population. +SDNY _00007906 + + + +12 +1 +Okay. +2 +So, between evaluating him, +3 at the same time, we're looking at saying, +4 okay, can he go to general population. +5 +6 +So, it's a dual role that +7 we're going to -- +8 +Sure. +9 +But I had gotten word, and I +10 don't recall the date, where from my Regional +11 Director which stated he's not to go to general +12 population until further notice. +13 +The Regional Director, +where is that in the chain of command for BOP? +15 +We have five regional +16 +offices. +17 +: Okay. +18 +EMPLOYEE 22] +Each region has a Regional +19 Director. +20 +Okay. +21 +22 +This is the Northeast +Region. +23 +Okay. +24 +EMPLOYEE 22E +Where we have 21 +25 +institutions. +So, he supervises and is in +SDNY _00007907 + + + +13 +1 charge of the 21 institutions. +2 +Okay. So, is he -- +3 +(Indiscernible *00:08:37). +4 +5 +PMPLOYEE 22 +-- your direct supervisor? +He's my director supervisor. +6 +Okay. Who is that? +7 +(phonetic sp.). +8 +9 +Yeah. +10 +And +told you, +11 do you recall if it was verbally or an email? +12 Phone call? +13 +We had talked about it, too, +but I would have to check if there was an email +15 to go with it. But we did talk and said, hey, +16 we're going to hold off on putting him out in +17 +general population. +18 +Okay. Do you recall when +19 you officially were, you and +, spoke +20 about this? +21 +EMPLOYEE +22 +I don't want to give you the +22 wrong date. +But it was within that, you know, +23 maybe a couple weeks after he arrived. +24 +Okay. So, it was a few +25 +weeks after he arrived -- +SDNY _00007908 + + + +14 +1 +2 +Okay. After +3 told you to keep him, or it was agreed upon -- +4 +5 +-- to keep him in Special +6 Housing Unit. +7 +8 +Who did you notify that he +9 was to stay in the Special Housing Unit? How +10 does that communication -- +11 +So, what it does is I get my +12 exec staff together -- +13 +: Um-hum. +14 +EMPLOYED 22 — Which is my Associate +15 Wardens, the Captain, my exec, and we have our +16 +meetings, +and I tell them he's not, you know, I +17 lay out the specific instructions. He's not to +18 go out to general population. And -- +19 +were there, sorry. +20 +Go ahead. +21 +22 +NO. +And that's basically how we +23 +start. +24 +okay• +25 +Yeah. +SDNY_00007909 + + + +15 +1 +Were there any other +2 specific directions or instructions given to +3 the staff regarding him? +4 +Well, so at the time of him +5 staying in there, we had to find him initially +6 a roommate. +7 +Okay. +8 +So, and it's hard especially +9 in Special Housing Unit when you've got gang +10 members +in +there that are not appropriate to be +11 housed with. +So, we came up with, I came up +12 with Tartaglione, who was in there. White +13 male, probably be able to cope with him. And +14 that's typically how we, you know, that's part +15 of the evaluation process. +16 +: Is it standard for inmates +17 +in Special Housing Unit to have cellmates? +18 +We typically would like for +19 them to have it. +20 +Sure. +21 +But certain situations +22 dictate that they can. If an inmate's a total +separation from a group, and we get word from +24 +US Attorney's office or the arresting agents +25 that, hey, he's to be totally separated, then +SDNY _00007910 + + + +16 +1 they would be housed by themselves. They could +2 have an incident in the institution, you know, +3 for example our gang members, somebody has an +4 issue, and for example, +the +Bloods, then we +5 have to say hey, let's separate him from there. +6 You know? +7 +was there any directions +8 specifically that Mr. Epstein was to have a +9 cellmate at all times? +10 +From psychology when -- +11 +: Okay. +12 +- said hey, that he's +13 required, he needs to have a cellmate at all +14 +times. +15 +Okay. And that occurred +16 later on? +When he first arrived, there was no +17 +specific directions regarding that; correct? +18 +_EMPLOYED 22 +No, it wasn't. +19 +Okay. +20 +Wait, let me. +21 +Sure. +22 +You mean when he first came +23 +in were we talking about him having a cellmate? +24 +25 +Initially. +I don't recall any talks +SDNY _00007911 + + + +17 +1 about him. +2 +Okay. +3 +Initially, and trying to +4 figure out when he first came in, how he was +5 housed. I don't recall how he was housed when +6 he first came in, but -- +7 +The MCC is no +8 stranger to high profile - +10 +-- inmates. +Generally +11 speaking, how do you normally, or generally +12 handle these type of high profile inmates? Any +13 other special considerations or concerns. How +14 +does this work? +15 +Again, you come in. We +16 evaluate him to determine, okay, if they can go +17 out to general population or not. We've had, +18 you know, we've had a bunch that come in that +19 were able to go out. We had Siock (phonetic +20 sp.), you know, the phone that, I don't know if +recall, the one that sent the bombs to the +22 ex-presidents. +23 +(Indiscernible *00:12:41). +24 +25 +Him. +So, when he first came +SDNY _00007912 + + + +18 +1 in, you know, he was high profile. +So, we +2 brought him in to determine -- +3 +FEMALE VOICE: Excuse me. +4 +Yeah. +5 +FEMALE VOICE: Can you guys step out here +6 for just a moment? +7 +We, pausing the interview +8 at 10:55 a.m. (tape paused). +9 +10 +We're resuming the interview with +11 +EMPLOTEE 22 +12 +2ИP01E 22 +13 +Yeah. +14 +(Indiscernible *00:00:14). +15 The time is now 10:56. Joining the interview +16 room is Assisting United States +Attorney from +17 +the Southern District of New +18 +19 +20 +I apologize. +21 Can +you spell your name for transcription +22 purposes? +23 +Sure. +24 +Thanks. +25 +Thank you. +Before we were +SDNY _00007913 + + + +19 +1 just going over some of the overall high- +2 profile inmates and the general -- +3 +4 +-- evaluation of them. +5 Going back to, you said earlier that a few +6 weeks had occurred. +You and the Regional +7 Director discussed keeping Epstein in the +8 Special Housing Unit. +10 +How often was the Regional +11 +Director being briefed on Epstein? +12 +I guess the situation +13 dictated it. If something happened, then we'd +14 notify him, or he needed some questions for +15 him, he would call me. But I don't want to, I +16 don't recall the specific amount of times. +17 +we were in contact. +18 +19 +TEN LOVED 220 +Frequent contact. +20 +Okay. How often were you, +are you notified differently of high-profile +22 inmates or how often were you being aware or +23 +notified of Epstein's housing situation? +24 +Well, I mean, he was in the +25 Special Housing Unit. +So, I knew where he was. +SDNY _00007914 + + + +20 +1 +Okay. +2 +So, it wasn't like I had to +3 be updated +as to where he was. I knew where he +4 was. +5 +Okay. +6 +I mean, I knew that he went +7 on his attorney visits, spent the whole day +8 there. +Would be the first one in, last one +9 out. +So, I mean, that's what I knew. And then +10 I kind of (Indiscernible *00:02:06) with the +11 attorneys. I had some outside attorneys +12 complain about, you know, they were taking up +13 the attorney room. +So, I knew that was, you +14 know, those issues were coming up with the +15 attorney room. +16 +Okay. Going back to +17 general policies at the -- +18 +19 +-- within the BOP, +20 actually when Epstein arrive -- +21 +EMPLOYEE 221 +22 +- I think we already +23 +covered this, but just to, were any special +24 +arrangements or considerations given to him? +25 +As far as -- +SDNY_00007915 + + + +21 +1 +obviously you said earlier +2 he was put in the SHU on Monday. +3 +4 +After, was it, at that +5 point, was there any issues that you're aware +6 of regarding him? Anything that you needed to +7 be aware of other than just who he was? +8 +NO. +Just who he was and the +9 basic screening. The intake screening. +10 +: Okay. +At the time he +11 +first arrived, did you have any, was there any +12 +notification of any mental health concerns? +13 +EMPLOYEE 220 +No, not that I know of. +14 +: Okay. How -- +15 +Are you talking about the +16 weekend he came in, or -- +17 +: Yeah. +18 +(Indiscernible *00:03:19). +19 +First arrival. +20 +That weekend, I don't know. +But I know afterwards, he was medically +assessed and they were, you know, our health +23 service department assessed him and he, I think +24 he might have told him that he had certain +25 medications. +SDNY _00007916 + + + +22 +1 +Okay. +When -- +2 +•EMPLOYEE 22 +-- that he was taking. +3 +When inmates come into the +4 MCC, are they all screened for mental +health +5 issues or medical issues? +6 +Well, yes. They come in, +7 you're +screened for your medical. +The unit +8 team screens you and psychology screens you. +9 But -- +10 +What timeframe does that +11 +occur? +12 +Typically like with him, he +13 +came in on the weekend. +So, it depends if +there was a psychologist. Maybe the next day +15 someone would go screen him, the on-call +16 psychologist. +But, you know, or Monday if +17 someone came in. But typically the on-call +18 psychologist is there through the weekend and +19 will screen them. +20 +Who is notified of the +21 results of those screenings? +of? +23 +: Of the medical screen and +24 psychological screenings, who gets notified of +25 that? +SDNY _00007917 + + + +23 +1 +As far as what? +It they +2 find something in there? +3 +Yes. +4 +Like what would be an +5 example? +I mean -- +6 +Any medical concerns that +7 people need to be aware of. +Any psychological +8 issues. +How does that information get +9 disseminated? +10 +Because when we talk about +11 +medical issues, some of that falls under +12 privacy issues. +13 +14 +So, you know, it's not going +15 to be divulged as to -- +16 +Okay. +17 +-- just like that. +18 +Sure. +19 +But as far as psychological, +20 +if it was something that psychologists did an +21 +interview and said, hey, there's a mental +health issue or something, then she would, you +23 +know, she would let her Associate Warden know. +24 She would let me know that, hey, there's some +25 +issues. +SDNY_00007918 + + + +24 +1 +Okay. And when he first +2 arrived, were you made aware of any medical or +3 mental issues regarding him? +4 +Mental health, I don't +5 recall any mental health. But I was told that +6 he was on certain medications or whatever. +But +7 it was general. It wasn't -- +8 +9 +- anything major. +10 +Okay. And just, +and +11 +that's a general policy for all inmates that +12 +arrive? +13 +The screening, yeah. +14 +Just the medical +15 +screening. +They all get that? +16 +17 +Is there any, as a result +18 of those screenings, is there any, does it have +19 +any bearing on where they're placed, whether +20 +it's special housing or general population? +I mean typically if you do, +22 like I said, if you do an intake screening and +23 the individual comes in and they have no +24 issues, +no separation issues, and, you know, +25 then they can populate like anyone else. But +SDNY _00007919 + + + +25 +1 if there +are +issues with them going out in +2 general population; i.e., safety issues, then +3 you would be placed in the Special Housing. +Until we could further +6 evaluate if you could go to general population. +7 +someone during the +8 mental health screening, the mental health, the +9 psychologist deemed them to be suicidal -- +10 +окау. +-- what are the suicidal +12 watch policies as it relates to that? +13 +So, if the psychologist was +to say, hey, they're suicidal, then they would +15 be placed on suicide watch. +16 +: Okay. +17 +Now if the psychologist is +18 not there and someone exhibits suicidal +19 ideations or statements or thoughts, then +20 they're placed on suicide watch. +Can you explain to me what +22 suicide watch is, +where it is in the MCC -- +23 +It's on the second floor of +24 +the institution, on the same floor of the +25 hospital. +SDNY _00007920 + + + +26 +1 +2 +Okay. +And it's a cell, and if you +3 go on suicide watch, you're placed in a smock. +4 +Okay. +5 +That covers you and then +6 you're watched for 24 hours. +7 +Now the smock, is that +8 made of paper, or -- +It's cloth. +10 +11 +Cloth? +It's like, you ever see +12 those movies where they have those heavy bomb +13 vests? +14 +15 +Uh -- +It's something, I mean, I +16 don't want to you know, say, but it's something +17 like that. +18 +19 +Okay. +And it just hangs. +20 +Sure. +21 +Hangs on them just like +22 +that. +So -- +23 +And you said they' re +24 +25 +monitored for 24 hours. +How are they, is it - +There's a companion sitting +SDNY _00007921 + + + +27 +1 there. +An +. inmate. +2 +In the cell? +3 +No. Outside the cell. +4 +5 +Okay. +It's a cell where you sit +6 and observe. +7 +Okay. +Is the companion +8 another inmate or a staff? +9 +EMPLOYEE 22 No, it's a trained inmate +10 companion. Now, we have four cells. +• If those +11 cells get full, then we have to move them up to +12 the Special Housing Unit and then put a staff +13 watch on them. +14 +: Okay. What policies are +15 in place for suicide watch as it relates to +16 staff response, +notification, how people get +17 notified, if they're moving from suicide watch +18 to off +suicide watch. How does that work? +19 +That works through +20 psychology. +21 +22 +Psychology evaluates and +23 they' 11 say, okay, we've evaluated him and, you +24 know, wherever we're going, typically you +25 always usually go from the Special Housing Unit +SDNY _00007922 + + + +28 +1 to suicide. +So, they'd say, okay you know +2 what, they're ready to go back up. +Okay. What role, how does +4 the program, is the psychologist the program +5 coordinator? +6 +The chief psychologist runs +7 the department. +8 +9 +And then she has various +10 psychologists that +work under her. +11 +Okay. +12 +And then evaluate because we +13 have a different mission as far as we have a +14 +forensic mission. +So, we get a lot of forensic +15 studies in the institution. +16 +Okay. +17 +And then we have a regular +18 psychologist also that handles the inmate +19 population but they work together and they +20 handle everything. +okay. Who's ultimately +22 responsible for placing somebody on suicide +23 +watch or off suicide watch? +24 +EMPLOYEE 22E +Well placing it, a staff +25 member comes and says hey, this guy is +SDNY_00007923 + + + +29 +1 suicidal. +You can place him on suicide watch. +2 +Okay. Anybody in the +3 institution can do that? +4 +Yeah. If I come upon an +5 inmate that's saying, "Hey, I'm going to kill +6 myself." Okay, we get him on suicide watch. +7 Psychology comes and, you know, evaluates them +8 and then comes up with a plan. +9 +Within the psychology +10 department -- +11 +12 +-- or the medical +13 department there in mental health, who there +14 ultimately makes that decision? +15 +EMPLOYEE 221 +I believe, and don't quote +16 +me on this. +I believe the psychologists. +17 +: Okay. +18 +You know, they're trained +19 professionals. +So, they can make a decision +20 and they consult with the Chief in, you know, +21 determining okay what's the plan of action to +22 move forward. +23 +: And are you, when +24 +someone's placed in suicide watch, are you +25 notified of that? +SDNY _00007924 + + + +30 +1 +Yeah. They send out a form +2 every day stating like who's on suicide watch, +3 who's on psyche observation. So -- +4 +Okay. +5 +-- we're aware of who it is +6 and then they'll send out a form if there's no +7 one on +there. +8 +You said earlier that +9 while on suicide watch, there was an observer. +10 +11 +How does an inmate become +12 an observer? +13 +It's an inmate companion. +14 +: A companion, I'm sorry. +15 +So, it's a trained program. +16 +So, they have to go through training. They +17 have to take courses, and then they become +18 eligible to become a companion. +19 +Who authorizes the use of +20 +an inmate companion? +21 +The psychology department +22 +runs that. +So -- +23 +: Do you have any input as +24 +the warden in selecting or training or +25 implementing the inmate companion program? +SDNY _00007925 + + + +31 +1 +No. +2 +Does every institution +3 have an inmate companion program? +4 +Yes. +5 +Who's the Chief +6 Psychologist? +7 +EMPLOYEE 220 m +(phonetic +8 sp.) . +9 +: And +is the one +10 who is ultimately responsible for determining +11 if someone is on suicide watch and removing +12 them; correct? +13 +Well in conjunction with our +14 +staff. +15 +: +• Okay. +16 +Because you could be, a +17 +psychologist is assigned to the individual when +18 +they're working a plan with them. And if they +19 come to the determination that hey, you know +20 +what, they no longer need to be on suicide +21 +watch. +22 +Okay. But as the clinical +23 director, she's ultimately responsible. +24 +She's not the clinical. +25 She's the Chief Psychologist. +SDNY _00007926 + + + +32 +1 +Okay. +2 +Clinical Director is a +3 separate position. +4 +Okay. +I apologize for +5 that. +6 +That's fine. +7 +Thank you for clarifying. +8 +9 +Who in the medical staff, +10 just for my clarification, who in the medical +11 +staff is ultimately responsible for removing +12 somebody from suicide watch? +13 +The psychology department +14 +determines to remove somebody from -- +15 +: So, who in the psychology +16 department? +17 +Again, it depends on who's +18 +evaluating the inmate. +19 +: Okay. So -- +20 +EMPLOYEE 22 And so we have one, two, +21 +three, really we have, (Indiscernible +22 +*00:12:26) +, uh, four. +We have four +23 psychologists on staff. +24 +You have four +25 psychologists on staff. +And any one of those +SDNY_00007927 + + + +33 +1 four +can +remove somebody? +2 +Can remove somebody. +3 +Do those four have, who's +4 those four supervisors? +5 +6 +7 +Yeah. +8 +What authority does she +9 have to overrule them? +10 +EMPLOYDE 22 +And I'm not a psychologist - +11 - +12 +: Sure. +13 +- to know what procedures +14 +they use -- +15 +: Um-hum. +16 +-- or what conversation they +17 have to determine if she's going to overrule +18 them. +I mean, she's the supervisor, and it's +19 just like with any, you know, profession you +20 have. +21 +22 +If I come up with some +23 +reasoning -- +24 +25 +In saying hey, I don't agree +SDNY _00007928 + + + +34 +1 with your decision, then we debate it and then +2 we ultimately come to a decision. +3 +Okay. +4 +As to yay or nay. +5 +Okay. +6 +So, it's kind of the same +7 thing. +8 +While on suicide watch, +9 you said there's a 24-hour companion. What +10 does +staff do for the inmates while they're on +11 +suicide watch? +12 +Well we have a camera, well +13 they're trained to, there's a phone there. +14 let's say something happened where an inmate's +15 trying to do harm to himself. They pick up the +16 phone and they call for assistance, because it +17 goes directly to control center, and we respond +18 accordingly to it. +But we also in our control center, while +20 the individual +is on suicide watch, there's a +21 camera there. +22 +Okay. +23 +EMPLOYEE +To view -- +24 +What specific training +25 does staff get as it relates to the suicide +SDNY _00007929 + + + +35 +1 watch? +2 +Once a year during our +3 annual training, we have suicide prevention +4 training. +5 +Okay. +6 +During our annual training. +7 +And that's required +for +8 all - +9 +All employees. +10 +What does that training +11 +cover? +12 +Suicide signs, prevention, +13 coping, just anything pertaining to suicide, +14 +sir. +Signs to look for. +15 +16 +Um +17 +Is there any specific +18 staff that are more trained, or specifically +19 trained for this area of the prison? +20 +EMPLOYEE 22 Our Special Housing Unit +22 +training. +staff get quarterly suicide prevention +23 +: Okay. Is that part of +something the MCC does independent, or is that +25 policy dictated? How does that -- +SDNY _00007930 + + + +36 +1 +That's our policy dictates +2 that they get quarterly training. +3 +Okay. +That's BOP policy; +4 correct? +5 +Yes. +6 +When someone, you +7 said that any staff member at the BOP can place +8 somebody on suicide watch? +9 +Yes. +10 +Is there any paperwork or +11 documentation for that that they have to fill +12 out? +13 +No. +Basically they'll tell +14 +that, you know, +that hey we need to place him +15 on watch, and we'll place him on watch, and +16 then we'll contact psychology. +17 +: Okay. +18 +To come in and talk to them. +19 +Okay. There's no referral +20 +that says, "I placed inmate" -- +21 +No. Psychology will handle +22 +it -- +23 +: Okay. +24 +- here and there, in their +25 +notes and their documentation that they were +SDNY _ 00007931 + + + +37 +1 placed on it, when they were placed on it. +2 +So, the psychology +3 department is responsible for documenting when +4 people come +in in treatment. +5 +We, you know, we have what +6 we call a daily log in the -- +7 +8 +-- institution. +So, the 1og +9 would annotate somebody was placed on suicide +10 watch also. +11 +Is there any +12 specific forms or reports that get filled out +13 when somebody is removed from suicide watch? +14 +I believe psychology would +15 do those forms and saying in their reports why +16 they were removed and if they're ready to be +17 released. +18 +19 +Do you get those forms? +I don't get the special +20 medical ones. +I just, with the notification +21 +that, you know, with the one that email that +22 +goes out -- +23 +24 +-- that the individual was +25 +released from suicide watch. +SDNY_00007932 + + + +38 +1 +Do you get notified, you +2 just said you get notified in the email that +3 somebody's removed or -- +4 +It's an email that the +5 psychology department puts out stating who's on +6 suicide watch, who's been removed. +7 +Is that a daily list? +& Like they send it once a day, or when someone +9 new comes on and off? How does that -- +10 +It's a daily one. +-And -- +11 +12 +Okay. +And it states who's on +13 +watch, who's, you know, who's +got released, and +14 +15 +: Who does that get +16 disseminated to? +17 +It's a group. It's a group +18 email that gets sent to all department heads, +19 Captain, Lieutenants, everybody in the need to +20 know. +21 +This is the supervisors +22 within the institution? The Lieutenants, the +23 Captain. +24 +(Indiscernible *00:17:07). +25 +SDNY _00007933 + + + +39 +1 +And, don't quote me on that, +2 but I need to look at the chain -- +3 +: Okay. +4 +-- to see who's actually on +5 it. But - +6 +But it's not an +7 institution-wide email? +8 +It is kind of sent out +9 institution wide because you have the different +ERIAL +10 departments on it. +So, you can say it's +11 institution wide. +12 +: Not every person in the +13 +institution gets that email, though? +14 +No. +I don't -- +15 +Okay. Just not an MCC all +16 +type of -- +17 +No, it's not an all staff. +18 +19 +Yeah. +20 +What is the expectation of +21 +the department heads and the supervisors and +22 the Lieutenants and Captains once they get this +23 email? +What are they supposed to do with that? +24 +I mean, it's just a +25 +notification that the individual's being +SDNY _00007934 + + + +40 +1 removed from suicide watch. So, it depends on +2 where they're going. So, if they're going back +3 to Special Housing Unit, so it's notification +4 that hey, this person's been taken off. We +5 have nobody on watch right now. +6 +: Okay. Are they supposed +7 to disseminate that? What are they supposed to +8 do with that information? Are they supposed to +9 tell anybody where they - +10 +Well, I mean when that +11 +individual is released -- +12 +13 +Wherever they're going for, +14 +they're going to be notified by psychology that +15 they're coming directly -- +16 +: Okay. +17 +18 +19 +- to you. +So, it was just an +20 accountability -- +21 +22 +- thing just to know that +23 +24 +25 +hey, this person is getting off of watch. +So, psychology will notify +whatever unit they're going back to? +SONY _00007935 + + + +41 +1 +Well, it depends where +2 you're going back to. Typically I always go to +3 Special Housing Unit down. +4 +Okay. +5 +And typically when you do, +6 let's say an individual has tried to commit +7 suicide. +It's +an infraction. So, they usually +8 have an incident report that goes beyond that. +9 So, you have to come up to the Special Housing +10 Unit anyway before so that that infraction can +11 be resolved. +12 +Okay. +13 +So, there are a number of +14 aspects of, you know, how. Did you go straight +15 back or if you don't go back there. +16 +And this email that +17 psychology sends out with the list of who's in +18 and who's out of suicide watch -- +19 +Who's on watch, yeah? +20 +: - is that once a day or +21 +twice a +• day? +Is that morning and evening +22 thing? +23 +EMPLOYEE 221 +It depends. +24 +25 +When you come in in the +SDNY_00007936 + + + +42 +1 morning, they could say, you know, this is +2 who's on +watch, and then you get another one +3 stating who's been released off of watch. +4 +Okay. +Is there any policy +5 or standard operation procedure on how +6 (Indiscernible *00:19:21) that email gets sent +7 out? +8 +How what? +9 +How frequent that email -- +10 +No. +11 +Okay. +But it should be at +12 least once a day? +13 +That's when they send it +14 +out. I don't - +15 +Okay. When somebody is +16 +removed from Special Housing -- +17 +18 +- and placed in suicide +19 +watch on the second floor -- +20 +21 +-- is anything done to +22 their cell in Special Housing? Is there any +23 precautions or anything that go into that? +24 +So, typically let's say you +25 do leave, and it depends on how much space we +SDNY _00007937 + + + +43 +1 have. +We really don't have that much space. +2 +Okay. +3 +So, usually that cell, +4 depending on if when they were removed from the +5 cell, if they had a cellmate. +So, what happens +6 is that individual's property is removed, and +7 we could possibly put somebody else in that +8 cell. +10 +Um -- +11 +And again, the suicide +12 watch versus psychological, the psyche eval +13 that, you said that happened right away when +14 +someone first comes in the prison; correct? +15 +Well I -- +16 +A psyche eval? +17 +- I didn't say what you +18 +said before that. You said -- +19 +A psychological eval. +20 +окау. +21 +I want to clarify, earlier +22 +you said that people, inmates get that when +23 +they first come into the prison; correct? +24 +EMPLOYEE 22E +Yeah. Psychologically when +25 they initially have to come and actually +SDNY _00007938 + + + +44 +1 perform -- +2 +3 +Okay. +-- an initial intake +4 screening. +5 +Is there a +• level below +6 suicide watch? +7 +Well we also have what +8 call a psyche observation. +9 +: okay. +10 +EMPLOYEB 22 +And I think the best way to +11 +describe that would be it's a step-down from +12 suicide watch. For example, we might have a +13 +mental health inmate that is just mentally, you +know, +out there. So, we'll put them on psyche +15 observation. +They haven't said they're going +16 to hurt themselves, but they have the potential +17 to do it. +18 +Somebody might be on narcotics and acting +19 +erratic and you don't know what they're on. +20 So, they might end up doing it. But it's a +21 different type of observation because it's not +22 +as stringent as suicide watch. +23 +: Okay. +24 +Can you explain what that +25 means? +What are the requirements when an +SDNY _00007939 + + + +45 +1 inmate is on psyche eval, or psyche +2 observation? +3 +If they're on psyche +4 observation, we are not necessarily putting +5 them in a +smock. +You know? You can still have +6 your regular clothing. We're just observing +7 your behavior and that. So, that's the +8 difference. +9 +: And does the psychologist +10 stop by every day? +11 +They' re treated the same way +12 as somebody that's on suicide watch. They're +13 evaluated, come up with a plan. They're ready +14 +to be released. +Keep them on, more along those +15 lines. +16 +: Well is someone on psyche +17 +evaluation, do they have an inmate companion +18 +watching them? +19 +Psyche obs also has an +20 inmate companion. So, anybody in that area has +21 +an inmate watching them. +As the Warden, do you have +23 any input on the determinate if someone's in +24 psychological observation, in suicide watch or +25 observation status? Do you have any input on +SDNY _00007940 + + + +46 +1 that? +2 +I don't overrule medical +3 decisions. I'm not a +4 +5 +If they come to me and say +6 this is warranted whether it's medical care or +7 not, I don't -- +8 +9 +10 +EMPLOYDE 22 +: But you're briefed on it? +I'm briefed on it. Yes. +11 +12 +: Is that orally? +Orally they'll come and say, +13 +well +we'll discuss an inmate saying, hey, he +14 has mental issues. I feel that they need to be +15 placed here or there. And I'm going with your +16 evaluation. +I'm not going to, and I have good +17 psychologists. +So, I trust their judgment. +18 +: Can an inmate be taken off +19 of suicide watch by . I +or her staff +20 without consulting you? +They can. The +22 decides who's coming off of watch. So, they +23 can make the determination and, you know, they +24 send up to the Associate Warden, the Captain, +25 and it will come to release and if they're +SDNY _00007941 + + + +47 +1 going off it. +So, it doesn't -- +2 +But do they -- +3 +- have to necessarily, it's +4 not my approval. +5 +Do they typically consult +6 you when that happens? +7 +Depending on, you know, if +8 it's the case, you know? +Who it is, you might +9 be, like I said, a high profile individual they +10 would say, "Hey, we're taking +him off of watch. +11 We're doing this." So, we'll be following the +12 plan closely, so -- +13 +When it comes to Epstein, +14 +Jeffrey Epstein - +15 +16 +-- he was in the mental +17 health program. Can you just tell us your +18 understanding of his involvement with the +19 psychologist at MCC? +Um, let me back-track. +21 +22 +Sure. +It's not a mental health +23 +program. +24 +okay• +25 +Um -- +SDNY_000079-12 + + + +48 +1 +Sorry. +2 +Being, I guess, reviewed by +3 psychology -- +4 +Sure. +5 +-- they're following him. +6 He was on their case. +7 +Okay. +8 +And you want to know what I +9 knew about it? +10 +Yes. +11 +Again, he was under their +12 care. They were evaluating him, and, you know, +13 going through their protocol to determine why +14 he was on watch. If he was on suicide watch, +15 can he come off of suicide watch? Was he +16 suicidal? +Things like that. +17 +: At any time, were you +18 aware or notified of him being suicidal or +19 having any suicidal ideations or attempts? +20 +EMPLOYEE 22 Well we had an incident +21 +where he was in the cell with Tartaglione -- +22 +: Okay. +23 +- that it might've been a +24 +suicide attempt and it might not have been a +25 suicide attempt. +So, we followed the protocols +SDNY _00007943 + + + +49 +1 and put him on watch. +There was also an +2 internal investigation where he was interviewed +3 and his cellmate was interviewed, and he +4 basically +denied (Indiscernible *00:25:35). +5 +When you say "he denied", +6 Tartaglione -- +7 +He said -- +8 +-- or Epstein? +9 +No, Epstein stated that, +10 "Hey, I didn't try to kill myself." And then +11 Tartaglione said that he was sitting in the +12 cell. He thought he was having a heart attack. +13 So, I forget the words psychology used to +14 +determine what their conclusion was as far as +15 the actual act. +16 +17 +Did you review the +18 +incident report for the suicide attempt? +19 +I reviewed the investigative +20 report that the Lieutenant interviewed both of +21 them, took their statements, and all that +22 because the review process goes from, the +23 Lieutenant initiates it. It goes to the +24 Captain, +Associate Warden, and myself. And +25 then I, uh, sign off on it. +SDNY _00007944 + + + +50 +1 +Did you speak with +2 +after she had consulted with Mr. Epstein +3 when he was placed on +suicide watch? +4 +Um, yes. +We have SHU +5 meetings, and we have it once a week, and +6 Epstein was brought up, and she talked about +7 Mr. Epstein. +8 +After the suicide attempt? +Yes. +10 +the SHU thing typically? +12 +13 +14 +15 +16 +meetings? +17 +What day of the week is +It's Thursdays. +All right and -- +- what happens at the SHU +It's a list where we go +18 around and we talk about every inmate. +We have +19 inmates that are in there for infractions, +20 criminal issues, from your office, a high- +21 profile guy might come in. So, we just talk +2 +22 about, okay, what's the status. If we call in +23 a disciplinary citation, that means they've +24 been sanctioned and they're doing time, and +25 then we look at the release date. We have some +SDNY _00007945 + + + +51 +1 in there pending investigations. +Cellphone +2 introduction. +Drug introduction. +So, that +3 goes through the investigative process, and +4 then we +have, you know, +we also +have our SAMs +5 +(phonetic sp.) +inmates that are housed in +6 there. +7 +So, we basically discuss +and talk about +8 every inmate. +9 +: And who attends these +10 meetings? +11 +Myself, all the Associate +12 Wardens, the Unit Managers, psychology, the +13 Captain, +the +: SHU Lieutenant, the Investigative +14 Lieutenant. +So, we just have everyone there +15 that's involved in the -- +16 +: And what's your +17 understanding of whether the SHU Lieutenant or +18 the Captain brief out the duty Officers in the +19 SHU about the outcome of that SHU meeting every +20 week. +21 +EMPLOYEE +22 +I don't understand what you +22 mean. +23 +: So, do you have an +24 understanding of whether, because the duty +25 Officers are not present in the SHU meeting; +SDNY _00007946 + + + +52 +1 +correct? +2 +3 +No. +Do you have an +4 understanding of how, for instance, if you tell +5 the Lieutenant, I want this done in the SHU, +6 will the Lieutenant then tell his duty Officers +7 after the meeting? +8 +Well, the duty officer is +9 supposed to make rounds throughout the +10 institution when they're on duty to observe and +11 report if anything is not right. +And then if +12 we have incidents, they make notifications, you +13 know, to the region. +14 +15 +: To the region? +To, like let's say we have a +16 +fight. +17 +18 +Or maybe like you said, a +19 suicide attempt. +So, they have to contact the +20 Regional Duty Officer. That's their +21 notification. +They make the Regional Duty +22 Officer, +and then it moves up the chain that +way, and then I have to make my notifications, +24 which I make my notifications to the Regional +25 Director. +SDNY _00007947 + + + +53 +1 +Okay. And my question is, +2 does any information, do you have an +3 understanding of whether any information that's +4 conveyed in these SHU meetings gets briefed +5 down to the line Officers who are responsible +6 for patrolling the SHU? +7 +8 +It does? +9 +Yeah. The SHU Lieutenant is +10 there, and he's in the meeting, he or she is in +11 the meeting, and they're talking to their staff +12 on what needs to be done or the status, you +13 know. +We're +going in and we determine if +14 somebody can be released, then that will be +15 conveyed back that hey, an individual can be +16 released. +17 +: So, you were saying that +18 after the July 23 suicide attempt, there was a +19 Thursday SHU meeting? +20 +EMPLOYEE 22 Right. +21 +In which +22 discussed at +least her initial observations of +23 Mr. Epstein? +24 +25 discuss +Well, she would initially +it there, but she would also initially, +SDNY _00007948 + + + +54 +1 whoever, you know, if the Warden is there, +2 initiate it to the AW. So, that would be +3 something immediate that she would say, hey, +4 he's on watch and this happened. +5 +And what happened at that +6 first SHU meeting after the suicide attempt? +7 +The week of July 22nd to the +8 26th, I was on leave. +: Okay. +10 +So, I was, you know, I was +11 +getting called. So, I don't know the +12 specifics, but I was aware of, you know, I got +13 called that hey, there was an attempt and the +14 +protocols were followed. +15 +• Okay. +16 +Notifications were made. +17 +: Okay. So, the following +18 +week +which +I think is the week of the 29tn. +19 +The 29th or the 30th, yeah. +20 +You were back in the +21 +office? +22 +That Monday. So, if you +23 +have a calendar, I can look at it. +24 +I think it's the 29th -- +25 +So, yeah. So, the 29th is a +SDNY _00007949 + + + +2 +55 +1 Monday. +I have to check, did I take a extra +2 day or not? I'm not sure, but the 2gth, I +3 should've, I would've been back. +4 +So, that Thursday meeting +5 which 1ooks like would've been August 1st, you +6 were present at? +7 +Yes. +8 +And what was discussed +9 during the SHU meeting? +10 +EMPLOYDE 22 +The SHU meeting, we'll +11 discuss +every inmate. Every inmate on the +12 list, what's their status? Updates and all +13 that stuff. +14 +: Okay. And specifically +15 +with respect to Epstein, what was discussed? +16 +I don't recall specifically. +17 I know we would've talked about him. +We +18 +would've probably talked about, you know, his +19 psychological status and I got to remember on +20 the first, he was probably back in the Special +21 Housing Unit. +So, we were probably, you know, +22 talking about his housing conditions, what's he +23 doing, and usually the conversation was during +24 the day he was +down at the attorney visits, you +25 know? +SDNY _00007950 + + + +56 +1 +And then there were certain exams that we +2 had to do that we wanted to get done on him. +3 And then we discussed that. +Uh, what kind of exams? +Physicals and then, you +6 know, and I don't know if that was before or +7 after his sleep apnea machine that he was, you +8 know, requesting. +9 +: Um-hum. +10 +Because typically, you know, +11 you have to go through the fitting and the +12 process, but, you know, we allowed that one to +13 come in. +We checked it, security wise, and +14 said it was fine to come in, and we got it. +15 So, I think we might have been discussing that, +16 more along +those lines. +17 +But we discuss every inmate in there. I +18 don't specifically remember it. I know we +19 would've talked about what the issues were +20 pertaining to him. +21 +Um, +let's go back to -- +22 +23 +MS. l +- the suicide attempt. +24 +25 +You said that you were on +SDNY_00007951 + + + +57 +1 leave that week, but you were notified by your +2 Associate Warden? +3 +Associate Warden, yes. +4 +okay. 1 +Were you receiving +5 daily updates? +6 +Not, I mean, they called me +7 during the day the first time +that it happened. +8 Hey, this is what happened. He's on watch. +9 And then the next day, you know, he was still +10 on watch. +So, there was really no, I didn't +11 need that much updates because we knew he was +12 on watch. +13 +Okay. +14 +Um -- +15 +: And you notified your +16 Regional Director? +17 +I notified my Regional +18 Director. +And then while I was on leave, my +19 Regional Director was also in contact with my +20 acting AW. +21 +Did the -- +22 +Acting Warden, I'm sorry. +23 +: Did the Regional Director +24 +convey any directions to your AW during that +25 time? +SDNY_00007952 + + + +2 +58 +1 +I believe just the basics, +2 you know. +Keep him updated what's going on +3 because at the time he was under psychology's +4 care. +5 +6 +So, once they're in that, +7 there's really not +that much input to go on +8 because they're on watch. +9 +And then Epstein was +10 downgraded from suicide watch to psyche +11 +observation. +12 +Psyche observation. +13 +While he was still on the +14 +second floor? +15 +Yes. +16 +Were you notified of that +17 change? +18 +Yes, that he was on psyche +19 +obs. +20 +Okay. And did you discuss +21 +at all? +22 +Yeah. +we talked about it. +23 Again, it was, you know, him going back up to +24 the Special Housing Unit. Although he wasn't +25 suicidal, it was just a matter of, okay, who +SDNY _00007953 + + + +59 +1 are we going to house him with? +2 +3 +You know, coming to that +4 decision and then that would give her more time +5 to work with him if she needed. +6 +: Okay. Did you have a +7 discussion with •. +about whether +she +8 felt he was still suicidal? +9 +EMPLOYEE 22 Again, if the psychologist +10 tells me that he's ready and he goes, I don't +11 question medical judgment. I trust her +12 judgement. If she says he's not suicidal and +13 he's ready to go back, then we trust her +14 judgment. +15 +: And she did -- +16 +EMPLYEB 22 +Because she -- +17 +: - tell you that? +18 +She said he was ready to go +19 back. +He wasn't suicidal and that he was ready +20 to go back. +21 +22 +Did you review any of her +23 +reports or the psychologist's reports -- +I don't -- +24 +-- during the time he was +25 on the second floor? +SDNY _00007954 + + + +60 +1 +2 medical files. +No. +I don't review any +3 +And he came back to the +4 SHU on the 30th, +is that right? +5 +EMPLOYEE ZZ +Uh, yes. +6 +Okay. +7 +8 +And what discussions did +9 you have, let's start with . +•- about +SERIAL +10 the conditions +of his confinement in the SHU? +11 +She just said to get him in, +12 you know, we're going to put him, get him a +13 cellmate because typically every inmate that, +14 you know, is on suicide or whatever, we say, +15 okay, we're going to give him a cellmate. So, +16 that was when we went through the process of +17 figuring out, okay, who could we possibly put +18 him in with? Um, the pickings were slim. +19 +So, I came up with Tartaglione, and no +wait, no. Tartaglione, he had been put down +there originally because +: of Tartaglione. +23 +So, what happened was, we +24 had to come up with some more inmates. +So, I +25 came up with three. +It was, I believe, Reyes, +SDNY_00007955 + + + +61 +1 +and who was the other one? We had +2 another sex offender in there that we were +3 going to put him in there, and he said, "If he +4 comes +in here, it's going to be a problem." +5 So, we didn't put him in there. +6 +So, we ended up putting Reyes in there. +7 +8 +Reyes, an older gentleman. +9 +10 +I, so we figured that was a good +11 +fit, and then I sent an email of the three to +12 the Director's Chief of Staff I sent an email +13 to. +14 +And what is his name? +15 +(phonetic +16 +sp.). +17 +: Okay. And so you emailed +18 him, +here are the three +19 +Here are the three -- +20 +-- possible -- +21 +22 +-- possible ones. +23 +EMPLOYEE +24 +Did you tell +- +25 +SDNY_00007956 + + + +62 +1 +Did you tell Mr. +2 that he needed to have a cellmate? +Yes. That's what the +4 discussion was, for a cellmate. +So, I sent +5 that up, spoke with my Regional Director. I +6 believe he received it too, and came to the +7 conclusion Reyes would probably be the best fit +8 for him. +So, we put him in the cell with +9 Reyes. +10 +: Is there a policy about +11 whether an inmate needs to have a cellmate +12 after they've been taken off of suicide watch? +13 +There's no policy, but it's +14 sound correctional judgment. I mean even if an +15 individual is not on suicide watch, and you're +16 in the Special Housing Unit, you typically want +17 +somebody in there with them. +18 +: Um-hum. +19 +Because, I mean, you never +20 know what could happen. +So, just for somebody +21 to talk to, you know, pass the time. So, you +22 +typically put somebody in there unless again +we're in a situation where they're just totally +24 separated from somebody -- +25 +SDNY _00007957 + + + +63 +1 +-- and we can't put them in +2 there because it becomes a life safety issue. +3 +How long after someone is +4 taken off suicide watch would you typically +5 direct that they have a cellmate? +6 +It would depend on the +7 situation, because you could be getting +8 released to a unit where you would +9 automatically have a cellmate going through, or +10 you know, +direction could put out that, hey. +11 make sure the individual has a cellmate. +12 +So, there's no really timeframe on when +13 you would decide that. +14 +: Just to clarify, as it +15 relates to, I know you guys just discussed +16 this, but just making sure I'm following you +17 guys correctly. As it relates to the first +18 suicide attempt back on July 23d, Mr. Epstein. +19 +20 +You were on leave. +21 +Yeah, the 22nd +22 +You were notified via +23 +telephone of this, and you notified the +24 Regional Director. +Is that correct? +25 +Yeah, of the, yeah, I did +SDNY _00007958 + + + +64 +1 call him to tell him. +2 +You called the Regional +3 Director? +4 +Yes. +5 +-- while on leave to +6 notify him? +Did you notify anybody else of the +7 23d incident? +8 +No, I called my boss, +and -- +9 +Okay. +10 +Yeah. +11 +And that is, +via the +12 policy and your responsibilities, as a BOP +13 policy and your responsibility as a Warden, is +14 +there anybody else that you were supposed to +15 +notify? +16 +No. +17 +Okay. +18 +No. +19 +: And your staff was +20 notified because they were working in the +21 +institution; correct? +Which staff? +Your Assistant Warden, who +23 +24 +25 +-- +Yeah. She was the Acting +SDNY _00007959 + + + +65 +1 Warden, +so she -- +2 +Acting Warden. +3 +Yeah. +4 +Who was that? +5 +At the time, +I believe it +6 was +(phonetic sp.). +7 Yeah, +she was Active Warden. +8 +Okay. +Do you happen to +10 +9 know if she notified anybody? +She would've notified the +11 Region also. +12 +13 +Okay. +And she would've notified +14 +the region, but she was just calling me -- +15 +: Okay. +16 +-- just to let me know like, +17 +hey, this is what's going on. +18 +Okay. And back when, a +19 few days later when Epstein was removed from +20 suicide watch to psyche observation -- +21 +22 +-- were you notified of +23 +that change? +24 +That he was being moved? +25 +Just downgraded from +SDNY _00007960 + + + +66 +1 suicide watch to psychological observation. +2 +Yes. +3 +Did you notify anybody of +4 that? +5 +Um, I might've called my +6 boss to let him know that, hey, he's been +7 downgraded off of suicide watch. +8 +Okay. +10 +Yeah. +'ERIAL +You don't recall +11 +12 +13 +14 +specifically calling? +No, I don't. +Okay. +But I probably would've +15 +notified him. +16 +Okay. +Did you recall +17 +notifying anybody specifically about that +18 downgrade? +19 +What, +as far as him? +20 +EMPLOYDE 22 +Yep. +21 +No, I don't recall, but it +22 +would've probably been my boss telling me -- +23 +: Okay. +24 +EMPLOYEE 22E +- hey, we moved him from +25 suicide watch down to -- +SDNY _00007961 + + + +67 +1 +And that's the Regional +2 Director? +That's the Regional +4 Director. +5 +And what's his name? +6 +7 +And then a few days later +8 when he was removed from observation and placed +9 back in Special Housing Unit, you were notified +10 of that? Were you notified of that? +11 +oh, yes. +12 +: Did you notify anybody of +13 +that? +14 +When he was removed and +15 placed back in the -- +16 +: Yes. +17 +- Special Housing? Yeah, I +18 let my supervisor know that that was the plan. +19 +: Okay. +20 +EMPLOYEE 22 He was moving him, because +21 +remember we had to +get him -- +22 +23 +EMPLOYEE +22 +-- a roommate. +24 +25 +So, that was the whole +SDNY _00007962 + + + +68 +1 process, notifying, hey, he's coming off watch. +2 He's going to the Special Housing Unit. +3 +4 +And he's going to get a +5 roommate. +6 +Other than your Regional +7 Director, did you notify anybody else? +8 +That no was conting of y +Yes. +10 +EMPLYED 22 +-- or talk about it? +11 +YeP • +12 +Yeah. My exec staff. +13 +Okay. +14 +And said that, you know, +15 +what the expectation was that, you know, he's +16 going to have a cellmate. +17 +So, you told, during that +18 meeting, do you recall when that meeting was? +19 +I don't recall when the +20 meeting was, but I just told them, hey, he +21 needs to have a cellmate. This is his +22 cellmate. +Cellmate at all times. And, you +23 know, put it out to your -- +24 +Okay. Um - +25 +Put it out to your people? +SDNY _00007963 + + + +69 +1 +To the departments and your +2 areas of responsibility on that's how he was +3 going to be housed. +4 +And who did you +5 specifically tell that to? +6 +My Associate Wardens were +• in +7 there, whoever +was +acting, the Captain because +8 that specifically falls under his area. +: Um-hum. +10 +EMPLOYEET 22 +The Special Housing Unit. I +11 +told him specifically he needs to be housed +12 alone. I informed his Lieutenant, you know, +13 +and his offices and basically on each shift, +14 just be mindful, you know, of making rounds and +15 just not for him, just for everybody. +16 +: And what's the Captain's +17 name? +18 +EMPLOYED LОYED22 +19 +-• okay. +20 +21 +22 +Did you tell Captain +this before Epstein was moved back to +23 +the SHU? +24 +Yeah. +We had a meeting, and +25 I got together +and I said, hey, this was going +SDNY_00007964 + + + +2 +70 +1 to be the plan that Reyes was going to be moved +2 in with him. He was going to have a cellmate, +3 and that was the protocol we were going to +4 follow. +5 +confirm that he +6 would tell his Lieutenants, or his -- +7 +He confirmed. I followed up +8 and asked him, did you put it out to the +9 Lieutenants and staff working, and he told me +10 yes. +11 +: And was that before +12 Epstein, his confirmation, did that come before +13 Epstein was moved back to the SHU, or around +14 the first day he was in the SHU? +15 +No before. I had the +16 conversation with him, and then I followed up +17 afterwards and said, "Hey, did you disseminate +18 the information?" And he said, "Everything was +19 disseminated." +20 +But it wasn't just a one-day thing. It +21 +was a constant, I told him, a constant follow +22 up, you know? +Make sure that, you know, these +23 protocols are being followed. +24 +How many times do you +25 recall telling Captain +that, between +SDNY _00007965 + + + +71 +1 when Epstein +went back to the SHU -- +2 +3 +4 +-- and then his suicide? +I don't recall the number of +5 times, but it was just a conversation +6 constantly reminding that let's be vigilant on +7 just not him, but everybody in the Special +8 Housing Unit. +9 +Could you estimate daily? +10 Once? +Twice? +11 +I wouldn't say daily. I +12 would say, I don't have an actual number. I +13 don't want to say an actual number, but you +14 know, if I did encounter, or I made rounds in +15 the unit, I would, you know, tell staff up +16 there, you know, be vigilant with your +17 protocol. +18 +So, I don't know the specific amount of +19 time. +I make my rounds once a week at a +20 minimum, but, you know, sometimes it's more. +21 Sometimes it's +less. +When it comes to the +23 ability, so you specifically go back to, what +24 you said earlier about Reyes. +25 +SDNY _00007966 + + + +72 +1 +You came up with three +2 possible - +3 +4 +-- roommates for him, and +5 with that list, did you brief that up the chain +6 for approval, or where did that go that list? +7 +LEMPLOYEE 22 +I sent it to, I made my boss +8 aware of it. +: Okay. +10 +EMPLOYEET 22 +And then +I sent it to the +11 Chief of Staff in the Director's office. +So, I +12 don't know what conversations -- +13 +Sure. +14 +-- took place above that. +15 +Um -- +16 +Okay. +17 +I just know about -- +18 +: You briefed it up the +19 +chain. +You briefed your suggestions up the +20 chain. +21 +I went up the chain. +22 +And there was, were there +23 +any objections +to that list? +24 +I gave the three possibles - +25- +SDNY _00007967 + + + +73 +1 +2 +- but you know, one I had +3 was a 26-year-old drug dealer I know he, and he +4 was +still in there, and +I was +like although he +5 was separated, I just didn't —- +6 +7 +-- feel that he could, you +8 know, he might, somebody could convince him to +9 do something. +So, he didn't, I didn't feel +10 comfortable with him, and I forget the other +11 +one. +And I think the other one might've been +12 somebody that was going to be releasing soon. +13 +Okay. +14 +So, I took in the factors +15 Reyes' age +16 +: Um-hum. +17 +-- and second when he +18 checked himself in and feeling that he was +19 going to be long-term. +20 +Okay. That, so you made +special +care and consideration in picking +22 +Epstein's roommate, cellmate? +23 +Based on the -- +24 +Yep. +25 +-- options I had -- +SDNY_00007968 + + + +74 +1 +Yep. +2 +- which wasn't too many. I +3 mean, he had to have a cellmate, and the +4 options weren't good. +5 +Are staff in the Special +6 Housing Unit allowed to assign cellmates +7 arbitrarily or on their own without consulting +8 a Captain, Lieutenant, or yourself +9 (Indiscernible *00:46:26). +10 +Yeah, the offices on their +can, you know, if they have to move +12 somebody around can move somebody around based +13 +on they know who can be housed with who. If +14 +somebody's separation, they know who's +15 separated from an individual. So, they can do +16 that. +17 +18 +: Okay. +I mean, they're capable of +19 doing that. +20 +Okay. +As it relates, talk +about Reyes a little bit. +23 +He's no longer in MCC; +24 +correct? +25 +SDNY_00007969 + + + +75 +1 +When was he released from +2 the facility? +3 +_EMPLOYEE 22] +He was released, I believe, +4 on Friday. +5 +: Okay. Was he transferred +6 out? Was he released from custody? Under what +7 conditions, do you know? +8 +From what I understand, it +9 was with all belongings. So, I don't -- +10 +: Okay. +11 +-- who took him. +You can't, +12 I mean, even if you look on Sentry, you don't +13 know where he was +14 +: Um-hum. +15 +EMPLOYEE 22 but when we looked at him +16 originally, it still showed that he was going +17 to court. +18 +Okay. +19 +EMPLOYED 22E +So, that he was going to be +20 +long-term. +Now it's just showing there's no +DST. +So, I don't know where Reyes is. +Okay. But he's not in +22 +23 +24 +25 +MCC? +EMPLOYEE +22 +No, he's not in MCC. +SDNY _00007970 + + + +76 +1 +Uh -- +2 +Prior to, you had, you +3 were very active in making sure that Epstein +4 had an appropriate cellmate? +5 +6 +What were you, leading up +7 to the last week Friday, what were you aware of +8 Reyes, any court proceedings or any issues or +9 concerns about him leaving the MCC? +10 +I was off on Friday. +11 +12 +: Okay. +So, I didn't know anything +13 about his court proceedings -- +14 +: Okay. +15 +- or whatever. I just know +16 this from after the fact. +17 +: Okay. When it comes to +18 Reyes, the staff in the Special Housing Unit, +19 how do they get notified of court dates, of the +20 probability of someone being released from the +21 facility? How does that process work? +They get a call from +receiving, it's called receiving and discharge. +24 +25 +Where the inmates are +SDNY _00007971 + + + +2 +77 +1 processed in and processed out. +So, they get +2 notification that hey, such and such is +3 leaving, and send him down. +4 +Okay. +Does the MCC +5 usually, or sometimes, what's the, how often or +6 frequently does the MCC get advanced notice of +7 an inmate leaving? +8 +EMPLOYEE 22] +9 inmate's designated -- +It depends. If the +10 +: Um-hum. +11 +-- then we know in advance +12 he's designated. But usually the Marshalls +13 will come and say, whoever is picking him up, +14 "Hey, we're taking such and such." We might +15 get a list ahead of time if somebody's going to +16 maybe one of the county facilities or some they +17 just come and say, "Hey, we need this guy." +18 +: Okay. Ultimately Friday, +19 the gth, Reyes +is discharged. +20 +Leaving Epstein, actually +22 let's talk about without a cellmate. Was there +23 a plan in place if that were to happen? +24 +we'd review it and say, +25 okay, who can he be with? But he wouldn't have +SDNY _00007972 + + + +78 +1 been alone. +2 +Was there anybody in the +3 Special Housing Unit that was +already vetted to +4 room with, or cell with Epstein? +5 +No. Because again, didn't +6 anticipate Reyes leaving -- +7 +Okay. +8 +-- like that. +But we +9 would've gotten somebody in there temporarily. +10 +When did you first become +11 +aware of Reyes leaving the MCC? +12 +EMPLOYDE 22 After the death of Mr. +13 Epstein. +14 +: Okay. +15 +Um, when I came, you know, +16 that was like my first question was like, where +17 +is his cellmate? +18 +: Okay. +19 +I was told he was gone. +20 +When were you first +21 +notified of the death of Epstein? +22 +I got a call about 6:50 and +23 +told me that, hey -- +24 +25 +- that he attempted suicide +SDNY _00007973 + + + +79 +1 and they were going through life-saving +2 measures. +3 +And who contacted you? +4 +My Associate +Warden, +5 +6 +7 +Yes. +8 +Uh -- +9 +Was she at the scene? +10 +EMPLOYDE 22 +No, she wasn't. +The +11 Lieutenant had called the Captain. +The Captain +12 called her, and then she called me. +13 +And is it Lieutenant +14 +is that it? +15 +Lieutenant +was the +16 Operations Lieutenant. +17 +Would you mind, in that +18 conversation, would you mind just telling us +19 about that conversation? +20 +EMPLOYEE 22 She told me Epstein, they +21 found him in his cell. They had a +22 defibrillator on him and that they were working +23 on him. +24 +25 +And when she told me that, I +SDNY _00007974 + + + +80 +1 was +like, okay. Where are they at? Is EMS +2 coming in? She said she didn't have that much +3 information because the Lieutenant was down +4 with Epstein performing life-saving measures. +5 So, that's when I came in. +6 +when did you start asking +7 questions about Reyes? On the phone or when +8 you arrived at the facility? +So, when I got there, I was +10 like, where is the cellmate. +11 +: Um-hum. +12 +I asked the lieutenant, like +13 where is his cellmate, and Lieutenant said, "I +14 asked the same question when I went down and, +15 you know, +started." +• He asked the officer, +16 "Where's his cellmate?" +17 +And, you know, just couldn't, you know, he +18 +was disoriented and told me he had said that. +19 So, that's when we started, you know, started +20 the process of where's Reyes? +21 +Just for timeline +22 purposes, about what time did you arrive? +23 +I got there about 7:30. +24 +Okay. Who within the +25 Special Housing Unit would've had the ability +SONY _00007975 + + + +81 +1 or who within the Special Housing Unit would've +2 had the ability or the authority to back-fill +3 Reyes' spot as Epstein's cellmate? +4 +Well what would've happened, +5 which was instructed to them, was -- +6 +: Okay. +7 +- they would've told the +8 Lieutenant or Captain, hey, Reyes, I mean +9 Epstein needs a cellmate. And then we would've +10 started the process of getting him a cellmate. +11 Because when, and this was Epstein's routine. +12 He got up early in the morning at 8, and he +13 didn't come back to his cell until about 7:30 +14 at night from his attorney visits. +15 +Reyes left in the morning. So, he doesn't +16 come back to his cell until in the evening, +17 which on that particular day, he got back +18 about, from what I understand, around 6:45. +19 +: Okay. +20 +Yeah. +You said that they were +instructed to notify that Epstein needed a +23 +cellmate? +24 +So, the Captain, as I told +25 you before -- +SDNY _00007976 + + + +82 +1 +2 +-- when I told them about +3 the expectations. +4 +YeP. +5 +All that was Epstein needs a +6 cellmate. +7 +Yep. +8 +And he's to be having a +9 cellmate at all times. If he doesn't, then +10 they need to notify you and then you can push +11 it up. +12 +So, you told the Captain - +13 - +14 +I told the Captain +15 specifically that. +16 +Okay. And the Captain was +17 to tell his, below him. +18 +He conveyed it to the +19 Lieutenant, to the Officers, and disseminated +20 +it out. +Okay. So, he should've +22 been notified. How should the notification +23 +have worked? +24 +25 +When he -- +-- when Reyes, realized +SDNY _00007977 + + + +83 +1 that Reyes was dismissed? +2 +The Officers should've +3 called the Lieutenant -- +4 +Which Officers? +5 +The ones working the unit? +6 +The Special Housing Unit? +7 +The Special Housing Unit +8 Officers. +Okay. +10 +11 packed up. They - +Because they know that he +12 +13 +So, +once he gets packed up, +14 +they go -- +15 +Okay. +16 +They should've known, hey, +17 let me notify and move it up the chain, Epstein +18 doesn't have a cellmate. +19 +How does Reyes' belongings +20 +get packed up? +Who does that? +21 +EMPLOYEE 221 +When the staff in SHU pack +22 +up his stuff. +23 +: Okay. So, the staff in +24 +SHU would -- +25 +They' 1l come to the door -- +SDNY _00007978 + + + +84 +1 +2 +- and if they say WAB, it's +3 with all belongings. +4 +Okay. +5 +So, they more than likely +6 just took his stuff -- +7 +8 +-- and then whatever he had +9 in his cell, and if he had something in the +10 property room, they might've gone to get it. +11 Or if they didn't, then we would somewhere down +12 the line ship it to wherever his destination +13 is. +14 +: Is the staff that's +15 packing up Reyes' belongings different than the +16 Correctional Officers? +17 +Reyes' property would've +18 been stored up in our Special Housing Unit. +19 +20 +EMPLOYDE 22 +: Right. +And then it would've been +taken by our Special Housing Unit staff to our +22 +receiving and discharge center. +23 +Is that staff, when you +say "staff", is that a different responsibility +25 than being a Correctional Officer? +SDNY _00007979 + + + +85 +1 +Well we're all, we're all +2 correctional workers -- +3 +4 +-- but their department +iSr +5 you know, the receiving and discharge -- +6 +7 +-- of inmates. +8 +9 +So, that's where you process +ERIAL +10 +in -- +11 +: Got you. +12 +-- or process out. So, they +13 would take the stuff down to them. They'd +14 +process in and process out. +15 +› Okay. So, these are +16 people that are different, have different +17 responsibilities than, okay. +18 +19 +I got it. +20 +The Special House - +21 +Thank you for - +22 +But the Officers in the +23 SHU would have been responsible for packing up +24 Reyes' belongings? +25 +Right. They would've taken +SDNY _00007980 + + + +2 +86 +1 all of his belongings. Now +I don't know if he +2 has some property still in the property room. +3 But whatever was in his cell, they would've +4 gathered and taken down. +5 +So, the Officers that are +6 in the Special Housing Unit either would have +7 actively participated or observed Reyes' +8 belongings being packed up and leaving? +9 +EMPLOYEE 22 Right, and taken. +And +10 again, I don't know where Reyes +went. +11 +Sure. +12 +I don't know if he went to +13 +court. +14 +15 +I don't know -- +16 +17 +- but the terminology with +18 +all belongings. +19 +Sure. +20 +So, he was being -- +21 +Is there any documentation +22 +or reports about when Reyes' belongings would +have been collected from Special Housing Unit? +24 +I wouldn't say belongings, +25 but there would be something showing that he +SDNY _00007981 + + + +2 +87 +1 was departed the institution. +2 +Okay. And that would be +3 in the system somewhere? +4 +Uh, yeah. +They would be +5 receipts, but our receiving and discharge would +6 have that. +7 +Okay. +8 +And it will also show in +9 Sentry, which we use to track on when he was +10 keyed out. +11 +Okay. +So, just to recap. +12 +13 +The Officers that were +14 working in the Special Housing Unit would've +15 observed Reyes' belongings leaving. They were +16 instructed via the Captain through your orders +17 that if Epstein was to have a cellmate at all +18 times. +19 +EMPLOYEE 22 At all times. +20 +And that if that wasn't, +21 +you know, +supposed to be briefed up to the +22 Captain and then ultimately to you. Is that +23 +correct? +24 +Right. The Lieutenant, if +25 the SHU Lieutenant was working, the SHU +SDNY_00007982 + + + +88 +1 Lieutenant happened to be off that day. +2 +3 +And then it goes up the +4 chain to notify somebody that he doesn't have a +5 cellmate. +6 +7 +So, the SHU Lieutenant was +8 off that day, you said? +EMPLOYEE 22 He was off that day of - +10 +: And which SHU was that? +11 +Huh? It was the Lieutenant +12 at the time was +13 +14 +15 +Uh, Lieutenant +› So, who was the Acting +16 +Supervisor? +17 +We didn't, well the +18 Operations, if we don't have a SHU Lieutenant +19 on duty, the Operations Lieutenant is the +20 Lieutenant that would come up, make rounds, and +21 (Indiscernible *00:57:40). +Okay. And who was that on +23 +Friday? +24 +25 look at the roster. +I don't recall. I have to +SDNY _00007983 + + + +89 +1 +Okay. +Let's talk a little +2 bit about staffing that day. +3 +Okay. +4 +Um -- +5 +EMPLOYEE ZZ +Well, can I -- +6 +Yes. +7 +-- say one thing? +8 +Of course. +9 +I sent a memorandum to, did +10 he give it to you? +11 +12 +Well, I got a memorandum +13 this morning -- +14 +This morning, yes. +15 +About the offices saying +16 that they knew that he left and when he left he +17 told the evening watch guy that Epstein needed +18 a cellmate. +19 +: Do you know why that's +20 dated today? +21 +Because when I came in this +22 morning, one of my Lieutenants came in and I +asked him, I said, "Hey, have you heard +24 anything about what went on on Friday?" And +25 that's when he told me he had talked to the +SDNY _00007984 + + + +90 +1 Officer, and the Officer told him he had +2 notified them as to that, you know, Epstein +3 needed a +Bunkie. +4 +Okay. And who -- +5 +Um -- +6 +-- asked the Officer to +7 put that +in writing? +8 +Uh, Lieutenant +He +9 had told him to put it in writing. +10 +Just +for, uh, +11 +(Indiscernible *00:58:59) if I may just -- +12 +Yeah. +13 +-- read it so we're on the +14 +same page, here. +15 +16 +So, we have a memo dated +17 +August 12,, +2019 to the Warden from -- +18 +(phonetic sp.) I -- +19 +20 +EMPLOYEE 221 +Yeah. +21 +22 +EMPLOYEE +22 +23 +: And the subject is, Past +24 +Information +from Special Housing Units. +25 +SDNY_00007985 + + + +91 +1 +And +? +2 +3 +Was suggested, was told by +4 Lieutenant +to write this memo? +5 +6 +Yes. +Okay. And the memo, just +7-- +8 +I don't think you need to +9 (Indiscernible *00:59:26). +10 +ока, yep. +Just-- +11 +Yeah. +12 +-- thanks. Just making +13 +sure we're +on -- +14 +: I appreciate that, yeah. +15 +Overall staffing at MCC, +16 if we can just go down that road for right now. +17 +Where, are you guys at full staff? Where are +18 +you in terms of staffing levels? +19 +We're understaffed. +20 +Okay. +21 +EMPLOYEE +22 +So, we're starting the +22 hiring process +right now, but we do have to, +23 you know, there's some posts that we can't +24 fill. But -- +25 +Where are you in terms of +SDNY _00007986 + + + +92 +1 staffing? +Like what percentage are you, would +2 you say? +3 +I believe we're in our low +4 80s, high 70s. I'd have to +look at the +5 staffing or whatever. +6 +7 +But somewhere around 80%. +Right, but it doesn't only, +8 that's not the only issue. +The only issue - +9 +: Sure. +10 +_EMPLOYEB 22 +- is like we, let's say +we're staffed to 80%, we've got about 30 people +12 that we can't use. Either they're on Workman's +13 Comp. They're on AWOL status. You name it, we +14 have it. But the problem is, it takes a while +15 to go through that process to remove an +16 employee. +17 +So, we can't just hire when you have a +18 bunch of people like that on you. So, that's +19 where we're at. +20 +: Okay. So, how do you as a +Warden and as an institution compensate for +22 being 20% understaffed? +23 +Well, I mean everyone has to +24 chip in. +I mean, we're not like the state +25 where you have +your Correctional workers and +SDNY _00007987 + + + +2 +93 +1 you have the contractor workers. +Everyone, +2 despite the fact that you might have a +3 different job title, you know how to perform +4 the functions of a Correctional Officer. +You +5 have to qualify with weapons every year. You +6 take training on working the housing units, and +7 the majority of them weren't hired off the +8 street as into their positions. There might be +9 a few. But the majority were Correctional +10 Officers and then promoted into the different +11 positions. +12 +So, we have annual refresher training +13 every year where we train and move on like +14 that. But that's just not, it's not their +15 primary discipline, being a Correctional +16 Officer. +17 +: You said all staff are +18 trained as Corrections Officers? +19 +The terminology is you're +20 Correctional workers. +21 +Okay. +22 +So, you know how to perform +23 +the functions of a Correctional Officer. +24 +25 +Carry firearms. +You can do +SDNY _00007988 + + + +94 +1 escorted trips. You could work the housing +2 unit. +The only ones who probably are exempt +3 from that are doctors and attorneys and +4 psychologists, +the professionals. But everyone +5 else, +6 +And where do the +7 Correctional workers receive this +training? +8 +Well initially you go to +9 Glencoe. +10 +Okay. +11 +Everyone goes to Glencoe for +12 +training. +13 +14 +And then specialized +15 +training, we have annual refresher training +16 every year where we +re-qualify and go over +17 +certain correctional topics. +18 +Okay. Let me ask you +19 +about some specific people. +20 +Okay. +21 +If you happen to know if +22 +they, what their primary duties are. +23 +Okay. +24 +25 +Michael Thomas? +He's a material handler +SDNY _00007989 + + + +95 +1 foreman. +2 +What is a material +3 handler? +4 +They work in the warehouse. +5 So, in the warehouse, it has several functions. +6 You either work in the commissary which the +7 inmates shop for food. He can work in the +8 laundry where you do that, or you work in the +9 warehouse where you're processing -- +10 +: Um-hum. +11 +-- in stuff. What's the +12 other one? +We also have an outside warehouse +13 where we take deliveries. +So, that's our, and +14 +it's under our trust fund department. +15 +: Okay. And the night of +16 +August 9th, August 10th -- +17 +18 +- do you happen to know +19 +if Mr. Thompson was working as a Correctional +20 Officer in that primary responsibility? +He was one of the Officers +in the Special Housing Unit. +23 +: Okay. Do you know how +24 +often he works as a Correction, his +25 +responsibility as an Officer? +SDNY _00007990 + + + +96 +1 +What they do is since he +2 works in that department, we might, if we need +3 him during the daytime, assign him over to the +4 department. +But he does +overtime. He was +5 working +overtime then. +So, we have a lot of +6 overtime. +So, individuals in other departments +7 work the +overtime. +8 +Is that something they can +9 do voluntarily, or are they told to do that? +10 How does +that work? +11 +EMPLOYED 22] +We have a volunteer list for +12 the individuals that don't work in the +13 department. +14 +: Okay. +15 +If you're a Correctional +16 Officer, we have what's called a mandation +17 list. +So, if we call around and I say, "Hey, +18 we need somebody to work this", and everyone +19 turns it down and says, "No, I don't want to +20 work it", then we go to the mandation list. +21 +22 +Which is you're next up to +23 +be mandated to work a post. +24 +Okay. +Um -- +25 +Was he mandated that +SDNY _00007991 + + + +97 +1 night? +2 +I believe he wasn't. He +3 wouldn't be mandated because he +works as a +4 +material handler foreman. +5 +Got it. +6 +So, he signed up for it. +7 +Okay. +8 +Yeah. +9 +: So, just to clarify, the +10 Correctional Officers or only the Officers are +11 +on the mandated list? +12 +13 +The rest of Correctional +14 workers have the opportunity to volunteer for +15 overtime? +16 +EMPLOYEE 22] +Right. You volunteer for +17 +overtime. +18 +Okay. +19 +Or during the daytime, I can +20 +say, "Look I need to fill these posts. I need +you to come from your department to work over +in Correctional services." +: okay. +Noel (phonetic +22 +23 +24 +25 +sp.). +Uh, is a Correctional +SDNY _00007992 + + + +98 +1 Officer. +2 +She's a Corrections +3 Officer? +4 +5 +ENE LOVED 22 +Corrections Officer. +Okay. Do you happen to +6 know if she was working overtime or her regular +7 shift that day? +8 +I'm not sure. I think it +9 might've been (Indiscernible *01:04:52). +I'm +10 not sure. +I think her regular, I'm not sure. +11 +Okay. +12 +Her regular shift was +13 evening watch, +and then she did it. So -- +14 +: Okay. +15 +• Does she typically work in +16 the SHU? +17 +Uh, yes. +She's been +18 +(Indiscernible +*01:05:01). +19 +Okay. +20 +EMPLOYED 22 And I don't know if that was +21 +her assigned quarterly post, but I do believe +22 +it is. +23 +Captain [ +24 +EMPLOYEE +He's the Captain. +25 +SDNY_00007993 + + + +99 +1 +He's an +2 Officer. +3 +He's an Officer? +4 +Yeah. +5 +6 +EMPLOYEE +He's an Officer. +7 +8 +Michael Davis? +He's an Officer. +9 +(phonetic +10 +sp.)? +11 +She is the psychologist. +12 +Okay. So, the only one, +13 +the only one, Michael Thomas, is the only one +14 who's primary responsibility is not an Officer? +15 +And +16 +, yep. Okay, great. +17 +Are you notified when a +18 +Corrections Officer is mandated to work +19 +overtime? +Who makes that decision? +20 +The Lieutenant on shift +21 +handles that. +22 +What are the rules, or any +23 policies in terms of overtime? Is there a +24 limit? Is there, how does the overtime work? +25 Is there a cap in terms of hours a week? +SDNY _00007994 + + + +100 +1 +2 +3 +It's voluntary. +And then it's, like you +4 said, the prison business is 24 +5 +6 +We don't have the luxury to +7 turn around and say we can't fill a post. Now +8 I might have a post that might require, you +9 know, X amount of people, but I have to staff +10 it at a minimum where we're safe coming and +11 going. +12 +13 +EMPLOYDE +• 22 +So, there's really no set +14 +amount. +I mean, depending, you know, I've been +15 here, when I first got here where our staffing +16 was really bad where people were doing four a +17 week. +18 +When you say- +19 +You know? +20 +: -- "four a week", what is +21 +-- +22 +Four overtimes a week. +23 +Now is, when you say, what +24 +is an overtime? Is that like another 8-hour +25 +shift? +SDNY _00007995 + + + +101 +1 +Another 8-hour shift. +2 +Okay. So, you -- +3 +So, it depends on, you know, +4 the number of people we have, those +5 volunteering. +So, right now we're in the +6 hiring process +where we are getting, you know, +7 bodies to fill in these positions. +8 +So, an overtime shift is +9 eight additional hours? +10 +EMPLOYEET 22 +Eight additional hours. +11 +: Okay. +Is there any -- +12 +: Go ahead. +13 +-- is there any limit on +14 how many 16-hour days a week an employee can +15 work? +16 +You just can't exceed the +17 +amount of 16 hours in a day. +18 +Could you explain that for +19 +me? +20 +Okay. You work eight hours. +21 +22 +You can only work 16 hours +23 +that day. +24 +25 +okay• +You can't work 24 hours. +SDNY _00007996 + + + +102 +1 You can't, you're not like a fireman where, you +2 know, you're on duty 24 hours in. +3 +4 +Okay. +so, +there's a limit on the +5 daily. +6 +7 +That you can do. +8 +But there's no limit on +9 how many days in a row you can work those 16 +ERIAL +10 hours? +11 +No. +If somebody wants to, +12 they could. +13 +Do you have any unofficial +14 +or any guidance on that front? +15 +16 mean you have some +No, not really, because I +people that sign up for +17 overtime. +18 +Got you. +19 +You know? +They say - +20 +21 +-- hey, they might, I don't +22 know people's financial situations. +23 +24 +But they might say, hey, you +25 +know, I need to get some extra money -- +SDNY_00007997 + + + +103 +1 +Yeah. +2 +-- for X, Y and Z. So, I +3 don't know the specifics -- +4 +okay• +5 +•EMPLOYEE 22 +- on why somebody would. +6 +You know I had a previous +7 job where my supervisor wouldn't let us work 21 +8 days in a row. +We had to take that 22nd day +9 off. +10 +11 +Do you guys have anything +12 +unofficial like that that -- +13 +Well they have their two +14 +days oft. +15 +Okay. +16 +EMPLOYEE 22] +So, you get two days off. +17 +So -- +18 +Is that -- +19 +-- and that -- +20 +Is it required that they +21 +take those two +days? +22 +Yeah. You take your two +23 days. What you choose to do with those two +24 +days is your business. But we don't, like if +25 someone, it has to be an emergency. Let's say +SDNY _00007998 + + + +104 +1 it's your Friday. +You won't get mandated on a +2 Friday because +Federal Law states you have to +3 have X amount of hours off during the week. +4 +Okay. +5 +In conjunction to days off. +6 So, (Indiscernible *01:08:57). +7 +So, the most 16-hour days +8 an employee can work is five, so they have two +9 days off? +10 +Well not necessarily, +11 because you could say hey I want to work on my +12 days off. +13 +Okay. +So, you can come in +14 +on your days off then? +15 +On your days off. That's +16 voluntary. +17 +18 +19 +EMPLOYDE 22 +I can't just turn around -- +Sure. +20 +21 +22 +but if you want -- +-- and say you have to stay +Okay. +23 +EMPLOYEE +22 +Um -- +24 +Anything on the +25 +overtime? +SDNY _00007999 + + + +105 +1 +NO. +2 +Okay. Talk a little bit +3 about the cameras in the facility. +4 +Okay. +5 +What is your understanding +6 on the general reliability of them? +7 +They're not good. We were +8 just funded to get new cameras installed but, +9 you know, when you're installing the cameras, +10 there's a lot you have to do. The building is +11 built in 1975. It's not like a new building, +12 and we've got to go through cinderblock. +13 There's a lot of things that, you know, are in +14 that block. Asbestos. So, we have to do the +15 wiring. SO, the system is outdated. Um -- +16 +: When you say they're not, +17 are they not reliable? Is it poor quality in +18 recording? +19 +What's the -- +It's the recording, but what +20 do they call that, the DVRs? +21 +22 +The ones that hold the +23 +recordings, they're breaking down. So, +24 sometimes we have where they're not recording. +25 +We have to get it fixed, you know, more along +SDNY _00008000 + + + +106 +1 those lines. +2 +How were you aware, how +3 are you as the Warden made aware of cameras not +4 working appropriately or any issues with the +5 recording devices? +6 +The department head would +7 bring it up to me, or the Associate Warden +8 would tell me, you know, we were informed that +9 the cameras aren't working. +10 +What is the normal +11 +procedure when the cameras go down? +12 +So, if the cameras go down, +13 then the contact has to look and determine +14 what's the problem with the cameras. +15 +Okay. How long would you +16 +say that the cameras have been unreliable? +17 +What do you mean by +18 +"unreliable?" +19 +I'm sorry, how long would +20 you say +the cameras have been not working? +21 +They work, but periodically +22 they go down. +23 +Okay. +24 +EMPLOYEE 22E +That's what I meant by it, +25 but they do record. You can, you know, it's +SDNY_00008001 + + + +107 +1 the quality. +Like you go to some places and +2 some agencies where you have that bird vision +3 type camera. That's not what we have. +4 +Okay. +5 +EMPLOYED +22 +I mean, it's, you can see +6 things, we can do some identifying, but they're +7 not, you know, +and they're only in certain +8 locations. +9 +And again, the chain of +10 notification is the staff, the Corrections +11 Officers or Corrections worker notifies the +12 +Shift Lieutenant? +13 +EMPLOYED 221 +As far as with the cameras? +14 +Yes. +If they're -- +15 +It depends on -- +16 +-- not operating. +17 +-- who's using the cameras +18 and reviewing the cameras. +19 +: Okay. +20 +EMPLOYEE 22 You know, usually our +investigative department's doing it, and they +22 do the check, and if they come in and check and +23 check the cameras and say, stuff's not +24 recording, then they notify the Comp Shop or +25 the facilities +manager and say, hey, we have +SDNY _00008002 + + + +108 +1 problem. +The cameras are not recording. +2 +: So, does SIS have a room +3 where they can see the cameras in the facility? +4 +We have a, the camera room +5 is in our communications room behind that area. +6 +: Okay. So, if a camera, if +7 the camera in the SHU was not working -- +8 +9 +: -- someone in that camera +10 +room would be able to see that there's no feed +11 +from that particular camera? +12 +It's not the feed, it's the +13 +recording. You can have, you always have the +14 life feed that you can see what's going on. +15 it's the recording of it. +16 +: Um-hum. +17 +And the recordings +18 typically, and don't quote me on it, are on a +19 two-week or less timeline. So, what it is is, +20 if it gets to that two-week period, the memory +21 gets full, then it starts re-recording over +22 +again. +So, that's how most camera systems +23 +work. +24 +But if for instance a +25 camera in the SHU was down -- +SDNY _00008003 + + + +109 +1 +2 +-- someone in that camera +3 room would see that the camera was down. +4 +Or the SIS would check and +5 say, determine hey the recordings are not down +6 or yeah, you're right, or even the screen. +7 +8 +If we didn't have a visual +9 screen to say, hey, there's problems with the +10 camera. +11 +And did that happen with +12 the SHU camera? Was anyone notified that it +13 wasn't working? +14 +Well, and this is what I was +15 told after the fact, the SIS Lieutenant I +16 believe conveyed that to the Communication +17 Officer that there was a problem with the +18 +cameras. +19 +Is that Lieutenant +20 +(phonetic sp.)? +21 +Lieutenant +22 +: And it's a she? +23 +EMPLOYEE +Yes, +she. +24 +When did she know about +25 +it? +SDNY _00008004 + + + +110 +1 +I believe +she told me she +2 told him on Thursday that she made a +3 notification for it. +4 +5 +6 +And that would be an oral +7 notification? +8 +I'm not sure. +9 +10 +But she did say she notified +11 +him. +So -- +12 +13 +Are +you made aware of +14 +those notifications as well that the cameras +15 are down and not working? +16 +EMPLOYEE 22] +It would depend. +17 +Okay. +18 +You know, +on how bad it was. +19 +If it was something that you can run out and +20 fix immediately, you know, it would say, hey, +21 you know, we can fix it. But if it was +22 something that was going to be for a while, I +23 +would have +to be notified. +24 +And were you notified of +25 this? +SDNY_00008005 + + + +111 +1 +I was told on Saturday. +2 yeah. +3 +Okay. +You were told after +4- +5 +After -- +6 +-- the fact. +7 +-- the fact I was told. +8 +9 +Okay. +That the cameras weren't +10 +working. +11 +I'm sorry, just who +12 +notified you of this? +13 +Lieutenant +told me. +14 +Lieutenant, okay. Talking +15 +about, let's +talk about phone calls in the SHU. +16 +EMPLOYED 220 +17 +What are the regulations +18 or policies about giving inmates unreported +19 phone calls? +20 +During the intake screening, +21 +you can come in and in certain SHU situations, +22 +an inmate will get an unmonitored call if they +23 +don't have their telephone account set up. +24 +25 +So, +they're afforded that +SDNY _00008006 + + + +112 +1 opportunity. +2 +How does the inmate get a +3 telephone account set up? +4 +Typically he has to go out +5 of SHU into a housing unit and go through the +6 voice recognition process in order to get set +7 up for it. You can't do it in the Special +8 Housing Unit. +9 +: And we said earlier that +10 Mr. Epstein was never left, was always in +11 +Special Housing Unit. +12 +Was always in the Special +13 +Housing Unit. +14 +: Did he have an opportunity +15 to get a telephone account set up? +16 +The problem with Mr. Epstein +17 +was he was in the attorney room all day. +18 +: Okay. +19 +From beginning to end, and +20 that's something that you do during the daytime +21 because our communications people are there. +22 So, we did, and then again, he had to be in an +23 assigned unit to get that. It's just to have +24 +it set up. +25 +Was Mr. Epstein +SDNY _00008007 + + + +113 +1 allowed phone calls? +2 +Was he what? +3 +Was Mr. Epstein allowed +4 phone calls? +5 +Yeah. His initial one, he +6 didn't get his initial one, so we had to give +7 him a call, his initial call when he came in. +8 +9 +Then while you're in the +10 Special Housing Unit, you're entitled to one +11 call every 30 days. +12 +13 +So, he was entitled to a 30- +14 day phone call. +15 +› And are those normally +16 +monitored, recorded? How do those? +17 +Typically in his case, that +18 he didn't have his +monitor set up, the unit +19 manager stood there and listened to the call. +20 +: Okay. Um -- +21 +And would that be the +22 +Lieutenant? +23 +No. It was the Unit +24 +Manager. +25 +And who would that be? +SDNY _00008008 + + + +114 +1 +That was +2 +3 +4 +So +5 +50r +should +6 have been listening to that phone call? +7 +Right, and from what I +8 understand, +he was listening. +9 +: Okay. Are those phone +10 calls recorded anywhere to ensure just to -- +11 +No, they're not recorded, +12 but we can trace the phone line to get the +13 phone number. +14 +: Okay. +15 +To determine where the call +16 +was made. +17 +: Okay. And in tracing of +18 that to get the phone number, is the length of +19 the call -- +20 +Yes. +21 +22 +-- noted as well? +EMPLOYEE +Yes. +23 +Okay. But in terms of +24 putting that into a system or a monitoring, +25 there's +not a database for that? +SDNY _00008009 + + + +115 +1 +we didn't, because again, he +2 wasn't set up. +3 +Okay. Are you aware of +4 how many phone calls Mr. Epstein's made while +5 in the Special Housing Unit? +6 +I'm not sure. I'm not aware +7 how many made. But I don't, I know he made +8 that one -- +: Um-hum. +10 +-- that day and I'm aware of +11 the initial one, but I don't believe he made +12 that many, because I do believe I saw a +13 correspondence that his attorney made to our +14 +attorney about him getting a phone call. +15 +• Okay. +16 +That he hadn't gotten a +17 phone call. +So, there's some correspondence on +18 +that. +19 +Okay. You got any else on +20 the -- +21 +No. +22 +Okay. +23 +Let's go over real quick +24 +(Indiscernible *01:18:13). +25 +We +covered this a little +SDNY _00008010 + + + +116 +1 earlier. +I just wanted to go over it again. +2 When were you first notified of Mr. Epstein's +3 suicide, or medical, or situation? +4 +About 6:45 -- +5 +6 +- 6:50. +7 +Who did you notify? +8 +I immediately called my boss +9 - +10 +Okay. +11 +- to let him know and then +12 tell him that I was on my way to the +13 institution. +14 +Did you notify anybody +15 else? +16 +Who, me? +17 +Yes. +18 +No. I just, I let him know, +19 +get dressed, get to the institution. +20 +Okay. When you arrived at +21 +the institution, did you speak to any staff +22 there? +23 +When I got there, I saw +24 +obviously the Lieutenant. +Um -- +25 +Which -- +SDNY _00008011 + + + +117 +1 +Lieutenant +2 +Uh, Lieutenant +when he +3 came in and my first, you know, any time you +4 have a suicide attempt, you want to make sure +5 your staff are all right and how they're doing. +6 So, I went to, you know, to check on him to +7 kind of get a debrief on what was going on. +He +8 kind of debriefed me on the situation. +Um +9 +What did Lieutenant +10 tell you? +11 +So, I asked him, so I +12 basically told him what happened, and he said, +13 he talked to Officer Noel and she said we +14 didn't do the 3 o'clock count or the 5 o'clock +15 count. +16 +And then he said he talked to Noel, +17 Officer Noel, +and she said, no he talked to +18 Officer Thomas +and that Officer Thomas said, "I +19 messed up. +We messed up. " Something about it's +20 not her fault. But he said he was just talking +Det way off the back- +Let me back-track a little. I did make +23 one more call, because I couldn't get in +24 contact with Lieutenant +I called up to +25 the Special Housing Unit. +SDNY _00008012 + + + +118 +1 +Okay. +2 +And I believe Ms. Noel +3 picked up the phone, and I asked her, you know, +4 what was going. And she told me what was going +5 on. +But she really couldn't talk. So, then I +6 came, when I got to the institution, I saw her +7 and I said, "Hey, are you all right? +8 everything fine." And she was like okay. +9 +So, I had somebody from our crisis support +10 team that was there talk to her to make sure +11 that she was all right, and then I went to try +12 to find Thomas. She said Thomas had left. +13 +So, I +said, okay, "Left where? Where did +14 he go?" +15 +They said, you know, "He went home. He +16 was distraught." +17 +SOr +then I get another call saying Thomas +18 +was outside, and that he told me, "I'm not +19 answering any questions from you. I want my +20 union", I said Thomas, "I'm not concerned about +21 what happened. I'm concerned about your well- +22 being. +Make sure you're all right. You've +23 been through a traumatic experience" +, and he +24 just kept talking. +25 +SOr +there +was a staff member out there. I +SDNY _00008013 + + + +119 +1 said, try to find him if he's outside. +Sor +2 they went outside and they said, you know, he +3 was gone. +4 +I didn't see Ms. Noel, but I told them to +5 get a memorandum from her on what happened. +6 They told me said she wasn't feeling well and +7 she had to +talk to her Union rep. +8 +So, and I said, "You know what, let them +9 go. +We'll get back with them or somebody will +10 get back with them." And they left. +•And we +11 just started the process of collecting and +12 preserving. +13 +Have Noel or Thomas been +14 +in to work since then? +15 +No. Noel, I sent some +16 support staff on Sunday to go talk to them. +17 Today, +the mother of Thomas' child, she works +18 at the institution but they're not together, +19 said, "Hey, he was with her all weekend but she +20 can't get in contact with him." I sent her and +21 a Lieutenant to go over to his house to find +22 out if he's okay. +He called me a little irate +23 saying, "You know, you're sending people to my +24 house. +You know, I was sleeping." +25 +I said, "I'm checking on your well-being", +SDNY _00008014 + + + +120 +1 you know. And then I didn't know, and I asked +2 him, I said, "Did you call in for work today?" +3 +And he said, "Yes, I did." And he said, +4 "He was sleeping and he was tired." +5 +And I said, "Well I'm just checking on +6 your well-being and just seeing how you are", +7 and I left +it at that. +8 +That was this morning? +That was this morning. +10 +So, he basically called in +11 sick today? +12 +He called in sick today. +13 +She's on days off Monday and Tuesday. +14 +15 +I'm going to assign both of +16 them with no inmate contact, so they're going +17 to be away from inmates and assigned on the +18 outside (Indiscernible *01:23:09). +19 +20 +And then Lieutenant +EMPLOYDE 22 +And then that's basically +21 +22 +what Lieutenant +told me, and I told him, +"Write a memorandum on what was said", and he +23 +wrote the memorandum and he submitted it. +24 +Has he been in to work +25 since Saturday? +SDNY _00008015 + + + +121 +1 +Yes, he did. Actually he +2 stayed there late on Saturday. He basically +3 worked a double, and then he came back and +4 worked during the day on it. +50r +he hasn't +5 taken any time off. +6 +7 +Is he there now? +He's there. +He's there +8 today, so he's working here. +9 +: And -- +10 +Oh, and I do have an +11 addition. And I did ask him, you know, when he +12 got there what happened, and he says, he +13 doesn't know what the condition was because +14 when Thomas called for the emergency medical, +15 he opened the door and took him down himself +16 and started life-saving measures. +17 +: So, Epstein was hanging +18 from +the door? +19 +We don't know what he was +20 doing because Thomas was the first one there, +21 +and when responding staff came, he was already +22 there doing compressions and life-saving +measures. +SOr +I definitively can't say where, +24 was he hanging? What position he was or not +25 because nobody knows when they responded, so. +SONY _00008016 + + + +122 +1 +What is the policy +2 regarding if an Officer or staff member sees an +3 inmate in that situation? +4 +Okay. And I won't want to +5 quote this is a policy thing, but you call for +6 assistance and you wait for assistance to come +7 because you don't know if that's a ploy. +So, +8 if you go in there as one person, and you know, +9 when somebody's hanging, that's dead. That is +10 dead weight. +11 +So, you go in there, you don't know if +12 it's a ploy. +So, you go in there and get +13 overpowered, guess what? Now that individual +14 has the cell door keys for every key on that +15 range, and that could be a recipe for disaster. +16 +So, +it might sound inhumane that, you +17 know, +we have to wait because the individual on +18 the grill can't come down range either because +19 if they get overpowered, guess what, we've lost +20 a whole unit. And that's the most secure unit +21 in the institution. +So, she has to stay outside with the keys +23 on the grill because there are two different +24 keys. +They don't mix. And we wait for +25 responding staff to come in and perform, you +SDNY _00008017 + + + +123 +1 know, the life-saving measures without +2 endangering your safety. +3 +So, he went in and, you know, so again, +4 there's no idea of what the cell looked like, +5 what his position was, or anything. +6 +Captain +and Captain +7 +8 +9 +, are they at work now? +Captain — +I think. +10 +His secretary is +11 +okay. 1 +12 +Yeah. +13 +That may be a mistake. +14 +LEMPLOYEE 22 +Yeah. +15 +So, Captain +was +the +16 +Captain on Friday; right? +17 +18 +19 +Yes. +And I need to, and I'm not +20 sure if he was at work either. I think he +21 might've been off. But +is his +22 +secretary. +23 +okay. And +24 Lieutenant is it +25 +was the +SDNY_00008018 + + + +124 +1 midnight +Lieutenant. +2 +Okay. And he, she? +3 +She worked, apparently she +4 worked at night and +relieved her early. +5 +Okay. +6 +At 5:33, but then I heard +7 she came back and then +left again. So, I don't +8 know, I believe she went up to the unit. +9 +Has she been at work since +10 then? +11 +I believe she's on days off. +12 +13 +EMPLOTEE 22 +So, +she'll be back tonight. +14 +Okay. Do you want to step +15 out for a minute? +16 +Actually before -- +17 +Unless you have anything +18 +(Indiscernible *01:27:13). +19 +Just a few -- +20 +Okay. +21 +-- if I can jump back a +22 +little bit. +23 +24 +Specifically go back to, +25 did you have any one-on-one interactions with +SDNY _00008019 + + + +125 +1 Epstein? +2 +Let's see, I had one, I saw +3 him by the attorney visit, small conversation. +4 Another one I saw him when I was making rounds +5 on the unit when he had first gotten into the +6 cell with Reyes. +He was going into the shower. +7 I asked him, "How was everything going." +He +8 said, "I'm good. I'm fine." +9 +And then Reyes, I said, "How's he doing?" +10 Reyes was like, "I +want to go back to a unit." +11 +So, you know, was just that type of +12 conversation while making rounds. +13 +Okay. Thank you. +14 +15 +• And did you want just step +16 +outside? +17 +Huh? +18 +: Do you mind if we just take a +19 +step out? +20 +No, I have no problem. +It is 12:23. +We're +22 pausing the interview. +23 +We're resuming the interview at this time. +24 +It is 12:29 in the afternoon. +25 +So, the first +SDNY_00008020 + + + +126 +1 question is, I just want to make sure we have +2 the name right. +3 +EMPLOYEE ZZ +4 +The Lieutenant or the +5 Captain that you told that Epstein should have +6 a cellmate? +7 +Well, it was +Captain +8 +9 +, okay. +10 +EMPLOYEE LOYEB22 +Yeah. +11 +: Okay. And I know you're +12 probably already doing this, but we just wanted +13 to make sure you're preserving all of the +14 emails that you referenced, any text messages +15 that you've sent about this, any communications +16 that you've had at all. +17 +Well when I had gave the +18 direction, +it was given verbally in a meeting. +19 +20 +_: Um-hum. +I didn't send emails out. I +21 +had a direct conversation. +22 +23 +So, it was everyone in the +24 +room. +So -- +25 +Okay. But for instance, +SDNY _00008021 + + + +127 +1 the email that you sent listing here are the +2 three possibilities for +3 +oh, yes. +4 +-- who's +-- +5 +All of that -- +6 +-- the best. All of that. +7 +Yeah. If you want that -- +8 +-- you're preserving. +9 +-- that's there. It's +10 preserved. +11 +Okay. +12 +I'm sure this will +13 inevitably happen, +and it's +report for this. +14 Has that already been drafted? Is that a +15 process? +16 +For? +17 +Will there be an incident +18 report regarding the discovery of Jeffrey +19 Epstein's body? +20 +EMPLOYDE 22 +It's called a report of +21 +incident, a 583. +So, we did that today. +22 +Okay. +23 +EMPLOYEE +22 +You know -- +24 +25 +-- just a brief statement on +SDNY _00008022 + + + +128 +1 what happened, the times -- +2 +Okay. +3 +- and moving forward with +4 that. +5 +Do you know who drafted +6 that? +7 +The SIS Lieutenant does it. +8 +9 +EMPLOYEE 22 And then I review it because +10 it's ultimately sent from me. +It's a report of +11 +incident -- +12 +: Um-hum. +13 +-- to our central office. +14 +So, I 1ook at it, the synopsis. +15 +: Okay. +16 +Just for terminology to make +17 +sure it's accurate. And it's just a brief +18 statement saying that, you know, he made +19 rounds. +20 +21 +He was unresponsive. Life- +22 +saving measures were initiated. Taken to the +23 +outside hospital and then he was pronounced +24 +deceased at that time. And then we just move +25 on from there. +SDNY _00008023 + + + +129 +1 +Just a couple of more -- +2 +3 +-- housekeeping stuff just +4 to say, +have you had any contact with the press +5 regarding this? +6 +No, I have not. +7 +Has any press +contacted +8 you directly? +No, they have not. +10 +Have you directed any +11 +staff to destroy anything? +12 +No, I have not. +13 +What directions have you +14 +given the staff in terms of preserving things? +15 +So, initially when we came, +16 when I got in, +I told the Captain, get all the +17 log books up there, the rounds, anything +18 pertaining to get it and anything we can think +19 of that might be needed. And it's given to the +20 +SIS. +It's in the SIS office with the SIS +21 Lieutenant. +22 +So, told them to preserve it, and whoever +23 needed it, I know the IG has come by. They've +24 taken some stuff. But basically preserve +25 everything that might be needed to be +SDNY _00008024 + + + +130 +1 preserved. +And then if any requests come, you +2 know, we'll go and get it and preserve it. +3 +Are you -- +4 +Can I just +ask one quick +5 question about the log books? +6 +Yeah. +7 +Actually while she's +8 looking at it - +Yeah. +10 +-- do you mind? +11 +This is -- +12 +Are you aware of any +13 objects missing from his +cell? Are you aware +14 of anything peculiar occurring since his +15 suicide? Since his body was discovered? +16 +You mean missing from his +17 +cell? +18 +19 +Yes. +I didn't observe the cell, +20 so I don't know what's in -- +21 +Were you ever notified of +22 +any, after his body was discovered, have you +23 been notified of any peculiarities or anything +24 that stuck out in your mind as odd? +25 +As far as what would've been +SDNY _00008025 + + + +131 +1 in his cell, or? +2 +Anything in general as it +3 relates to him? +4 +Not that I can think of. I +5 mean, it's just documents that we're still +6 trying to gather - +7 +Sure. +8 +-- and locate, but -- +9 +It's nothing odd because I +¡ERIAL +10 don't know what happened in that cell. +11 +12 +So, I don't know what +13 +would be -- +14 +15 +-- considered odd. Were +16 you aware of him having any contraband in his +17 +cell? +18 +Contraband? +19 +Anything -- +20 +Wel1 -- +21 +-- he wasn't supposed to +22 +have? +Any unapproved things in his cell? +23 +EMPLOYEE +22 +No. +24 +25 +I mean, he would've received +SDNY _00008026 + + + +132 +1 an incident report. +2 +Okay. +3 +And the only incident report +4 he had was, I guess it was the cloth that was +5 found on the initial one, but then our +6 Disciplinary Hearing Officer concluded that we +7 couldn't' +sustain any charges on him because +it +8 was inconclusive -- +: okay. +10 +- with it, but that's - +11 +: Okay. And were you aware +12 of him having any enemies or anything, or being +13 a specific target by anybody? +14 +Where? +15 +• In the institution? +16 +No. I mean no one's came to +17 me specifically saying, you know, "He's my +18 enemy", or all that, so I don't, you know. +19 +: Was he not to be, not to +20 be celled with anybody because of any problems +21 +that he would have, or -- +22 +I mean. +23 +Let me rephrase that a +24 little. +were you aware of any other inmates +25 who had targeted him specifically? +SDNY _00008027 + + + +133 +1 +No. +2 +3 +4 +The 1og books -- +5 +6 +-- just for the record, +7 I'm showing a log book Tier G dated 08/10/2019. +8 +EMPLOYEE 221 +9 +So, this is filled out by +10 a Corrections Officer -- +11 +12 +-- who's doing the checks +13 -- +14 +15 +-- every 30 minutes. +16 +17 +Correct? +18 +Yes. +19 +And they're supposed to +20 +write the time they start and end and then +21 +initial it? +22 +Who did it. +23 +And then the Operations +24 Lieutenant signs it at the end of the shift. +25 +The shift that they reviewed +SONY _00008028 + + + +134 +1 it. +2 +Okay. +Okay. +3 +This is not complete for the +4 simple fact that, you know, with the emergency +5 coming, I had them take it and preserve +.it. +6 So, it was part of the preservation. +S0r +7 that's probably why it doesn't go all the way +8 up to 8 o'clock. +Got it. +10 +Because as soon as I came +11 in, I told the Lieutenant grab the 30-minute +12 checks. +13 +And is this a signature or +14 a circle for a signature? +15 +That's a signature. +16 +Okay. +17 +Whoever was in, and I +18 believe, and I'm not sure, but if it was the +19 morning watch Lieutenant, it would be +20 Lieutenant +21 +22 +EMPLOYEE +Yeah. +23 +I think that's all the +24 +questions that we have. +25 +Great. +That's it. The +SDNY _00008029 + + + +135 +1 time is now 12:35. +Warden, we really +2 appreciate your time. +3 +Okay. +4 +And the interview is +5 completed, oh actually before we do that. Is +6 there anything that you would like to tell us? +7 Any statements that you would like to +make? +8 Anything you think we should know about the +9 incident in general? Just wanted to give you +10 an opportunity if there's anything that you +11 think we should know that we haven't discussed. +12 +I can't think of anything +13 else. +But I mean, as it comes along, I'll pass +14 it on to the IG. Anything I get or any +15 information. +16 +Thank you. +17 +Okay. +18 +19 +20 +PRO +23 +24 +25 +SDNY_00008030 + + + +136 +CERTIFICATE +I hereby certify that the foregoing pages +represent an accurate transcript of the +electronic sound recording of the proceedings +before the Department of Justice, Office of the +Inspector General in the matter of: +Interview of +PROTECTE +SDNY_00008031 + + + +A +Ability - 71:23, +80:25, 81:2 +Able - 15:13, 17:19, +108:10 +Above - 72:14 +Accordingly - 34:18 +Account - 111:23, +112:3, 112:15 +Accountability - 40: +20 +Accurate - 128:17 +Act - 49:15 +Acting - 44:18, +57:20, 57:22, 64:25, +65:2, 69:7, 88:15 +Action - 29:21 +Active - 65:7, 76:3 +Actively - 86:7 +Actual - 49:15, +71:12, 71:13 +Addition - 121:11 +Advance - 77:11 +Advanced - 77:6 +Affairs - 5:23 +Affirm - 4:21, 4:23 +Afforded - 111:25 +Afternoon - 125:24 +Age - 73:15 +Agencies - 107:2 +Agent - 3:10, 3:12, +5:19 +Agents - 15:24 +Agree - 33:25 +Agreed - 14:3 +Ahead - 14:20, +77:15, 101:12 +Allowed - 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64:8, 66:6, +66:22, 72:7, 116:8 +Both - 49:20, +120:15 +Breaking - 105:23 +Brief - 51:18, 72:5, +127:25, 128:17 +Briefed - 19:11, +46:9,46:10, 53:4, +72:18, 72:19, 87:21 +Brought - 8:7, 8:10, +8:17, 18:2, 50:6 +Building - 105:10, +105:11 +Built - 105:11 +Bullock - 114:1, +114:2, 114:5 +Bunch - 17:18, +92:18 +Bunkie - 90:3 +Bureau - 3:15 +Business - 10:2, +100:4, 103:24 +Calendar - 54:23 +Called - 11:9, 54:11, +54:13, 57:6, 64:2, +64:8, 66:5, 76:23, +79:11, 79:12, 83:3, +96:16, 116:8, +117:24, 119:22, +120:10, 120:12, +121:14, 127:20 +Calling - 65:14, +Calls - 111:15, +111:19, 113:1, 113:4, +114:10, 115:4 +Camera - 34:12 +34:21, 107:3, 108:4, +108:6, 108:7, 108:9, +108:11, 108:22, +108:25, 109:2, +109:3, 109:10, +109:12 +Cameras - 105:3, +105:8, 105:9, 106:3, +106:9, 106:11, +106:12, 106:14, +106:16, 106:20, +107:13, 107:17, +107:18, 107:23, +108:1, 108:3, +109:18, 110:14, +111:9 +Can't - 63:1, 75:11, +91:23, 92:12, 92:17, +100:7, 101:16, +101:25, 102:1, +104:18, 112:7, +119:20, 121:23, +122:18, 135:12 +Cap - 99:25 +Capable - 74:18 +Captains - 39:22 +Captain's - 69:16 +Care - 46:6, 48:12, +58:4, 73:21 +Career - 5:10 +Carry - 93:25 +Case - 11:2, 47:8, +48:6, 113:17 +Celled - 132:20 +Cellmates - 15:17, +74:6 +Cellphone - 51:1 +Cells - 27:10, 27:11 +Center - 34:17, +34:19, 84:22 +Central - 128:13 +Certain - 15:21, +21:24, 24:6, 56:1, +94:17, 107:7, 111:21 +Chain - 12:14, 39:2, +52:22, 72:5, 72:19, +72:20, 72:21, 83:17, +88:4, 107:9 +Change - 58:17, +65:23 +Charge - 13:1 +Charges - 132:7 +Check - 13:14, 55:1, +107:22, 107:23, +109:4, 117:6 +Checked - 56:13, +73:18 +Checking - 119:25, +120:5 +Checks - 133:12, +134:12 +Chief - 5:22, 28:6, +29:20, 31:5, 31:25, +61:12, 72:11 +Child - 119:17 +Chip - 92:24 +Choose - 103:23 +Cinderblock - 105:1 +2 +Circle - 134:14 +Citation - 50:23 +Clarification - 32:10 +Clarify - 43:21, +63:14, 97:9 +Clarifying - 32:7 +Clinical - 31:22, +31:24, 32:2 +Closely - 47:12 +Cloth - 26:9, 26:10, +132:4 +Clothing - 45:6 +Clyde - 98:25, 99:1 +CMC - 11:11 +Collected - 86:23 +Collecting - 119:11 +Comes - 24:23, +28:25, 29:7, 29:8, +38:9, 43:14, 47:13, +61:4, 71:22, 76:17, +135:13 +SDNY_00008032 + + + +Comfortable - 73:1 +0 +Coming - 7:7, 7:25, +10:22, 20:14, 40:15, +46:22, 59:3, 68:1, +68:8, 80:2, 100:10, +134:5 +Command - 12:14 +Commissary - 95:6 +Commit - 41:6 +Commitment - 9:8 +Communication - 1 +1:22, 14:10, 109:16 +Communications - +108:5, 112:21, +126:15 +Comp - 92:13, +107:24 +Companion - 26:25, +27:7, 27:10, 30:13, +30:14, 30:18, 30:20, +30:25, 31:3, 34:9, +45:17,45:20 +Compensate - 92:2 +1 +Complain - 20:12 +Complete - 134:3 +Completed - 135:5 +Compressions - 12 +1:22 +Concerned - 118:20 +, 118:21 +Concerns - 17:13, +21:12, 23:6, 76:9 +Concluded - 132:6 +Conclusion - 49:14, +62:7 +Condition - 121:13 +Conditions - 55:22, +60:10, 75:7 +Confinement - 60:1 +0 +Confirm - 9:25, 70:5 +Confirmation - 70:1 +2 +Confirmed - 70:7 +Conjunction - 31:1 +3, 104:5 +Consideration - 10: +22, 73:21 +Considerations - 1 +7:13, 20:24 +Considered - 6:12, +131:15 +Constant - 70:21 +Constantly - 71:6 +Consult - 29:20, +47:5 +Consulted - 50:2 +Consulting - 46:20, +74:7 +Contact - 19:17, +19:19, 36:16, 52:19, +57:19, 106:13, +117:24, 119:20, +120:16, 129:4 +Contacted - 79:3, +129:7 +Contraband - 131:1 +6, 131:18 +Contractor - 93:1 +Control - 34:17, +34:19 +Conversation - 33: +16, 55:23, 70:16, +71:5, 79:18, 79:19, +125:3, 125:12, +126:21 +Conversations - 72 +:12 +Convey - 57:24 +Conveyed - 53:4, +53:15, 82:18, 109:16 +Convince - 73:8 +Cooperating - 61:1 +0 +Coordinator - 28:5 +Cope - 15:13 +Coping - 35:13 +Correction - 95:24 +Correctional - 5:17, +62:14, 84:16, 84:25, +85:2, 92:25, 93:4, +93:9,93:15, 93:20, +93:23, 94:7, 94:17 +95:19, 96:15, 97:10 +97:13, 97:22, 97:25 +Corrections - 93:18 +, 98:2, 98:4, 99:18, +107:10, 107:11, +133:10 +Correctly - 63:17 +Correspondence - +115:13, 115:17 +Couldn't - 61:9, +80:17, 117:23, 118:5 +Couldn't' - 132:7 +Count - 117:14, +117:15 +County - 77:16 +Couple - 13:23, +129:1 +Course - 89:8 +Courses - 30:17 +Court - 75:17, 76:8, +76:13, 76:19, 86:13 +Cover - 35:11 +Covered - 20:23, +115:25 +Covers - 26:5 +Criminal - 6:12, +50:20 +Crisis - 118:9 +Currently - 4:9 +Custody - 8:5, 75:6 +D +Daily - 37:6, 38:7, +38:10, 57:5, 71:9, +71:11, 102:5 +- 69:18, +69:19, 69:22, 70:5, +70:25, 98:23, 123:6, +123:15, 126:8, 126:9 +Database - 114:25 +Date - 7:5, 12:10, +13:22, 50:25 +Dated - 89:20, +90:16, 133:7 +Dates - 76:19 +- 3:10, 3:17 +Davis - 99:7 +Days - 65:19, 67:7, +101:14, 102:9, +103:8, 103:14 +103:16, 103:21, +103:23, 103:24 +104:5, 104:7, 104:9, +104:12, 104:14, +104:15, 113:11, +120:13, 124:11 +Daytime - 96:3, +97:19, 112:20 +DC - 5:22 +Dead - 122:9, +122:10 +Dealer - 73:3 +Death - 78:12 +78:21 +Debate - 34:1 +Debrief - 117:7 +Debriefed - 117:8 +Deceased - 128:24 +Decide - 63:13 +Decides - 46:22 +Decision - 29:14, +29:19, 34:1, 34:2, +59:4, 99:19 +Decisions - 46:3 +Deemed - 25:9 +Defibrillator - 79:22 +Definitively - 121:2 +Deliveries - 95:13 +Demisa - 99:9, +99:15 +Denied - 49:4, 49:5 +Departed - 87:1 +Departments - 39:1 +0, 69:1, 96:6 +Department's - 107: +21 +Describe - 44:11 +Designated - 77:9, +77:12 +Despite - 93:2 +Destination - 84:12 +Destroy - 129:11 +Determinate - 45:23 +Determination - 11: +20, 31:19, 46:23 +Determine - 10:25, +11:2, 11:24, 17:16, +18:2,33:17,48:13, +49:14, 53:13, +106:13, 109:5, +114:15 +Determined - 3:5 +Determines - 32:14 +Determining - 29:2 +1,31:10 +Devices - 106:5 +Dictate - 15:22 +Dictated - 19:13, +35:25 +Dictates - 10:10, +36:1 +Difference - 45:8 +Different - 28:13, +39:9, 44:21, 84:15, +84:24, 85:16, 93:3, +93:10, 122:23 +Differently - 19:21 +Directed - 129:10 +Direction - 63:10, +126:18 +Directions - 15:2, +16:7, 16:17, 57:24, +129:13 +Directly - 34:17, +40:15, 129:8 +Director - 12:11, +12:13, 12:19, 13:5, +19:7,19:11, 31:23, +32:2,52:25, 57:16, +57:18, 57:19, 57:23, +62:5, 63:24, 64:3, +67:2, 67:4, 68:7 +Director's - 61:12, +72:11 +Disaster - 122:15 +Discharge - 76:23, +84:22, 85:5, 87:5 +Discharged - 11:7, +77:19 +Disciplinary - 50:23 +, 132:6 +Discipline - 93:15 +Discovered - 130:1 +5, 130:22 +Discovery - 127:18 +Discussing - 56:15 +Discussions - 60:8 +Dismissed - 83:1 +Disoriented - 80:18 +Disseminate - 40:7, +70:17 +Disseminated - 23: +9, 38:16, 70:19, +82:19 +Distraught - 118:16 +District - 18:17 +Divulged - 23:15 +-46:3, +46:21, 99:16, +109:19, 109:21, +111:13 +Doctors - 94:3 +Documentation - 3 +6:11, 36:25, 86:21 +Documenting - 37: +3 +Documents - 131:5 +Doesn't - 47:1, +81:15, 82:9, 83:18, +88:4, 92:7, 121:13, +134:7 +Door - 83:25, +121:15, 121:18, +122:14 +Double - 121:3 +Downgrade - 66:18 +Downgraded - 58:1 +0, 65:25, 66:7 +- 33:5, 33:6, +46:19, 50:1, 53:21, +58:21, 59:7, 60:9, +99:15 +Drafted - 127:14, +128:5 +Dressed - 116:19 +Dropped - 7:10, +7:18, 8:8, 10:3 +Drug - 51:2, 73:3 +DST - 75:21 +Dual - 12:6 +Duties - 94:22 +Duty - 51:18, 51:24, +52:6, 52:8, 52:10, +52:20, 52:21, 88:19, +102:2 +Dvrs - 105:20 +E +Each - 12:18, 69:13 +Earlier - 19:5, 21:1, +30:8,43:21,71:24, +112:9, 116:1 +Early - 81:12, 124:4 +Eight - 101:9, +SDNY _00008033 + + + +101:10, 101:20 +Eligible - 30:18 +Email - 13:11, +13:14, 37:21, 38:2, +38:4, 38:18, 39:7, +39:13, 39:23, 41:16, +42:6,42:9, 61:11, +61:12, 127:1 +Emailed - 61:17 +Emails - 126:14, +126:20 +Emergency - 103:2 +5, 121:14, 134:4 +• - 32:22 +Employee - 92:16, +101:14, 104:8 +Employees - 3:24, +35:9 +Employer - 3:9 +EMS - 80:1 +Encounter - 71:14 +Endangering - 123: +2 +Enemies - 132:12 +Enemy - 132:18 +Ensure - 114:10 +Enters - 11:6 +Entitled - 113:10, +113:13 +Epstein's - 19:23, +73:22, 81:3, 81:11, +115:4, 116:2, 127:19 +Erratic - 44:19 +Escorted - 94:1 +Estimate - 71:9 +Eval - 43:12, 43:16, +43:19, 45:1 +Evaluate - 9:10 +10:14,17:16, 25:6, +28:12 +Evaluated - 27:23, +45:13 +Evaluates - 27:22, +29:7 +Evaluating - 12:2, +32:18, 48:12 +Evaluation - 15:15, +19:4, 45:17, 46:16 +Evening - 41:21, +81:16, 89:17, 98:13 +Everybody - 38:19, +69:15, 71:7 +Everybody's - 11:1 +4 +Everyone - 3:7, +51:14,92:23, 93:1, +94:4,94:11, 96:18, +126:23 +Everything - 28:20, +70:18, 118:8, 125:7, +129:25 +Ex - 17:22 +Example - 16:3, +16:4,23:5, 44:12 +Exams - 56:1, 56:4 +Exceed - 101:16 +Exec - 14:12, 14:15, +68:12 +Exempt - 94:2 +Exhibits - 25:18 +Expectation - 39:20 +, 68:15 +Expectations - 82:3 +Experience - 118:2 +3 +Explain - 25:21, +44:24, 101:18 +Extra - 55:1, 102:25 +F +Facilities - 77:16, +107:25 +Facility - 7:19, 75:2, +76:21, 80:8, 105:3, +108:3 +Factors - 10:21, +73:14 +Failure - 6:11 +Falls - 23:11, 69:8 +Far - 10:1,20:25, +23:1, 23:19, 28:13, +49:14, 66:19, +107:13, 130:25 +Fault - 117:20 +FBI - 3:13 +Federal - 3:15, +104:2 +Feed - 108:10, +108:12, 108:14 +Feel - 46:14, 73:7, +73:9 +Feeling - 73:18, +119:6 +Felt - 59:8 +FEMALE - 18:3, +18:5 +Fight - 52:16 +Figure - 17:4 +Figured - 61:10 +Figuring - 60:17 +Files - 60:2 +Fill - 36:11, 81:2, +91:24,97:20, 100:7, +101:7 +Filled - 37:12, 133:9 +Financial - 102:22 +Find - 7:11, 8:11, +15:5, 23:2, 118:12, +119:1, 119:21 +Fine - 32:6, 56:14, +118:8, 125:8 +Firearms - 93:25 +Fireman - 102:1 +Fitting - 56:11 +Five - 12:15, 104:8 +Fix - 110:20, 110:21 +Fixed - 105:25 +Floor - 25:23, +25:24, 42:19, 58:14, +59:25 +Follow - 7:15, 70:4, +70:21 +Followed - 48:25, +54:14, 70:7, 70:16, +70:23 +Following - 3:2, +47:11, 48:5, 54:17, +63:16 +Food - 95:7 +Foreman - 95:1, +97:4 +Forensic - 28:14 +Forget - 49:13, +73:10 +Form - 3:23, 4:2 +11:10, 30:1, 30:6 +Formal - 8:6 +Forms - 37:12, +37:15, 37:18 +Forward - 6:9, 10:5, +29:22, 128:3 +Found - 8:15, +79:21, 132:5 +Four - 27:10, 32:22, +32:24, 33:1, 33:3, +33:4, 100:16, +100:20, 100:22 +Fraud - 10:24, +10:25 +Frequent - 19:19, +42:9 +Frequently - 77:6 +Friday - 75:4, 76:7, +76:10, 77:18, 88:23, +89:24, 104:1, 104:2, +123:16 +Front - 102:14 +Full - 27:11, 91:17, +108:21 +Fully - 4:11 +Functions - 93:4, +93:23, 95:5 +Fund - 95:14 +Funded - 105:8 +Further - 9:10, +12:12, 25:5 +Furtherance - 3:4 +G +Gang - 10:21, 15:9, +16:3 +Gathered - 86:4 +Gave - 72:24, +126:17 +Generally - 17:10, +17:11 +Gentleman - 61:8 +Gets - 22:24, 38:18, +39:13, 42:6, 53:4, +83:13, 108:20, +108:21 +Give - 13:21, 59:4, +60:15, 89:10, 113:6, +135:9 +Given - 15:2, 20:24, +126:18, 129:14, +129:19 +Glencoe - 94:9, +94:11 +Goal - 11:24 +Gone - 78:19, +84:10, 119:3 +Good - 46:16, +61:10, 74:4, 105:7, +125:8 +Grab - 134:11 +- 90:18, +90:19, 91:1,91:2 +Grill - 122:18, +122:23 +Group - 15:23, +38:17 +Guess - 19:12, +48:2, 122:13, +122:19, 132:4 +Guidance - 102:14 +I - 89:10 +Guys - 18:5, 63:15, +63:17, 91:17, 103:11 +Hadn't - 115:16 +Hand - 4:17 +Handle - 17:12, +28:20, 36:21 +Handler - 94:25, +95:3,97:4 +Handles - 28:18, +99:21 +Hang - 10:15 +Hanging - 121:17, +121:24, 122:9 +Hangs - 26:19, +26:21 +Hard - 15:8 +Harm - 34:15 +Harry - 99:5 +Hasn't - 121:4 +Haven't - 44:15, +135:11 +Head - 106:6 +Health - 21:12, +21:22,22:4,23:22, +24:4, 24:5, 25:8, +29:13, 44:13, 47:17, +47:22 +Heard - 89:23, +124:6 +Hearing - 132:6 +Heart - 49:12 +Heavy - 26:12 +Hereby - 4:20, 4:22 +High - 7:22, 9:8, +17:8, 17:12, 18:1, +19:1, 19:21, 47:9, +50:20, 92:4 +Hire - 92:17 +Hired - 93:7 +Hur: - 91:22, +Hold - 13:16, +105:22 +Home - 118:15 +Honest - 6:11 +Hospital - 25:25, +128:23 +Hour - 34:9, 100:24, +101:1, 101:14, 104:7 +Hours - 26:6, 26:24, +99:25, 100:4, 101:9, +101:10, 101:17, +101:20, 101:22, +101:25, 102:2, +102:10, 104:3 +House - 59:1, +85:20, 119:21, +119:24 +Housed - 15:11, +16:1, 17:5, 51:5, +69:3, 69:11, 74:13 +Housekeeping - 12 +9:3 +How's - 125:9 +Hurt - 44:16 +l'd - 92:4 +Ideations - 25:19, +48:19 +Identifying - 107:6 +IG - 129:23, 135:14 +I'II - 3:7, 4:15, +135:13 +Immediate - 54:3 +Immediately - 110:2 +0,116:8 +Implementing - 30: +25 +Incidents - 52:12 +Inconclusive - 132: +SDNY 00008034 + + + +8 +Individual's - 39:25, +43:6 +Inevitably - 127:13 +Influence - 4:10 +Informed - 69:12, +106:8 +Infraction - 41:7, +41:10 +Infractions - 50:19 +Inhumane - 122:16 +Initial - 44:3, 53:22, +113:5, 113:6, 113:7, +115:11, 132:5, +133:21 +Initially - 7:9, 10:3, +11:23, 15:5, 16:24, +17:3,43:25, 53:24, +53:25, 94:8, 129:15 +Initiate - 54:2 +Initiated - 128:22 +Initiates - 49:23 +Inmates - 9:12, +15:16, 17:10, 17:12, +19:2, 19:22, 22:3, +24:11, 34:10, 43:22, +50:19, 51:5, 60:24, +76:25, 85:7, 95:7, +111:18, 120:17, +132:24 +Inmate's - 15:22, +34:14, 77:9 +Input - 30:23, 45:23, +45:25, 58:7 +Inspector - 3:11 +Installed - 105:8 +Installing - 105:9 +Institutions - 12:25, +13:1 +Instructed - 81:5, +81:22, 87:16 +Instructions - 14:17 +, 15:2 +Intake - 21:9, 24:22, +44:3, 111:20 +Interactions - 124:2 +5 +Internal - 5:23, 6:5, +49:2 +Interview - 3:3, 3:6, +18:7, 18:9, 18:15, +23:21,125:22, +125:23, 135:4 +Interviewed - 49:2, +49:3, 49:20 +Introduction - 51:2 +Investigation - 3:4, +49:2 +Investigations - 6:6 +, 51:1 +Investigative - 5:19, +49:19, 51:3, 51:13, +107:21 +Involvement - 47:1 +8 +Irate - 119:22 +Issue - 16:4, 23:22, +63:2, 92:8 +Issues - 9:15, +10:23, 10:25, 20:14, +21:5, 22:5, 23:8, +23:11, 23:12, 23:25, +24:3, 24:24, 25:1, +25:2, 46:14, 50:20, +56:19, 76:8, 106:4 +l've - 6:2, 100:14 +- 79:13, 79:15, +117:1, 117:2, 117:9, +117:24, 120:19, +120:21, 124:4 +Jeffrey - 6:20, +47:14, 127:18 +- 69:18, +126:8 +Job - 93:3, 103:7 +Joiner - 99:5 +Joining - 18:15 +Judgement - 59:12 +Judgment - 46:17, +59:11, 59:14, 62:14 +July - 53:18, 54:7, +63:18 +Jump - 124:21 +Justice - 3:23, 6:7 +K +Kevin - 61:15 +Key - 122:14 +Keyed - 87:10 +Keys - 122:14, +122:22, 122:24 +Kick - 11:13 +Kill - 29:5, 49:10 +Known - 9:4, 83:16 +Knows - 121:25 +L +Lamine - 3:3, 3:14, +4:18, 4:19 +Lane - 123:24, +123:25 +Late - 121:2 +Later - 16:16, 65:19, +67:7 +Laundry - 95:8 +Leading - 76:6 +Leave - 42:25, 54:8, +57:1, 57:18, 63:20, +64:5 +Leaving - 76:9, +77:3, 77:7, 77:21, +78:6, 78:11, 86:8, +87:15 +Left - 81:15, 89:16, +112:10, 118:12, +118:13, 119:10, +120:7, 124:7 +Length - 114:18 +Let's - 6:14, 16:5, +34:14,41:6,42:24, +52:15, 56:21, 60:9, +71:6, 77:22, 89:1, +92:10, 103:25 +111:15, 115:23, +125:2 +Level - 44:5 +Levels - 91:18 +Lieutenants - 38:19 +, 38:22, 39:22, 70:6, +70:9, 89:22 +Limit - 99:24, +101:13, 102:4, 102:8 +Line - 53:5, 84:12, +114:12, 117:21 +Lines - 45:15, +56:16, 106:1 +List - 38:7, 41:17, +50:17, 55:12,72:5, +72:6,72:23,77:15, +96:11, 96:17, 96:20, +97:11 +Listened - 113:19 +Listening - 114:6, +114:8 +Listing - 127:1 +Locate - 131:8 +Locations - 107:8 +Log - 37:6, 37:8, +129:17, 130:5, +133:4, 133:7 +Long - 5:25, 63:3, +73:19, 75:20, +106:15, 106:19 +L02ger - 31:20, +Look - 9:25, 35:14, +39:2, 50:25, 54:23, +75:12, 88:25, 92:4, +97:20, 106:13, +128:14 +Looked - 75:15, +123:4 +Looking - 8:16, +12:3, 130:8 +Lost - 122:19 +Lot - 6:5, 28:14, +96:5, 105:10, 105:13 +Low - 92:3 +Luxury - 100:6 +M +Machine - 56:7 +Major - 24:9 +Majority - 93:7, 93:9 +Making - 63:16, +69:14, 76:3, 91:12, +125:4, 125:12 +Male - 15:13 +Manager - 107:25, +113:19, 113:24 +Managers - 51:12 +Mandated - 96:23, +96:25, 97:3,97:11, +99:18, 104:1 +Mandation - 96:16, +96:20 +Many - 70:24, 74:2, +101:14, 102:9, +115:4, 115:7, 115:12 +Marshalls - 77:12 +Material - 94:25, +95:2, 97:4 +MCC - 17:7, 22:4, +25:22, 35:24, 39:15 +47:19, 74:23, 75:23, +75:24, 76:9, 77:4, +77:6, 78:11, 91:15 +Means - 44:25, +50:23 +Meant - 106:24 +Measures - 79:2, +80:4, 121:16, +121:23, 123:1, +128:22 +Medical - 7:14, +22:5, 22:7, 22:23, +23:6, 23:11, 24:2, +24:14, 29:12, 32:9, +32:10, 37:20, 46:2, +46:6, 59:11, 60:2, +116:3, 121:14 +Medically - 21:21 +Medications - 21:25 +, 24:6 +Meeting - 8:19, +51:19,51:25, 52:7, +53:10, 53:11, 53:19, +54:6,55:4,55:9, +55:10, 68:18, 68:20, +69:24, 126:18 +Meetings - 14:16, +50:5, 50:16, 51:10, +53:4 +Member - 10:22, +28:25, 36:7, 118:25, +122:2 +Members - 15:10, +16:3 +Мето - 90:16, 91:4, +91:6 +Memorandum - 89: +9, 89:12, 119:5, +120:22, 120:23 +Memory - 108:20 +Mental - 21:12, +22:4,23:21, 24:3, +24:4,24:5,25:8, +29:13, 44:13, 46:14, +47:16, 47:22 +Mentally - 44:13 +Messages - 126:14 +Messed - 117:19 +Michael - 94:24, +99:7, 99:13 +Midnight - 124:1 +Might've - 9:21, +10:24, 48:23, 66:5, +73:11, 84:10, 98:9, +123:21 +- 31:7, 31:9, +33:5, 33:6, 46:19, +50:2, 53:21, 58:21, +59:7, 60:9 +Mindful - 69:14 +Minimum - 71:20, +100:10 +Missing - 130:13, +130:16 +Mission - 28:13, +28:14 +Mistake - 123:13 +Mix - 122:24 +Monday - 3:1, 7:11, +8:11,8:12, 8:18, +10:2, 21:2, 22:16, +54:22, 55:1, 120:13 +Money - 102:25 +Monitor - 113:18 +Monitored - 26:24, +113:16 +Monitoring - 114:24 +Morning - 8:19, +41:21, 42:1, 81:12, +81:15, 89:13, 89:14, +89:22, 120:8, 120:9, +134:19 +Mother - 119:17 +Move - 27:11, +29:22, 74:11, 74:12 +83:17, 93:13, 128:24 +Moved - 5:14, +65:24, 66:24, 69:22, +70:1, 70:13 +Moves - 52:22 +Movies - 26:12 +Moving - 6:9, 27:17, +67:20, 128:3 +SDNY_00008035 + + + +Much - 42:25, 43:1, +57:11, 58:7, 80:2 +N +Narcotics - 44:18 +Nathan - 3:17 +Nathaniel - 114:2 +Nay - 34:4 +Needed - 19:14, +21:6, 59:5, 62:2 +81:22, 89:17, 90:3, +129:19, 129:23, +129:25 +New - 9:7, 18:17, +38:9, 105:8, 105:11 +News - 8:4, 8:16 +Night - 81:14, +95:15, 97:1, 124:4 +Nobody - 40:5, +121:25 +Noel - 97:23, +117:13, 117:16, +117:17, 118:2, +119:4, 119:13, +119:15 +Normal - 7:14, 7:20, +106:10 +Normally - 17:11, +113:15 +Northeast - 12:21 +Note - 6:10 +Noted - 114:21 +Notes - 36:25 +Notice - 8:6, 12:12, +77:6 +Notification - 21:12, +27:16, 37:20, 39:25, +40:3, 52:21, 77:2, +82:22, 107:10, +110:3, 110:7 +Notifications - 52:1 +2, 52:23, 52:24, +54:16, 110:14 +Notifies - 107:11 +Notify - 14:8, 19:14, +40:24, 64:6, 64:15, +66:3, 67:12, 68:7, +81:22, 82:10, 83:17, +88:4, 107:24, 116:7, +116:14 +Notifying - 66:17, +68:1 +Objections - 72:23 +Objects - 130:13 +Obs - 45:19, 58:19 +Observation - 30:3, +44:8,44:15, 44:21, +45:2, 45:4,45:24, +45:25, 58:11, 58:12, +65:20, 66:1, 67:8 +Observations - 53: +22 +Observe - 27:6, +52:10, 130:19 +Observed - 86:7, +87:15 +Observer - 30:9, +30:12 +Observing - 45:6 +Occur - 22:11 +Occurred - 16:15, +19:6 +Occurring - 130:14 +Odd - 130:24, +131:9, 131:15 +Offender - 61:2 +Offense - 6:12 +Office - 3:11, 5:19, +15:24, 50:20, 54:21, +72:11, 128:13, +129:20 +Officers - 51:18, +51:25, 52:6, 53:5, +82:19, 83:2, 83:4, +83:8, 84:16, 85:22, +86:5, 87:13, 93:10, +93:18, 95:21, 97:10, +107:11 +Offices - 12:16, +69:13, 74:10, 89:15 +Officially - 8:13, +13:19 +Often - 19:10, +19:20, 19:22, 77:5, +95:24 +OIG - 3:4, 3:23 +Old - 73:3 +Older - 61:8 +Ones - 37:20, +61:21, 83:5, 94:2, +105:22 +One's - 132:16 +Opened - 121:15 +Operating - 107:16 +Operation - 42:5 +Operations - 79:16, +88:18, 88:19, 133:23 +Options - 73:25, +74:4 +Oral - 110:6 +Orally - 46:11, +46:12 +Order - 112:6 +Orders - 87:16 +Originally - 60:21, +75:16 +- 13:7, +13:8, 13:10, 13:19, +14:2, 67:6 +Outcome - 51:19 +Outdated - 105:15 +Overpowered - 122 +:13, 122:19 +Overrule - 33:9, +33:17,46:2 +Overtime - 96:4, +96:5, 96:6, 96:7, +97:15, 97:17, 98:6, +99:19, 99:23, 99:24, +100:24, 101:8, +102:17, 104:25 +Overtimes - 100:22 +Own - 74:7, 74:11 +P +Pack - 83:21 +Packed - 83:11, +83:13, 83:20, 86:8 +Packing - 84:15, +85:23 +Paperwork - 36:10 +Participated - 86:7 +Pass - 62:21, +135:13 +Past - 90:23 +Patrolling - 53:6 +Paused - 18:8 +Pausing - 18:7, +125:22 +Peculiar - 130:14 +Peculiarities - 130: +23 +Pending - 51:1 +People - 11:10 +23:7, 27:16, 37:4, +43:22, 68:25, 85:16, +92:11, 92:18, 94:19, +100:9, 100:16, +101:4, 102:16, +112:21, 119:23 +People's - 102:22 +Percentage - 92:1 +- 61:1, 90:8, +91:4 +Perform - 44:1, +93:3, 93:22, 122:25 +Performing - 80:4 +Period - 108:20 +Periodically - 106:2 +1 +Person - 11:15, +39:12, 40:23, 122:8 +Person's - 40:4 +- 61:24 +- 61:15, +61:25, 62:1 +Phone - 13:12, +17:20, 34:13, 34:16, +80:7, 111:15, 111:19, +113:1, 113:4, +113:14, 114:6, +114:9, 114:12 +114:13, 114:18, +115:4, 115:14, +115:17, 118:3 +Physicals - 56:5 +Pick - 34:15 +Picked - 118:3 +Picking - 73:21, +77:13 +Pickings - 60:18 +Place - 27:15, 29:1, +36:7, 36:14, 36:15, +72:14, 77:23 +Places - 107:1 +Placing - 28:22, +28:24 +Plan - 29:8, 29:21, +31:18, 45:13, 47:12, +67:18, 70:1, 77:23 +Ploy - 122:7, 122:12 +Policies - 6:15, +10:9, 11:5, 20:17, +25:12, 27:14, 99:23 +111:18 +Policy - 10:9, 24:11, +35:25, 36:1, 36:3, +42:4, 62:10, 62:13, +64:12, 64:13, 122:1, +122:5 +Poor - 105:17 +Populate - 10:18, +24:25 +Position - 5:24, +32:3, 121:24, 123:5 +Positions - 93:8, +93:11, 101:7 +Possibilities - 127: +2 +Possibles - 72:24 +Post - 96:23, 98:21, +100:7, 100:8 +Posts - 91:23, 97:20 +Potential - 44:16 +Precautions - 42:23 +Present - 3:6, 5:23, +51:25, 55:6 +Preservation - 134: +6 +Preserve - 129:22, +129:24, 130:2, 134:5 +Preserved - 127:10, +130:1 +Preserving - 119:12 +, 126:13, 127:8, +129:14 +Presidents - 17:22 +Press - 129:4, 129:7 +Prevent - 4:11 +Prevention - 35:3, +35:12, 35:21 +Previous - 103:6 +Prior - 76:2 +Prison - 6:6, 6:16, +35:19, 43:14, 43:23, +100:4 +Prisons - 3:15 +Privacy - 23:12 +Probability - 76:20 +Problem - 61:4, +92:14, 106:14, +108:1, 109:17, +112:16, 125:20 +Problems - 109:9, +132:20 +Procedure -42:5, +106:11 +Procedures - 7:15, +33:13 +Proceedings - 76:8, +76:13 +Processed - 8:9, +77:1 +Processing - 95:9 +Profession - 33:19 +Professionals - 29: +19,94:4 +Profile - 7:22, 9:8, +17:8, 17:12, 18:1, +19:2, 19:21, 47:9, +50:21 +Program - 28:4, +30:15, 30:25, 31:3, +47:17, 47:23 +Promoted - 5:17, +5:20, 93:10 +Pronounced - 128: +23 +Property - 43:6, +84:10, 84:17, 86:2 +Protocol - 48:13, +70:3, 71:17 +Protocols - 48:25, +54:14, 70:23 +Provide - 3:25 +Psyche - 30:3, +43:12, 43:16, 44:8, +44:14,45:1,45:3, +45:16, 45:19, 58:10, +58:12, 58:18, 65:20 +Psychological - 22: +24, 23:7, 23:19, +43:12, 43:19, 45:24, +55:19, 66:1 +Psychologically - 4 +3:24 +Psychologist - 22:1 +SDNY_00008036 + + + +4,22:16, 22:18, +25:9, 25:13, 25:17, +28:4,28:6, 28:18, +31:6, 31:17, 31:25, +33:10,45:9, 47:19, +59:9, 99:11 +Psychologists - 23: +20, 28:10, 29:16, +32:23, 32:25, 46:17, +94:4 +Psychologist's - 59 +:22 +Psychology's - 58: +3 +Push - 82:10 +Puts - 38:5 +Putting - 13:16, +45:4, 61:6, 114:24 +Q +Qualify - 93:5, +94:16 +Quality - 105:17, +107:1 +Quarterly - 35:21, +36:2, 98:21 +Quick - 115:23, +130:4 +Quote - 29:15, 39:1, +108:18, 122:5 +R +Raise - 4:16 +Range - 122:15, +122:18 +Ranks - 5:15 +- 3:12, 17:23, +115:23, 125:18 +Ray - 13:7, 13:8, +67:6 +Re - 94:16, 108:21 +Ready - 9:11, 10:14, +28:2, 37:16, 45:13, +59:10, 59:13, 59:18, +59:19 +Realize - 8:11 +Realized - 82:25 +Reason - 4:11 +Reasoning - 33:23 +Reasons - 7:3 +Rebekah - 18:17, +18:23 +Recap - 87:11 +Receipts - 87:5 +Receive - 94:7 +Received - 62:6, +131:25 +Receiving - 57:4, +76:23, 84:22, 85:5, +87:5 +Recipe - 122:15 +Recognition - 112:6 +Recorded - 113:16, +114:10, 114:11 +Recording - 105:18, +105:19, 105:24, +106:5, 107:24, +108:1, 108:13 +108:15, 108:21 +Recordings - 105:2 +3, 108:17, 109:5 +Referenced - 126:1 +4 +Referral - 36:19 +Refresher - 93:12, +94:15 +Region - 12:18, +12:22, 52:13, 52:14, +65:11, 65:14 +Regular - 28:17, +45:6, 98:6, 98:10, +98:12 +Regulations - 111:1 +7 +Release - 11:9, +46:25, 50:25 +Released - 37:17, +37:25, 38:13, 40:11, +42:3, 45:14, 53:14, +53:16, 63:8, 75:1, +75:3, 75:6, 76:20 +Releasing - 73:12 +Reliability - 105:6 +Reliable - 105:17 +Relieved - 124:4 +Reminding - 71:6 +Remove - 32:14, +33:1, 33:2, 92:15 +Removed - 37:13, +37:16, 38:3, 38:6, +40:1, 42:16, 43:4, +43:6, 65:19, 67:8, +67:14 +Removing - 31:11, +32:11 +Rep - 119:7 +Report - 41:8, +49:18, 49:20, 52:11, +127:13, 127:18 +127:20, 128:10, +132:1, 132:3 +Reports - 8:16, +37:12, 37:15, 59:22, +86:22 +Request - 3:25 +Requesting - 56:8 +Requests - 130:1 +Require - 100:8 +Required - 16:13, +35:7, 103:20 +Requirements - 44: +25 +Resolved - 41:11 +Respect - 55:15 +Respond - 34:17 +Responded - 121:2 +5 +Responding - 121:2 +1, 122:25 +Response - 27:16 +Responsibilities - 6 +4:12, 85:17 +Responsibility - 64: +13, 69:2, 84:24 +95:20, 95:25, 99:14 +Responsible - 28:2 +2, 31:10, 31:23, +32:11, 37:3, 53:5, +85:23 +Result - 24:17 +Results - 22:21 +Resuming - 18:9, +125:23 +Reviewed - 3:22, +11:14, 48:2, 49:19, +133:25 +Reviewing - 107:18 +Reyes' - 73:15 +81:3, 83:19, 84:15, +84:17, 85:24, 86:7, +86:22, 87:15 +- 88:12, 88:13, +88:14 +Road - 91:16 +Role - 6:5, 12:6, +28:3 +Room - 18:16, +20:13, 20:15, 78:4, +84:10, 86:2, 108:2, +108:4, 108:5, +108:10, 109:3, +112:17, 126:24 +Roommate - 15:6, +67:23, 68:5, 73:22 +Roommates - 72:4 +Roster - 88:25 +Rounds - 52:9, +69:14, 71:14, 71:19, +88:20, 125:4, +125:12, 128:19, +129:17 +Routed - 11:9 +Routine - 81:11 +Row - 102:9, 103:8 +Rules - 99:22 +Run - 110:19 +Runs - 28:6, 30:22 +S +Safe - 100:10 +Safety - 25:2, 63:2, +123:2 +Samantha - 99:9 +Sams - 51:4 +Sanctioned - 50:24 +Saturday - 111:1, +120:25, 121:2 +Saving - 79:1, 80:4, +121:16, 121:22, +123:1, 128:22 +Saw - 8:3, 115:12, +116:23, 118:6, +125:2, 125:4 +Scene - 79:9 +Scott - 65:6,79:5, +79:6 +Screen -22:15, +22:19, 22:23, 109:6, +109:9 +Screened - 22:4, +22:7 +Screening - 7:14, +21:9,24:13, 24:15, +24:22, 25:8, 44:4, +111:20 +Screenings - 22:21, +22:24, 24:18 +Screens - 22:8 +Second - 25:23, +42:19, 58:14, 59:25, +73:17 +Secretary - 123:10, +123:22 +Secure - 122:20 +Security - 56:13 +See - 9:14, 10:14, +26:11, 39:4, 107:5, +108:3, 108:10, +108:14, 109:3, +119:4, 125:2 +Seeing - 120:6 +Sees - 122:2 +Selecting - 30:24 +Sending - 119:23 +Sends - 41:17 +Sent - 17:21, 38:18, +39:8, 42:6, 61:11, +61:12, 62:4, 72:7, +72:10, 89:9, 119:15, +119:20, 126:15, +127:1, 128:10 +Sentry - 75:12, 87:9 +Separate - 16:5, +32:3 +Separated - 15:25, +62:24, 73:5, 74:15 +Separation - 9:15, +10:23, 15:23, 24:24, +74:14 +Service - 21:23 +Services - 97:22 +Set - 100:13, +111:23, 112:3, 112:6, +112:15, 112:24, +113:18, 115:2 +Several - 11:10, +95:5 +Sex - 61:2 +Shall - 5:3, 5:5 +She'll - 124:13 +She's - 31:23, +31:24, 31:25, 33:17, +33:18, 98:2, 98:17, +120:13, 124:11, +130:7 +Shift - 8:9, 69:13, +98:7,98:12,99:20, +100:25, 101:1, +101:8, 107:12 +133:24, 133:25 +Ship - 84:12 +Shirley - 65:6 +Shop - 95:7, 107:24 +Should've - 7:24, +55:3, 82:21, 83:2, +83:16 +Show - 87:8 +Showed - 75:16 +Shower - 125:6 +Showing - 75:20, +86:25, 133:7 +Sick - 120:11, +120:12 +Sign - 11:10, 11:13, +49:25, 102:16 +Signature - 134:13, +134:14, 134:15 +Signed - 3:23, 97:6 +Signs - 35:12, +35:14, 133:24 +Simple - 134:4 +Siock - 17:19 +SIS - 108:2, 109:4, +109:15, 128:7, +129:20 +Sit - 27:5 +Sitting - 26:25, +49:11 +Situation - 19:12, +19:23, 62:23, 63:7 +116:3, 117:8, 122:3 +Situations - 15:21, +102:22, 111:21 +Skipper - 65:6, +79:5, 79:6 +Sleep - 56:7 +Sleeping - 119:24, +120:4 +SDNY_00008037 + + + +Slim - 60:18 +Small - 125:3 +Smock - 26:3, 26:7, +45:5 +Solemnly - 4:20, +4:22 +Somebody's - 7:22, +38:3, 74:14, 77:15, +122:9 +Someone's - 29:24, +45:23 +Sound - 62:14, +122:16 +Southern - 18:17 +Sp - 13:7, 17:20, +31:8, 51:5, 61:16, +65:6,90:18, 97:24, +99:10, 109:20, 114:2 +Space - 42:25, 43:1 +Specialized - 94:14 +Specific - 7:5, +14:17, 15:2, 16:17, +19:16, 34:24, 35:17, +37:12, 71:18, 94:19, +132:13 +Specifics - 54:12, +103:3 +Spell - 3:7, 18:21 +Spelling - 3:15 +Spent - 20:7 +Spot - 81:3 +Staffed - 92:11 +Staffing - 89:2, +91:15, 91:18, 92:1, +92:5, 100:15 +Standard - 15:16, +42:5 +Start - 6:16, 14:23, +60:9, 80:6, 133:20 +Started - 5:11, 5:16, +80:15, 80:19, 81:10, +119:11, 121:16 +Starting - 91:21 +Starts - 108:21 +State - 92:24 +Statement - 127:25, +128:18 +Statements - 4:16, +4:24, 5:1,25:19, +49:21, 135:7 +Stating - 30:2, 38:5, +42:3 +Status - 9:10 +45:25, 50:22, 53:12, +55:12, 55:19, 92:13 +Stay - 14:9, 104:20, +122:22 +Stayed - 121:2 +Staying - 15:5 +Step - 18:5, 44:11, +124:14, 125:15, +125:19 +Stood - 113:19 +Stop - 45:10 +Stored - 84:18 +Straight - 41:14 +Stranger - 17:8 +Street - 93:8 +Stringent - 44:22 +Stuck - 130:24 +Studies - 28:15 +Stuff's - 107:23 +Submitted - 120:23 +Substances - 4:10 +Suggested - 91:3 +Suggestions - 72:1 +9 +Suicidal - 25:9, +25:11, 25:14, 25:18, +29:1,48:16, 48:18, +48:19,58:25, 59:8, +59:12, 59:19 +Sunday - 119:16 +Supervises - 12:25 +Supervisor - 13:4, +13:5, 33:18, 67:18, +88:16, 103:7 +Supervisors - 33:4, +38:21, 39:21 +Support - 118:9, +119:16 +Supposed - 39:23, +40:6, 40:7, 40:8 +52:9, 64:14, 87:21, +131:21, 133:19 +Sustain - 132:7 +Swear -4:15, 4:20, +4:22 +Synopsis - 128:14 +System - 87:3 +105:15, 114:24 +Systems - 108:22 +T +Taking - 10:22, +20:12, 22:2,47:10, +77:14 +Tape - 18:8 +Target - 132:13 +Targeted - 132:25 +Tartaglione - 15:12, +48:21, 49:6,49:11, +60:19, 60:20, 60:21 +Team - 22:8, 118:10 +Telephone - 63:23, +111:23, 112:3, +112:15 +Telling - 5:10, 6:25, +66:22, 70:25, 79:18 +Tells - 59:10 +Temporarily - 78:9 +Term - 73:19, 75:20 +Terminology - 86:1 +7, 93:19, 128:16 +Terms - 10:9, 11:5, +91:18,91:25, 99:23, +99:25, 114:23, +129:14 +Text - 126:14 +Thanks - 18:24, +91:12 +These - 17:12, 51:9, +53:4, 70:22, 85:15, +97:20, 101:7 +They'd - 28:1, 85:13 +They'll - 27:23, +30:6, 36:13, 46:12, +83:25 +They've - 50:23, +62:12, 129:23 +Thomas - 94:24, +99:13, 117:18, +118:12, 118:17, +118:20, 119:13, +121:14, 121:20 +Thomas' - 119:17 +Thompson - 95:19 +Threats - 9:15 +Three - 32:21, +60:25, 61:11, 61:18, +61:19, 72:1, 72:24, +127:2 +Thursday - 53:19, +55:4, 110:2 +Thursdays - 50:12 +Tier - 133:7 +Timeframe - 22:10, +63:12 +Timeline - 80:21, +108:19 +Times - 16:9, 16:14, +19:16, 68:22, 70:24, +71:5,82:9,87:18, +87:19, 128:1 +Tired - 120:4 +Title - 3:8, 93:3 +- 97:23 +Today - 3:1, 4:13, +6:11, 6:19,89:20, +119:17, 120:2, +120:11, 120:12, +121:8, 127:21 +Tonight - 124:13 +Took - 49:21, 72:14, +73:14, 75:11, 84:6, +121:15 +Topics - 94:17 +- 123:7, +123:8, 123:10, +123:21, 123:23 +Total - 15:22 +Trace - 114:12 +Tracing - 114:17 +Track - 47:20, 87:9, +117:22 +Train - 93:13 +Trained - 27:9, +29:18, 30:15, 34:13, +35:18, 35:19, 93:18 +Training - 30:16 +30:24, 34:24, 35:3, +35:4, 35:6, 35:10, +35:22, 36:2, 93:6, +93:12, 94:7, 94:12, +94:15 +Transcription - 3:5, +18:21 +Transferred - 75:5 +Traumatic - 118:23 +Treated - 45:11 +Treatment - 37:4 +Trips - 94:1 +Trust - 46:17, 59:11, +59:13, 95:14 +Truth - 5:3, 5:4, 5:5, +5:6 +Truthfully - 4:13 +Tuesday - 120:13 +Turn - 100:7, 104:18 +Turns - 96:19 +Twice - 41:21, 71:10 +Two - 32:20, +103:13, 103:16, +103:21, 103:22, +103:23, 104:8, +108:19, 108:20, +122:23 +U +Unapproved - 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45:18, +45:21 +Weapons - 93:5 +We'd - 19:13, 77:24 +Week - 50:5, 50:10, +51:20, 54:7, 54:18, +57:1, 71:19, 76:7, +99:25, 100:17, +100:20, 100:22, +SDNY _00008038 + + + +101:14, 104:3, +108:19, 108:20 +Weekend - 7:10, +7:18, 10:3, 21:16, +21:20, 22:13, 22:18, +119:19 +Weeks - 13:23, +13:25, 19:6 +Weight - 122:10 +We'll - 36:15, 36:16 +44:14, 46:13, 47:11, +55:10, 119:9, 130:2 +Weren't - 7:6, 8:1, +74:4, 93:7, 111:9 +We've - 17:17, +17:18, 27:23, 92:11, +105:12, 122:19 +What's - 7:19, +29:21, 50:22, 51:16, +55:12, 55:22, 58:2, +65:17, 67:5, 69:16 +77:5, 95:11, 96:16, +105:18, 106:14, +108:14, 130:20 +Where's - 80:16, +80:20 +White - 15:12 +Whole - 5:4, 5:6, +7:13, 20:7, 67:25, +122:20 +Wide - 39:7, 39:9, +39:11 +Will - 3:2, 3:6, +22:19, 36:21, 40:24, +46:25, 52:6, 53:14, +77:13, 87:8, 111:22, +119:9, 127:12, +127:17 +Wiring - 105:15 +Wise - 56:13 +Won't - 104:1, 122:4 +Word - 12:9, 15:23 +Words - 49:13 +Worked - 6:7, +82:23, 121:3, 121:4, +124:3, 124:4 +Worker - 107:11 +Workers - 85:2, +92:25, 93:1, 93:20, +94:7, 97:14 +Workman's - 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(NY) (FBI)" ≤ +(USANYS)" +Subject: FW: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential +materials, scenes +Date: Wed, 07 Apr 2021 20:29:21 +0000 +Inline-Images: image001 jpg +Hi +As you can see below, the defense wants to the do the Bronx warehouse review on April 12th. Would you please +coordinate with the warehouse and let me know how to arrange the logistics for this? +Also, let me know when you're available for a call to discuss several of the other issues raised in this most recent email. +Thanks, +From: Laura Menninger +Sent: Wednesday, April 7, 2021 4:23 PM +To: +(USANYS) < +Cc: Jeff Pagliuca ; 'BOBBI C STERNHEIM' < bcsternheim@mac.com> +Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes +My apologies, I meant to include in my previous email that we could have the Bronx view on Monday. April 12. Thank you +for the logistics. +Regarding the spreadsheets you provided, I have several issues. +First, there are a couple of items that you have noted for the Bronx Warehouse but will in fact need to be brought to 500 +Pearl for review because you labeled them as "Highly Confidential" and not "bulky." These appear to include: +NY Evidence List +• Items 1B127-130 (4 boxes). +• Item 1B13 (1 box) +Florida Evidence List +• Item 1, Subitem 26 - one large framed photo from Master Bedroom. +Second, with regard to the "Bulky" photos (Florida Items 1, Subitems 8, 15a, 15b and 15c), are we permitted to +photograph those or not? If not, we will need them transported to 500 Pearl. + + +Third, Florida Item 8, Subitem 8, says it is Sixteen DVD-R Discs from PBSO but you do not indicate that we can review +those. Why? We need to address with the Court promptly any issues related to our request to view all evidence. +Fourth, Electronic surveillance - Your email yesterday stated that these were all "electronic files" with no corresponding +physical item. However, for several, the chart indicates "Blu-Ray Disks;" is there a reason we cannot inspect these? +Another Florida item is listed as "one original recording of an interview dated 4/24/07"; I am suspicious that "one original +recording of an interview" is not truly only an "electronic" file? I was practicing law in 2007 and do not recall "electronic +files" being the standard then. Can you please confirm? I know that Chris has written separately about the many files for +which the metadata has apparently been stripped, so we will have to address purely electronic information at another +date. +Shredded Paper - Yes, we need to review that as well. +"Missing from Assigned Box" items - can you please provide more of an explanation for all "missing items"? +I will let you know any other issues as I see them. However, now that we have made travel plans in reliance on your +agreement to produce all evidence items, I am hoping that you can promptly answer these questions so that we can +resolve any of them as needed this week. +Thank you, +-Laura +Laura A. Menninger | Partner +Haddon, Morgan & Foreman, P.C. +150 E. 10th Avenue | Denver, CO 80203 ++1 303 831 7364 (Office) +Imenninger@hmflaw.com +Sent: Wednesday, April 7, 2021 1:44 PM +To: Laura Menninger +Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes +Hi Laura, +The Bronx warehouse is located at 2350 Lafayette Ave, Bronx, NY. There is plenty of street parking outside of the +building. Whatever day you wish to have the review conducted at the warehouse, an AUSA and an agent will meet the +attorney, investigator, and paralegal at the warehouse to escort them into the building to the evidence review room. The +AUSA will remain present at the warehouse to answer any questions that may arise. +The FBI has informed me that they can make the evidence available for review at the warehouse any day next week or the +week of April 19th. Please just let me know what day you prefer, and we will coordinate with the FBI to arrange for the +review. + + +From: Laura Menninger +Sent: Wednesday, April 7, 2021 3:30 PM +To: +(USANYS) < +Cc: Jeff Pagliuca ; Christian R Everdell - Cohen & Gresser LLP (ceverdell@ cohengresser.com) +; 'BOBBI C STERNHEIM' +Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes +Thank you for the updated spreadsheets and the information regarding the timing of the review at 500 Pearl. +I believe we will be able to have an attorney, investigator and paralegal present at the Bronx warehouse to take photos of +the "excluded from transportation" items. Please let us know the particulars for that visit when you have a moment. +Thank you, +Laura +Laura A. Menninger | Partner +Haddon, Morgan & Foreman, P.C. +150 E. 10th Avenue | Denver, CO 80203 ++1 303 831 7364 (Office) +Imenninger@hmflaw.com +Sent: Wednesday, April 7, 2021 10:06 AM +To: Laura Menninger ; +PiL +(USANYS) < +Cc: Jeff Pagliuca ; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com) +; 'BOBBI C STERNHEIM' +Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes +Good morning, +Attached please find the revised spreadsheets, which reflect designations under the Protective Order for the three mini- +VHS tapes that I referenced below. +I learned this morning that the Marshals intend to bring Ms. Maxwell back to the MDC each review day at 4:30pm. So we +can plan for the review to take place at 500 Pearl Street from 9:30am to 4:30pm each day beginning on April 13th. + + +Sent: Wednesday, April 7, 2021 12:09 AM +To: 'Laura Menninger';_ +(USANYS) < +Cc: 'Jeff Pagliuca' < jpagliuca@hmflaw.com>; 'Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)' +; 'BOBBI C STERNHEIM' +Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes +Good evening, +Today, the Marshals confirmed that they will produce Ms. Maxwell to 500 Pearl Street on April 13, 2021 and every day +thereafter until the evidence review is complete. My understanding is that Ms. Maxwell should arrive to 500 Pearl Street +at approximately 9:30am each morning. So we are confirmed for evidence review in the proffer rooms on the 5th floor of +the 500 Pearl Street courthouse beginning at 9:30am on April 13th. +. I will plan to be present and to continue assisting with +logistics. If any questions or concerns arise, please feel free to call my cellphone at I +To assist in preparing for this review, attached please find annotated versions of the three evidence spreadsheets I +previously emailed to you: (1) a spreadsheet of New York evidence; (2) a spreadsheet of Florida evidence; and (3) a more +detailed spreadsheet of the sub-items contained in the Florida evidence spreadsheet. A couple things to note: +• These spreadsheets now indicate the Protective Order designation, if any, for each item to be reviewed. As you will +see, there are three mini-VHS tapes that I need to double check before assigning a final designation. I expect to be +able to access a mini-VHS cassette player later this week, at which point I will be able to provide an updated +spreadsheet with a confirmed designation for those three items. Additionally, please note that there is one item +about which we plan to provide you with a letter later this week. +• These spreadsheets also indicate where each item will be made available for the defense to review. As you will see, +we have now learned that one item (consisting of shredded paper) is currently at FBI headquarters and will not be +available for review next week. Please let me know if you believe you need to review that item, and I will inquire as +to whether and how it can be relocated to New York. Additionally, all 1D items consist of electronic data (as +opposed to 1B items, which are physical items). As is noted in the spreadsheets, the electronic data that constitute +the 1D items in this case have either already been produced to you in discovery (e.g., pen register data, GPS data, +and aerial footage), or are digital recordings of interviews that will be produced as non-testifying witness +statements. Because these 1D items are data files stored in the FBI system, there is no corresponding physical item +to produce for you to review. +Please let me know when you would like to schedule a time for a smaller group from the defense team to review evidence +at the Bronx warehouse. + + +Sent: Monday, April 5, 2021 10:48 PM +To: Laura Menninger ;Q +(USANYS) < +Cc: Jeff Pagliuca ; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com) +; BOBBI C STERNHEIM' +Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes +Laura, +Thank you for your email and for your understanding as we work through the logistics of arranging this review. Your +modifications and clarifications are acceptable to us. Below I address each specifically: +• The FBI can arrange for a lawyer, investigator, and paralegal to inspect and photograph the precluded items at the +Bronx warehouse either next week or the week after. Please let us know what day you would like to arrange for +that inspection, and I will coordinate with the FBI accordingly. I would suggest trying to schedule this visit early +next week if possible so that if there are items that you believe need to be produced to 500 Pearl Street, we will +have time to do so during a subsequent day of review at 500 Pearl if the FBI agrees to transport the items). +• Tomorrow, I will send you evidence spreadsheets with annotations of which items the FBI will not be producing to +500 Pearl Street, and which items we are designating under the Protective Order. Please note that certain items +will be designated "Confidential," in which case they may be photographed, but the photographs should be treated +as Confidential under the Protective Order. Other items will be designated "Highly Confidential," in which case they +may not be photographed, absent specific authorization from an AUSA. I note the possibility of authorization to +photograph this latter category because some Highly Confidential evidence items include both nude and non-nude +portions, in which case we would permit photography of the non-nude portions. +• In light of our decision to produce non-testifying witness statements beginning on April 12, 2021, we are no longer +segregating any electronic media that contain witness statements during this review. This is because all of the +witness statements on the electronic media in the FBI's possession are from witnesses whom the Government does +not expect to call at trial in this case. Please note that we intend to produce digital audio files to you containing the +contents of the electronic media with these non-testifying witness statements, but you are of course welcome to +review the original recordings themselves. +• In terms of space, I have been informed that we will not be permitted to conduct this review in a courtroom and +will instead be required to do so in the proffer rooms. I have reserved the two largest proffer rooms available at +500 Pearl. We can use the largest proffer room for evidence review, and the slightly smaller proffer room as a +private meeting space for the defense team. +• Confirmed, I will ask the FBI to bring all electronic highly confidential images to 500 Pearl Street, including the +2,100 that were not previously reviewed and the electronic images that were previously provided for review at the +MDC. +• Confirmed, I will ask the FBI to bring the 7 hard-copy highly confidential materials to 500 Pearl Street. +As 1 mentioned earlier today in a separate email, the FBI and AUSAs are prepared to facilitate this review beginning April +13th and continuing every day thereafter until your review is complete. I have also formally requested that the Marshals +produce Ms. Maxwell to 500 Pearl Street on April 13"h and every day thereafter until the review is complete. The +Marshals previously confirmed their willingness to produce Ms. Maxwell for such a review in general, but they have not +yet confirmed their ability to do so on any particular dates. I will let you know as soon as the Marshals inform me +whether they can accommodate these specific dates. + + +From: Laura Menninger +Sent: Friday, April 2, 2021 5:36 PM +To: +(USANYS) < +Cc: Jeff Pagliuca ; Christian R Everdell - Cohen & Gresser LLP (ceverdell@ cohengresser.com) +; 'BOBBI C STERNHEIM' +Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes +Thank you for your email. Your proposal is largely acceptable to us, with the following modifications and clarifications. +• For the items that you propose below to exclude from the evidence transported to 500 Pearl Street (with the +exception of the cash held at 26 Federal Plaza), we will need to have access for a lawyer, investigator and paralegal +to inspect and photograph those items at the Bronx warehouse. This seems to include the bulky items, electronic +devices and "fragile" items. +• Once they are photographed and shared with the team and our client, we can decide whether a separate +inspection by our client and/or any expert is necessary at a later time. To be clear, the government's photos +of these same items are insufficient. +• If there are any items we are not permitted to photograph (and perhaps you will be able to tell us by April 5 +which those are), we likely will need to have those transported because there is no way for our client to +inspect the evidence. We can wait to finalize this issue until you have finished deciding what items you +consider non-photographable, and if we can't agree, then discuss next steps. +• Please let us know when these "non-transportable" items can be inspected and photographed at the Bronx +warehouse. It makes sense that it would be done soon so that we can raise any issues as necessary with the +Court. +• For playing any of the electronic media, we will obtain the necessary equipment to play at 500 Pearl Street and +seek permission to bring those devices into the Courthouse. You can segregate out the section of recordings that +contain "witness statements" and advise us then which ones cannot be played, but we still need to inspect the +outside of those recordings. +• As far as space, can you please advise whether the largest proffer room will be available for review of evidence? It +is my understanding that it can accommodate a large number of the team members at one time. If not, is a locked +courtroom available for us to review the evidence? The agents could bring out a limited number of boxes at a time +for inspection. +• We understand that the evidence will not be taken outside of the monitoring of the agents or your staff and +appreciate that you will have a separate room for us to consult with our client privately (without the evidence). +• We understand that all of the highly confidential materials, including not only the 2,100 images not previously +disclosed as well as the electronic images that were only shown to NY counsel and the client at the MDC, will be +available for review on a singular laptop at 500 Pearl Street. +• We also understand the 7 hard-copy highly confidential materials will also be available for inspection at 500 Pearl +Street. +Please let me know if you have any questions or disagree with my understanding. If you agree, we can then proceed as +scheduled on April 12 and continue day to day until we are finished, with a break if necessary for the arraignment. +Laura A. Menninger | Partner +Haddon, Morgan & Foreman, P.C. + + +150 E. 10th Avenue | Denver, CO 80203 ++1 303 831 7364 (Office) +Imenninger@hmflaw.com +Sent: Saturday, March 27, 2021 4:38 PM +To: Laura Menninger < menninger@hmflaw.com>;| +(USANYS) <| +Cc: Jeff Pagliuca ; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com) +; 'BOBBI C STERNHEIM' +Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes +Counsel, +Thank you for your email. Below please find our response. If this is acceptable to you, then we will proceed with +arranging the logistics of having your client produced to 500 Pearl the week of April 12** and the week April 19th +. We will +also arrange for the FBI to transport evidence to 500 Pearl for review the week of April 12th +Physical Evidence +• It is not reasonable or feasible to insist that the FBI bring all physical evidence to 500 Pearl Street. That said, we are +certainly willing to work with you to ensure that your client can review any physical items that are material to the +preparation of her defense. +• We would propose excluding the below items from production to 500 Pearl: +• We appreciate your note that the massage tables are not needed, which will certainly help with the logistics +of transport. +• We also appreciate your indication that the cash items from 26 Federal Plaza do not need to be produced. +Those are the only items not located in the Bronx warehouse. +• The FBI has seized dozens of electronic devices, including desktop computers, servers, and laptops, from +Jeffrey Epstein's residences in 2019. Photographs of those devices were produced in our August 2020 +productions as part of the search warrant photographs, and you have received copies of the data that was +seized from those devices pursuant to a warrant. The production of these devices would be very +cumbersome, and we do not see any value in looking at an electronic device that cannot be turned on. +• The framed pictures are bulky and cumbersome to transport. These are also very delicate and are difficult +to transport. Photographs of those seized images were already provided to you as part of the photographs +from the searches of Epstein's residences. +• Certain items seized from the New York residence are bulky, fragile, and/or difficult to transport. These +include plaster busts of female torsos and a stuffed dog. Photographs of these items were already provided +to you from the search of the New York residence. +• The remaining physical items of evidence would fit into approximately 15 to 20 boxes. The FBI has indicated that it +would be feasible to transport those boxes to 500 Pearl Street. +• Regarding your request for equipment that can play the recordings, we believe they would require a VCR, a cassette +player, a CD player, an adapter for a micro VHS tape, and a microcassette player. If you wish to play these +recordings at 500 Pearl, you will need to provide that equipment. We have asked the FBI whether any other +equipment would be necessary and will let you know if that is the case prior to the date of your review. It is our +understanding that any recordings that are not witness statements and that are not highly confidential have been +produced to you in discovery. We are not aware of any discoverable, non-highly confidential, recordings that were +not produced to you as part of the Government's discovery productions in the fall. To confirm that understanding, +we are working with the FBI to physically doublecheck each recording. If we identify any discoverable recordings +that have not already been produced, we will promptly provide them to you. + + +• The segregation of highly confidential material will require the FBI and an AUSA to physically review each item to +confirm the item's status. We will endeavor to do so by your requested date of April 5, 2021. +• We can confirm that neither the AUSA(s) nor the agents) will record or attempt to record any part of the evidence +review or conversations among the defense team or with the defendant during this review. Although the evidence +cannot be left outside of the presence of an agent, we will ensure that a room is available for the defense team and +the defendant to confer privately away from the agent(s) and the AUSA(s) without monitoring. +• As for your request for a space large enough to fit 8 members of the defense team, the defendant, an agent, an +AUSA, and the evidence, my office cannot control the space that the Marshals allow us to use at 500 Pearl outside +of the proffer rooms. We will certainly request as large a space as possible, but if we are required to use the +proffer rooms, then members of the defense team may need to rotate in and out of the room. I know members of +the defense team have been in those proffer rooms before, and they can hopefully provide some thoughts on how +we might use the proffer room space effectively for your purposes. If the Court grants authorization for the +defense to bring electronic devices into 500 Pearl, that is certainly fine with the Government, and you may note our +consent in your request to Judge Nathan for such authorization. +Highly Confidential Electronic Images +• The 2,100 electronic images were recovered during the responsiveness review of images and videos seized from +Jeffrey Epstein's devices, which review was not complete until early November 2020. We indicated on page 4 the +cover letter to our November 9, 2020 production, which included all other images and videos from those devices, +that "the Federal Bureau of Investigation ('FBI') seized multiple nude and partially nude images from several for the +above-listed electronic devices. All such images have been designated Highly Confidential. The FBI will make these +images available for review by the defense upon request." We did not receive a request from the defense to review +these images until your March 8, 2021 letter, which requested to "view and inspect all materials designated by your +office as 'Highly Confidential' under the terms of the Protective Order". +• We did not ask the FBI to bring the 7 hard copy images to the MDC in the fall because we did not understand you to +be requesting a review of physical, non-electronic evidence during those meetings. Our understanding of the +defense request at that time was to review the electronic highly confidential images that were recovered from CDs +from Epstein's residence. We will ensure that the 7 hard copy images are available to you for review at 500 Pearl. +From: Laura Menninger <|menninger@hmflaw.com> +Sent: Monday, March 22, 2021 5:19 PM +To: +•›• +(USANYS) < +Cc: Jeff Pagliuca ; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com) +; BOBBI C STERNHEIM' +Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes +All, + + +We have considered your proposal. Unfortunately, it does not permit us an adequate ability to review the evidence in the +case and does not permit our client to meaningfully participate in her own defense. +First, we are unable to meaningfully review the evidence without the benefit of our laptops and other electronic devices +which are needed to take notes of our review. We also need access to our devices during the review to compare the +physical evidence with the electronic discovery and with our work product. +Second, we need to provide our client the ability to review all discovery, including any recordings, in order to assist in her +own defense. Presuming that she will not be taken to the FBI downtown office, then your proposal offers no means by +which she can both inspect a recording in its physical form and listen to the recording at the same time. +In order to address the deficiencies in your proposal, we believe the following are necessary: +Physical Evidence +• All of the physical evidence currently located in the FBI Bronx warehouse will be transported to 500 Pearl Street +and made available during the week of April 12, with our client present, in a room sufficiently large to +accommodate 8 attorneys and investigators. +• We do not need the "bulky" massage tables transported; if there are any other extremely large evidence +pieces, let us know what they are and we can consider whether we can have someone review and +photograph those at the Bronx warehouse at an earlier time. +• From your email, it appears that only two items are not located at the Bronx warehouse - both envelopes +with cash. Please confirm this. We do not need the two "cash" evidence items transported to 500 Pearl. +• If there are other evidence items housed somewhere other than the Bronx, please let us know what they are +and where they are. +• We will be permitted to bring our laptops, and a camera, into 500 Pearl Street; we are happy to seek permission +from Judge Nathan to do so. +• Either the FBI can provide the equipment necessary to listen to any of the recordings at 500 Pearl Street or we can +bring the necessary equipment. If we are to provide the equipment, we will need to know in advance the formats +of each recording so that we can be prepared. You can note that on your Excel spreadsheet by the item number by +March 29 to give us adequate time to secure the necessary equipment. +• The FBI can segregate any physical evidence that you deem "highly confidential." You can identify any "highly +confidential" physical evidence items on your Excel spreadsheets by April 5 (one week before the evidence view). If +we need to photograph or reproduce any such item for expert evaluation, we will seek leave of court. Otherwise, +we will not photograph any such items during the review during the week of April 12. This will ensure the evidence +review proceeds smoothly and there will not be any need to ask permission to photograph on an item by item +basis. +• The FBI also can segregate any recordings which we will be able to inspect, but not listen to, during the evidence +view the week of April 12. You can note such designation on your Excel spreadsheet. If we disagree, we can seek +leave of the Court in advance. +• We understand that an FBI Agent and/or AUSA may be present during our physical evidence review at 500 Pearl +Street but of course must ensure that no recordings are made of our conversations and also ensure that there is a +separate, secure room in which we can confer with our client during the evidence view without monitoring by the +government. ( +• Please confirm whether all electronic recordings (other than the highly-confidential images and videos described +below) have previously been produced to us, and if not, please explain which ones were not produced by the +discovery deadlines last fall and why. +Highly Confidential Electronic Evidence +• Can you please explain why 2,100 + 7 "highly confidential" images have not been shared with us yet? It was our +understanding that you previously provided all "highly confidential" images to our client - and to defense counsel - +for review at the MDC in November. We are confused about where these previously undisclosed items were +located and why they have not yet been made available for inspection and review. +• During the week of April 19, Ms. Maxwell should be produced to 500 Pearl Street to review (with counsel and a +defense staff member, on the 1 laptop provided) all of the 5,507 electronic images and video marked "highly + + +confidential". These should be segregated into the three categories you describe (never-before produced, +previously produced, and the 7 hard-copy images). +Please let us know if you will not agree to any of these steps so that we can address the issues with the Court. +Thank you. +Laura A. Menninger | Partner +Haddon, Morgan & Foreman, P.C. +150 E. 10th Avenue | Denver, CO 80203 ++1 303 831 7364 (Office) +Imenninger@hmflaw.com +Sent: Tuesday, March 16, 2021 4:40 PM +To: Laura Menninger ; +(USANYS) < +Cc: Jeff Pagliuca ; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com) +; BOBBI C STERNHEIM' +Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes +All, +Attached please find two spreadsheets documenting all physical evidence in the FBI's custody, as well as a corresponding +discovery cover letter. We are sending a copy of these files to the MDC for your client as well. +In response to your questions, the FBI has informed me of the following: +Regarding the Highly Confidential nude/partially nudge images to be reviewed at 500 Pearl: +• There are three categories of these images: +• Approximately 2,100 electronic images and videos seized from Epstein's electronic devices (which have not +been previously provided to you) +• Approximately 3,400 electronic images from discs seized from Epstein's residences in 2019 (which have +previously been provided to you and your client for review at the MDC) +• Approximately 7 hard copy nude images located in the file from the FBI Florida office's investigation of +Epstein (which have not been previously provided to you) +• The FBI will make all three of those categories available to you. The electronic files will be provided on hard drives, +and the FBI will provide you with the hard copy images for review as well. +• All electronic images should be viewable as thumbnails, except those seized from Apple devices, which must +be viewed using Cellebrite. +• The Cellebrite software will be provided on the drive for your review of images and videos seized from Apple +devices. +• The electronic files have the same metadata on the hard drive that was available when the FBI seized each +image. For images that were carved or deleted, no metadata was recovered, so none is viewable. For all +other images, the metadata recovered should be viewable on the hard drive. +• The approximately 2,100 electronic images and videos seized from Epstein's devices are separated by folder +to indicate which device each image was seized from. +• Because these images are considered obscene material, the FBI is not permitted to make duplicates of them, and +there is a limited number of clean laptops on which these images can be reviewed. As a result, the FBI is only able +to provide a single laptop for review of these images. +Regarding the physical evidence: +• Attached are two lists of all physical items in the FBI's custody relating to this case. The first list relates to items +associated with the FBI Florida office's investigation of Epstein. The second list relates to items associated with the +FBI New York office's current investigation. + + +• The vast majority of physical evidence in the FBl's custody is located at the FBl's warehouse in the Bronx. Two +items (1B 77 & 1B 79) are located at 26 Federal Plaza, but the case agents can check those items out from 26 +Federal Plaza and bring them to the Bronx warehouse on whatever day you choose to conduct your review so that +you will have all evidence in one place. +• The FBI is able to arrange for the defense team to review all physical evidence at the Bronx warehouse under the +following conditions: +• The warehouse requires at least two weeks' notice in order to pull all of the items for the entire case and +place them in a location where a large group of people can view them. +• The warehouse is open during normal business hours between 9am and 5pm on weekdays. +• At least two FBI agents and an AUSA will be present at the Bronx warehouse to assist and answer questions. +• The evidence will be placed in a loading dock at the warehouse to provide additional space for the review. +To ensure that there is sufficient space, please let me know how many members of the defense team intend +to be physically present for this review. +• Electronic devices such as cellphones and laptops are not permitted in the warehouse. The defense team +may bring a digital camera that is not connected to the Internet or a cellular network into the warehouse. If +the defense team wishes to photograph an item of evidence, the defense will need to inform the agents who +are present, so that they may confirm that the photographed item is not Highly Confidential based on the +presence of nudity. +• Electronic media such as VHS tapes, cassette tapes, and CDs will not be playable at the warehouse. +• To the extent the defense requests that the FBI bring any physical items to 500 Pearl Street for your client to review, +the FBI is prepared to bring items that are reasonably sized to 500 Pearl Street. With respect to bulky or large +items, the defense team should be able to photograph those for your client to review, unless they are deemed +Highly Confidential, in which case the FBI can make arrangements to transport the item to 500 Pearl Street if +• The FBI is in the process of confirming that it can provide devices to play all of the electronic media in the case in a +single location at the FBI's offices in downtown Manhattan. We are also double-checking to confirm that all media +that does not contain witness statements have already been produced to you and your client in discovery. The FBI +anticipates that we can arrange for you to review all non-witness statement electronic media at the FBI's office in +downtown Manhattan in approximately three weeks. +• To the extent you wish to review all of the discs containing photographs, which were seized from Epstein's +residences in 2019, we note that all of those images have already been produced to you in discovery. For +your awareness, the FBI has informed me that it took their team several weeks to review all of the images on +Please let me know how you wish to proceed. +Sent: Monday, March 15, 2021 6:00 PM +To: 'Laura Menninger' ; L +(USANYS) < +Cc: Jeff Pagliuca ; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com) + + +; 'BOBBI C STERNHEIM' +Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes +Laura, +I expect to be able to answer all of your questions about the evidence review by tomorrow. +We have been looking into the discovery request you made last week, and we hope to have a response ready to provide +to you by next week. +From: Laura Menninger +Sent: Monday, March 15, 2021 3:01 PM +Cc: Jeff Pagliuca ; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com) +; 'BOBBI C STERNHEIM' +Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes +Now that the FBI team is back, when do you expect to have answers to all of the questions posed? If I had an idea of +when you would have answers, it could help me answer your question. +At a minimum, it would not seem to take too much time to know when someone can open the FBI vault and allow the +attorneys to make an initial view of the evidence. Also, I understand the FBI did not prepare an inventory of their +evidence when they seized it from NY and LSJ, so | don't think we need to wait for them to now prepare an inventory +before we start reviewing evidence. +Also, when do you believe you will have a response regarding the discovery I requested last Monday? +Thanks, +Laura +Laura A. Menninger | Partner +Haddon, Morgan & Foreman, P.C. +150 E. 10th Avenue | Denver, CO 80203 ++1 303 831 7364 (Office) +Imenninger@hmflaw.com + + +Sent: Friday, March 12, 2021 11:44 AM +To: Laura Menninger < menninger@hmflaw.com>: l +(USANYS) < +Cc: Jeff Pagliuca ; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com) +; 'BOBBI C STERNHEIM' +Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes +Counsel, +The FBI team on this case has been out of the office this week and will not be able to answer all of the questions you +asked during our Wednesday call until they are back in the office next week. Please let me know if you would like to wait +until all of those questions can be answered to schedule a day for your client to be brought to 500 Pearl Street to review +the highly confidential images. My understanding is that the FBI is able to provide at least one laptop containing those +highly confidential images in time for such a review to take place on Thursday 5/18, but I may not have the answers to all +of your questions about those images before that date, and I do not know whether you will also be able to visit the +evidence vault that same week. +Please let me know how you would like to proceed. I will reach back out once I have answers to your questions. +Thank you, +Sent: Tuesday, March 9, 2021 4:56 PM +To: Laura Menninger menninger@hmflaw.com>; l +(USANYS) < +Cc: Jeff Pagliuca ; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com) +; 'BOBBI C STERNHEIM' +Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes +That is the only excel spreadsheet indexing physical evidence that we have produced in discovery. That spreadsheet does +not include every physical item currently in the FBI's custody related to this case. For example, the August 20, 2020 +discovery production also included search warrant returns listing the physical items seized by the FBI's New York Office +during the 2019 searches of Jeffrey Epstein's residences in New York and the U.S Virgin Islands (see Bates range +SDNY_GM_00166007-SDNY_GM_00166043), but they are not contained in a spreadsheet. +As a courtesy, I have asked the FBI whether it would be possible to provide us with a similar excel index reflecting the +physical evidence seized by the FBl's New York Office, though it may take some time to compile such an index. + + +From: Laura Menninger +Sent: Tuesday, March 9, 2021 3:44 PM +To: +P; +(USANYS) < +Cc: Jeff Pagliuca ; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com) +; 'BOBBI C STERNHEIM' +Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes +Thank you. Is that the only index of physical evidence available? +Laura A. Menninger | Partner +Haddon, Morgan & Foreman, P.C. +150 E. 10th Avenue | Denver, CO 80203 ++1 303 831 7364 (Office) +Imenninger@hmflaw.com +Sent: Tuesday, March 9, 2021 1:38 PM +To: Laura Menninger ; l +(USANYS) < +Cc: Jeff Pagliuca ; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com) +; BOBBI C STERNHEIM +Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes +Counsel, +In advance of our call tomorrow, I wanted to send a copy of the attached index of physical items in FBI custody from the +FBI-Miami office, which we previously produced to you as part of our August 21, 2020 discovery production. Also +ncluded in that August 21, 2020 production were scans of numerous items listed on the index. Those scans can be found +within Bates range SDNY_GM_00172218-SDNY_GM_00173007. It may be useful to reference some of those items during +our conversation tomorrow, so I wanted to make sure you were aware of them. + + +Sent: Tuesday, March 9, 2021 2:03 PM +To: 'Laura Menninger' ; +(USANYS) < +Cc: Jeff Pagliuca ; BOBBI C STERNHEIM' +Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes +Yes, that works for us, thank you very much. We can use the below dial-in: +Dial-in: +Code: +From: Laura Menninger +Sent: Tuesday, March 9, 2021 11:19 AM +To: +(USANYS) < +Cc: Jeff Pagliuca ; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com) +; 'BOBBI C STERNHEIM' +Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes +Good morning. +We are free at 1:30 p.m. ET / 11:30 a.m. MST tomorrow. Would that work? We are generally free thereafter, so please +suggest another later time if not. +Thank you, +Laura +Laura A. Menninger | Partner +Haddon, Morgan & Foreman, P.C. +150 E. 10th Avenue | Denver, CO 80203 ++1 303 831 7364 (Office) +Imenninger@hmflaw.com +Sent: Tuesday, March 9, 2021 8:36 AM +To: Laura Menninger ;| +(USANYS) < +Cc: Jeff Pagliuca ; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com) +; BOBBI C STERNHEIM' +Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes +Good morning, +It would be helpful to have a call to discuss the requests contained in this letter. Are there times tomorrow when you +would be available to speak, please? + + +Thank you, +From: Laura Menninger +Sent: Monday, March 8, 2021 2:03 PM +To: +(USANYS) <| +-- +Cc: Jeff Pagliuca ; 'BOBBI C STERNHEIM' < bcsternheim@mac.com> +Subject: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes +Counsel - +Please see attached correspondence. +-Laura +F +Laura A. Menninger +Haddon, Morgan and Foreman, P.C. +150 East 10th Avenue +Denver, Colorado 80203 +Main 303.831.7364 FX 303.832.2628 +Imenninger@hmflaw.com +www.hmflaw.com +CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages +attached to it may contain information that is confidential or legally privileged. If you are not the intended +recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that you +must not read this transmission and that any disclosure, copying, printing, distribution or use of any of the +information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this +transmission in error, please notify the sender by telephone or return e-mail and delete the original +transmission and its attachments without reading or saving it in any manner. Thank you. \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/15b68fbf4b465d0d4fb2fe2e0d2b8702e62a591d9fc46f650c014a2c51b12550.receipt.json b/vision-fixhub/ds9-parsed-01/15b68fbf4b465d0d4fb2fe2e0d2b8702e62a591d9fc46f650c014a2c51b12550.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..0b0e3b87cc1fc4c21f7cb88a446fbc7cadc55908 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/15b68fbf4b465d0d4fb2fe2e0d2b8702e62a591d9fc46f650c014a2c51b12550.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -1464, + "dataset": "marble-joined", + "doc_id": "15b68fbf4b465d0d4fb2fe2e0d2b8702e62a591d9fc46f650c014a2c51b12550", + "engine": "marble-apple-vision", + "event_count": 17, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "c445efde44285b984532803e421fa1a302459c6d6b47eb9c31541b1f3eb18b60", + "output_sha256": "3cdac0cac2cd2e181c0221363ceb71f88062f5bebaf534c5408b40bcd8b15f11", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/15bbfd552184feb225cffb8e5a40ac55a3d406053deb4b2ce7a5b4f57cc938d1.md b/vision-fixhub/ds9-parsed-01/15bbfd552184feb225cffb8e5a40ac55a3d406053deb4b2ce7a5b4f57cc938d1.md new file mode 100644 index 0000000000000000000000000000000000000000..cb8363d2f5f53b0e092b1ec47a92fdd30418237c --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/15bbfd552184feb225cffb8e5a40ac55a3d406053deb4b2ce7a5b4f57cc938d1.md @@ -0,0 +1,6 @@ + +CORE 17 +Proa +PLEASE do not plug +into the USB's to charge +your PHONE/TABLET \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/15bbfd552184feb225cffb8e5a40ac55a3d406053deb4b2ce7a5b4f57cc938d1.receipt.json b/vision-fixhub/ds9-parsed-01/15bbfd552184feb225cffb8e5a40ac55a3d406053deb4b2ce7a5b4f57cc938d1.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..bf99f08b05f2b8b1a29b1c6f6d5747eb72c8744b --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/15bbfd552184feb225cffb8e5a40ac55a3d406053deb4b2ce7a5b4f57cc938d1.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "15bbfd552184feb225cffb8e5a40ac55a3d406053deb4b2ce7a5b4f57cc938d1", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "76082dccf2bbadfa5eccd47296be146111390f4bb93a2784d832f51450d2a020", + "output_sha256": "5a652d2cbea1682cb03392650abe73e9257be1713af83cdc1fdf836c845deff7", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1639c644e7c5508f5e8f737711b2e948139030eb37bcafd3bb5e0d20cb6c2665.md b/vision-fixhub/ds9-parsed-01/1639c644e7c5508f5e8f737711b2e948139030eb37bcafd3bb5e0d20cb6c2665.md new file mode 100644 index 0000000000000000000000000000000000000000..7410b7326389c92b108eda95b2700b66e44a4966 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1639c644e7c5508f5e8f737711b2e948139030eb37bcafd3bb5e0d20cb6c2665.md @@ -0,0 +1,20 @@ +From: Susan Harriman +To: = +Subject: Re: Epstein tidbit +Date: Sat, 13 Jul 2019 22:23:27 +0000 +Question (and by the way, GREAT JOB to you and your colleagues: +1) WHY has no one even verified that Jeffrey was ever even with Bear Stearns? I used to work for them and +they required everyone to be registered (licensed)-yet Broker Check shows NO RECORD of THIS Jeffrey +Epstein EVER having been licensed in any capacity, EVER. Three Jeff Epsteins are/have been licensed but +none of them are this one: +https://brokercheck.finra.org/ +2) I have an even better case for you involving two Ivy League Directors of Cardiology, one of whom is +Manhattan based, their Cayman Islands hedge fund whose largest investor is Abbott Labs (who happens to +own Heartmate) and $150M in cash from Colombia paid for seed research clinical trials (with focus in +cardiology) completed in 2015, one of which was....yep, Heartmate.... where 26 are dead and 28,882 +Medicare-reimbursed patients had to go back to the hospital. Gerardo Reyes from Univision went to +Colombia and got hte records for me, I promise you will want to review this and decide for yourself. +When you get thru the Epstein mania give me two hours and I'll come there at my own expense and give you a +case I stumbled that eminates from a massive securities fraud case who sent monies to the hedge fund +Susan +- diff --git a/vision-fixhub/ds9-parsed-01/1639c644e7c5508f5e8f737711b2e948139030eb37bcafd3bb5e0d20cb6c2665.receipt.json b/vision-fixhub/ds9-parsed-01/1639c644e7c5508f5e8f737711b2e948139030eb37bcafd3bb5e0d20cb6c2665.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..2e08b903966777ad30bb6e5e5cd27cea70cb9b92 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1639c644e7c5508f5e8f737711b2e948139030eb37bcafd3bb5e0d20cb6c2665.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "1639c644e7c5508f5e8f737711b2e948139030eb37bcafd3bb5e0d20cb6c2665", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "0e68d042e18e11c7768d13410eb5abf5608799f86b254f51acb9922fe2ba646d", + "output_sha256": "981cacf82ea11bfa3e477d024ecfd1f89b6cad7edc5a891e30ae45cccbd5c4c8", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/164248d62a693afc2772ffc149eb391d789408ceca1061902bc5d71f65af0b1d.md b/vision-fixhub/ds9-parsed-01/164248d62a693afc2772ffc149eb391d789408ceca1061902bc5d71f65af0b1d.md new file mode 100644 index 0000000000000000000000000000000000000000..a23abe7055b673aebb1265ecbd0d30472faec795 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/164248d62a693afc2772ffc149eb391d789408ceca1061902bc5d71f65af0b1d.md @@ -0,0 +1,30 @@ +From: +To: +Subject: Fwd: ME Report +Importance: Normal +Priority: Normal +Sensitivity: None +Supervisory Special Agent +FBI/NYPD +Violent Crimes Task Force +kjponder@fbi.gov +-- Forwarded message --- +Date: Aug 28, 2019 12:16 PM +Subject: ME Report +To: +Cc: +Deputy Director of Forensic Investigations/Forensic Operations +I am reaching out because I understand your office is prepared to release a copy of the final report regarding the +Couthey. Dete tipe Cinor y is a member the New York side Depast men a chi aporn to work it the +FBI's Violent Crimes Task Force. I have also copied Supervisory Special Agent +who oversees our +Task Force, on this message. +Thank you for your assistance on this issue. If you have any questions about this or other matters, please do not +hesitate to reach out to me directly. +Best Regards, + + +Special Agent in Charge +Criminal Division +FBI New York Office +(O)| diff --git a/vision-fixhub/ds9-parsed-01/164248d62a693afc2772ffc149eb391d789408ceca1061902bc5d71f65af0b1d.receipt.json b/vision-fixhub/ds9-parsed-01/164248d62a693afc2772ffc149eb391d789408ceca1061902bc5d71f65af0b1d.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..6a58b10a14e772bcccc9bc684daf57fba50dabe7 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/164248d62a693afc2772ffc149eb391d789408ceca1061902bc5d71f65af0b1d.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "164248d62a693afc2772ffc149eb391d789408ceca1061902bc5d71f65af0b1d", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "a171fb177fb7280becbfd01b0e8ab3056335ff8f138a932a096247877e9d9ec0", + "output_sha256": "36c77343e9a59c1d363bd82d6118760151b7ec2a387776ed8fc943e467dcdc54", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/16476ad123847d29f8d025c0417a64d4d84a2b963b7204f7fed95daad7d0f460.md b/vision-fixhub/ds9-parsed-01/16476ad123847d29f8d025c0417a64d4d84a2b963b7204f7fed95daad7d0f460.md new file mode 100644 index 0000000000000000000000000000000000000000..c41e6f1af2d104d5181a8603db8703cef537dc6f --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/16476ad123847d29f8d025c0417a64d4d84a2b963b7204f7fed95daad7d0f460.md @@ -0,0 +1,40 @@ +From: +To: "Daniel J. Kaiser" +Ce: +"William H. Kaiser" +Subject: RE: Epstein case, SDNY +Date: Fri, 26 Jul 2019 03:37:49 +0000 +Dan, Kimberly, +Following up on our discussions regarding I +• we were wondering if you have time for a brief call tomorrow, or if +not, at your earliest convenience next week? We don't expect to take long but do want to be quickly in touch when +you're available. +thank you, +Assistant U.S. Attorney +Southern District of New York +From: Daniel J. Kaiser < +Sent: Sunday, July 14, 2019 08:05 +Tol +Cc:| +William H. Kaiser • +Subject: Re: Epstein case, SDNY +Thanks to all of you for handling the meeting with +Dan +Daniel J. Kaiser +Kaiser Saurborn & Mair, P.C. +so professionally. We greatly appreciate it. +On Jul 14, 2019, at 12:09 AM, +> wrote: +Team - following up on our meeting yesterday, I wanted to make sure you all have the contact info for our full team. My +colleagues +and +Tare also working on the case, and they're copied here and we're all +reachable at these email addresses or by phone anytime at: + + +We greatly appreciated f +i being willing to talk with us, and I expect we'll be in touch again in the coming weeks. +And of course if anything comes up that you want to reach out to us about, please don't hesitate at all. +thank you, +Assistant U.S. Attorney +Souther District of New York diff --git a/vision-fixhub/ds9-parsed-01/16476ad123847d29f8d025c0417a64d4d84a2b963b7204f7fed95daad7d0f460.receipt.json b/vision-fixhub/ds9-parsed-01/16476ad123847d29f8d025c0417a64d4d84a2b963b7204f7fed95daad7d0f460.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..eca6fec0837ea4608b59893462b94e880ebacd25 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/16476ad123847d29f8d025c0417a64d4d84a2b963b7204f7fed95daad7d0f460.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "16476ad123847d29f8d025c0417a64d4d84a2b963b7204f7fed95daad7d0f460", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "4a10bc75a49db37b6366841286c6fdbd86afbe02ad27a25ee759a5f1a616c6a4", + "output_sha256": "5c1627519228695e17d5b23be52139bd5c059f698cba147d765d75d02166d731", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1650ca42179766a9d7f24c12e0920025731e6d2451c82f7a0062b3dfdfb3122d.md b/vision-fixhub/ds9-parsed-01/1650ca42179766a9d7f24c12e0920025731e6d2451c82f7a0062b3dfdfb3122d.md new file mode 100644 index 0000000000000000000000000000000000000000..a6c817a5adf0267a9e91e1cc609ecb887cc2d49c --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1650ca42179766a9d7f24c12e0920025731e6d2451c82f7a0062b3dfdfb3122d.md @@ -0,0 +1,754 @@ +From: +C° Contractor 2 +Bce: "Berman, Geoffrey (USANYS)" < +(USANYS)" +Subject: SDNY News Clips Friday, August 16, 2019 +Date: Fri, 16 Aug 2019 20:52:48 +0000 +Attachments: 2019_8-16.pdf +SDNY News Clips +Friday, August 16, 2019 + + +Contents +Public Corruption +Avenatti +Epstein +Complex Frauds and Cybercrime +Panama Papers +Goldstein +Violent and Organized Crime +Hernandez +Terrorism and International Narcotics +Akasha +Matters of Interest +Trial-Heavy Fall Will Test FCPA Unit, Shape Law +I Tried to Tell the World About the MCC. No One Wanted to Listen. +Public Corruption +Avenatti +Avenatti Says Nike Agreed To Pay Zion Williamson $35K +Law 360 +By Zachary Zagger +8/15/19 +Embattled attorney Michael Avenatti referenced alleged texts between Nike executives discussing an illicit +$35,000 payment to eventual NBA No. 1 draft pick Zion Williamson before he committed to Duke University, in +a motion filed late Wednesday seeking to escape federal criminal charges alleging he attempted to extort the shoe +company. +Avenatti told a federal court that federal prosecutors in Manhattan are selectively and vindictively prosecuting +him over allegations he attempted to extort Nike by threatening to go public with evidence of illicit payments to +amateur basketball players in violation of NCAA rules during settlement negotiations for a potential lawsuit by a +California youth coach. +Avenatti argued that prosecutors went after him without even looking at the "claim of right" of his client Gary +Franklin Sr., a former coach for a youth basketball team in California sponsored by Nike's Elite Youth +Basketball, or EYB, program. Franklin sought to file the suit before Avenatti even came on board after he grew +uncomfortable with Nike EYB executives making him funnel illicit payments to his youth players, Avenatti +argued. +"The haste with which this white-collar case was brought ... without any meaningful attempt to understand the +underlying facts or Coach Franklin's 'claim of right' — raises significant questions about law enforcement's +motives," the motion said. "It raises serious questions as to why, in a white-collar case, the [U.S. Attorney's +Office for the Southern District of New York] disregarded its usual deliberate and careful investigative process in +favor of a quick arrest of Mr. Avenatti and a big media splash." + + +Prosecutors say Avenatti threatened to extort Nike by revealing the misconduct allegations on the eve of its +quarterly earnings call if Nike didn't pay his client $1.5 million and hire Avenatti and another attorney to conduct +an internal investigation costing between $15 million and $25 million. +In Wednesday's motion to toss those charges, Avenatti's legal team provided a taste of the type of evidence +Avenatti claimed he would unveil, arguing that it was evidence that Franklin had a valid legal claim against Nike +and that the company was in need of an internal investigation. +The motion references an alleged text exchange in February 2017 between Jamal James, a former executive with +Nike EYB, Carlton Debose, director of the EYB program, and Nike's former recruiting coordinator John Stovall. +James allegedly texted Debose and Stovall asking whether they would be "willing to do ... whatever may be +needed" for Williamson, then Indiana University basketball player Romeo Langford and another unnamed player +from Michigan. +Stovall responded with a list: "Langford - 20 Zion - 35 plus [minor] - 15." +Debose then sent a text that he was willing to pay the trio "$70,000" and that they should "stay aggressive," the +motion alleged. +Williamson went on to play at Duke, a Nike-sponsored school and was selected No. 1 overall by the New +Orleans Pelicans in this year's NBA draft. He later signed a shoe sponsorship deal with Nike's Jordan Brand. +Langford was selected 14th overall by the Boston Celtics. +NCAA rules prohibit recruits from receiving such payments, and last year a former Adidas executive and another +consultant were convicted last year on corruption charges brought by the same prosecutor's office for the similar +illicit payments aimed at steering players to Adidas schools. +A Nike spokesman issued a statement to Law360 Thursday that said: "Nike will not respond to the allegations of +an individual facing federal charges of fraud and extortion. Nike will continue its cooperation with the +government's investigation into grassroots basketball and the related extortion case." +Avenatt's motion further questioned whether U.S. Attorney for the Southern District of New York Geoffrey +Berman was a "stalking horse" for President Donald Trump after he and the president got into a public feud over +Avenatti's representation of adult film actress Stormy Daniels +— whose real name is Stephanie Clifford - +- in a +lawsuit over a hush-money deal with Trump. +The motion questioned why Berman, who was appointed by Trump after working for and donating to his +presidential campaign, did not recuse himself as he did with an investigation into Trump's personal lawyer +Michael Cohen, who negotiated the alleged hush-money. +"That Mr. Avenatti would not have been prosecuted except for the animus is abundantly clear given that USA +Berman has opted to not seek an indictment of the only other similarly situated individual (or Nike, for that +matter, and its executives)," the motion argued. +The other individual is celebrity lawyer Mark Geragos, who represented former NFL quarterback Colin +Kaepernick in a collusion grievance against the league. Avenatti and Geragos met with Nike's attorneys from +Boies Schiller Flexner LLP, who reported Avenatti to federal investigators, about a potential pre-lawsuit +settlement in Franklin's case just four days before prosecutors brought charges against him. Geragos has not been +charged. +The Nike extortion case is just one of three federal criminal cases Avenatti is facing. In one of those cases, Los +Angeles federal prosecutors have charged him with embezzling millions from five separate clients, tax evasion +and obstruction, bank fraud, and bankruptcy fraud. + + +On Wednesday, a receiver for Avenatti's defunct law firm Eagan Avenatti LLP urged the California federal court +in that case to prohibit Avenatti from having "unfettered access" to client files and electronic data at the firm +because it would present "unacceptable risks that such access may lead to unnecessary and irreparable damage to +the rights and interests of EA's former clients." +Representatives with the U.S. attorney's office and Avenatti did not respond to requests for comment Thursday. +Avenatti is represented by Jose M. Quinon and Scott A. Srebnick. +The government is represented by Matthew D. Podolsky, Robert B. Sobelman and Daniel C. Richenthal of the +U.S. Attorney's Office for the Southern District of New York. +The case is U.S. v. Avenatti, case number 1:19-cr-00373, in the U.S. District Court for the Southern District of +New York. +Epstein +New Jersey's Teterboro Airport was travel hub of Jeffrey Epstein's sex traffic ring +USA Today +Christopher Maag +8/16/19 +Jeffrey Epstein's globe-trotting life of luxury and alleged sex trafficking traveled through an unlikely hub: +Teterboro Airport in New Jersey. From his mansion in Manhattan to his ranch in New Mexico and his island in +the Caribbean, Epstein allegedly used his fleet of private jets to deliver dozens of sex slaves - some as young as +14- to celebrities, royals and famous politicians, according to statements made in criminal and civil court filings +since 2008, some of which were first released to the public last week. +The heart of Epstein's global transportation network was a corporate airport carved from a New Jersey swamp. +His planes, which ranged from a Cessna to a Gulf Stream jet to a Boeing 727, recorded at least 730 flights to and +from Teterboro between 1995 and 2013, according to flight logs contained in documents unsealed last week by a +federal court in a lawsuit brought by one of Epstein's alleged victims against one of his close associates. +This represents roughly a third of all of Epstein's flights, more than any other airport recorded in the logs. +Epstein was arrested July 6 at Teterboro Airport after flying from Paris. He was charged with two counts of sen +rathicking. In the indictment, the U.S. Attorney's Office for the Southern District of New York, said Epstein anc +his employees operated a sex trafficking network that transported dozens of girls between his homes in Palm +Beach, Florida, and Manhattan. +Epstein will never see trial. +He was found dead in his jail cell at the Metropolitan Correctional Center in New York City on Aug. 11. Two +days later, U.S. Attorney General William Barr pledged to continue the investigation into Epstein's trafficking +network and possible co-conspirators. +"Let me assure you that this case will continue on against anyone who was complicit with Epstein," Barr said at +a news conference. + + +If that investigation moves forward, flight logs from Epstein's planes may prove to be an essential piece of +evidence. The logs are voluminous, spanning thousands of flights between 1995 and 2013. +The logs were kept by David Rodgers, just one of at least six pilots employed by Epstein at various times, court +documents show. +The other pilots included +Bill Hammond. Pete Rathgeb, Gary Roxburgh and Bill Murphy, +according to a statement of facts illed by +in her 2015 lawsuit against Epstein associate +Ghislaine Maxwell. In that suit. +alleges Epstein lent her out as a minor for sex with his friends. +Logs from the other pilots have not surfaced in court records. +Iwere subpoenaed by federal +prosecutors in Manhattan shortly after Epstein's arrest in July, The New York Times reported, and both pilots +have cooperated with the investigation. +Attempts to reach +for comment were unsuccessful. +Epstein and his associates also allegedly booked some of his sex trafficking victims on commercial flights, +according to statements in court documents. +The logs, all 106 pages of which are written in +blocky handwriting, mirror the ups and downs of +Epstein's professional and personal life. According to statements made in state and federal court documents, they +also show the names and initials of Epstein's victims, and of the people he allegedly employed to help operate +his sex trafficking network. +The logs record 322 flights between Teterboro and Palm Beach, the site of Epstein's waterfront mansion. This is +where Epstein recruited dozens of girls to provide him and his associates with massages and sex, according to +claims made in documents from a local police investigation that were recently unsealed in federal court. +flew Epstein's planes an additional 112 times between Teterboro and the U.S. Virgin Islands, where +Epstein owned a 78-acre island with a mansion and two swimming pools, the flight logs show. It was there on a +beach in 2001 that +and +performed massages and sex with Epstein, according to +a court deposition by +who was 21 at the time. +was 17. She flew to and from Teterboro on Epstein's jet eight times starting when she was 16, according +to the logs. In the Caribbean, workers at the airport in St. Thomas were disgusted to see Epstein, by then a man +in his late 40s, flying with so many underage girls, according to interviews published by Vanity Fair magazine. +Teterboro Airport +Teterboro Airport sits in the floodplain of the Hackensack River, 12 miles west of Manhattan. It is a popular +destination for corporate jets, which often ferry wealthy business executives and celebrities to and from New +York City. +It operates as a reliever airport, removing smaller and slower aircraft from the congested flight paths of the +region's three large commercial airports - LaGuardia, JFK and Newark Liberty. Most flights at Teterboro are +coordinated by five fixed-base operators, private companies that operate as one-stop shops for wealthy plane +owners. These operators handle everything from aircraft maintenance and fueling to baggage handling and hotel +reservations for passengers. +All workers at Teterboro Airport receive training to report suspicious activity to law enforcement, said Cheryl +Ann Albiez, a spokeswoman for the Port Authority of New York and New Jersey, which owns the airport. +Members of the Port Authority Police Department patrol the airport, Albiez said, and are instructed to report +matters, including sex trafficking, to the FBI. + + +"Teterboro is really an airport for the rich and famous," said Taina Bien-Aimé, executive director of the New +York-based Coalition Against Trafficking in Women. "The customers there are very privileged, and can pull +strings that can lead to confidentiality." +The flight logs unsealed by a federal court judge Aug. 9 list 82 trips to and from Teterboro by +and +48 trips byl +According to a 2008 plea agreement in an earlier sex trafficking case in Florida +which reduced Epstein's punishment from a potential life sentence to 13 months in jail +were identified as "potential co-conspirators." +Epstein's planes ferried underage girls from Teterboro to his various homes, according to allegations in court +documents. Epstein's planes also flew direct from Teterboro to Paris, London, Ireland and Aspen, according to +the flight logs. Prominent people listed in the logs as flying through Teterboro on Epstein's planes included Bill +Gates and Alberto Pinto, a famous interior designer. +Another person who appears in the logs is Alan Dershowitz, a famous lawyer who helped lead Epstein's legal +defense team against sex trafficking charges in 2007. Dershowitz was listed as flying through Teterboro on +Epstein's planes seven times, according to the logs. The trips included one flight on Feb. 5.2004, in which the +logs indicate Dershowitz flew from Teterboro to Palm Beach accompanied by Epstein and +has claimed in various legal actions, including one as recent as April 2019, that Epstein forced +her to have underage sex with several of his associates, including Dershowitz. +flight logs do not indicate that Dershowitz and +were ever on the same flight. +Dershowitz has aggressively denied +Dershowitz for defamation. +allegations, calling her a liar. +responded by suing +In that complaint, +claims she was "regularly abused by Epstein and was lent out by Epstein to others for +sexual purposes." +"Dershowitz was also a participant in sex trafficking, including as one of the men to whom Epstein lent out +Plaintiff for sex," according to the complaint filed with the U.S. District Court in the Southern District of New +York. +Oral arguments in the defamation case are scheduled for next month. Dershowitz has filed a motion to dismiss. +Lolita Express +Another person who appears hundreds of times in the flight logs is Ghislaine Maxwell, a close friend of Epstein. +In depositions related to +civil lawsuit against Maxwell, which were recently unsealed by a federal court +judge in Manhattan, several women alleged that Maxwell served as a recruiter and manager of Epstein's network +of underage girls. Maxwell has vigorously denied the allegations, and she has never been charged with a crime. +case against Maxwell settled in 2017. +According to the flight logs, Maxwell flew hundreds of times on Epstein's Boeing 727, a former commercial +airliner coined the Lolita Express by news tabloids, a nickname based on Vladimir Nobokov's novel about a +middle-aged professor who repeatedly rapes a 12-year-old girl. +The plane is registered with the FAA using a tail number that ends in Epstein's initials, JE. Other planes that +appear in +Logs include a twin-engine Cessna with a tail number ending in Maxwell's initials, GM. Both +planes spent days on the tarmac at Teterboro when not in flight, according to the logs. + + +The logs also appear to document changes in Epstein's business and social standing. +Beginning in 1995 and continuing for several years, Epstein flew regularly tol +home to +billionaire executive +founded +I a company that owns retail chains including +Over time the two men grew so close that +gave Enstein power of attorney over his personal finances, +with broad authority to invest and borrow money onl +behalf. Those details were included in an Aug. 8 +letter from +to members of the l +•Foundation, a charity he controls. The letter, which attempts to +explain +relationship with Epstein, was also sent to news organizations. +According to the letter, +cut ties with Epstein in 2007, as Epstein prepared to defend himself against +charges of trafficking young girls in Florida. +Around that time, Epstein's flights to +ceased, according to the flight logs. +How the logs were being recorded also changed. +For years, +filled his logs with the names and initials of people boarding Epstein's planes. When he +didn't know his passengers' names, +saagunted for them by writing notations such as "3 females" or "2 +nannies," according to an interview with +by Palm Beach police contained in recently unsealed court +documents. +But in February 2007, as state and federal investigators ramped up their investigations into Epstein's alleged +trafficking ring, the names and initials of many of the passengers were no longer recorded in the logs. +Prosecutors seek to question +with ties to Epstein +NY Post +By Lia Eustachewich +8/16/19 +Prosecutors in the US are seeking to interview a +with links to Jeffrey Epstein, according +to a new report. +Epstein's accusers told investigators that +was part of the convicted pedophile's inner circle in the +early 2000s, The Telegraph in the UK reported. +One of the alleged victims, +said +once showed her how to massage Epstein at his +mansion in Florida, according to court documents unsealed earlier this month. +"At that point, I met +and she took me up to Jeffrey's bathroom and he was present,"| +said in a deposition. "And her and I both massaged Jeffrey. She was showing me how to massage. And then she +— he took — he got off the table, she got on the table. She took off her clothes, got on the table, and then he was +showing me moves that he liked. And then I took my clothes off. They asked me to get on the table so I could +feel it. Then they both massaged me." +perved as a personal assistant to Ghislaine Maxwell, Epstein's girlfriend and alleged madam who victims +said groomed them to become his sex slaves. +told lawyers that Maxwell referred to +as "her slave," according to the filing. + + +Flight logs indicate that she flew on Epstein's so-called "Lolita Express" around the same time Epstein was +allegedly trafficking girls and her name appeared in his "little black book" of contacts, The Telegraph said. +with the dream of becoming a model or +actress and met Maxwell in New York. Maxwell set the young woman up in a Florida apartment and promised to +take care of her in exchange for running errands and doing paperwork. +ives in +and works as a +She could not be reached for comment by The Telegraph. +Jeffrey Epstein's former cellmate cleared of wrongdoing in incident that preceded his death +NBC News +By Rich Schapiro and Jonathan Dienst +8/16/19 +Jeffrey Epstein's former cellmate was cleared of any wrongdoing in the incident that left Epstein semiconscious +in his cell three weeks before his death, according to the cellmate's lawyer and a source familiar with the matter. +Epstein, the disgraced financier who was facing federal sex-trafficking charges, was placed under suicide watch +after he was found in a fetal position with marks around his neck inside the cell he was sharing with Nicholas +Tartaglione, a former upstate New York police officer facing quadruple murder charges. +The July 23 incident at Manhattan's Metropolitan Correctional Center (MCC) was being investigated as a +possible suicide attempt, assault or ruse by Epstein to get himself transferred to a different facility after he was +denied bail on the sex-trafficking charges, officials said at the time. +But Tartaglione's lawyer Bruce Barket told NBC News that the day before Epstein's death, officials at the MCC +informed him in an email that the internal investigation had concluded and his client would face no charges or +internal discipline. +"We've always maintained Nick did nothing wrong and that's clearly been borne out here by the jail itself," +Barket said. +An official familiar with the case confirmed Barket's account. A spokesperson for the MCC declined comment. +The disclosure deepens the mystery over why Epstein was removed from suicide watch in the days before he +apparently took his own life. +Federal prison officials have released no information on the July 23 incident. Prison experts said the decision to +take Epstein off suicide watch, where he would have been placed in a special cell and observed on a round-theclock basis, would have been more appropriate if the incident was determined to be an assault as opposed to an +attempt on his life. +"What this means is that whatever happened to Epstein was inflicted on himself," said Cameron Lindsay, a +former warden at four federal facilities. "It looks like a pretty straightforward case of someone who wanted to +die." +Lindsay said the "prudent, safe decision" would have been to keep him on suicide watch. +"Gosh, if I were him I'd want to be dead and I'm sure there are a multitude of people that would have wanted him +to be dead," Lindsay said. "It's corrections 101." + + +Epstein, 66, died last Saturday in an apparent suicide inside his cell in a special housing unit where he was +supposed to be checked every 30 minutes. +The death has brought increased scrutiny on the federal prison system, with lawmakers demanding answers on +how a high-profile inmate facing up to 45 years in prison could be left alone after a previous incident that raised +questions about his emotional state. +The FBI and the Justice Department Office of Inspector General are investigating the circumstances of Epstein's +death at the MCC. +The judge overseeing the federal sex trafficking case asked for details of the incident after the MCC's warden +filed legal papers to officially inform the court of Epstein's death. +"One open question, among others, is whether the investigations referenced in your letter will include the +incident at MCC involving Mr. Epstein on or about July 23, 2019," Judge Richard Berman wrote in his response +dated Aug. 12. +"To my knowledge, it has never been definitively explained what the BOP concluded about that incident." +The warden, who has since been reassigned from the facility, responded the same day but offered no new +information. +"I can confirm that, although an internal investigation was completed regarding the July 23, 2019 incident, the +current investigations by the FBI and OIG will include this incident as well," wrote the warden, Lamine N'Diaye. +"Accordingly, I cannot divulge any information about the prior investigation at this time." +Complex Frauds and Cybererime +Panama Papers +Privilege Can't Shield Does In Panama Papers Case, US Says +Law 360 +By David Hansen +8/15/19 +A Boston financier embroiled in the fallout from the Panama Papers document leak can't shield communications +and documents from disclosure because they were used to commit crimes, the government has told a New York +federal court. +Harald Joachim von der Goltz's discussions with attorneys furthered illegal activities such as hiding assets +subject to U.S. taxes and willfully neglecting to file foreign bank account reports, the government argued in a +motion filed Wednesday. The government asked the court to waive attorney-client and work product protections +for the communications and documents under the crime-fraud exception. +"The government easily satisfies its burden of showing that documents reflecting relevant information were +made in furtherance of a fraud or crime and, accordingly, the crime-fraud exception applies," it said. +Von der Goltz already had disclosed the information anyway, in depositions and other communications with +government attorneys, so the documents shouldn't be protected, the government added. +Von der Goltz was indicted in December over his role in what prosecutors say was a decades-long criminal +scheme run by law firm Mossack Fonseca & Co. and related entities to evade U.S. taxes through offshore bank + + +accounts and shell companies, among other means. +With help from Mossack Fonseca, the government contends, clients such as von der Goltz used shell companies +in offshore jurisdictions with strict financial secrecy laws that were technically owned by sham foundations to +hide large amounts of money from the Internal Revenue Service. +The government seeks all communications von der Goltz made about his financial entities, including a family +trust and foundation, with his attorneys at Mossack Fonseca and two unnamed law firms referred to as the +Owens Firms. +Whatever privilege von der Goltz had was void because he used the services of Mossack Fonseca to create shell +companies holding unreported assets in the U.S. and overseas for himself, the government argued. In support, the +government cited a grand jury finding of probable cause that he conspired with agents at the firms to hide assets +of the entities. That has been sufficient to exert the crime-fraud exception to privilege in prior cases, it argued. +Von der Goltz also voluntarily waived privilege over information about the financial entities, the government +argued. He was named in news reports about the Panama Papers, a breach of about 11.5 million Mossack +Fonseca documents detailing offshore financial services it provided to wealthy clients. This public information +served as a waiver of privilege, and von der Goltz did not object to it, the government said. +In addition, von der Goltz disclosed information about his financial entities during a subsequent federal +investigation, the government argued. He did not assert privilege over the discussions until "many months later," +the government said. +William A. Burck, an attorney for von der Goltz, declined to comment. +Representatives of the government did not respond to a request for comment. +The government is represented by Eun Young Choi, Thane Rehn and Kristy Jean Greenberg of the U.S. +Attorney's Office for the Southern District of New York, and by Michael Parker and Parker Tobin of the U.S. +Department of Justice's Criminal Division. +Von der Goltz is represented by Alexander Benjamin Spiro, William A. Burck and Daniel Rickert Koffmann of +Quinn Emanuel Urquhart & Sullivan LLP. +The case is U.S. v. Ramses Owens et al., case number 1:18-cr-00693, in the U.S. District Court for the Southern +District of New York. +Goldstein +4th NY Doc Charged With Taking Insys Kickbacks Cops Plea +Law 360 +By Pete Brush +8/16/19 +A Manhattan osteopathic doctor pled guilty Friday to taking $196,000 from Insys Therapeutics Inc. to prescribe +its Subsys painkiller, becoming the fourth of five New York physicians charged with taking kickbacks in the +form of speaker fees to admit guilt. +Jeffrey Goldstein, 49, copped to a count of conspiracy before U.S. Magistrate Judge Henry Pitman. He faces a +maximum prison sentence of five years at his sentencing, tentatively scheduled for Jan. 22 before U.S. District + + +Judge Kimba M. Wood. +Goldstein said he took Insys speaker fees from 2013 to 2015, which actually were kickbacks that influenced him +to prescribe Subsys, a powerful painkiller, to patients. He said he never prescribed the fentanyl spray in a way +that was medically unnecessary. +"I am sorry for what I've done and I apologize to the court," he said. +Goldstein faces a possible prison sentence in the range of four years and nine months to five years, according to +his plea agreement. He has agreed to forfeit $196,000. +Prosecutors say the Insys speaker program consisted of "predominantly social affairs" where no educational +presentation occurred. Attendees' signatures were sometimes faked at the events, they say. +Three other doctors — Alexandru Burducea, Todd Schlifstein and Dialecti Voudouris — who were arrested and +charged alongside Goldstein in 2018 by the Manhattan U.S. attorney's office have also entered guilty pleas. +An attorney for Goldstein, Marc Agnifilo of Brafman & Associates PC, reiterated after the hearing that his client +"never sacrificed his medical judgment." +"The gravamen of the crime is economic in nature," Agnifilo said. "There's no allegation that the prescriptions +were medically inappropriate in any way." +A fifth defendant, anesthesiologist Gordon Freedman, remains on track to stand trial before Judge Wood. Unlike +his co-defendants, Freedman faces more serious charges. Prosecutors say Freedman prescribed "staggering +quantities" of Oxycodone and fentanyl that killed a patient. +Goldstein is represented by Mare Agnifilo and Jacob Kaplan of Brafian & Associates PC. +The government is represented by David Abramowicz and Noah Solowiejczyk of the U.S. Attorney's Office for +he Southern District of New York +The case is U.S. v. Freedman et al., case number 1:18-cr-00217, in the U.S. District Court for the Southern +District of New York. +Violent and Organized Crime +Hernandez +Tekashi 6ix9ine accused of faking kidnapping for new album 'buzz' +NY Post +By Emily Saul +8/16/19 +A defense attorney for one of the men accused of kidnapping and robbing rapper Tekashi 6ix 9ine said Friday that +he believes that rainbow-tressed entertainer orchestrated the scheme himself to build publicity ahead of an album +"No robbery or kidnapping or assault happened," said Devereaux Cannick, the defense attorney for alleged +rapper-snatcher Anthony Ellison. "He was about to drop another album...gotta get that buzz up. That's how he +makes money." +The comments came after Manhattan federal court judge Paul Engelmeyer moved the trial for Ellison, who's +pleaded not guilty, and his alleged accomplice and fellow Nine Trey Gangsta Blood Aljermiah Mack back to + + +Sept. 16. +Tekashi, whose real name is Daniel Hernandez, is expected to testify against the two men as government +cooperator following his guilty plea earlier this year to federal racketeering charges. Prosecutors have said they +intend to introduce his music videos as evidence at trial. +Cannick also claimed Friday that the car used to kidnap the "GUMMO" crooner in July 2018 had been +inexplicably wired by the government ahead of time — meaning the whole encounter was recorded. +"We believe that's going to be very useful to us," the attorney said, smiling. +He added that the inked rapper's own Instagram account appears to show him unscathed in the days after the +charged attack. +In a video posted July 24, 2018, Tekashi says he's going to donate a percentage of profits from his latest album, +"FEFE," to charity. The footage then shows him handing out cash to screaming children in a playground. +Ellison and Mack both face up to life behind bars if convicted. A rep for Tekashi declined to comment. +Terrorism and International Narcotics +Akasha +Kenyan drug lord Baktash Akasha sentenced to 25 years +The Star (Kenya) +By Oliver Mathenge +8/16/19 +A US court has sentence self-confessed international drug trafficker Baktash Akasha to 25 years in prison. +The Presiding Judge Victor Marrero also imposed a US$100,000 (Sh10.3 million) fine on Baktash. +Baktash and his younger brother Ibrahim Akasha were charged for exporting tonnes of heroin to the United +States. +They pleaded guilty to the charges and agreed to a plea bargain with the office of the Manhattan district attorney. +Ibrahim will be sentenced by Presiding Judge Victor Marrero in November. +The Akashas were extradited from Kenya without the knowledge of their families or lawyers despite there being +a case in court challenging their extradition. +During the hearing in July, the judge said that he was "inclined" to accept the prosecution's narrative that the two +are brutal mobsters. +He based his sentiments on a claim that Baktash was involve in a contract killing of South African drug lord +identified as Pinky. +The two pleaded guilty to conspiring to import heroin into the United States and conspiring to import +methamphetamine into the United States. + + +They also pleaded guilty to distributing heroin while knowing and intending that the drugs would be imported +into the US, and distributing methamphetamine while knowing and intending that the drugs would be imported +into the US. +Each of these four crimes carries a maximum sentence of life imprisonment and a mandatory minimum sentence +of 10 years in prison. +The Akasha brothers also pleaded guilty to participating in a conspiracy to carry and use machineguns and +destructive devices during and in relation to, and to possess machineguns and destructive devices in furtherance +of, drug-trafficking offenses, which carries a maximum sentence of life imprisonment. +They also pleaded guilty to obstruction of justice, which carries a maximum sentence of 20 years in prison. +A document by the prosecution tabled in court on July 25, 2019 outlines reasons why the court should not be +lenient on the Akasha brothers. +These reasons include Baktash's killing of his former wife, tourturing his son, contracting killers to assassinate +his father as well as gun-trafficking operations with terrorist group al Shabaab. +"The Akashas protected their lucrative drug business with violence, murder, and related threats, doing whatever +was necessary to advance the criminal empire they inherited from their father after he was murdered in 2000," +the document by the prosecution states. +The document says that in 2014, as part of a sting operation by the Drug Enforcement Administration, the +Akashas were given the opportunity to import mass quantities of heroin and methamphetamine into the United +States. +"They jumped at the chance. Ultimately, the Akashas supplied confidential sources working at the direction of +the DEA with 99 kilograms of heroin and 2 kilograms of methamphetamine," it reads. +The prosecution also said that at the time of their arrest, the Akashas had another 500 kilograms of heroin en +route from the Afghanistan-Pakistan region towards Kenya for intended distribution in the United States. +"While the Akashas pled guilty to their involvement in this drug importation conspiracy, they have now denied +their participation in acts of brutal violence, and sought to minimize the extent of their historical drug +operations," US state attorneys told the court. +The prosecutors relied on the testimony of Vicky Goswami whoo they described as "the Akashas" trusted coconspirator who is now a cooperating witness for the Government. " +"Goswami is uniquely situated to provide the Court with an inside perspective of this crime family's illegal +businesses. He had a decades-long criminal relationship with the Akashas," they told the court. +In 2013, after he was released from a long prison sentence in Dubai, Goswami moved to Kenya and worked in +partnership with Baktash, Ibrahim, and others on their drug ventures and violence. +Goswami told the Court, the Akashas' involvement in, among other things, the murder of Pinky; the kidnapping +and assault of rival drug trafficker David Armstrong. +He also gave details of violent attacks on associates of another rival drug trafficker Ali Punjani, including the +kidnapping of an individual known as "Speedy" and the near-fatal assault of Tony Sanghani. +Goswami also described the Akashas' extensive use and possession of firearms, including handguns, +machineguns, and grenades, as well as the Akashas' gun-trafficking operations with terrorist group al Shabaab. + + +The prosecution also used Goswami to describe how the Akashas used violence and guns as part of an illegal +extortion business in Kenya. +"Goswami is also expected to testify about Baktash's violent behavior outside of his illegal businesses, including +torturing one of his children, beating his current wife, and murdering his prior wife," the prosecution said at the +pre-trial stage. +According to Manhattan US Attorney Geoffrey Berman, Baktash and Ibrahim Akasha were the leader and deputy +of a sophisticated international drug trafficking network, responsible for tons of narcotics shipments throughout +the world. +"Not only did they manufacture and distribute narcotics for over two decades, they kidnapped, beat, and +murdered others who posed a threat to their enterprise," Berman said. +He added that when the brothers encountered legal interference, they bribed Kenyan officials — including +judges, prosecutors, and law enforcement officers- +- in an effort to avoid facing the charges against them in the +United States. +Matters of Interest +Trial-Heavy Fall Will Test FCPA Unit, Shape Law +Law 360 +By Jody Godoy +8/15/19 +Prosecutors from the U.S. Department of Justice's Foreign Corrupt Practices Act unit are set to try six cases this +October, an unprecedented boom that will require prosecutors to multitask and may give courts more chances to +interpret foreign-bribery law. +The Foreign Corrupt Practices Act unit at the U.S. Department of Justice will have its hands full this fall with six +trials set to start. (AP) +The half-dozen trials slated for October run the gamut from core FCPA cases to money laundering and fraud +charges connected to foreign bribery. The sudden glut of trials stems from the FCPA unit bringing more cases, a +sign that it is coming into its own, said Fry Wernick, a former assistant chief of the unit who recently joined +Vinson & Elkins LLP. +"I think you see a maturing of the unit. Where you have been charging more and more individuals, inevitably +you will have more and more trials. In the past, you would typically see one trial every year or two," Wernick +In the past, the FCPA unit has focused much of its energy on corporate settlements. Judges play a minimal role in +those deals, leaving it largely up to prosecutors and defense attorneys to decide what constitutes a violation of +the law. That essentially means settlements and DOJ guidance stand in for legal precedent. +While most companies can't risk the consequences of trial and potential conviction, individual defendants have +different incentives and are putting the government to the proof and testing legal theories. Emily Westridge +Black of Haynes and Boone LLP sees this as a good thing +"From the defense side, the hope and expectation is that we will be able to establish some enforceable limits to +liability, and then also that there will be additional clarity about what the statute actually means," Black said + + +Tarek Helou of Wilson Sonsini Goodrich & Rosati PC, who recently left the FCPA unit as an assistant chief, +noted that the more successful prosecutors are at trial, the more chance defendants have to press their case in the +appeals courts, which can dictate how federal courts apply the FCPA in each region. However, he doesn't think +that is a cause for concern for the DOJ. +"It will help shape the law. But I don't think it is going to shape it in a way that is inconsistent with what we have +done," Helou said. +The FCPA unit is not trying the cases alone. Prosecutors from U.S. attorney's offices and, in one case, the DOT's +Money Laundering and Asset Recovery Section are working with them. But the raft of proceedings could put a +dent in the number of corporate settlements the unit finishes by the end of the year, particularly since FCPA unit +chief Daniel Kahn and two of his three assistant chiefs are slated to try some of the cases personally. +Wernick said that while the trials may not necessarily get in the way of settlements, they are bound to have an +effect on the unit, given the all-encompassing nature of trial preparation. +"There is certainly going to be a need to shift resources to cover for the trials. They can do it. It's just a new +problem that they are going to have to deal with," Wernick said. +In the most highly anticipated of the six trials, former Alstom SA executive Lawrence Hoskins will confront +charges in Connecticut federal court that he set up a scheme to bribe Indonesian officials. The British executive's +case led to an important ruling by the Second Circuit that said prosecutors can't charge a person with conspiring +to violate the FCPA if the individual couldn't be charged with violating the law itself. +The effect is that prosecutors at Hoskins' trial will have to prove that the Alstom executive was an "agent" of the +company's subsidiary. +The trial itself will test what that term means in practice. Black pointed out that the DOJ's 2012 FCPA Resource +Guide states that "the fundamental characteristic of agency is control" — something one doesn't expect to be +exercised from the bottom up. +"From a practitioner's standpoint, it will be fascinating to see what evidence they will have to show that an +officer of a parent functioned as the agent of a subsidiary," Black said. +Meanwhile, a circuit split could be in the works. Dmitry Firtash, a Ukranian national charged with conspiracy to +violate the FCPA, lost a motion to dismiss that count when an Illinois federal judge refused in June to follow the +Hoskins ruling, stating that the Seventh Circuit puts few limits on conspiracy charges. +Black noted that if a split does materialize, it could make an attractive question for the U.S. Supreme Court to +weigh in on, given the court's interest in statutory interpretation and harmonizing criminal law in the circuits. +The Hoskins case, with all the interesting legal issues involved, is only one of the trials the FCPA unit has on its +plate. +In Brooklyn on Oct. 7, Lebanese salesman Jean Boustani faces allegations that he bribed Mozambican officials +to obtain business for shipbuilder Privinvest. While some of Boustani's co-defendants are charged with FCPA +violations, he himself is not. He suggested in a recent motion to dismiss that such charges wouldn't have stuck in +light of Hoskins, and argued the securities fraud charges against him should be tossed because they don't apply to +foreign transactions. +In Miami on Oct. 15, former financial adviser Frank Chatburn Ripalda is set to face nine criminal counts, +including conspiracy, FCPA violations and money laundering, over alleged schemes to bribe PetroEcuador +officials on behalf of Ecuadorian company GalileoEnergy and Brazilian construction firm Odebrecht. + + +On the same day, a federal judge in Fort Lauderdale is scheduled to begin trial in another PetroEcuador case. +Armengol Alfonso Cevallos Diaz, an Ecuadorian national residing in Florida, faces charges of money laundering +and conspiracy to violate the FCPA for his role in funneling $4.4 million in bribes to PetroEcuador officials, +including payments from GalileoEnergy. +FCPA unit assistant chief Lorinda Laryea is scheduled to try the Hoskins case and has appeared in both the +Chatburn and Cevallos Diaz cases. +On Oct. 28, the same day the Hoskins trial opens, former Barbados minister Donville Inniss is scheduled to go +on trial in Brooklyn. +Inniss is not charged with violating the FCPA but rather with conspiracy and money laundering for allegedly +taking $36,000 in bribes from an insurer called the Insurance Corp. of Barbados Ltd. It is the second time the +FCPA unit went after a foreign official after a company disclosed bribes and itself dodged charges under the +FCPA corporate enforcement policy. The other case is on appeal in the Ninth Circuit. +The last of the six trials is scheduled to begin the next day in Maryland. Former Transport Logistics International +Inc. executive Mark Lambert stands accused of bribing a Russian energy official to get the company contracts +with the Russian government. According to Wernick, who was on the case before he left the DOJ, FCPA assistant +chief Christopher Cestaro has joined the trial team. +The trial pileup is due in part to the number of individuals the FCPA unit has charged, which has gone up slightly +in the past three years, according to an annual tally by Shearman & Sterling LLP. According to the firm's figures, +21 people were charged in 2018, a nine-year high. +The unit is on track to top that, with 21 individuals already charged in 2019, according to the DOJ. +An increase in prosecutors and agents is behind the uptick in cases, Wernick said. The unit has grown from 19 +attorneys in 2014 to its current 32 and sought to hire more experienced attorneys over the same period, he said. +In 2015, the FBI created permanent international corruption squads in New York, Los Angeles and Washington, +D.C., and it added a fourth this year in Miami. On top of that, Wernick pointed to criminal investigators from the +IRS and the Department of Homeland Security working with the FCPA unit as well as the increased access to +foreign evidence that U.S. prosecutors get via tighter relationships with their overseas peers. +More agents means cases can be made the old-fashioned way, through wiretaps, undercover work and flipped +cooperators. Those methods are also subject to challenges by defendants who feel their rights were violated; +several challenges have been raised this year. +Chatburn claimed it was improper for a cooperator to tape his calls after he retained counsel. Lambert called for +an evidentiary hearing into an FBI informant and cooperator's roles in recruiting him into the alleged bribery +scheme. And Richard Boncy and Joseph Baptiste, who were convicted in Boston this year of a scheme to bribe +officials in Haiti, complained that the FBI deleted some calls that agents recorded +Those bids have not succeeded so far, but as with all trials, they could resurface if the cases end up on appeal. +I Tried to Tell the World About the MCC. No One Wanted to Listen. +The Atlantic +By Jeanne Theoharis +8/16/19 + + +"URGENT," the emails were marked. Since Jeffrey Epstein's death at the Metropolitan Correctional Center, at +least 20 reporters and shows from a broad cross section of the nation's major news outlets have reached out for +context and comment about the federal penitentiary. I spent a decade trying to get media outlets to pay attention +to the Metropolitan Correctional Center in Lower Manhattan, pleading with journalists for hours on the phone, +over email, and in person, to launch investigations of the jail. Over and over, for years, these media organizations +did not follow up. +Suddenly, there was urgency to talk about the conditions at MCC. The jail now provided an intriguingly grimy +backdrop to an already sordid story. The question is whether a sustained light will actually be shined on the +conditions there, or whether the widespread fascination with MCC just becomes part of the spectacle. +I spent years, alongside lawyers, civil-rights leaders, concerned citizens, and family members of the incarcerated, +taking part in vigils outside MCC to call attention to the inhumanity happening within its walls. Over and over, +Department of Justice officials did nothing. +I went to court hearings and read court filings where people being held there attested to the inhumane conditions +at MCC. Judges repeatedly refused to intervene. Nearly all were persuaded by the government's incessant claims +that such conditions were justified by necessity and national security. +When the news broke about Epstein's death, Attorney General William Barr said he was shocked, calling for an +investigation into the "serious irregularities" at MCC. Then on Tuesday, attempting to foist the blame on +underlings, he reassigned the warden and put two guards on administrative leave. +This is willful shock, a deeply disingenuous surprise. The scandal is not a few rogue employees. The surprise is +not that a man in federal custody who had shown suicidal tendencies managed to kill himself, nor conversely that +a man could be killed behind bars. Barr and his DOJ (like previous DOJ officials) knew MCC was structured on +"irregularities." So did U.S. Attorney Geoffrey Berman, and his predecessor, Preet Bharara. So did the judges of +the Southern District of New York. The federal prison system is replete with "irregularities." +The real scandal is that the horrors of MCC have existed for decades, hidden in plain sight. The journalist Aviva +Stahl published a searing exposé last year in Gothamist on conditions at MCC that documented the filth, rodents, +overflowing sewage, deeply substandard medical care, wrenching isolation, and the often indifferent and at +times, cruel-staff. From reports from lawyers and people imprisoned there, to the legal motions they have filed +attempting to mitigate the inhumane conditions, to the hundreds of administrative remedies prisoners have filled +out to request remediation (the first step prisoners must take to document problems with their conditions), to the +research of scholars and human-rights organizations, the abusive and corrupt conditions at MCC are well +documented. +But a broad swath of public officials, from the attorney general on down, have chosen to countenance these +conditions-—and major news organizations haven't pressed the issue. As attention finally came to the despicable +conditions at Rikers, few journalists looked across the river to MCC. Perhaps many labored under the +misapprehension that while state and local (and private) jails might be mismanaged, abusive, and decrepit, the +federal government runs a largely rights-respecting, clean operation. On top of this, the federal government—and +the Bureau of Prisons in particular—-makes it supremely difficult to investigate its prisons and jails, constantly +throwing up justifications for denying access to the materials researchers want ("too burdensome," " national +security," "privacy," "internal agency workings") and shrouding their practices in secrecy. +When news about MCC reaches the public, it typically comes in sensational stories about alleged megacriminals such as Epstein, Sammy "The Bull" Gravano, or Joaquin "El Chapo" Guzman being held there the +crimes with which they are charged completely obscuring the jail itself. Moreover, while Americans broadly +profess to oppose torture and cruelty, there's a tendency to look away from (or even take some glee in) the +abusive conditions facing incarcerated people, particularly those who are publicly reviled. + + +I don't know why the overwhelming majority of journalists I talked with over the years never published serious +investigations into MCC. Perhaps racialized assumptions played a role, separating victims of government abuse +whose situations seemed urgent and worthy of months of painstaking research from those who are assumed to +pose exceptional danger and thus perhaps deserve extreme measures. I was highlighting the inhumane conditions +that largely unknown Muslims facing terrorism charges were experiencing at MCC. Now they are calling me +about the über-rich, white Jeffrey Epstein. +Or perhaps it was the simple incongruity of the U.S. government running a high-rise dungeon in Manhattan's +financial district, which featured conditions more commonly associated with the jails of foreign dictatorships. +The descriptions of the dirty, decrepit, vermin-infested, hyper-isolating jail sitting in an elite zip code never +seemed to stick. +The public attention to Epstein's suicide could change that but only if the public resists the seductive scandal of +it all and insists on seeing the structural problems that Epstein's time at MCC exposes. +First the basics: MCC is a pretrial federal facility run by the Bureau of Prisons, which is part of the Department +of Justice and overseen by Congress, that holds people awaiting trial on charges in the Southern District of New +York. This means that the people it holds are presumed innocent, and the law ostensibly prohibits their +punishment before conviction. Opened in 1975, MCC today houses about 750 people in a facility built for fewer +than 500. The conditions of their confinement vary widely, depending on where they are held, from the general +population to the Special Housing Unit on the ninth floor to the fearsome 10 South wing. The SHU is for people +the jail deems not safe in general population or who have allegedly broken jail rules; it features much more +restrictive conditions, including solitary confinement. Epstein began in the general population but was reportedly +in the SHU on 9 South when he died. +Lawyers and people held there awaiting trial regularly report appalling conditions. The temperature is not +adequately regulated; the facility is often sweltering in the summer and so cold in the winter that prisoners report +having trouble thinking and wearing layers of clothes to be able to sleep. A single psychiatrist serves both MCC +and the Metropolitan Detention Center, another federal facility located in Brooklyn. People report being +"treated" through the slat in their cell door. The facility is run down, and the plumbing and elevators break often. +The most inhumane section of MCC is 10 South. The majority of the people held there over the past two decades +have been Muslims facing terrorism charges; Guzman was held there as well. No outdoor recreation is allowed +for 10 South prisoners, and windows are frosted so they are cut off from natural air and light. Besides the filth +and vermin (even cell-cleaning supplies are often denied), one chief complaint is the lack of ventilation. On 10 +South, prisoners are alone in their cells almost all of the time; they even shower there. Their sole escape is the +hour when they are moved to a solitary cage for exercise. Sometimes, that recreation is denied, leaving prisoners +to go days without leaving their cells. Cells are electronically surveilled, so that every action including using +the toilet, showering, and talking is monitored. +The defense attorney Robert Boyle has described the conditions at MCC as producing "a continuing +deterioration in his [client's] health" and has noted reports from other lawyers with clients in similar conditions +"unable to make rational decisions in relation to the trial they face." +Nearly all of the people held on 10 South are under special administrative measures imposed by the attorney +general, which restrict their communication with the outside world. On 10 South, you can be punished for +yelling through the walls, for saying "As-Salaam Alaikum" to another prisoner, for making the call to prayer. +While some talk between prisoners through walls or doors is not punished, there is always the threat of +punishment, and sometimes guards exercise their prerogative to do so. Prisoners report going months without +any talking all before they have been convicted of any crime. +The SAMs also mean that anyone in contact with the prisoner, a list typically restricted to a lawyer and the +prisoner's immediate family, is forbidden from communicating anything they hear from the detainee. Put another + + +way, lawyers or family members can be punished for disclosing any specifies of the conditions they hear the +prisoner is facing. +The British civil-rights lawyer Gareth Peirce, who has spent decades defending Irish and Muslim prisoners +accused of terrorism, visited MCC after clients she was representing were extradited from the UK to the U.S. No +stranger to prison abuses, Peirce was astonished by the conditions at MCC. "Diabolical," was how she described +it. +According to studies, rates of suicide in jail are higher than in prison. And Epstein had reportedly already made +one attempt to take his own life. While MCC is a special breed of hell, its approach to mental health is indicative +of the BOP's broad, cruel indifference to mental-health care. Faced with a spate of suicides in 2012, for instance, +the BOP director sent every prisoner in federal custody an absurd letter. "At times you may feel hopeless about +your future, and your thought may turn to suicide," Director Charles E. Samuels wrote, 'If you are unable to +think of solutions other than suicide, it is not because solutions do not exist; it is because you are currently +unable to see them. Do not lose hope." +International organizations have condemned MCC's conditions. From 2007 to 2012, the European Court for +Human Rights stayed the extradition of six UK subjects, concerned about inhumane prison conditions at U.S. +deral facilities like MCC and the nation's supermax prison in Colorado, before finally capitulating to U. +essure in 2012. Amnesty International in 2014 decried the conditions at MCC. as has the former UN Speci +Rapporteur for Torture Juan Mendez; so, too, did a extensive 2014 report by Human Rights Watch and Columbia +Law School's Human Rights Institute. +The question now is whether MCC will just serve as the dirty backdrop to bizarre conspiracy theories and sordid +accountings of Epstein's last hours, allowing the inhumanity to remain hidden in plain sight or whether +Epstein's death is going to finally force us to see what is going on in Lower Manhattan and insist conditions at +MCC finally be addressed. diff --git a/vision-fixhub/ds9-parsed-01/1650ca42179766a9d7f24c12e0920025731e6d2451c82f7a0062b3dfdfb3122d.receipt.json b/vision-fixhub/ds9-parsed-01/1650ca42179766a9d7f24c12e0920025731e6d2451c82f7a0062b3dfdfb3122d.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..ac80c1edddda123353a376b1d8f393b8c2be93e1 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1650ca42179766a9d7f24c12e0920025731e6d2451c82f7a0062b3dfdfb3122d.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -234, + "dataset": "marble-joined", + "doc_id": "1650ca42179766a9d7f24c12e0920025731e6d2451c82f7a0062b3dfdfb3122d", + "engine": "marble-apple-vision", + "event_count": 22, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "cf50658dd2c93b0f2f3e07ff313aec46603688f79efe2e6d22fff4a451c87ad9", + "output_sha256": "1f286a979410254dec7e022917160f412fd2a3e67234836152abfdae0d3b427b", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1653520267f7bbce343704347fd356a7cbd2732c254db835d71b922677fe5d83.md b/vision-fixhub/ds9-parsed-01/1653520267f7bbce343704347fd356a7cbd2732c254db835d71b922677fe5d83.md new file mode 100644 index 0000000000000000000000000000000000000000..71110a21734e546dbf4deca71b37011d121a020b --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1653520267f7bbce343704347fd356a7cbd2732c254db835d71b922677fe5d83.md @@ -0,0 +1,266 @@ +CG +COHEN & GRESSER LLP +Christian R. Everdell ++1 (212) 957-7600 +ceverdell@cohengresser.com +800 Third Avenue +New York, NY 10022 ++1 212957 7600 phone +www.cohengresser.com +BY EMAIL +, Esq. +Esq. +, Esq. +United States Attorney's Office +Southern District of New York +1 St. Andrew's Plaza +New York, NY 10007 +Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) +Dear +We write on behalf of our client, Ghislaine Maxwell, to set forth requests for discovery and +Brady material. Based on our review of the government's productions of August 5, 2019, August +13, 2019, and August 21, 2020, we make the following requests for discovery, inspection, and +copying, in accordance with the guarantees of the Fourth, Fifth, and Sixth Amendments, Rule 16 +of the Federal Rules of Criminal Procedure, the Federal Rules of Evidence, and such other laws +and rules as may be applicable. We are still reviewing these productions, as well as the +government's most recent production of October 2, 2020, and reserve the right to supplement +these requests as necessary. +1. We request any oral, written, or recorded statements made by Ms. Maxwell, aside from +he statements made in prior civil case proceedings that you produced on August 13 +2020 and the statements made at the time of arrest, which you produced on August 21 +2020. Fed. R. Crim. P. 16(a)(1)(A), (B). +2. We request that the government disclose and identify any statements of alleged coconspirators that it intends to introduce at trial. +3. We request any prior criminal records of Ms. Maxwell. Fed R. Crim. P. 16(a)(1)(D). +4. We request any books, papers, documents, data, photographs, tangible objects, +buildings or places, or copies or portions of any of these items. Fed R. Crim. P. +16(a)(I)(E). + + +Page 2 +a. Based on our review of the discovery, it does not appear that any documents or +tangible objects were obtained from Ms. Maxwell through a search warrant or a +search incident to arrest. Please confirm this. +b. We will schedule a time in the near future to inspect the originals of +photographs and any other evidence (including documents and tangible objects) +that have already been disclosed. +5. We request the results or reports of any physical or mental examination and of any +scientific test or experiment. Fed R. Crim. P. 16(a)(1)(F). +6. We request a written summary of any testimony that the government intends to +introduce at trial under Federal Rules of Evidence 702, 703 or 705, which summary +must describe the witness's opinions, the bases and reasons for those opinions, and the +witness's qualifications. Fed R. Crim. P. 16(a)(1)(G). +7. We request that the government disclose the identities of the individuals identified in +the indictment as Minor Victims 1-3. +8. We request that the government disclose the complete birthdays of the individuals +identified in the indictment as Minor Victims 1-3. +9. We request all written and oral communications concerning the negotiations relating to +the Non-Prosecution Agreement ("NPA") signed by Jeffrey Epstein on September 24, +2007. Such communications include: +a. All communications between the government - including, but not limited to, +attorneys and staff at the U.S. Attorney's Office for the Southern District of +Florida, the United States Attorney's Office for Southern District of New York, +the Department of Justice, state prosecutor's offices, the FBI, and any other +federal and state investigative agencies - and Mr. Epstein's attorneys. +b. All communications between and among any government employees including, +but not limited to, attorneys and staff at the U.S. Attorney's Office for the +Southern District of Florida, the United States Attorney's Office for Southern +District of New York, the Department of Justice, state prosecutor's offices, the +FBI, and any other federal and state investigative agencies. +c. Unredacted copies of all emails and other correspondence between the +government and Mr. Epstein's attorneys concerning the negotiation of the NPA, +which you previously produced on August 13, 2020. See, e.g., +SDNY_GM_00134069 et seq. + + +Page 3 +10. We request that the government produce a complete copy of the diary, only sever +ages of which were produced by the government on August 21, 2020. Se +SDNY GM_00165982-00162988. +1 +' We regust 3 oral, be armediated copy orse produced by the overment +12. We request that the government produce all versions and drafts of the book/memoi +"The Billionaires Playboy Club" produced by the government on August 13, 2020, and +identify the dates of each version/draft. See, e.g., SDNY_GM_00117607-608, +00117626-635, 00117637-640, 00117726-727, 00117761-762, 00117836-837 (sample +list). +13. We request the following documents and materials related to the individuals identified +in the indictment as Minor Victims 1-3 and for any other witness who has alleged that +Ms. Maxwell engaged in or facilitated improper sexual conduct at any time up to the +present: +a. All diaries, notes, journals, e-mails, text messages, letters, or other writings by +these individuals, including but not limited to, all written communications +between these individuals and Mr. Epstein or Ms. Maxwell; +b. All travel and immigration records, as well as copies of any passports and travel +documents; +c. All school records or other educational records; +d. All phone records; +e. All photographs; +f. All financial records, including all records reflecting any payments or money +transfers from Mr. Epstein or his associated businesses to these individuals or +their family members or their counsel; +g. All police reports or complaints to law enforcement authorities filed by these +individuals; +h. Any submissions to the Epstein Victims' Compensation Program made by any +of these individuals; +i. All communications between or among these individuals, or between these +individuals and counsel for any other such individual, including but not limited +to, emails, text messages, social media posts, and other correspondence; +j. All public statements made by these individuals concerning Mr. Epstein or Ms. +Maxwell; +k. Any record or report of any physical, medical, mental, or psychological +examination of these individuals; +' We also make this request, as well as Requests 11-16, pursuant to the government's Brady obligations. + + +Page 4 +1. Any record, report or other document reflecting the use or abuse of alcohol or +m. Any Neal ideal dog, includio ariven the government and the attorneys +for these individuals - including , but not limited to, Bradley Edwards, David +Boies, Sigrid McCawley, Peter Skinner, Stanley Pottinger, Paul Cassell, +Spencer Kuvin, and Jack Scarola (the "Attorneys") - concerning or relating to +14. We request all written and oral communications and other documents concerning any +meetings between the Attorneys and prosecutors and staff from the United States +Attorney's Office for the Southern Distriet of New York ("SDNY") concerning Jeffrey +Epstein and/or Ghislaine Maxwell. +a. This request includes all communications and documents related to any +meetings that took place in or about 2016 in which certain of the Attorneys met +with SDNY prosecutors to ask SDNY to initiate a criminal investigation into +Mr. Epstein and Ms. Maxwell. See New York Daily News, "Manhattan Federal +Prosecutors Declined to Pursue Jeffrey Epstein and Ghislaine Maxwell Case in +2016: Sources" (Oct. 13, 2020), https://www.nydailynews.com/new-york/nyjeffrey-epstein-maxwell-case-20201013-jmzhl7zdrzdgrbbs7yc6bfnszustory.html; see also Bradley J. Edwards, Relentless Pursuit: My Fight for the +Victims of Jeffrey Epstein, at 281. +b. This request also includes all communications and documents related to any +meetings between any of the Attorneys and SDNY prosecutors and staff +concerning or relating to Mr. Epstein and/or Ms. Maxwell that took place in or +about 2018, when the government asserts that it began the SDNY investigation +into this case (see Dkt. 63), or at any time thereafter. +15. We request the complete FBI's case file regarding the investigation of +for obstruction of justice, referenced in the government's production cover +letter of August 21, 2020 +16. We request copies of the "82-page pros memo and 53-page indictment" drafted as part +of the investigation conducted by the Southern District of Florida. See +SDNY GM 00131226. +17. We request all e-mails, text messages, letters, or other written communications to or +from Ms. Maxwell. +18. We request all medical records or reports concerning Mr. Epstein. + + +Page 5 +19. We request all subpoenas and voluntary request for production of documents issued in +20. We request that the government disclose and identify any evidence it intends to +introduce under Federal Rule of Evidence 404(b) or as background of the conspiracies +charged in the Indictment. +21. We request information about the composition of the grand jury that indicted this case, +including a list of grand jurors, their attendance dates, the reasons for any absence, and +whether attendance was in person or virtual. +22. We request that the government disclose whether any persons were present during +grand jury proceedings other than the grand jurors, witnesses under examination, court +reporters, and attorneys from the United States Department of Justice. +Consistent with the requirements of Brady v. Maryland, 373 U.S. 83 (1963) and Kyles v. +Whitley, 514 U.S. 419, 438 (1995), as well as your own professional obligations, we request that +the government conduct an affirmative search for, locate, identify, and produce, all documents, +books, papers, photographs, scientific tests or experiments, tangible objects, written or recorded +statements, grand jury transcripts and oral statements, reports, memoranda, names, and addresses +or persons or other evidence or information favorable to the defense as to either guilt or +punishment, or tends to affect the weight or credibility of the evidence to be presented against Ms. +Maxwell, or which will lead to evidence favorable to or exculpatory of Ms. Maxwell, including +but not limited to information which is within the possession, custody, or control of the +government. Impeachment evidence, as well as exculpatory evidence, falls within Brady's +definition of evidence favorable to the accused. See United States v. Bagley, 473 U.S. 667 (1985); +United States v. Agurs, 427 U.S. 97 (1976). We also make the following specific Brady requests: +1. Exculpatory Evidence: We request all such evidence requested above and evidence +known to the government which tends to exculpate Ms. Maxwell of the offense +alleged, including exculpatory statements. This request includes, but is not limited to: +a. Any statements or written communications made by any witness who has +alleged that she was sexually abused or assaulted by Mr. Epstein, but has not +alleged that Ms. Maxwell participated in, was involved in, or facilitated the +alleged sexual abuse. These include, but are not limited, to, all diaries, notes, +journals, e-mails, text messages, letters, or other writings by these individuals. +b. Any evidence suggesting that Ms. Maxwell was not involved in or aware of the +conduct alleged in the indictment. + + +Page 6 +c. Any evidence concerning witnesses who have contacted the government or law +enforcement authorities about alleged sexual abuse by Mr. Epstein or Ms. +Maxwell who were determined not to be credible. +d. Any evidence suggesting that any witness who has alleged that she was +sexually abused or assaulted by Mr. Epstein, with or without the involvement of +Ms. Maxwell, was not a minor at the time the alleged sexual abuse took place. +e. All investigative efforts to verify any information provided by any and all +witnesses, where such efforts were negative. +f. All discussions with any witness, including law enforcement, that reveal Brady +information. +2. Favorable Statements and Witnesses: We request that the government produce any +ritness statements favorable to Ms. Maxwell, and identify the names of any witnesse +ho have information favorable to Ms. Maxwell. This includes any witness who th +government does not intend to call at trial, but who made a favorable statement +concerning Ms. Maxwell. +3. Evidence of Criminal Investigation of Any Government Witness: We request any +evidence that any prospective witness is under investigation by federal, state or local +uthorities for any criminal conduct. This includes their entire criminal record (bot +rests and convictions, whether adult or juvenile) and probation reports, supervise +release, pre-sentence reports, violation reports, intelligence reports and all +supplementals. +4. Evidence of Misconduct of Government Agents: We request information about any +allegation of misconduet of any government agents or attorneys involved in any +investigation into Mr. Epstein and Ms. Maxwell. +5. Impeachment Evidence: We request any evidence that may be used to impeach a +prospective government witness. This request includes, but is not limited to: +a. Any evidence that any prospective government witness has engaged in any +criminal act, whether or not resulting in a conviction, and whether any witness +has made a statement favorable to Ms. Maxwell. +b. Any information tending to establish that the witness is or was a user of any +drug or alcohol and any other information which tends to discredit the witness's +ability to perceive, recollect and/or narrate events. + + +Page 7 +c. Any information concerning any government witnesses' history of emotional +disorders and psychiatric or psychological counseling, which may bear on a +witness's ability to perceive or relate events accurately and truthfully. +d. Any evidence suggesting that any witness who has alleged that she was +sexually abused or assaulted by Mr. Epstein, with or without the involvement of +Ms. Maxwell, had a financial motive or incentive to accuse Mr. Epstein or Ms. +Maxwell. +6. Giglio Information: Pursuant to Giglio v. United States, 405 U.S. 150 (1972), we +request dates and descriptions of any and all considerations or promises (express or +implied) of consideration given during the course of the investigation by any law +enforcement officials to or on behalf of any witness the government intends to call at +trial, or any such consideration or promises expected by any such witness in the future. +This includes but is not limited to the following: +a. Rewards, monetary or otherwise; +b. Employment; +c. Protection and relocation; +d. The rejection, dismissal, immunization from prosecution or reduction of any +federal, state or local offenses charged in the past or present or that might be +charged in the future; +e. Reduction of sentence, improvement of custody status or leniency at sentencing +by making the witnesses' cooperation known to the prosecution, Court, +probation or parole officer, or other federal, state or local agency or jurisdiction; +f. Other incidents of cooperation. +7. Evidence of Bias or Motive to Lie: We request any evidence that any prospective +government witness is biased or prejudiced against Ms. Maxwell or has a motive to +falsify or distort his or her testimony. Pennsylvania v. Ritchie, 480 U.S. 39 (1987); +United States v. Strifler, 851 F.2d 1197 (9th Cir. 1988). +8. Contradictory Statements: We request all prior contradictory statements of any +prospective government witness. Giles v. Maryland, 386 U.S. 66 (1967). +9. Statements Relevant to the Defense: We request disclosure of any statement that may +be "relevant to any possible defense or contention" that Ms. Maxwell might assert. +10. We request any other materials or documents not otherwise accounted for in other +requests herein that arguably reflect the (1) motivation of any government witness to +cooperate with the prosecution team, (ii) the competency or credibility of the witness, +or (il) the witness's bias or hostility against Mr. Epstein or Ms. Maxwell. + + +Page 8 +Please note that under both Federal Rule of Criminal Procedure 16(c) and Brady, the duty +to disclose is a continuing one, and you must disclose promptly any additional discovery evidence, +information, or material of which you or any member of the prosecution team become aware. +In the event that you are unable or unwilling to provide the information and documents +requested in this letter, please advise us by October 21, 2020, so that we may file any necessary +motions with the Court. +Thank you in advance for your attention to these matters. +Sincerely, +Is/ Christian Everdell +cc: \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/1653520267f7bbce343704347fd356a7cbd2732c254db835d71b922677fe5d83.receipt.json b/vision-fixhub/ds9-parsed-01/1653520267f7bbce343704347fd356a7cbd2732c254db835d71b922677fe5d83.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..a21aef9b3f5e7533d35470a4956a8a1d13621aa3 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1653520267f7bbce343704347fd356a7cbd2732c254db835d71b922677fe5d83.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -239, + "dataset": "marble-joined", + "doc_id": "1653520267f7bbce343704347fd356a7cbd2732c254db835d71b922677fe5d83", + "engine": "marble-apple-vision", + "event_count": 12, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "76df9eba1905ba1106ea3e8c3d05a96c2519442dcbe31c3bc6eaf2794f9f9004", + "output_sha256": "073ecbb5c2ecf49352e82c3659c7702a02a23da24d5a20307959bc5bc9e1d52c", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/167390e0abffce33824245d76da010bee643cef91f75d8d6a13b100d4373462d.md b/vision-fixhub/ds9-parsed-01/167390e0abffce33824245d76da010bee643cef91f75d8d6a13b100d4373462d.md new file mode 100644 index 0000000000000000000000000000000000000000..bd7e860f69c9f2f7e2563885400f856457359b71 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/167390e0abffce33824245d76da010bee643cef91f75d8d6a13b100d4373462d.md @@ -0,0 +1,223 @@ +From: +To: +Subject: RE: Follow-up +Date: Wed, 29 Jan 2020 20:17:50 +0000 +Inline-Images: image001 jPg +Sure - we have indicated that we are generally interested in speaking with her, but I think internally our view was that if +we feel we're able to charge without doing this interview first, that it's likely a good candidate for a post-charge +conversation. As a refresher, was an assistant to GM approximately 2003-07, and functionally worked for both GM +and JE. JE paid her through his corporation. During her employment, she was over 18 l +On at least +three occasions, GM instructed her to go to JE residence and she was assaulted; on two of those occasions, there were +other women in the room and ] was instructed to engage in sexual acts with those women, one of whom was I +and the other +doesn't remember the name of. More generally, she is also a witness to the relationship +between JE and GM. She also noted that GM sometimes used the alias "Jennifer Miller." +Because she was not underage, and her timeline doesn't overlap with when we think GM was chargeable, I think we +didn't feel a need to interview pre-charge, but we certainly can if that changes, her attorneys are happy to schedule it if +and when we would like. +From: +To: +Sent: Wednesday, January 29, 2020 11:26 +Subject: FW: Follow-up +Can you remind me what the status is here - have we requested an interview with this witness? Thanks. +From: Teri Gibbs < +Sent: Tuesday, January 28, 2020 7:08 PM +To: +Cc: +>; Colleen Mullen +Subject: Re: Follow-up +Hil +As we discussed last week, our client, +has in her possession documents from and email +correspondence with Ghislaine Maxwell. Thus far, we have received authorization to share the list of office +numbers Ms. +used during her employment with Ghislaine Maxwell from 2003-2007. Please see +attached. +Please let us know if you have any questions. +Best, +Teri +On Wed, Jan 22, 2020 at 1:48 PM +Will do, speak with you then. Thanks. +P wrote: + + +From: Teri Gibbs < +Sent: Wednesday, January 22, 2020 16:44 +To: +Cc: | +Subject: Re: Follow-up +P; Colleen Mullen +Great. Tomorrow at 12PM PST/3PM EST works. Please call our conference line at _ +Best, +Teri +On Wed, Jan 22, 2020 at 1:39 PM +wrote: +Teri, +I can give you a call at 3:00 p.m. tomorrow (Thursday). Please let me know what number is best to reach you at, and +I'll plan to call you then. +thanks, +From: Teri Gibbs & +Sent: Tuesday, January 21, 2020 20:15 +To: +Cc: +Mullen < +Subject: Re: Follow-up +›; Colleen +Wonderful, +I am available tomorrow through Friday from 1PM-3PM EST. Please let me know what +time works best for you. +Best, +Teri +On Tue, Jan 21, 2020 at 5:06 PM +wrote: +Teri, +We would be happy to set up a call to speak with you and receive the new information —please let us know a few +times this week that would work for you. +thanks, + + +From: Teri Gibbs <| +Sent: Tuesday, January 21, 2020 18:50 +To: l +Cc:| +Mullen < +Subject: Re: Follow-up +P; Colleen +Hi +I am following up regarding our clients, +and +. We have more +that may be important to your investigation. Please let us know if +you would like to speak with us over the phone or set up interviews with either of them. +Best regards, +Teri +On Mon, Jan 6, 2020 at 1:12 PM Teri Gibbs < +> wrote: +Great. Please call our conference line at +You should receive an invitation in a few +moments from UberConference. You will not need a sign-in pin. +Looking forward to our call on Wednesday at 12:30PM PST. +Best, +Teri +On Mon, Jan 6, 2020 at 1:07 PM +P wrote: +Yes, we can do Wednesday at 12:30 p.m. PST (3:30 p.m. EST). Please let us know the best number to reach +you at, and we'll call you then. +From: Teri Gibbs < +Sent: Monday, January 06, 2020 12:15 +Subject: Re: Wines re Prince Andrew +We have a last-minute mediation that is now scheduled for Tuesday. Are you available on +Wednesday between 10-11AM PST and 12-2PM PST or Thursday at any time between 9 AM-5PM +PST? +Thank you in advance for your flexibility. +Best, +Teri + + +On Fri, Jan 3, 2020 at 6:04 PM +> wrote: +Teri, +No problem, and thanks for getting back to us. We could do a call on Tuesday the 7th at 11:00 a.m. PST +(2:00 p.m. EST). Please let us know the best number to reach you at, and we'll give you a call then. +thanks, +From: Teri Gibbs < +Sent: Thursday, January 02, 2020 19:26 +To: +Cc:| +Subject: Re: Witness re Prince Andrew +Hil +Thank you for your response. I apologize for the delay. I hope you had a wonderful holiday. +Attorney Lisa Bloom and I are available at the following times for a phone or video conference: +• Tuesday (1/7) between 10AM-1PM PST +• Wednesday (1/8) between 10-11AM PST and 12-2PM PST +Please let me know if any of these times work for you. +Best regards, +Teri +On Fri, Dec 20, 2019 at 9:55 AM +» wrote: +Teri, +Thanks for being in touch. In the first instance, before we would request an interview directly, it would +be helpful for us to get a full attorney proffer from you about what the client's information is, what you +expect she would convey in an interview, any relevant documentary or other corroborating materials, +etc. That way we can make sure we're not re-victimizing any individual unnecessarily, and be efficient +with any necessary follow-up interview of the individual him- or herself. Please let us know when a +good time would be for an attorney proffer? And we can figure out scheduling. +thanks very much, +From: Teri Gibbs < +Sent: Thursday, December 19, 2019 20:01 +To: +Cc: +Subject: Witness re Prince Andrew +(NY) (FBI) < + + +Hi +We have a client who witnessed Prince Andrew's interactions with +I would +like to set up a phone or video interview with the appropriate party to allow our client to make a +statement. Please let me know how to proceed. +Best regards, +Teri Gibbs +- +Notice To Recipient: This e-mail is meant for only the intended recipient of the transmission, and may be a communication privileged by law. If you +received this e-mail in error, any review, use, dissemination, distribution, or copying of this e-mail is strictly prohibited. Please notify us immediately +of the error by return e-mail and please delete this message and any and all duplicates of this message from your system. Thank you in advance +for your cooperation. +IRS Circular 230 Disclosure: In order to comply with requirements imposed by the Internal Revenue Service, we inform you that any U.S. tax advice +contained in this communication (including any attachments) is not intended to be used, and cannot be used, for the purpose of (i) avoiding +hereities under the Internal Revenue Code or (i promoting, marketing, or recommending to another party any transaction or matter addressed +Notice To Recipient: This e-mail is meant for only the intended recipient of the transmission, and may be a communication privileged by law. If you +received this e-mail in error, any review, use, dissemination, distribution, or copying of this e-mail is strictly prohibited. Please notify us immediately of +the error by retum e-mail and please delete this message and any and all duplicates of this message from your system. Thank you in advance for your +cooperation. + + +IRS Circular 230 Disclosure: In order to comply with requirements imposed by the Internal Revenue Service, we inform you that any U.S. tax advice +contained in this communication (including any attachments) is not intended to be used, and cannot be used, for the purpose of (i) avoiding penalties +under the Internal Revenue Code or (i) promoting, marketing, or recommending to another party any transaction or matter addressed herein. +- +Notice To Recipient: This e-mail is meant for only the intended recipient of the transmission, and may be a communication privileged by law. If you received +this e-mail in error, any review, use, dissemination, distribution, or copying of this e-mail is strictly prohibited. Please notify us immediately of the error by +return e-mail and please delete this message and any and all duplicates of this message from your system. Thank you in advance for your cooperation. +IRS Circular 230 Disclosure: In order to comply with requirements imposed by the Internal Revenue Service, we inform you that any U.S. tax advice +contained in this communication (including any attachments) is not intended to be used, and cannot be used, for the purpose of (l) avoiding penalties under +the Internal Revenue Code or (i) promoting, marketing, or recommending to another party any transaction or matter addressed herein. +- +Notice To Recipient This e-mail is meant for only the intended recipient of the transmission, and may be a communication privileged by law. If you received +this e-mail in emor, any review, use, dissemination, distribution, or copying of this e-mail is strictly prohibited. Please notify us immediately of the error by return +e-mail and please delete this message and any and all duplicates of this message from your system. Thank you in advance for your cooperation. +IRS Circular 230 Disclosure: In order to comply with requirements imposed by the Internal Revenue Service, we inform you that any U.S. tax advice contained +in this communication (including any attachments) is not intended to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal +Revenue Code or (ii) promoting, marketing, or recommending to another party any transaction or matter addressed herein. +- + + +Notice To Recipient: This e-mail is meant for only the intended recipient of the transmission, and may be a communication privileged by law. If you received this e- +mail in error, any review, use, dissemination, distribution, or copying of this e-mail is strictly prohibited. Please notify us immediately of the error by return e-mail +and please delete this message and any and all duplicates of this message from your system. Thank you in advance for your cooperation. +IRS Circular 230 Disclosure: In order to comply with requirements imposed by the Internal Revenue Service, we inform you that any U.S. tax advice contained in +this communication (including any attachments) is not intended to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal +Revenue Code or (i) promoting, marketing, or recommending to another party any transaction or matter addressed herein +Notice To Recipient: This e-mail is meant for only the intended recipient of the transmission, and may be a communication privileged by law. If you received this e-mail +in error, any review, use, dissemination, distribution, or copying of this e-mail is strictly prohibited. Please notify us immediately of the error by return e-mail and please +delete this message and any and all duplicates of this message from your system. Thank you in advance for your cooperation. +RS Circular 230 Disclosure: In order to comply with requirements imposed by the Internal Revenue Service, we inform you that any U.S. tax advice contained in this +communication (including any attachments) is not intended to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code +or (ii) promoting, marketing, or recommending to another party any transaction or matter addressed herein. +- + + +Notice To Recipient: This e-mail is meant for only the intended recipient of the transmission, and may be a communication privileged by law. If you received this e-mail in +error, any review, use, dissemination, distribution, or copying of this e-mail is strictly prohibited. Please notify us immediately of the error by return e-mail and please +delete this message and any and all duplicates of this message from your system. Thank you in advance for your cooperation. +IRS Circular 230 Disclosure: In order to comply with requirements imposed by the Internal Revenue Service, we inform you that any U.S. tax advice contained in this +communication (including any attachments) is not intended to be used, and cannot be used, for the purpose of (i) avoiding penalties under the internal Revenue Code a +(il) promoting, marketing, or recommending to another party any transaction or matter addressed herein +-- +Notice To Recipient: This e-mail is meant for only the intended recipient of the transmission, and may be a communication privileged by law. If you received this e-mail in +error, any review, use, dissemination, distribution, or copying of this e-mail is strictly prohibited. Please notify us immediately of the error by return e-mail and please delete +this message and any and all duplicates of this message from your system. Thank you in advance for your cooperation. +IRS Circular 230 Disclosure: In order to comply with requirements imposed by the Internal Revenue Service, we inform you that any U.S. tax advice contained in this +communication (including any attachments) is not intended to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) +promoting, marketing, or recommending to another party any transaction or matter addressed herein. diff --git a/vision-fixhub/ds9-parsed-01/167390e0abffce33824245d76da010bee643cef91f75d8d6a13b100d4373462d.receipt.json b/vision-fixhub/ds9-parsed-01/167390e0abffce33824245d76da010bee643cef91f75d8d6a13b100d4373462d.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..7e9978ecd721262f9f36be3b955d04bdf42714c9 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/167390e0abffce33824245d76da010bee643cef91f75d8d6a13b100d4373462d.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -96, + "dataset": "marble-joined", + "doc_id": "167390e0abffce33824245d76da010bee643cef91f75d8d6a13b100d4373462d", + "engine": "marble-apple-vision", + "event_count": 8, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "c2b79326d0548fabb7e1b3dd5b72799769630ce3db43f89f58986a98f36064ec", + "output_sha256": "285fce868c1e31f90f85468a9d21f8ac0f7072fa2a421d43f9a0b6f08d69c6b6", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/16b1120a8db36588987af1e84dcbe233efaa9c7d88e9cdbe045c0e15c4b9c845.md b/vision-fixhub/ds9-parsed-01/16b1120a8db36588987af1e84dcbe233efaa9c7d88e9cdbe045c0e15c4b9c845.md new file mode 100644 index 0000000000000000000000000000000000000000..569b2474aa8a7aacd6b98c8deb9f522b9eed1ce3 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/16b1120a8db36588987af1e84dcbe233efaa9c7d88e9cdbe045c0e15c4b9c845.md @@ -0,0 +1,47 @@ +From: +To: " +Ce: " +Subject: RE: subpoena of William Hammond +Date: Tue, 30 Jul 2019 14:39:09 +0000 +Sure - you can call +thanks, +or let us know if there's a number we can reach you at if you prefer we call you. +From: +Sent: Tuesday, July 30, 2019 07:16 +To: +Cc: +Subject: Re: subpoena of +Would 4:30 work? +Sent from my iPhone +On Jul 29, 2019, at 11:22 PM, +wrote: +Is there a good time for you tomorrow afternoon, 2:00 or later? +thanks, +From: | +Sent: Monday, July 29, 2019 10:25 +To: L +Subject: RE: subpoena of William Hammond +Let me know when would be a good time for a call to further discuss the Hammond subpoena. +Thanks, + + +(212) 997-7400 +From: +Sent: Tuesday, July 16, 2019 12:53 PM +To: +Ccil +Subject: RE: subpoena of William Hammond +Following up on our phone conversation earlier today, thank you for being in touch and advising us of your +representation of William Hammond in connection with receipt of a grand jury subpoena. So you have contact info +for our full team, we're all reachable anytime at the copied emails or by phone at: +As we briefly discussed, the documentary materials we are seeking from Mr. Hammond in the first instance are any flight +manifests, flight plans, or other documents reflecting passengers and/or travel records, dating back to 2000. And we +would like to hear from L labout observations, if any, of young women or girls on flights, as well as any discussions +with Mr. Epstein about his relationships with young women or girls, or his legal issues relating to those relationships. +We are also interested to know the identities of Epstein's employees and staff whom Mr. Hammond is aware of, current +and previous. +As I mentioned on the phone, given the prospect of attorney proffer information and/or a possible voluntary interview, +we are prepared to hold in abeyance the current subpoena return date of July 22, 2019. +thank you, +Assistant U.S. Attorney +Southern District of New York diff --git a/vision-fixhub/ds9-parsed-01/16b1120a8db36588987af1e84dcbe233efaa9c7d88e9cdbe045c0e15c4b9c845.receipt.json b/vision-fixhub/ds9-parsed-01/16b1120a8db36588987af1e84dcbe233efaa9c7d88e9cdbe045c0e15c4b9c845.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..de0a896a05f80dd3a465b2491598f1d35b9c39d1 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/16b1120a8db36588987af1e84dcbe233efaa9c7d88e9cdbe045c0e15c4b9c845.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "16b1120a8db36588987af1e84dcbe233efaa9c7d88e9cdbe045c0e15c4b9c845", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "4811c679159f8808a93eebbee04e409120b6361d7cc30f7ee768c9a0b2b78f16", + "output_sha256": "7dbfe953ee73e7d8d7242ee0c8225a4cdc302efe20c5b81f590c6213849cc4d7", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/16bf0f027b0d0906eed2540d7c0b0cb92b1e240528e16761a195519ad5fb66c8.md b/vision-fixhub/ds9-parsed-01/16bf0f027b0d0906eed2540d7c0b0cb92b1e240528e16761a195519ad5fb66c8.md new file mode 100644 index 0000000000000000000000000000000000000000..c94a25e26d2b1368fe59c75beddc6cdd544bd29e --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/16bf0f027b0d0906eed2540d7c0b0cb92b1e240528e16761a195519ad5fb66c8.md @@ -0,0 +1,32 @@ +From: " +To: +Cc: " +Subject: FW: US v. Maxwell - 20 Cr. 330 (AJN) - Discovery request +Date: Tue, 09 Mar 2021 19:13:21 +0000 +Attachments: 2021.03.08_LAM_Letter +to USAO +_re_discovery_(F) pdf +Inline-Images: image001 jpg +Hey L +Give me a call when you have a minute so we can discuss this. +Thanks, +From: Laura Menninger < +Sent: Monday, March 8, 2021 2:00 PM +To: +Cc: Jeff Pagliuca ‹ +P; Christian R Everdell - Cohen & Gresser LLP +P; 'BOBBI C STERNHEIM' < +Subject: US v. Maxwell - 20 Cr. 330 (AJN) - Discovery request +Counsel: +Please see attached correspondence of today's date. +-Laura +Laura A. Menninger +Haddon, Morgan and Foreman, P.C. +www.hmflaw.com +CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages +attached to it may contain information that is confidential or legally privileged. If you are not the intended +recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that you +must not read this transmission and that any disclosure, copying, printing, distribution or use of any of the +information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this +transmission in error, please notify the sender by telephone or return e-mail and delete the original +transmission and its attachments without reading or saving it in any manner. Thank you. diff --git a/vision-fixhub/ds9-parsed-01/16bf0f027b0d0906eed2540d7c0b0cb92b1e240528e16761a195519ad5fb66c8.receipt.json b/vision-fixhub/ds9-parsed-01/16bf0f027b0d0906eed2540d7c0b0cb92b1e240528e16761a195519ad5fb66c8.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..c8d8d7244163f8ec6b922573b47fc2782b1fcaaa --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/16bf0f027b0d0906eed2540d7c0b0cb92b1e240528e16761a195519ad5fb66c8.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "16bf0f027b0d0906eed2540d7c0b0cb92b1e240528e16761a195519ad5fb66c8", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "e897171bb2eb7e8630e5bbd50782ccae04f7bdace22eb63ec276133a7dafe22d", + "output_sha256": "bf2ce9c5ae92e7c7e12107a1e162921d22b9c82765f25878203f422e535d1269", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/16dec510730bd2517049c6ae016856e413e8176953612b888496bc5f12875dbe.md b/vision-fixhub/ds9-parsed-01/16dec510730bd2517049c6ae016856e413e8176953612b888496bc5f12875dbe.md new file mode 100644 index 0000000000000000000000000000000000000000..a33bc5e86635e723413499249d930d2011253c86 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/16dec510730bd2517049c6ae016856e413e8176953612b888496bc5f12875dbe.md @@ -0,0 +1,20 @@ +From: +To: +Subject: Request for assistance - C-20 +Importance: Normal +Priority: Normal +Sensitivity: None +I am available. +- +On Jul 29, 2020 2:25 PM, +(NY) (FBI)" +Squad C-20 (VCAC/HT) is looking for assistance related to the ongoing Epstein/Maxwell investigation. This is a +unique opportunity to assist with a high profile case. If you are available, please contact SAI +copy your respective SSA. +Tracy - for your visibility and any Agents in the NADP who may be available. +Thank you, +SSA +FBI - New York Office +(desk) +(cell) +- diff --git a/vision-fixhub/ds9-parsed-01/16dec510730bd2517049c6ae016856e413e8176953612b888496bc5f12875dbe.receipt.json b/vision-fixhub/ds9-parsed-01/16dec510730bd2517049c6ae016856e413e8176953612b888496bc5f12875dbe.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..baedf553257ad6de3828c24a4fad2a49caf44ec0 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/16dec510730bd2517049c6ae016856e413e8176953612b888496bc5f12875dbe.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "16dec510730bd2517049c6ae016856e413e8176953612b888496bc5f12875dbe", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "2fda6fac67bf4b42a219bef7fd9fe9feee5bc8aa1574e38a55bf11363401195a", + "output_sha256": "45fcd830a1baf8d155d305fd555050102b7e69ac4a55e9341a9bbd8908161ffc", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/16df279a17d351bcd4178fb9f517e5837d097a0b313c4550fb8832327f4e9f97.md b/vision-fixhub/ds9-parsed-01/16df279a17d351bcd4178fb9f517e5837d097a0b313c4550fb8832327f4e9f97.md new file mode 100644 index 0000000000000000000000000000000000000000..b4764fb5fde9efd7b8209febf5b46ffd94169f09 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/16df279a17d351bcd4178fb9f517e5837d097a0b313c4550fb8832327f4e9f97.md @@ -0,0 +1 @@ +No Images Produced diff --git a/vision-fixhub/ds9-parsed-01/16df279a17d351bcd4178fb9f517e5837d097a0b313c4550fb8832327f4e9f97.receipt.json b/vision-fixhub/ds9-parsed-01/16df279a17d351bcd4178fb9f517e5837d097a0b313c4550fb8832327f4e9f97.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..96bb1dcb8f65299e24f53c70a2f947b4f4f21d4c --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/16df279a17d351bcd4178fb9f517e5837d097a0b313c4550fb8832327f4e9f97.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "16df279a17d351bcd4178fb9f517e5837d097a0b313c4550fb8832327f4e9f97", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "27ef3ff470867c5ee48d41c3da2bf710e0e0691e8b434be17a88a80b998159f5", + "output_sha256": "3874328764c818fba06683a6d5ddc2edc2d7850aaf4ba18646f81d3f8420a729", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/170c3b5a8e8448d8a50259768077ff66d706a6dcf93195060ad3e41c0fd451e8.md b/vision-fixhub/ds9-parsed-01/170c3b5a8e8448d8a50259768077ff66d706a6dcf93195060ad3e41c0fd451e8.md new file mode 100644 index 0000000000000000000000000000000000000000..608cbb6b488c327198b04bf6efe302d6e34aff7b --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/170c3b5a8e8448d8a50259768077ff66d706a6dcf93195060ad3e41c0fd451e8.md @@ -0,0 +1,313 @@ +From: "McEnany, John (USANYS)" < +To: " +Cc: "Jones, David (USANYS)" = +- "Kochevar, Steven (USANYS) 2 +Subject: RE: Jeffrey Epstein-Related Touhy Requests +Date: Sun, 02 Aug 2020 17:44:15 +0000 +j' = +(USANYS)" +BTW, I probably don't need to tell you, our Touhy communications with VB are probably disclosable as Giglio +info. +From: Kochevar, Steven (USANYS) < +Sent: Tuesday, July 28, 2020 5:32 PM +To: McEnany, John (USANYS) { +Cc: Jones, David (USANYS) ‹ +| (USANYS) 4 +Subject: RE: Jeffrey Epstein-Related Touhy Requests +John, +Per our call yesterday, please find attached an updated letter responding to the Touhy request from the Epstein victim. +The Maxwell team is okay with this version of the letter. Please let me know if this is what you had in mind, or happy to +discuss/change things if not. +Thanks, +From: Kochevar, Steven (USANYS) +Sent: Sunday, July 26, 2020 10:10 PM +To: McEnany, John (USANYS) ‹ +Cc: Jones, David (USANYS) 4 +| (USANYS) 4 +Subject: RE: Jeffrey Epstein-Related Touhy Requests +John, +Please find attached a letter responding to a Touhy request from an Epstein victim and the documents to be produced +with it. The Maxwell team has signed off on this response. We anticipate that requester's counsel understands that the +government has additional documents here and may press on why more are not being released. To attempt to address +that issue up front, the letter notes that documents governed by 6(e) cannot be produced. +Please let us know if you have any concerns. +Thanks, +From: McEnany, John (USANYS) 4 +Sent: Monday, June 8, 2020 12:18 PM + + +To: Kochevar, Steven (USANYS) < +Cc: +(USANYS) < +(USANYS) Y +Subject: RE: Jeffrey Epstein-Related Touhy Requests +Good by me +From: Kochevar, Steven (USANYS) 4 +Sent: Monday, June 8, 2020 12:06 PM +To: McEnany, John (USANYS) < +Cc: +(USANYS) < +Subject: RE: Jeffrey Epstein-Related Touhy Requests +John, +We have received another informal Touhy inquiry from an Epstein victim. Please find attached a letter to victim's counsel, +outlining the Touhy process. This is basically the same letter we sent to Roberta Kaplan at the outset of the prior Touhy +process. We intend to proceed along the same lines with this request as with the prior request. Please let me know if you +have any edits or concerns. +Thanks, +From: McEnany, John (USANYS) 4 +Sent: Friday, May 22, 2020 6:27 PM +To: +Cc: +(USANYS) < +Subject: RE: Jeffrey Epstein-Related Touhy Requests +»; Kochevar, Steven (USANYS) < +(USANYS) Y +Thanks for the further info. With apologies, I now think Steven was right in the first place: if plaintiffs ask us for +the docs and we don't have them then I guess it does make most sense for us to simply say, we don't have them, +try SDFla and/or NDGA. SDFLa and NDGA may say, pound sand, and if plaintiffs subpoena one or the other of' +those districts, then we see if the subpoenaed district Touhy-refers the subpoena to Geoff as the "responsible" +USA, and take it from there. So I am OK with Steven's plan for dealing with plaintiff's further requests as he +outlines in his May 20 email. +From: +Sent: Friday, May 22, 2020 5:37 PM +To: Kochevar, Steven (USANYS) { +Cc: +(USANYS) I +Pi +Subject: RE: Jeffrey Epstein-Related Touhy Requests +P; McEnany, John (USANYS) 4 +(USANYS) T +We do possess the FBI investigative files from the SDFL investigation. What we do not have, and avoided obtaining for a +variety of reasons (including conflict issues, discovery issues, and a desire not to create even an appearance that we were +stepping into the shoes of a district that was unable to prosecute due to the prior non-prosecution agreement) are any +files specifically from the U.S. Attorney's Office in SDFL. As relevant here, for example, we do not have any materials +relating to the purported immunity discussions relating to l +I we have not identified any such materials in the FBI + + +files, and we assume that any discussions or correspondence on that issue likely would have been between defense +counsel and the SDFL USAO. +On the civil side, I can't immediately think of a reason you guys shouldn't be able to make a request to either SDFL or +NDGA, whichever is the right entity, for any such materials. We've just avoided literally any contact with SDEL on the +criminal side. +Let us know if any additional questions on this at all, we realize it's a little complex. +From: Kochevar, Steven (USANYS) < +Sent: Friday, May 22, 2020 17:16 +To: McEnany, John (USANYS) ‹ +(USANYS) - +Cc: +Subject: RE: Jeffrey Epstein-Related Touhy Requests +Understood. Thanks, John. David Jones thought this approach was reasonable, but I'II check with Sarah too. Overall, I +don't think we have a ton of precedent for referring folks to another USAO on a Touhy, and certainly not to a third USAO +in the referral context. +Some information that might be useful in this that I don't have a complete understanding of-are the materials from the +S.D. Fla. investigation available to us? As in, have we ever seen or used them? If not, is there a particular reason for that? +We may be in the odd situation of technically having some purview over those materials by virtue of the Touhy regs, but +without access to them. But please let me know if I'm overlooking some dimension of our cooperation (if any) with the +other USAOs. +Thanks, +From: McEnany, John (USANYS) < +Sent: Friday, May 22, 2020 4:34 PM +To: Kochevar, Steven (USANYS) { +| (USANYS) { +(USANYS) < +Cc: +Subject: RE: Jeffrey Epstein-Related Touhy Requests +I have some hesitation on just referring them to NDGa for the SDFla investigative stuff. First, under Touhy +section 16.22(b), the responsible USA is the USA for the district "where the issuing authority" is located. They +actually have an action filed in this district, no? Like it or not, we may be stuck with dealing with their requests +for docs from the Florida investigation. Stephen, you might want to consult wiser Touhy heads in civ div, like +Sarah for instance. Also, it is possible that Touhy does not fall within the scope of SDFla's recusal. I can't see +NDGA racing to embrace doing Touhys on this. +From: Kochevar, Steven (USANYS) 4 +Sent: Wednesday, May 20, 2020 7:24 PM +To: McEnany, John (USANYS) | +_ (USANYS) | +(USANYS) +Cc: +Subject: RE: Jeffrey Epstein-Related Touhy Requests + + +All, +Closing the loop on this: we produced documents responsive to an Epstein victim's Touhy request about a month ago. The +requesters got back to us (by phone) with a fairly lengthy list of follow-up questions about what we produced and +additional/related demands. We don't have much responsive to many of their follow-ups, or do not think it would be +appropriate to produce additional material they're seeking-for example, materials that are part of the ongoing +investigation. Alex and I intend to have a call with requester's counsel to explain to them that we will not be producing +One small wrinkle: they have asked us for materials from S.D. Fla's investigation (which we don't have) and asked whether +they need to submit a separate request to that office. We intend to tell them that N.D. Ga. has stepped into the shoes of +S.D. Fla. For Epstein purposes, that they can submit a request there (or to S.D. Fla.) for the materials they're seeking, and +possibly provide them with a contact at N.D. Ga. if they ask. +Please let us know if you have any concerns. We hope that this will be the last step on this request. +Thanks, +From: McEnany, John (USANYS) 4 +Sent: Monday, April 20, 2020 5:52 PM +To: Kochevar, Steven (USANYS) 4 +(USANYS) +(USANYS) +Cc: +Subject: RE: Jeffrey Epstein-Related Touhy Requests +I take it we fully know that Jane Doe is +I had a little pause on handing out the GJ subpoena, but since it's something previously disclosed to her, I can't +see much of a problem disclosing it to her again. +So I don't have a problem with you sending this out. Thanks for your work on this, Steven. +-John +From: Kochevar, Steven (USANYS) < +Sent: Thursday, April 16, 2020 7:07 PM +To: McEnany, John (USANYS) < +(USANYS) +(USANYS) < +Cc: +Subject: RE: Jeffrey Epstein-Related Touhy Requests +All, +Please find attached a letter responding to the Touhy request for documents related to Jeffrey Epstein submitted by a +victim who is a plaintiff in a civil suit against Epstein's estate. I am also attaching the documents to be produced in +response to the request. Please let me know if you have any edits or concerns. If not, I plan to contact requester's counsel +next week, let them know about the production, and send them the letter and the documents. I'm also attaching their +request letter here. (Alex, Alison, and Maurene are signed off on the letter and gathered the documents.) + + +Thanks, +From: +Sent: Friday, January 3, 2020 8:49 PM +To: Kochevar, Steven (USANYS) < +Cc: McEnany, John (USANYS) 4 +Pi +(USANYS) +(USANYS) +Subject: RE: Jeffrey Epstein-Related Touhy Requests +Steven, +Thanks very much for drafting this, and I think generally it looks great. My only small thought would near the end, in the +penultimate paragraph, where I'd suggest replacing the first two sentences with (something like): "My understanding is +that you may intend to make a formal written request pursuant to the above-described regulations. [If you +choose to submit ...]" I say that only because the current language makes it sound like they were supposed to submit +something in writing, or that they otherwise erred, when in fact what they actually asked for was just an explanation of +the appropriate form in which to make a formal request-which they can do consistent with the regulations set forth in +the letter. Does that sound alright? And of course on any of these I also entirely defer to John. +thanks again, +Alex. +From: Kochevar, Steven (USANYS) ≤ +Sent: Friday, January 03, 2020 12:55 +To: +Cc: McEnany, John (USANYS) < +P; +(USANYS) * +(USANYS) +Subject: RE: Jeffrey Epstein-Related Touhy Requests +All, +Please find attached an initial letter to Kaplan Hecker re: the request for information related to Epstein. Please let me +know if you have any edits or concerns. Once I have sign-off, I'll send to Robbie Kaplan (by mail and at +rkaplan@kaplanhecker.com, or let me know if I should use a different address). +Alex, assuming there are not huge changes to be made here, I think the letter/email could just go out as the next contact +with Robbie on this, but | leave it up to you if/how you want to separately give her notice that it's on the way. +Thanks, +From: Kochevar, Steven (USANYS) +Sent: Thursday, January 2, 2020 7:16 PM +To: +Cc: McEnany, John (USANYS) 4 +(USANYS) - +(USANYS) +Subject: RE: Jeffrey Epstein-Related Touhy Requests + + +Alex, +Thanks, +All sounds good to me-thanks for the call and note. I'Il circulate a draft of the initial letter. +From: +Sent: Thursday, January 2, 2020 7:10 PM +To: Kochevar, Steven (USANYS) < +Cc: McEnany, John (USANYS) < +P; +(USANYS) Y +(USANYS) +Subject: RE: Jeffrey Epstein-Related Touhy Requests +steven, +Thanks for talking with me this evening about this, we appreciate it. To briefly memorialize our discussion, and to loop in +everybody on the case on the criminal side, you'll be the point person for requests from civil plaintiffs / victims in +connection with Epstein lawsuits, and we'll work with you on those requests given our knowledge of the relevant facts +and materials. +In terms of this first question from the plaintiff, which was essentially presented as a question of how they should go +about making a request for certain materials possibly in the possession of the Government, we'll plan to take a look at the +letter you draft that will essentially set forth the requirements for making a Touhy request (e.g., similar to, or including. +the kind of information in John's example below), and separately sometime early next week I'll let plaintiff's counsel +(Robbie Kaplan at Kaplan & Hecker) know that they can expect to hear from someone in our Civil Division, within +approximately a week or so (of when that conversation occurs), and that we anticipate that communication will include +the relevant requirements of making such a request. +Please let me know if I'm forgetting anything, thanks again, and talk soon. +Alex. +From: McEnany, John (USANYS) 4 +Sent: Thursday, January 02, 2020 10:01 +To: +P; Kochevar, Steven (USANYS) < +Subject: Jeffrey Epstein-Related Touhy Requests +Alex, Steven, +I spoke to Jeffrey O about continuing to use Steven as the POC to outsiders for Touhy requests for information +relating to Jeffrey Epstein. (Thank you Steven!) Alex, please give Steven a call. Steven, FWIW, following is a +markup of a "please give us a Touhy statement" email that I have used in the past. Alex anticipates that we will +be getting additional requests stemming from civil litigation by alleged victims, so it would be useful to have +some consistency here. Alex knows that the criminal AUSAs will have to do all the work digging for any +pertinent information, but it will be useful to have another AUSA handle the actual communications, particularly +since the criminal AUSAs may be dealing with the alleged victims as victim-witnesses in ongoing criminal +matters. Thanks again, +-John +Here's some draft language you may or may not find useful: + + +Dear XXX: +I am the Assistant U.S. Attorney who will be handling the request that you made to AUSA Rossmiller for certain +information relating to Jeffrey Epstein. To assist us in evaluating your request, we ask that you provide us with a +detailed written statement of the litigation for which you seek this information; the pertinence of the information +sought to your litigation; and the availability (or absence) of means in that litigation, including discovery, to +obtain the information in question. This statement should be relatively thorough—i.e., it should not assume that +the persons reviewing your request will have any particular familiarity with the litigation in question. +For your information, following are the general principles that govern disclosure, in unrelated litigation, of +information obtained during the course of our official duties. Specifically, the response of federal agencies to +subpoenas and other third-party discovery demands is largely governed by Department of Justice regulations, +commonly referred to as Touhy regulations. See generally 5 U.S.C.A. § 301; United States ex rel. Touhy v. +Ragen, 340 U.S. 462 (1951) (authorizing such regulations). These regulations dictate the procedure for obtaining +a government employee's testimony or government records in state or federal proceedings. The Department of +Justice has its own Touhy regulations that set out the procedure it follows in responding to demands for +"production or disclosure" of information from the Department and its employees for use in state or federal court +proceedings. See 28 C.F.R. §$ 16.21-16.29. These Touhy regulations channel review of such demands to the +responsible United States Attorney, and then provide a set of procedures for the United States Attorney to follow +when considering such demands. See id. §§ 16.22(b), 16.24. These regulations apply to both current and former +Government employees. See id. §§ 16.21(a), 16.22(a), 16.28. The Department's Touhy regulations prohibit any +Department employee from testifying or producing documents in a case in which the Government is not a party, +even in response to a subpoena, "without prior approval of the proper Department official in accordance with §$ +16.24 and 16.25 of this part." Id. § 16.22(a). For matters concerning our Office, the proper official is the United +States Attorney for the Southern District of New York. Id. § 16.22(b). To facilitate the process of determining +whether such approval will be given, a party seeking such information must provide this Office with an affidavit +or written statement setting forth the testimony sought and its relevance to the proceeding for which it is sought. +See id. § 16.22(c), (d). We will then evaluate the request in light of governing rules of procedure in the case for +which the information is sought, substantive law, and privilege; specific statutory prohibitions such as may apply +to federal tax information, grand jury matters, or classified information; and the requirement of Deputy or +Associate Attorney General approval where the disclosure would identify a confidential source over the +objection of the agency or source, would interfere with enforcement proceedings or reveal sensitive investigative +techniques, or would reveal trade secrets without the owner's consent. See 28 C.F.R. § 16.26. To the extent +information sought derives from a criminal investigation, such information may be subject to, inter alia, the law +enforcement privilege. The law enforcement privilege protects against the disclosure of information that would +"reveal a confidential source or informant, ... reveal investigatory records compiled for law enforcement +purposes ... interfere with enforcement proceedingsL,] or disclose investigative techniques and procedures .... +Id. § 16.26(b)(4)-(5); see also In re City of New York, 607 F.3d 923 (2d Cir. 2010); In re Dep't of Investigation of +the City of New York, 856 F.2d 481, 484 (2d Cir. 1988); Tuite v. Henry, 181 F.R.D. 175, 176 (D.D.C. 1998) ("The +federal law enforcement privilege is a qualified privilege designed to prevent disclosure of information that +would be contrary to the public interest in the effective functioning of law enforcement"), aff'd, 203 F.3d 53 +(D.C. Cir. 1999). The Government's privilege not to disclose material contained in the files of criminal +investigations is well-recognized. See In re Department of Investigation of the City of New York, 856 F.2d at 483; +Friedman v. Bache Halsey Stuart Shields, Inc., 738 F.2d 1336, 1341 (D.C. Cir. 1984); Kinoy v. Mitchell, 67 +F.R.D. 1, 11 (S.D.N.Y. 1975) (discussing privilege for files compiled in connection with a criminal +investigation). To the extent documents are sought for use in state court proceedings, note that the Department's +decision whether to authorize testimony or produce documents is not reviewable in state court. Review of the +agency's decision may only be had pursuant to the federal Administrative Procedure Act in federal court. See US. +EPA v. Gen. Elec. Co., 197 F.3d 592, 598-99 (2d Cir. 1999) (review pursuant to Administrative Procedure Act), +modified in part, 212 F.3d 689 (2d Cir. 2000); 5 U.S.C. § 702 (sovereign immunity waived to permit +Administrative Procedure Act only in "a court of the United States"). Federal sovereign immunity bars any +proceeding in state court to enforce a subpoena or otherwise compel testimony or production of documents. See +Louisiana v. Sparks, 978 F.2d 226, 234-36 (5th Cir. 1992); Boron Oil Co., 873 F.2d at 69-71; see also, e.g., +People v. Rodriguez, 546 N. Y.S.2d 861, 862-63 (Ist Dep't 1989) (holding that "state courts are without authority + + +to compel production of such files without the federal government's consent"); People v. Carbonaro, 427 +N. Y.S.2d 701, 702-03 (Kings Co. Sup. Ct. 1980) (quashing subpoena served on federal employee where +Department of Justice ordered him not to comply); Jacoby v. Delfiner, 51 N.Y.S.2d 478, 479 (N.Y. Co. Sup. Ct. +1944), aff'd, 63 N. 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09:07 +JD 8/4 09:07 +JD 8/4 09:08 +Y JD 8/4 09:10 +OT/CT Start +End +OT +KS 8/4 09:32 +SJ 8/4 10:42 +SJ 8/4 10:51 +SJ 8/4 10:51 +Y SJ 8/4 11:30 +OTiCT Start End +OT +Y SJ 814 11:35 +oTer Start End +Y SJ 8/4 11:38 +CrcT Start End + + +7 SOUTH +OPS LT +11 SOUTH #2 +11 SOUTH #2 +[Sick / Annual] +11 SOUTH #2 +(Inserted NCS) +11 SOUTH #2 +9 NORTH +9 NORTH +ACT LT +[Inserted NCS) +(sp)5 SOUTH +(sp)5 SOUTH +(Inserted) +[Inserted] +(Inserted] +[Inserted] +(Sick / Annual +[Sick / Annual] +[Sick / Annual] +[Sick / Annual] +SHU #2 +Sick Leave +Sick Leave +**Recapitulation*** +Splt Shft Officer +12 +12 WHA +12 +12 +12 +3 «Unassigned> +8 +«Unassigned> +8 +12 +Morning Watch +5 +AM Watch +3 +Day Watch +13 +PM Watch +3 +Evening Watch +12 +"Back Page Categories** +Sick Loave +LoVe 64 +Annual Leave +4 +LWOP +1 +1/25/20197:21:20 AM +Relieved Officer's +New Status +[Sick / Annual] +(Removed] +[Sick / Annual] +(Sick/Annual) +Sick Leave +(Sick/Annual] +[Time Change] +(Sick/Annual] +[Sick/Annual] +[Sick/Annual] +[Sick/Annual] +Day Off +Day Off +Day Off +Day Off +[Time Change] +Annual Leave +LWOP +Sunday August 04, 2019 +Page 5 +Relleving Officor's +Ret +Relleving Officer +Previous Status +Shft Changed By +89 NORTH +Y SJ 8/4 11:52 +Shift +OTICT Start End +7 SOUTH +OT +9 NORTH +TAIL +Annual Leave +«Unassigned› +«Unassigned> +«Unassigned› +8 11 SOUTH +Shift +9 NORTH +Staff +11 SOUTH +Shift +ACT LT +OPS LT +Shift +5 SOUTH +[Sick / Annuall +[Sick / Annual] +12 OPS LT +Staff +[Sick / Annual] +I s +SJ 8/4 11:52 +KS 814 11:56 +KS 8/4 11:59 +SJ 8/4 12:22 +SJ 8/4 12:22 +SJ 8/4 12:26 +SJ 8/4 12:27 +JD 8/4 13:06 +Y SJ 8/4 13:18 +OTeT Start End +Y SJ 8/4 13:25 +OT/CT Start End +OT +JD 8/4 13:58 +JD 8/4 13:58 +JD 8/4 13:58 +OT/CT Start End +OT +08:00 09:00 +KS 8/6 14:31 +KS 8/6 14:31 +KS 8/6 14:31 +KS 8/6 14:31 +KS B/6 14:32 +KS 8/6 14:32 +KS 8/6 14:32 +KS 8/6 14:33 +RW 8/8 12:33 +OT/CT Start End +OT +MC 8/11 11:32 +CM 8/22 08:15 + + +Sunday August 04, 2019 +Page 6 +COP +MILITARY LEAVE +1 +Total Correctional Sves. Staff: 113 +Non Correctional Svcs. Staff: 9 +Overtime Occurrences: 2 +Comptime Occurrences: ( +Ops Lt. Evening Watch Signature: +Captain's Signature: +1/25/20197:21:20 AM \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/1722c8d77c0decac261575cceecb399bda6ad8d565c6c642252aff43d7aa57e0.receipt.json b/vision-fixhub/ds9-parsed-01/1722c8d77c0decac261575cceecb399bda6ad8d565c6c642252aff43d7aa57e0.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..6d9b72e495ccc3c8349b4a924160a2dcec594de7 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1722c8d77c0decac261575cceecb399bda6ad8d565c6c642252aff43d7aa57e0.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -86, + "dataset": "marble-joined", + "doc_id": "1722c8d77c0decac261575cceecb399bda6ad8d565c6c642252aff43d7aa57e0", + "engine": "marble-apple-vision", + "event_count": 6, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "5eb8c1171bc1b54b7c4f779f9163500e478ebc4dd4488c1a5a31a849dbfe8350", + "output_sha256": "54d91e2eb15ca1d8ef2cb736d7d4af439b53643a62213ff94167456e0d0937d4", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/17284e83442b4b1db6546a5f3200d7fba4f6ae7a7ab2ae0c4b01bea68b2fbecb.md b/vision-fixhub/ds9-parsed-01/17284e83442b4b1db6546a5f3200d7fba4f6ae7a7ab2ae0c4b01bea68b2fbecb.md new file mode 100644 index 0000000000000000000000000000000000000000..46f6a4bcb71e2969ac4d7c488a8977ef435e793a --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/17284e83442b4b1db6546a5f3200d7fba4f6ae7a7ab2ae0c4b01bea68b2fbecb.md @@ -0,0 +1,165 @@ +From: BOBBI C STERNHEIM - +To: +Ce: Christian Everdell - +Jeff Pagliuca ‹ +Subject: US v. Maxwell -Trial Start Date +Date: Mon, 10 May 2021 21:33:55 +0000 +Laura Menninger +Good afternoon- +Following up on the status of our conferral emails as our joint letter (re: trial start date) is due today. +Thanks- +Bobbi +BOBBI C. STERNHEIM, ESQ. +Law Offices of Bobbi C. Sternheim +**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely. +Please use email or fax, instead of regular mail, for all correspondence during this time. +We continue to work regular business hours throughout this situation. +Thank you for your consideration. Our best wishes for your good health and well being. +This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim +that may be confidential and/or privileged. +If you are not the intended recipient, you may not read, copy, distribute, or use this information. +If you have received this transmission in error, please notify the sender immediately by reply e-mail and +then delete this message. Thank you. +On May 9, 2021, at 12:14 PM, BOBBI C STERNHEIM +» wrote: +Good afternoon- +In our 4/22 letter, we provided specific details concerning cases and trial dates +to justify our request for a continuance to 11/8. +Beyond a vague statement regarding consideration of availability of witnesses and counsel, +you have provided no specific details why the government cannot proceed to trial on 11/8. + + +Starting the trial on 11/29 - besides disrupting Thanksgiving holiday plans - will push the trial +Our previous email explained our reasons for firmly pressing the 11/8 trial date, +but as an accommodation, we would consider starting on 11/15, but no later. +For now, we will not agree to exclusion of speedy trial time beyond 11/8. +These scheduling conflicts can be easily eliminated by consenting to bail for Ms. Maxwell. +It is unclear why the scheduling order, which contemplated a continuance, should be altered. +As previously discussed and raised with the Court, we need to review of 3500 material +and exhibits before determining the need to call any experts. +Enjoy the day. +Bobbi +BOBBI C. STERNHEIM, ESQ. +Law Offices of Bobbi C. Sternheim +•*Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely. +Please use email or fax, instead of regular mail, for all correspondence during this time. +We continue to work regular business hours throughout this situation. +Thank you for your consideration. Our best wishes for your good health and well being. +This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim +that may be confidential and/or privileged. +If you are not the intended recipient, you may not read, copy, distribute, or use this information. +If you have received this transmission in error, please notify the sender immediately by reply e-mail and +then delete this message. Thank you. +On May 7, 2021, at 9:30 PM, +Bobbi, +Thanks very much for letting us know your availability. Regarding the trial date, after considering the availability of +witnesses and counsel, we plan to propose a trial date of November 29, 2021. Could you please let us know your +position regarding that date, so that we can include it in our letter to the Court? In addition, please let us know +whether you consent to an exclusion of time under the Speedy Trial Act between now and the new trial date the Court +selects. + + +With respect to other scheduling matters, we intend to propose that the Court set a deadline of three months before +trial for the Government to disclose the identities of victims referenced in the indictment; this is an earlier proposal +than the timeframe we had originally proposed for the July trial date. We also intend to propose that the deadline for +defense expert disclosures be set for two months before trial, given the substantial length of the adjournment. Please +let us know your position regarding those proposed dates and we'll include it in our letter. +Thanks very much, and hope everyone has a nice weekend-- +From: BOBBI C STERNHEIM +Sent: Friday, May 7, 2021 5:26 PM +Christian Everdell • +Laura +Menninger +; Jeff Pagliuca • +Subject: Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) +We are available to begin November 8th and to conclude by the end of the year. +Laura has a civil trial scheduled for December 13th, but will try to move it. +Bobbi +BOBBI C. STERNHEIM, ESQ. +Law Offices of Bobbi C. Sternheim +**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely. +Please use email or fax, instead of regular mail, for all correspondence during this time. +We continue to work regular business hours throughout this situation. +Thank you for your consideration. Our best wishes for your good health and well being. +This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim +that may be confidential and/or privileged. +If you are not the intended recipient, you may not read, copy, distribute, or use this information. +If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete +this message. Thank you. +On May 7, 2021, at 5:16 PM, +Bobbi, + + +We understand that you're requesting a November 8* date, and that you prefer that date. Separate from your +preferences, our question was simply about your scheduling availability in light of the Court's order. Can you please +let us know your availability and we will note that accordingly in our submission to the Court? +From: BOBBI C STERNHEIM • +Sent: Friday, May 7, 20214:00 PM +Cc: Christian Everdell ‹ +Laura Menninger < +Subject: Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) +Good afternoon- +For the reasons stated in our letter-motion of 4/22 (Dkt. 246), +our earliest and preferred date in the fall is 11/8. +In light of Ms. Maxwell's extended period of detention +and its deleterious effect on her health and well-being. +we cannot agree to a date far beyond 11/8. +However, should you agree to her release pending trial, +we would have greater date flexibility. +Enjoy the weekend. +Bobbi +BOBBI C. STERNHEIM, ESQ. +Law Offices of Bobbi C. Sternheim +33 West 19th Street - 4th Floor +New York, NY 10011 +Main: +Cell: +Fax: +*; Jeff Pagliuca +**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely. +Please use email or fax, instead of regular mail, for all correspondence during this time. +We continue to work regular business hours throughout this situation. +Thank you for your consideration. Our best wishes for your good health and well being. +This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim +that may be confidential and/or privileged. +If you are not the intended recipient, you may not read, copy, distribute, or use this information. +If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete +this message. Thank you. +On May 7, 2021, at 1:13 PM, + + +Hi Bobbi, +Thanks for your response. Your April 22, 2021 letter does not address the defense's availability for trial dates after +Nore to ' and the our e her presive mere pit. reside are these on tria nice of 2022 +witnesses regarding their availability, so we're gathering a variety of data points. Please let us know your +availability and we can put together a proposal. +Thanks, +From: BOBBI C STERNHEIM • +Sent: Thursday, May 6, 2021 11:58 PM +Cc: Christian Everdel +1°; Laura Menninger +Subject: Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) +Feit Pagluca +Good evening- +Our 4/22 letter detailed our position. Please let us know your availability for 11/8. +Thank you- +Bobbi +BOBBI C. STERNHEIM, ESQ. +Law Offices of Bobbi C. Sternheim +This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim +that may be confidential and/or privileged. +If you are not the intended recipient, you may not read, copy, distribute, or use this information. +If you have received this transmission in error, please notify the sender immediately by reply e-mail and then +delete this message. Thank you. + + +On May 6, 2021, at 7:15 PM, +Counsel, +We write to confer in accordance with the Court's Order about a trial date in this case. Please let us know your +preferences and availability for trial dates from September 2021 through the end of the year. If you could please +provide details for any conflicts, that would be helpful. +Thank you, +Assistant United States Attorney +Southern District of New York +One Saint Andrew's Plaza +New York, NY 10007 \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/17284e83442b4b1db6546a5f3200d7fba4f6ae7a7ab2ae0c4b01bea68b2fbecb.receipt.json b/vision-fixhub/ds9-parsed-01/17284e83442b4b1db6546a5f3200d7fba4f6ae7a7ab2ae0c4b01bea68b2fbecb.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..33e6f192f84889331e21585513d55386f0188f47 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/17284e83442b4b1db6546a5f3200d7fba4f6ae7a7ab2ae0c4b01bea68b2fbecb.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -101, + "dataset": "marble-joined", + "doc_id": "17284e83442b4b1db6546a5f3200d7fba4f6ae7a7ab2ae0c4b01bea68b2fbecb", + "engine": "marble-apple-vision", + "event_count": 7, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "b603f96b03385a9c4dc234452de5f3e55b55e47941f8b61857d49048e533cb7a", + "output_sha256": "6bd4bfe41ebacb62ac6458445eb725cd2dc8866a7ba28f6e6ad4f02eb6be0fba", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/174a4984cae7aa844e132c81ad7a805551716b89d5e6843dc9d6688307163869.md b/vision-fixhub/ds9-parsed-01/174a4984cae7aa844e132c81ad7a805551716b89d5e6843dc9d6688307163869.md new file mode 100644 index 0000000000000000000000000000000000000000..42e68e0efb208fdb80e3d00989e6db3464ddf4b8 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/174a4984cae7aa844e132c81ad7a805551716b89d5e6843dc9d6688307163869.md @@ -0,0 +1,36 @@ +From: " +To: " +(USANYS)" { +1" < +P, +Cc: " +(USANYS)" +Subject: Epstein +Date: Wed, 16 Sep 2020 14:48:14 +0000 +Attachments: SDNY +_ 2019.08.22. +_JE_Victim_List.rc.xlsx +(USANYS)" ≤ +Hey Team - As I know I mentioned to at least +if not all of you, ODAG is in the process of setting up a meeting +with victims that will likely occur in DC in the next 3-4 weeks. The meeting is a requirement of the Department's +settlement in the CVRA litigation, and its purpose is to explain and review the findings of OPR's investigation. +have been in touch with +I from ODAG who is coordinating the meeting, and have shared with her some +lessons from our own victim meetings around the time of the nolle last year, and they are a taking a number of steps +based on that experience to try to, among other things, minimize the likelihood that substantive victim interactions or +statements occur. +and +They have two asks of us. First, they would like to make sure their list of victims is as up-to-date as possible. Attached is +the list we sent them after the nolle proceeding last August. Do we have any additions to it? I've also suggested +reach out to both +and the FBI victim services coordinator, but wanted to check with you as well. +Second, they wanted to know if FBI-NY wanted to send someone or a team down to DC for this. While entirely up to us, +as noted, they are sensitive to the need to avoid this becoming a substantive discussion of any victim's experience and +would like to instead offer any victim who would like to discuss her experience the opportunity to meet privately with an +FBI agent, so if we would like, we can have that FBI agent be a member of our cased team. I'm also happy to raise with +directly, but figured I'd give you guys the opportunity to do so if you preferred. +Thanks, +U.S. Attorney's Office for the +Southern District of New York +Tel. diff --git a/vision-fixhub/ds9-parsed-01/174a4984cae7aa844e132c81ad7a805551716b89d5e6843dc9d6688307163869.receipt.json b/vision-fixhub/ds9-parsed-01/174a4984cae7aa844e132c81ad7a805551716b89d5e6843dc9d6688307163869.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..ff0144ac686eeecf09b88eaff127dd0444c3cb31 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/174a4984cae7aa844e132c81ad7a805551716b89d5e6843dc9d6688307163869.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "174a4984cae7aa844e132c81ad7a805551716b89d5e6843dc9d6688307163869", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "df94510bf3b64851c2eee09bb9f3826c38f1d6704419b65a8c632578b05fe23a", + "output_sha256": "1c7a0f9e2316201ad3cf064ae647a4b63ac885f62250363ab6ace71daf7824e8", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1764930f58bda1a89e0baca17a6fed344a23a3af91004e30fe3d0a4b3d819d64.md b/vision-fixhub/ds9-parsed-01/1764930f58bda1a89e0baca17a6fed344a23a3af91004e30fe3d0a4b3d819d64.md new file mode 100644 index 0000000000000000000000000000000000000000..24b0927894069b709c79f447471dc2a2e20fc1c8 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1764930f58bda1a89e0baca17a6fed344a23a3af91004e30fe3d0a4b3d819d64.md @@ -0,0 +1,39 @@ +From: +To: +Subject: +Date: +Re: Create Work Orders July (Away From the Office) +Friday, August 9, 2019 6:51:31 AM +I will be out of the office on Monday August 5 - Friday August 9 I will have limited phone and email access. +Acting for me is +•on Monday 8/5 and Tuesady 8/6 she can be reached atl +and/or via radio +track 4. Wednesday thru Friday Mr. +will be acting and he can be reached at +track 4 via radio. +>>> +08/09/19 06:51>>> +Custody +1. 4/5 Door In Operable +2. 11 South Case Manger Phone +3. 2 Sally Phone Inoperable +4. 13 Door Power Supply +Psych +1 Relocate Phones +Lt's Office Custody +1. SHU LT add Line For Tel-conference +2. 10 South Phone Autodial +Business Office +1.Program Phone For Procurement Specialist +2. Added For Budget Analyst Business Office +Medical +1.DID for Radiology +Reentry +1. Rewire Office +Communication Technician +US Department of Justice +MCC-New York +150 Park Row +New York, NY 10007-1704 + + diff --git a/vision-fixhub/ds9-parsed-01/1764930f58bda1a89e0baca17a6fed344a23a3af91004e30fe3d0a4b3d819d64.receipt.json b/vision-fixhub/ds9-parsed-01/1764930f58bda1a89e0baca17a6fed344a23a3af91004e30fe3d0a4b3d819d64.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..cd464b67f5c1fae53ce29866b8368f2b7f334443 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1764930f58bda1a89e0baca17a6fed344a23a3af91004e30fe3d0a4b3d819d64.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "1764930f58bda1a89e0baca17a6fed344a23a3af91004e30fe3d0a4b3d819d64", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "18dfb0777bbacf9dc28d03eb4ddc9e89fafd3e74ac9111a7d307aa66f6c00972", + "output_sha256": "23e9a52a8bece7a8cca52cf362b0e269288ac98f1fe9d3ec38a1ab0b6027dfe6", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1766450c5851c9c7030145b13286bf298171d04ec2057d8a3cebbfce759855a2.md b/vision-fixhub/ds9-parsed-01/1766450c5851c9c7030145b13286bf298171d04ec2057d8a3cebbfce759855a2.md new file mode 100644 index 0000000000000000000000000000000000000000..19bc5fbdf315a9e1ad5bd40a6b167899260cd3de --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1766450c5851c9c7030145b13286bf298171d04ec2057d8a3cebbfce759855a2.md @@ -0,0 +1,16 @@ +From: +To: +Subject: RE: Call with Roy Black +Date: Tue, 12 Aug 2008 20:56:35 +0000 +Importance: Normal +Just got out of a 2 ½ hour meeting with DEA. It made me want to work on Epstein. +From: Y +Sent: Tuesday, August 12, 2008 3:55 PM +Subyect: cal with Roy Black +Hi +and I are doing a conf call with Roy at 4:15. Can you give me a call before then? Thanks. +Assistant U.S. Attorney +500 S. Australian Ave, Suite 400 +West Palm Beach, FL 33401 +Phone +Fax 561 820-8777 diff --git a/vision-fixhub/ds9-parsed-01/1766450c5851c9c7030145b13286bf298171d04ec2057d8a3cebbfce759855a2.receipt.json b/vision-fixhub/ds9-parsed-01/1766450c5851c9c7030145b13286bf298171d04ec2057d8a3cebbfce759855a2.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..d3510838bec9a7cd42b754c75f7f23e4c0097173 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1766450c5851c9c7030145b13286bf298171d04ec2057d8a3cebbfce759855a2.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "1766450c5851c9c7030145b13286bf298171d04ec2057d8a3cebbfce759855a2", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "f345a92d03231adcdd9424ea653a6ea4c0859813f619f91b7d9b1936436f892a", + "output_sha256": "08035f9be3981db408230be98a20ad668d45f88c4eb149fcad04efd08246eca0", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/17978f21a681868d05c3b68429935c72487154f03da4355d8fa5132e97071080.md b/vision-fixhub/ds9-parsed-01/17978f21a681868d05c3b68429935c72487154f03da4355d8fa5132e97071080.md new file mode 100644 index 0000000000000000000000000000000000000000..e79a655f9a405d9edd913c340fba17cded7d8d99 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/17978f21a681868d05c3b68429935c72487154f03da4355d8fa5132e97071080.md @@ -0,0 +1,8 @@ +From: +To: +Subject: transition.prep.memo.for.audrey.docx +Date: Wed, 02 Dec 2020 22:32:39 +0000 +Attachments: transition.prep.memo.for.audrey.docx +Here are some comments. Look forward to discussing tomorrow. +I started without redlining but then began to redline after the first paragraph or so. +Thanks for this good start on this effort. diff --git a/vision-fixhub/ds9-parsed-01/17978f21a681868d05c3b68429935c72487154f03da4355d8fa5132e97071080.receipt.json b/vision-fixhub/ds9-parsed-01/17978f21a681868d05c3b68429935c72487154f03da4355d8fa5132e97071080.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..730843e60c1a59e8404d2da4d6fcf852b537c714 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/17978f21a681868d05c3b68429935c72487154f03da4355d8fa5132e97071080.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "17978f21a681868d05c3b68429935c72487154f03da4355d8fa5132e97071080", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "669410058d86f7bbc1147a64d946cd612722e39c4f86dc1c85bf656cf053c9eb", + "output_sha256": "6653d134fd33aef5f7cfc33c16b21c89d719af23677d2fd69a331e16acde09b8", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/17a0470a7e50cabae2b8505718cd40174733548b4b0cd63543c5c07cf03b7b0e.md b/vision-fixhub/ds9-parsed-01/17a0470a7e50cabae2b8505718cd40174733548b4b0cd63543c5c07cf03b7b0e.md new file mode 100644 index 0000000000000000000000000000000000000000..87712dcb57b1395740cc78da5a75b55eea0c644f --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/17a0470a7e50cabae2b8505718cd40174733548b4b0cd63543c5c07cf03b7b0e.md @@ -0,0 +1,11 @@ +From: " +To: " +(USANYS)". +(USANYS)" < +Subject: pipeline +Date: Tue, 08 Dec 2020 15:58:38 +0000 +Public Corruption: +• Still pending for decision/resolution in early 2021 are +Counsel to the Acting U.S. Attorney +United States Attorney's Office +Southern District of New York diff --git a/vision-fixhub/ds9-parsed-01/17a0470a7e50cabae2b8505718cd40174733548b4b0cd63543c5c07cf03b7b0e.receipt.json b/vision-fixhub/ds9-parsed-01/17a0470a7e50cabae2b8505718cd40174733548b4b0cd63543c5c07cf03b7b0e.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..00aead6a7db90fb32e02e02e2216a5bdcf3fbd56 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/17a0470a7e50cabae2b8505718cd40174733548b4b0cd63543c5c07cf03b7b0e.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "17a0470a7e50cabae2b8505718cd40174733548b4b0cd63543c5c07cf03b7b0e", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "87dc37e6a9a79804d0c8fa7359d49fac5180a675206ae38390add86669a97da0", + "output_sha256": "d881cec10b7c9238967b0d91cefa160238207b2c5d336eb036365aef9ccdb6b6", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/17dde891141a06ab15b5bc8cf55c2feca90aae8a7555baff4dbcc8588d20b1d7.md b/vision-fixhub/ds9-parsed-01/17dde891141a06ab15b5bc8cf55c2feca90aae8a7555baff4dbcc8588d20b1d7.md new file mode 100644 index 0000000000000000000000000000000000000000..d61e271108960a5c930a73c583d542f5bd0e888f --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/17dde891141a06ab15b5bc8cf55c2feca90aae8a7555baff4dbcc8588d20b1d7.md @@ -0,0 +1,44 @@ +From: lenforcement < +To: +Subject: Apple Response; Case Number: 2019R01059; (19271022) +Date: Thu, 19 Sep 2019 21:10:22 +0000 +Importance: Normal +Attachments: 19271022_Production.zip.gpg +Via Email Delivery +AUSA +United States Attorney's Office +One St. Andrew's Plaza +New York, NY +Dear AUSA +Apple Inc. ("Apple") is providing APL000001 through APL000004 in response to the legal request received by Apple on +2019-08-13. These files are true copies of the data Apple has located based on a reasonable search of the last 12 months of +its data using the criteria and information provided in the legal request. Said files were prepared by Apple personnel in the +ordinary course of business. +For data security and customer confidentiality purposes, Apple's production of data containing customer personally +identifying information is encrypted using GPG encryption software. Law enforcement officers who receive Apple data +must be able to manage production files encrypted with the GPG format without technical assistance from Apple. +Technical information relating to GPG encryption software is available at: http://www.gpg4win.org/doc/en/gpg4wincompendium.html. Information in relation to installing GPG on Windows OS is included in this link under the heading +*Installing Gpg4win'. If you require further technical assistance/information, please consult your agency's Information +Technology Department. +The password for the GPG file will be provided in a separate email. Please note, any xls files will need to be opened in +"Read Only" mode. +You may note entries from IP addresses beginning with "17." and/or "10." for any available connection logs provided. IP +addresses beginning with "17." are assigned to Apple and their occurrence in these logs is reflective of activity on Apple +internal servers and not an indication of any user connections. IP addresses beginning with "10." in relation to Find My +iPhone ("FMIP") logs are also reflective of activity on Apple internal servers and not an indication of any user connections. +All evidence preservation pursuant to the herein request response is the responsibility of the requesting law enforcement +agency. +Sincerely, +lan +Apple Privacy & Law Enforcement Compliance +http://www.apple.com/privacy/ +Enclosures + + +For more information about Apple's Legal Process Guidelines for U.S. Law Enforcement, please visit: +http://www.apple.com/legal/privacy/law-enforcement-guidelines-us.pdf +#******************************************************************** +This transmission may contain confidential information intended only for the person(s) named above. Any other +distribution, re-transmission, copying or disclosure is strictly prohibited. If you have received this transmission in error, +please notify l +immediately and delete this file/message from your system. diff --git a/vision-fixhub/ds9-parsed-01/17dde891141a06ab15b5bc8cf55c2feca90aae8a7555baff4dbcc8588d20b1d7.receipt.json b/vision-fixhub/ds9-parsed-01/17dde891141a06ab15b5bc8cf55c2feca90aae8a7555baff4dbcc8588d20b1d7.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..ca06b4fcf7c8abd4802778ec36ef04b44a417e09 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/17dde891141a06ab15b5bc8cf55c2feca90aae8a7555baff4dbcc8588d20b1d7.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -26, + "dataset": "marble-joined", + "doc_id": "17dde891141a06ab15b5bc8cf55c2feca90aae8a7555baff4dbcc8588d20b1d7", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "6dc1513270320e2a0a6c8eeab71aef8e4ae9759e1fcf177f6208c9a3bbfc043e", + "output_sha256": "1eb517a8d39389b6fa8a4599ad1716a3f7295fe4d15517de0530d79d701fd5f8", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/17f0bc674e7f983a2db8e3433d588d5af3fb1e82aa94887b2f93d136d8c35ae9.md b/vision-fixhub/ds9-parsed-01/17f0bc674e7f983a2db8e3433d588d5af3fb1e82aa94887b2f93d136d8c35ae9.md new file mode 100644 index 0000000000000000000000000000000000000000..b26e00f456f14e1b3656775332c7f3e255d2f40d --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/17f0bc674e7f983a2db8e3433d588d5af3fb1e82aa94887b2f93d136d8c35ae9.md @@ -0,0 +1,11 @@ +C/O Thomas was assigned to staff watch; however, the wrong book was used (I/M companion log) in lieu of Staff Suicide Watch log. +discovered the wrong log was used. +completed a 2nd log using Suicide Watch log ( +initialed the log for +Thomas). +Entries are identical in both logs. +Associate Warden +MCC New York +New York. NY 10007 + +SDNY_00011191 \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/17f0bc674e7f983a2db8e3433d588d5af3fb1e82aa94887b2f93d136d8c35ae9.receipt.json b/vision-fixhub/ds9-parsed-01/17f0bc674e7f983a2db8e3433d588d5af3fb1e82aa94887b2f93d136d8c35ae9.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..1139023527f433eb4b33fc1478bab9f3f92d6275 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/17f0bc674e7f983a2db8e3433d588d5af3fb1e82aa94887b2f93d136d8c35ae9.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "17f0bc674e7f983a2db8e3433d588d5af3fb1e82aa94887b2f93d136d8c35ae9", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.stamp-stripping.confidential\"]", + "idempotent": true, + "input_sha256": "ac6df1c8b97c2793588276426cba2683900cd7717ee521b9713e5abe0c222f8f", + "output_sha256": "d31a96d3e8c80283bcc7bb569dd13879ae4ad45eed0ce8ba83ef65b89fde9a50", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/17f48471ffa2729245b45eab32d09cc5a36e70f98bed49f1286cef353e54d468.md b/vision-fixhub/ds9-parsed-01/17f48471ffa2729245b45eab32d09cc5a36e70f98bed49f1286cef353e54d468.md new file mode 100644 index 0000000000000000000000000000000000000000..491c915c345949a9bff88152a0734d5bda98c167 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/17f48471ffa2729245b45eab32d09cc5a36e70f98bed49f1286cef353e54d468.md @@ -0,0 +1,14 @@ +From: +To:/ +Ce: +Subject: Ghislaine Maxwell +Date: Sat, 06 Mar 2021 17:33:48 +0000 +Hi L +Hope you're doing well. Could you please let us know whether Ghislaine Maxwell has received (or has been offered) the +COVID-19 vaccine? +Thanks, +- +Assistant United States Attorney +Southern District of New York +One Saint Andrew's Plaza +New York, NY 10007 diff --git a/vision-fixhub/ds9-parsed-01/17f48471ffa2729245b45eab32d09cc5a36e70f98bed49f1286cef353e54d468.receipt.json b/vision-fixhub/ds9-parsed-01/17f48471ffa2729245b45eab32d09cc5a36e70f98bed49f1286cef353e54d468.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..713664c40ab70e3f55fd83dec4b35417bf0ef435 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/17f48471ffa2729245b45eab32d09cc5a36e70f98bed49f1286cef353e54d468.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "17f48471ffa2729245b45eab32d09cc5a36e70f98bed49f1286cef353e54d468", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "0ffe688d5d66b5bc89fa1e3f1db061fd641abc8339f07664f328762be2a8db55", + "output_sha256": "47fa1f0d1ad5c91b056059e32bea8d184f723c8543ba15a938075795ef8acdb9", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/180388076d060a20044ae39f35cffc064c6b2e6a5f0d011e85e15a6bc17dd32a.md b/vision-fixhub/ds9-parsed-01/180388076d060a20044ae39f35cffc064c6b2e6a5f0d011e85e15a6bc17dd32a.md new file mode 100644 index 0000000000000000000000000000000000000000..4429ece5a3781c6beb9803448094659530d89d5f --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/180388076d060a20044ae39f35cffc064c6b2e6a5f0d011e85e15a6bc17dd32a.md @@ -0,0 +1,33 @@ +From: +Subject: +Date: +Attachments: +Re: OT issues +Monday, August 12, 2019 11:16:44 AM +TEXT. hem +[pt_staff daily assign NOEL_1.rtf +[pt_staff daily_assign M THOMAS.If +rot staff daily assign +The attached reflects the OT worked by Noel and Thomas (2 officers on post at time of death) and l +verbally notified to provide cell mate). +(Officer +Note that Thomas works in Warehouse. His Daily Assignment Card only reflects overtime worked. His regular +schedule is 8am to 4pm, Monday through Friday, indicating he was off on days he worked Sat/Sun OT, and was +off the 8 hours prior to his overtime. Since he is not a Correctional Officer, none of these OT's would have been +a mandates and the fact they are all on morning watch means they are not augmentations. He signed up and +requested overtime on these dates. +Northeast Region +>>> +Yes...I'm in a meeting and will send soon. +> 8/12/2019 10:49 AM »>> +Sent from my Verizon, Samsung Galaxy smartphone +- Original message -- +From: +To: +Date: 8/12/19 10:34 AM (GMT-05:00) +Subject: OT issues +>>> +>>> +Per our discussion, it would be helpful to get a short description of the staffing issues at the MCC, +including (1) the OT for the staff in question and (2) OT issues at the MCC generally. +Thanks, diff --git a/vision-fixhub/ds9-parsed-01/180388076d060a20044ae39f35cffc064c6b2e6a5f0d011e85e15a6bc17dd32a.receipt.json b/vision-fixhub/ds9-parsed-01/180388076d060a20044ae39f35cffc064c6b2e6a5f0d011e85e15a6bc17dd32a.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..5fc0094276ac6c99556bdbc277f2116f7373d05d --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/180388076d060a20044ae39f35cffc064c6b2e6a5f0d011e85e15a6bc17dd32a.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "180388076d060a20044ae39f35cffc064c6b2e6a5f0d011e85e15a6bc17dd32a", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "ba525c32b6e5c6af2609b86d0d6a69f2033d05f7303c1e2d0e17e16d5ab58861", + "output_sha256": "e14d315b1463ab6219a12e9f0c4ea9e173962d6ed8c4c6db21ad1b0bab850d49", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/181e69f3c526435938572316b3f8e8148a15728bebee0cc1e0f4536cd61bd92e.md b/vision-fixhub/ds9-parsed-01/181e69f3c526435938572316b3f8e8148a15728bebee0cc1e0f4536cd61bd92e.md new file mode 100644 index 0000000000000000000000000000000000000000..2911b53409696e3a1ed17bde03dc662ee1b2ffff --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/181e69f3c526435938572316b3f8e8148a15728bebee0cc1e0f4536cd61bd92e.md @@ -0,0 +1,506 @@ +.: +LAST WILL AND TESTAMENT +OF +JEFFREY E. EPSTEIN +1, JEFFREY E. EPSTEIN, of Little St. James Island, St. Thomas, United States Virgin Islands, +do make, publish and declare this to be my Will hereby revoking all prior Wills and Codicils +made by me. +I direct my Executor to pay from my estate all expenses of +my last illness, my funeral and burial expenses, the administration expenses of my estate and all +of my debts duly proven and allowed against my estate. +B. +I direct my Executor to pay from my estate, as +compensation to each Executor for serving as Executor hereunder, the sum of Two Hundred +Fifty Thousand Dollars ($250,000) to each Executor upon the completion of probate of my +estate. No Executor shall receive any other compensation for serving as Executor hereunder; +provided, however, that my Executor shall be reimbursed from my estate for all reasonable +costs, expenses, charges, and liabilities incurred or paid in respect thereto, including fees and +expenses of counsel or any other agents hired by my Executor, and my Executor shall not be +liable therefor individually. +C. +I direct my Executor to pay from my estate the +federal and state transfer taxes described in Paragraph B(1) of Article SEVENTH. +direct my Executor to pay from my estate al +xpenses of storing, insuring, packing, shipping and delivering my tangible personal property i +accordance with Article SECOND. +SECOND: +I give all of my property, real and personal, wherever situated, +after the payments and distributions provided in Article FIRST, to the then acting Trustees of +The Jeffrey E. Epstein 2012 Trust (the "Trust") created under that certain Trust Agreement (the +"Trust Agreement) dated October 24, 2012, as the same may be amended from time to time, to +be held in accordance with the provisions comprising the Trust Agreement at the time of my +death. +THIRD: +A. +I appoint DARREN K. INDYKE, JOSEPH PAGANO and +2657367.1 +GJ_000138 + + +JAMES E. STALEY to be the Executors of this Will. If any one or more of my Executors fails +to qualify or ceases to act, I appoint ANDREW FARKAS as successor Executor. I authorize the +last acting Executor to designate his successor as Executor. +B. +If my estate must be administered in whole or in +part in any jurisdiction other than the state or territory of my domicile at the date of my death +and if my Executor is unable or unwilling to serve in such jurisdiction, then I appoint the +successor Executor of my estate designated in Paragraph A of Article THIRD provided that he is +able and willing to serve in such jurisdiction. If no Executor or successor Executor is able and +willing to serve in such jurisdiction, my Executor shall designate a successor Executor to serve +in such jurisdiction. Such designation shall be made by written instrument delivered to such +successor Executor. +C. +No bond or other security shall be required of any +Executor in any jurisdiction. +Any Executor may resign in the manner provided +for by the governing statutes of the state or territory having jurisdiction of the administration of +my estate or, in the absence of such statutory guidance, by filing a written notice of resignation +with the Court having jurisdiction of the administration of my estate. Any Executor who resigns +shall not be entitled to any compensation hereunder for any services rendered as Executor prior +to his resignation. +B. +My Executor shall not be accountable or +responsible to any person interested in my estate for the manner in which my Executor in good +faith exercises or declines to exercise any discretionary authority or power of my Executor. My +Executor shall not be liable for any loss or depreciation in value occasioned by reason of any +negligence, error or mistake of judgment in entering into any transaction, in making any sale or +investment, in continuing to hold any property or by reason of any action or omission, whether +by my Executor or any other fiduciary, unless my Executor has acted in bad faith. In the absence +of proof by affirmative evidence to the contrary, each Executor shall be deemed to have acted +within the scope of my Executor's authority, to have exercised reasonable care, diligence and +prudence and to have acted impartially as to all interested persons. An Executor shall not be +liable for the acts or defaults of another Executor. +FOURTH: The following provisions shall apply to my estate and to my +Executor, except as is otherwise specifically provided in this Will: +A. +My Executor has the entire care and custody of all +this power it would not be authorized or appropriate for fiduciaries under any statutory or other +rule of law. My Executor shall exercise my Executor's best judgment and discretion for what +ly Executor believes to be in the best interests of the beneficiaries hereunder. It more than tw +xecutors are empowered to participate in the decision to exercise or not exercise any fiduciar +power granted by this Will or by law, a majority of such Executors shall be empowered to make +such decision. +2 +GJ_000139 + + +Except as otherwise provided herein, my Executor +shall have the power: +(1) to enter upon and take possession of the +assets of my estate and collect the income and profits from such assets, and to invest and +reinvest such assets in real, personal or mixed assets (including the common trust funds of a +corporate fiduciary) or in undivided interests therein without being limited by any present or +future investment laws; +(2) to retain all or any part of the assets of my +estate (without regard to the proportion that any one asset or class of assets may bear to the +whole) in the form in which such assets were received or acquired by my Executor; +(3) +to sell or dispose of, exchange, transfer, +invest or loan all or any part of the assets of my estate which may, at any time, be held by my +Executor for such sums or upon such terms as to payment, security or otherwise as my Executor +determines, either by public or private transactions; +to buy and sell options, warrants, puts, calls +or other rights to purchase or sell (collectively "options") relating to any security or securities, +regardless of whether such security or securities are then held by my Executor, and whether +such options are purchased or sold on a national securities exchange, and to exercise with +respect to such options all powers which an individual owner thereof could exercise, including, +without limitation, the right to allow the same to expire; +and all other natural resources and rights to and interests therein (together with all equipment +pertaining thereto) including, without limiting the generality of the foregoing, oil and gas +royalties, leases, or other oil and gas interests of any character, whether owned in fee, as lessee, +lessor, licensee, concessionaire or otherwise, or alone or jointly with others as partner, joint +tenant, or joint venture in any other noncorporate manner, (a) to make oil, gas and mineral +leases or subleases; (b) to pay delay rentals, lease bonuses, royalties, overriding royalties, +taxes, assessments, and all other charges; (c) to sell, lease, exchange, mortgage, pledge or +otherwise hypothecate any or all of such rights and interests; (d) to surrender or abandon, with +or without consideration, any or all of such rights and interests; (e) to make farm-out, pooling, +and unitization agreements; (f) to make reservations or impose conditions on the transfer of +any such rights or interests; (g) to employ the most advantageous business form in which +properly to exploit such rights and interests, whether as corporations, partnerships, limited +partnerships, mining partnerships, joint ventures, co-tenancies, or otherwise exploit any and all +such rights and interests; (h) to produce, process, sell or exchange all products recovered +through the exploitation of such rights and interests, and to enter into contracts and agreements +for or in respect of the installation or operation of absorption, reprocessing or other processing +plants; (i) to carry any or all such interests in the name or names of a nominee or nominees; (i) +to delegate, to the extent permitted by law, any or all of the powers set forth herein to the +operator of such property; and (k) to employ personnel, rent office space, buy or lease office +equipment, contract and pay for geological surveys and studies, procure appraisals, and +generally to conduct and engage in any and all activities incident to the foregoing powers, with +3 +GJ_000140 + + +full power to borrow and pledge in order to finance such activities; together with the power to +allocate between principal and income any net proceeds received as consideration, whether as +royalties or otherwise, for the permanent severance from lands of oil, natural gas, minerals, and +all other natural resources; +(6) to hold all or any part of the assets of my +estate in cash or in bank accounts without the necessity of investing the same; +(7) +to improve, repair, partition, plat or +subdivide all or any part of the assets of my estate; +to litigate, defend, compromise, settle +bandon or submit to arbitration on such terms and conditions as my Executor determines an +claims in favor of or against my estate or the assets of my estate; +(9) to loan or borrow money in such amounts +and upon such terms and conditions as my Executor determines, assume such obligations or give +such guarantees as my Executor determines, for the purpose of the acquisition, improvement, +protection, retention or preservation of the assets of my estate, or for the welfare of the +beneficiaries of my estate; +(10) to carry on for as long and in such manner +as my Executor determines any business enterprise in which I owned any interest at my death, +either individually, or as a partner, joint venture, stockholder or trust beneficiary; to sell such +business enterprise as an ongoing business; to consolidate, merge, encumber, dissolve, liquidate +or undertake any other extraordinary corporate transaction relating to such business enterprise; +(11) to vote in person or by proxy any and all +stock or securities and to become a party to any voting trusts, reorganization, consolidation or +other capital or debt readjustment of any corporation, association, partnership, limited liability +partnership, limited liability company or individual with respect to stocks, securities or debts +held by my estate; +(12) except as provided in paragraphs B(19) and +B(20) of this Article FOURTH, to enter into any good faith transactions with my Executor +individually or with any corporation, partnership or other entity in which my Executor has an +ownership interest; +(13) to lease, mortgage, pledge, grant a security +interest in or otherwise encumber all or any part of the assets of my estate for any term of years +whether or not beyond the duration of my estate (including, without limitation, any such action +for the benefit of any of the beneficiaries of my estate); +(14) to abandon any property of my estate, real +or personal, which my Executor may deem worthless or not of sufficient value to warrant +keeping or protecting; to abstain from the payment of taxes, water rents or assessments and to +forego making repairs, maintaining or keeping up any such property; and to permit such +property to be lost by tax sale or other proceedings or to convey any such property for a nominal +4 +GJ_000141 + + +consideration or without consideration so as to prevent the imposition of any liability by reason +of the continued ownership thereof; +(15) to elect the mode of distribution of the +proceeds payable to my estate from any profit-sharing plan, pension plan, employee benefit +plan, individual retirement plan, insurance contract or annuity contract pursuant to the terms of +such plan; +(16) to allocate, in my Executors discretion, any +adjustment to basis provided to my estate under the provisions of Federal and State law with +respect to property comprising my estate, without any obligation to make a compensatory +adjustment among the beneficiaries hereunder on account of such allocation; +(17) to conduct any audit, assessment or +investigation with respect to any asset of my estate regarding compliance with any law or +regulation having as its object protection of public health, natural resources or the environment +("Environmental Laws"); to pay from the assets of my estate to remedy any failure to comply +with any Environmental Law (even to the exhaustion of all of the assets of my estate); and, as +may be required in my Executor's judgment by any Environmental Law, to notify any +governmental authority of any past, present or future non-compliance with any Environmental +Law; and +(18) to sell to the Trustee under the Trust +Agreement any stocks, bonds, securities, real or personal property or other assets or borrow +from the Trustee under the Trust Agreement even though the same person or persons occupy the +office of the Executor of my estate and the Trustee under the Trust Agreement. +(19) No executor shall directly or indirectly buy +or sell any property for the estate from or to himself, or from or to his relative, employer, +employee, partner, or other business associate. +(20) No executor shall lend estate funds to +himself, or to his relative, employer, employee, partner, or other business associate. +C. +Except as otherwise provided herein, my Executor +shall have the power: +to employ agents, +consultants, investment advisers (to whom my Executor has discretion to delegate my +Executor's investment authority and responsibility), other executors and other fiduciaries in the +administration of my Executor's duties; to delegate to such persons, or to one or more of my +Executors, the custody, control or management of any part of my estate as my Executor +determines and to pay for such services from the assets of my estate, without obtaining judicial +authorization or approval; +(2) to delegate, in whole or in part, to any +person or persons the authority and power to (a) sign checks, drafts or orders for the payment or +withdrawal of funds, securities and other assets from any bank, brokerage, custody or other +5 +GJ_000142 + + +account in which funds, securities or other assets of my estate shall be deposited, (b) endorse for +sale, transfer or delivery, or sell, transfer or deliver, or purchase or otherwise acquire, any and +all property, stocks, stock warrants, stock rights, options, bonds or other securities whatsoever, +(c) gain access to any safe deposit box or boxes in which my assets or assets of my estate may +be located or which may be in the name of my Executor and remove part or all of the contents of +any such safe deposit box or boxes and release and surrender the same, and (d) take any other +action that my Executor may have the power to take with respect to my estate and the property +thereof; no person or corporation acting in reliance on any such delegation shall be charged with +notice of any revocation or change of such delegation unless such person or corporation receives +actual notice thereof; +(3) to pay any property distributable to a +beneficiary under a legal disability, without liability to my Executor, by paying such property +(a) to such beneficiary, (b) for the use of such beneficiary, (C) to a legal representative of such +beneficiary appointed by a court or if none, to a relative for the use of such beneficiary, or (d) to +a custodian for such beneficiary designated by my Executor; +to distribute to any of the beneficiaries of +my estate in kind or in cash, or partly in kind and partly in cash, and to allocate different kinds +or disproportionate shares of assets or undivided interests in assets among all of such +beneficiaries; +(5) to have evidence of ownership of any +security maintained in the records of a Federal Reserve Bank under the Federal Reserve Book +Entry System; to deposit funds in any bank or trust company; to carry in the name of my +Executor or the nominee or nominees of my Executor and with or without designation of +fiduciary capacity, or to hold in bearer form, securities or other property requiring or permitting +of registration; and to cause any securities to be held by a depository corporation of which an +Executor is a member or by an agent under a safekeeping contract; provided, however, that the +books and records of my Executor shall at all times show that such investments are part of my +estate; +(6) to renounce and disclaim, in whole or in +part, and in accordance with applicable law, any assets, interests, rights or powers (including +ny power of appointment) which are payable to (or exercisable by) me or my estate, which are +ncludible in my estate or Gross Estate or over which I have any right, title, interest or power +and +on the life of an Executor which is included in my netie, such axe infor she pol py or ipate ly +the decision to exercise or not exercise any fiduciary power in connection with any incidents of +6 +GJ_000143 + + +ownership for such policy or annuity, including, without limitation, any decision to continue, +assign, terminate or convert such policy or annuity or to name the beneficiary of such policy or +annuity. +E. +An Executor hereunder may by a written notice +delivered to the other Executor (or Executors) decline to participate in the decision to exercise or +not exercise any fiduciary power granted by this Will or by law. +F. +If an Executor is not empowered (because of a +conflict of interest, declination to act or otherwise) to participate in the decision to exercise or +not exercise any fiduciary power granted by this Will or by law, then the remaining Executor or +Executors shall be empowered to make such decision. If no Executor is empowered to +participate in such decision, then the successor Executor of my estate designated in Paragraph A +of Article THIRD and able and willing to act shall be empowered to make such decision. If no +Executor or successor Executor is empowered to participate in such decision, my Executor may +designate a successor Executor to serve as Executor of my estate who shall be empowered to +make such decision but shall have no other power or authority of my Executor. Such designation +shall be by written notice delivered to such successor Executor. +(1) Except as otherwise specifically provided +herein and except as provided in Paragraph G(2) of this Article, my Executor shall allocate +receipts and disbursements in accordance with sound trust accounting principles and shall have +discretion to allocate receipts and disbursements when the treatment is uncertain under +applicable laws or generally accepted accounting principles in the judgment of my Executor. +(2) +Except as otherwise specifically provided in +this Will, my Executor shall not treat any part of the principal amount of the proceeds of sale of +any asset of my estate as income distributable to or for the benefit of any beneficiary entitled to +distributions of income; provided, however, that my Executor shall treat a portion of any +proceeds of sale of any financial instrument originally issued or acquired at a discount equal to +the amount which (a) has previously been characterized as ordinary income for income tax +purposes or (b) will be characterized as ordinary income for income tax purposes in the year of +such sale, as income for trust accounting purposes. +FIFTH: +Where a party to any proceeding with respect to my estate has the +same interest as a person under a disability, it shall not be necessary to serve legal process on the +person under a disability. +SIXTH: +If any beneficiary under the Trust shall in any way directly or +indirectly (a) contest or object to the probate of my Will or to the validity of any disposition or +provision of my Will or of the Trust or (b) institute or prosecute, or be in any way directly or +indirectly instrumental in the institution or prosecution of, any action, proceeding, contest, +objection or claim for the purpose of setting aside or invalidating my Will or the Trust or any +disposition therein or provision thereof, then I direct that (a) any and all provisions in the Trust +for such beneficiary and his issue in any degree shall be null and void and (b) my estate, whether +passing under my Will or the Trust or pursuant to the laws of intestacy, shall be disposed of as if +such beneficiary and his issue in any degree had all failed to survive me. +7 +GJ_000144 + + +SEVENTH: A. As used herein: +(1) The term "Executor" of a person's estate +means all persons or entities who occupy the office of executor, administrator, personal +representative, or ancillary administrator while such persons or entities occupy such office, +whether one or more persons or entities occupy such office at the same time or times, and +includes any successor or successors to that office. The term "Trustee" means all persons or +entities who occupy the office of Trustee under the Trust Agreement while such persons or +entities occupy such office, whether one or more persons or entities occupy the office of Trustee +at the same time or times, and includes any successor Trustee or Trustees. A reference to a +person's estate or probate estate means that person's estate which is subject to probate +administration. A reference to a person's Will means such person's Last Will and Testament and +any Codicil or Codicils thereto. +(2) The term "IRC section" means a section of +the Internal Revenue Code of 1986, as amended, or the corresponding provision of any +successor Internal Revenue law, as in effect as of the date of my death. +A reference to any tax also includes any +interest or penalties thereon. A reference to a person's "Gross Estate" means such person's gross +estate as finally determined for purposes of computing such person's federal estate tax. +(4) +Whenever the singular number is used, the +same shall include the plural, and the masculine gender shall include the feminine and neuter +genders. +B. +(1) The federal and state transfer taxes which +my Executor shall be obligated to pay pursuant to Paragraph B of Article FIRST shall consist of +all federal and state estate, inheritance, succession, and similar taxes (including any federal or +state generation-skipping transfer tax) imposed upon my probate estate or by reason of my death +in respect to all assets which pass under this Will or the Trust Agreement. Subject to Paragraph +B(2) of this Article, all federal estate taxes with respect to assets not passing under this Will or +the Trust Agreement (such assets are referred to as the "Apportionment Assets") and any +applicable state estate taxes with respect to the Apportionment Assets shall be apportioned +among all persons interested in the Apportionment Assets. My Executor shall make reasonable +efforts to collect all federal estate taxes and state estate, inheritance, succession and similar taxes +allocable to the Apportionment Assets from the recipients of the Apportionment Assets. Without +changing the apportionment of taxes in this Paragraph B(1), my Executor has discretion, but is +not required, to pay all or part of such taxes allocable to the Apportionment Assets. To the +extent my Executor pays such taxes allocable to the Apportionment Assets, my Executor shall +seek reimbursement for such taxes from the recipients of the Apportionment Assets. My +Executor shall not be personally liable for any of such taxes if my Executor is unable, with +reasonable efforts, to collect payment (or reimbursement) from any recipient of any +Apportionment Assets for any or all of such taxes allocable to such assets. +(2) My Executor has discretion to direct the +Trustee of the Trust Agreement to pay all or any portion of the taxes which my Executor is +8 +GJ_000145 + + +directed or obligated to pay pursuant to Paragraph B of Article FIRST and this Paragraph B +pursuant to a written direction delivered to the Trustee under the Trust Agreement. Any taxes +which my Executor directs the Trustee under the Trust Agreement to pay shall be allocated and +paid from the trusts under the Trust Agreement as provided under the Trust Agreement. +Except as otherwise specifically provided in this +Will, a bequest or devise to an individual who does not survive me shall lapse notwithstanding +any law to the contrary. +D. +To the extent that the distribution to the Trustee +under the Trust Agreement pursuant to Article SECOND shall not be effective, I give all the rest +of my property, real and personal, wherever situated, after the payments and distributions +provided in Article FIRST, to the person or persons named as Trustee or Trustees under the +Trust Agreement, be to held in trust under this Will in accordance with the provisions +comprising the Trust Agreement at the time of my death, which provisions are incorporated in +this Will by reference. +IN WITNESS WHEREOF, I have duly executed this Will the 24* day of +October, 2012. +JEFFREY ELEPSTEIN +The foregoing written instrument was on the date thereof, signed, published and +declared by the Testator therein named as the Testator's Will in the presence of us and of each +of us, who, at the Testator's request, in the Testator's presence and in the presence of each +her, have subscribed our names as witnesses thereto. +_residing at +residing at +RICHARD KAHN +9 +GJ_000146 + + +JEFFREY E. EPSTEIN, Richard anet and, Richard Kahunthe Testator +and the witnesses, respectively, whose names are signed to the foregoing instrument, having +been sworn, declared to the undersigned officer that the Testator, in the presence of the +witnesses, signed the instrument as his Will, that he signed, and that each of the witnesses, in the +presence of the Testator and in the presence of each other, signed the Will as a witness. +JEFFREY E. EPSTEIN +Shad Daunt +lichard Kaln +RICHARD KAHA +STATE OF +)ss: +COUNTY OF ) +Subscribed and sworn to before me by JEFFREY E. EPSTEIN, the Testator, who is personally +known to me or who has produced +Richard Barnett +as identification, and by +as id witness , and perhaly Kaln to me or who has +witness who is personally known to me or who has produced +as identification, on +October 24, 2012. +Sworn to before me this 24"* day of +October, 2012. +Votary Publi +Hither +Notar: +Cusi +Commis. +ER +New York +OUnt +1. 7. 20.14 +10 +GJ_000147 + + +FIRST CODICIL TO LAST WILL AND TESTAMENT +OF +JEFFREY E. EPSTEIN +1, JEFFREY E. EPSTEIN, of Little St. James Island, United States Virgin Islands, +having made my last will and testament dated October 24, 2012, declare this to be a +FIRST: +I hereby delete paragraph A of Article THIRD of my will and +substitute in its place the following new paragraph A of Article THIRD: +"A. +I appoint DARREN K. INDYKE, JOSEPH PAGANO and JAMES E. STALEY +to be the executors of this Will. If any one or more of my Executors fails to qualify or +ceases to act, I appoint DAVID J. MITCHELL as successor Executor. I authorize the +last acting Executor to designate his successor Executor." +SECOND: +testament. +In all other respects 1 ratify and republish my said last will and +IN WITNESS WHEREOF, I have dully executed this First Codicil to Last Will +and Testament of Jeffrey E. Epstein on the 6th day of June, 2013. +JEFFREY E EPSTEIN +presence of said Testator and of each other on the day and year last above written. +residing at +1 +GJ_000148 + + +AFFIDAVIT +STATE OF NEW YORK +COUNTY OF NEW YORK +) +) SS: +) +Each of the undersigned, being at least 18 years of age, being duly sworn, +deposes and says: +The foregoing instrument was subscribed in our presence and sight at +the end thereof by JEFFREY E. EPSTEIN, hereinafter referred to as the Testator, on +the 6th day of June, 2013. +2. +The Testator at the time of making such subscription declared and +published the foregoing instrument so subscribed to be a First Codicil to his Last +Will and Testament. +Each of the undersigned witnesses thereupon signed as a witness at +the end of the foregoing First Codicil to the Testator's Last Will and Testament at the +request of the Testator and in his presence and in sight of each other. +4. +The Testator, declares and each of the undersigned witnesses +confirms, that the Testator can read, write and converse in the English language; is +free from restraint and undue influence; is suffering no defect of sight, hearing or +speech and is suffering from no other physical or mental impairment; and is over 18 +The foregoing First Codicil to Last Will and Testament of Jeffrey E. +Epstein was executed as a single, original instrument and was not executed in +counterparts. +6. +Each of the undersigned witnesses was acquainted with the Testator +at such time and each of the undersigned witnesses makes this affidavit at Testator's +request. +2 +GJ_000149 + + +Each of the undersigned has, contemporaneously with the execution +of this affidavit, examined the signatures at the end of the foregoing First Codicil to +Last Will and Testament of Jeffrey E. Epstein, and such signatures are the signatures +affixed by the Testator and by each of the undersigned witnesses. +Testator, JEFPREY E. EPSTEIN +Celiaid +Witness, RICHARD KAHN +Delet +tRess, LESLEY GROFF +STATE OF NEW YORK +COUNTY OF NEW YORK +) +)ss: +) +Subscribed and sworn to before me by JEFFREY E. EPSTEIN, the Testator, who is +personally known to me or who has produced +as identification, and by +RICHARD KAHN, a witness who is personally known to me or who has produced +as identification, and LESLEY GROFF, a witness who is personally known to me or +who has produced +as identification, on June 6, 2013. +Sworn to before me this 6"* day of June, +2013. +Jotary Publi +Co +3 +GJ_000150 diff --git a/vision-fixhub/ds9-parsed-01/181e69f3c526435938572316b3f8e8148a15728bebee0cc1e0f4536cd61bd92e.receipt.json b/vision-fixhub/ds9-parsed-01/181e69f3c526435938572316b3f8e8148a15728bebee0cc1e0f4536cd61bd92e.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..9742f45e1192492903bba106ff0dd10f695fe46f --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/181e69f3c526435938572316b3f8e8148a15728bebee0cc1e0f4536cd61bd92e.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -156, + "dataset": "marble-joined", + "doc_id": "181e69f3c526435938572316b3f8e8148a15728bebee0cc1e0f4536cd61bd92e", + "engine": "marble-apple-vision", + "event_count": 13, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "8dbf39cc097b90a7cd796a06cca7606962ee589714582ed2b27e2b65ad779744", + "output_sha256": "0bf56baee090da7b84a43e79c3b2bd167d3a827228e865f4368a1fe302d5fc47", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1835668b4c89eed4ea8011c2fd8e35244053c3a6a923ddb122d2a6e7aa1f4441.md b/vision-fixhub/ds9-parsed-01/1835668b4c89eed4ea8011c2fd8e35244053c3a6a923ddb122d2a6e7aa1f4441.md new file mode 100644 index 0000000000000000000000000000000000000000..f28b32fec3f27210d72fc6f5d9ed98b03ad7d3d2 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1835668b4c89eed4ea8011c2fd8e35244053c3a6a923ddb122d2a6e7aa1f4441.md @@ -0,0 +1,13 @@ +From: " +To: ' +Subject: Epstein, Reg. No. 76318-054 +Date: Sat, 10 Aug 2019 22:14:05 + 0000 +Importance: Normal +Attachments: TEXT_1.htm; 2019_08_10_18_12_55.pdf; L +Psych Ops discontinued on 7/30/18 at 8:15 am +Associate Warden +MCC New York +150 Park Row +New York, NY 10007 +ext. | +NYM/AW-Programs~@bop.gov diff --git a/vision-fixhub/ds9-parsed-01/1835668b4c89eed4ea8011c2fd8e35244053c3a6a923ddb122d2a6e7aa1f4441.receipt.json b/vision-fixhub/ds9-parsed-01/1835668b4c89eed4ea8011c2fd8e35244053c3a6a923ddb122d2a6e7aa1f4441.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..c9e181f4e61ecf5e885c0e605da60d4450a67571 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1835668b4c89eed4ea8011c2fd8e35244053c3a6a923ddb122d2a6e7aa1f4441.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "1835668b4c89eed4ea8011c2fd8e35244053c3a6a923ddb122d2a6e7aa1f4441", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "f8dc5449bbe17643776e5d69d31c9aef9d05ebbc6e3b8e64cf58ce01b461d148", + "output_sha256": "612569e7e803a80a79373e1a71800e7b1b87ba2e3d56c5c83c17a4e0a29c3338", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/183dfe56987c4173e5abc396c074d45bb34af3662545481d94974853bb8a0be4.md b/vision-fixhub/ds9-parsed-01/183dfe56987c4173e5abc396c074d45bb34af3662545481d94974853bb8a0be4.md new file mode 100644 index 0000000000000000000000000000000000000000..9498cd66d08e879593481479c0e2381da7132597 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/183dfe56987c4173e5abc396c074d45bb34af3662545481d94974853bb8a0be4.md @@ -0,0 +1,32 @@ +From: " +To: ' +(USANYS)" _ +(USANYS)" < +Cc: +(USANYS)" ‹ +Subject: RE: EOUSA-2021-000288 :: 2020R00719 :: 20-CR-00330 :: USA v. Maxwell :: Blue Ant +Studios - Kevina Tidwell +Date: Fri, 06 Nov 2020 16:53:28 +0000 +Attachments: FOIA +_request_DOJ_Executive.pdf; EXEMPTION_MEMO.docx +Good morning all, +I have attached the exemption form for your review and signature. I available at any time to assist. +Thanks, +For these two cases: 1) +1. Ghislaine Maxwell 15-cv-7433 (LAP) and +2) United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN). +For the below events, I am requesting audio, video, photographic, and/or +other still image records including but not limited to diagrams and drawings, +as well as all transcripts and other metadata, physical or digital, associated +with these audio-visual records. A. Any other 911 calls regarding JE or GM. B. +All phone calls, interviews, or other recorded conversations with victims and +possible victims of JE and/or GM. C. All phone calls, interviews, or other +recorded conversations with the parents and other relatives of victims and +possible victims of JE and/or GM. D. All phone calls, interviews, or other +recorded conversations with witnesses and possible witnesses of JE and/or +GM. E. Surveillance photographs, audio, and video of JE, GM, their | +properties, or their associates. F. All phone calls, interviews, or other recorded +conversations with JE or GM, or representatives of JE or GM. A. All audio, +video, photographs, or drawings of JE and GM, including depositions, +subpoenas, or other interviews gathered during investigation or prosecution +efforts diff --git a/vision-fixhub/ds9-parsed-01/183dfe56987c4173e5abc396c074d45bb34af3662545481d94974853bb8a0be4.receipt.json b/vision-fixhub/ds9-parsed-01/183dfe56987c4173e5abc396c074d45bb34af3662545481d94974853bb8a0be4.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..b9cecef2e885bee3ca1f93192bf4686f2604a603 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/183dfe56987c4173e5abc396c074d45bb34af3662545481d94974853bb8a0be4.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "183dfe56987c4173e5abc396c074d45bb34af3662545481d94974853bb8a0be4", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "6236963fcad0ef918f52a6f28f79a987d03c31c305cade365d31ef1bd03809db", + "output_sha256": "893aa073ebd251130e51469b32d460b53593f72e36041c268aa9759b7b0240e6", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1843154c6da1219c16062f5d4bba349deb7de60b3203d8487efad949eb54ba76.md b/vision-fixhub/ds9-parsed-01/1843154c6da1219c16062f5d4bba349deb7de60b3203d8487efad949eb54ba76.md new file mode 100644 index 0000000000000000000000000000000000000000..b389c696c1511eebb10f6acc253dc68d485146aa --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1843154c6da1219c16062f5d4bba349deb7de60b3203d8487efad949eb54ba76.md @@ -0,0 +1,19 @@ +From: Bruce Barket < +To: +Cc: +Subject: (the same) three things +Date: Fri, 28 Feb 2020 18:06:01 +0000 +Good afternoon, +I am writing again to set up: 1. An opportunity to view the physical evidence from the July 23'd suicide attempt; 2. to +coordinate a visit to the MCC to view the cells; and 3. To request a family visit for Mr. Tartaglione on March 5th. That will +be the day after our next court appearance. +Please let me know. Thanks +Bruce A. Barket, Esq. +Barket Epstein Kearon Aldea & LoTurco, LLP +666 Old Country Road, Ste. 700 +Garden City, NY 11530 +www.barketepstein.com +This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear +that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review, dissemination, +distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this communication in error, +please notify us immediately by telephone or email and immediately delete this message and all its attachments diff --git a/vision-fixhub/ds9-parsed-01/1843154c6da1219c16062f5d4bba349deb7de60b3203d8487efad949eb54ba76.receipt.json b/vision-fixhub/ds9-parsed-01/1843154c6da1219c16062f5d4bba349deb7de60b3203d8487efad949eb54ba76.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..ad15ab1831f96220d8a96b5812860137c6c0c8e5 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1843154c6da1219c16062f5d4bba349deb7de60b3203d8487efad949eb54ba76.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "1843154c6da1219c16062f5d4bba349deb7de60b3203d8487efad949eb54ba76", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "64d2a93b9c9f6e6b24e7e81df0cf2773c7991a193177e3241b3962510c9df34b", + "output_sha256": "65183a45eb1cab0593a0450bfc2eb00cef9191dc23ff7b4981edb219c97f2b07", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/187cc7bf34cf3bf86cd86f214e29cd110e73109e8f06e2c42ade2bd17cb68464.md b/vision-fixhub/ds9-parsed-01/187cc7bf34cf3bf86cd86f214e29cd110e73109e8f06e2c42ade2bd17cb68464.md new file mode 100644 index 0000000000000000000000000000000000000000..685391509cba99d31c421846130e7e883c1b4ad8 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/187cc7bf34cf3bf86cd86f214e29cd110e73109e8f06e2c42ade2bd17cb68464.md @@ -0,0 +1,561 @@ +From: +Te: +Subject: +Date: +Attachments: +Leutenant 5 log and dally activily log Tor saturday, August 10, 2015. +Sunday, August 11, 2019 6:15:28 AM +Daily Activitles Report 8-10-2019 docs +LIEUTENANT'S LOG 08-10-2019.docm +Lieutenant's log and daily activity log for Saturday, August 10, 2019. +Federal Bureau of Prisens +Metropolitan Correctional Center +150 Park Row +Nam Olanh NO1 10007 + + +UNITED STATES GOVERNMENT +MEMORANDUM +METROPOLITAN CORRECTIONAL CENTER +New York, NY +10007 +August 11, 2019 +REPLY TO +ATTN OF: +SUBJECT: Daily Activity Report +TO: +Lieutenants +Departments Heads +Daily Activity as communicated or documented by the Operations +Lieutenant for August 10, 2019, was received and/or reviewed. The +following information was noted. +Morning Watch Shift: +reported Correctional assignment Sanitation +vacated, due to, a shortage of staff. Control Center Fire Panel +remains inoperative. +Day Watch Shift: +reported I/M Epstein #76318-054 found unresponsive in +Special Housing escorted to the outside hospital for treatment. +Evening Watch Shift: +correctional assignment 10 South #2 vacated, due to, +a shortage of staff. + + +INMATES IN OUTSIDE HOSPITAL/SUICIDE WATCH/FURLOUGH/DRY CELL: +on suicide watch w/inmate companion +pending bed space (SHU) +NOW ADMISSIONS TO MCC NeW York: +RELEASED FROM MCC NEW YORK: +NONESSIONS TO THE SPECIAL HOUSING UNIT: +TOTAL NUMBER OF CELLS IN SHU THAT ARE PRESENILY TRIPLE BUNKED: +None + + +THE FOLLOWING LEAVE WAS UTILIZED: +FURLOUGH: 00 +ANNUAL LEAVE: 05 +SICK LEAVE: 12 +OFFICIAL TIME: 00 +SUSPENSION: 00 +FFLA: 00 +EMLA: 00 +COP: 02 +ANOL: 00 +ADVANCE LEAVE: 00 +LWOP: 00 +ADMIN LEAVE: 00 +COMP TIME: 00 +TRAINING: 00 +GLYNCO: 00 +IWOP (M) : 00 +TOA: 00 +EPO: 00 +TRAVEL: 00 +THE FOLLOWING OVERTIMES WERE HIRED: +E-1 OVERTIME: +Number of staff = 34 +Hours = 263.00 +E-1 COMPTIME: +Number of staff = 00 +60-8 OVERTIME (USM MEDICAL) : +Number of Staff = 00 +O9D OVERTIME (SPECIAL) : +Number of Staff = 00 +SO OV OF EAT -157 : +87S OVERTIME (TREATY TRANS) : +Number of Staff = 03 + + +INSTITUTION TOTALS AT THE BEGINNING OF THE MORNING WATCH SHIFT: +08-10-2019 / 12:00 AM +UNIT B-A: +26 +UNIT E-N: +87 +UNIT E-S: +81 +UNIT G-N: +79 +UNIT G-S: +80 +UNIT H-A: +03 +UNIT I-N: +85 +UNIT K-N: +88 +UNIT K-S: 138 +UNIT Z-A: 77 +UNIT Z-B: 05 +TOTAL: +759 + + +UNITED STATES GOVERNMENT +MEMORANDUM +METROPOLITAN CORRECTIONAL CENTER +New York, NY 10007 +August 11, 2019 +REPLY TO +ATTN OF: +SUBJECT: Daily Activity Report +TO: +Lieutenants +Departments Heads +Daily Activity as communicated or documented by the Operations +Iieutenant for August 10, 2019, was received and/or reviewed. The +following information was noted. +Morning Watch Shift: +reported Correctional assignment Sanitation +vacated, due to, a shortage of staff. Control Center Fire Panel +remains inoperative. +Day Watch Shift: +reported I/M Epstein #76318-054 found unresponsive in +Special Housing escorted to the outside hospital for treatment. +Evening Watch Shift: +a shortage of staff. +correctional assignment 10 South #2 vacated, due to, + +SDNY_00008864 + + +INMATES IN OUTSIDE HOSPITAL/SUICIDE WATCH/FURLOUGH/DRY CELL: +pending bed space (SHU) +NEW ADMISSIONS TO MCC New York: +RELEASED FROM MCC NEW YORK: +ADMISSIONS TO THE SPECIAL HOUSING UNIT: +TOTAL NUMBER OF CELLS IN SHU THAT ARE PRESENTLY TRIPLE BUNKED: +None +MISSING FIRE AND SECURITY REPORT: +MISSING EQUIPMENT INVENTORY FORM: + +SDNY_00008865 + + +THE FOLLOWING LEAVE WAS UTILIZED: +FURLOUGH: 00 +ANNUAL LEAVE: 05 +SICK LEAVE: 12 +OFFICIAL TIME: 00 +SUSPENSION: 00 +FELA: 00 +EMLA: 00 +COP: 02 +AWOL: 00 +ADVANCE LEAVE: 00 +IWOP: 00 +ADMIN IEAVE: 00 +COMP TIME: 00 +TRAINING: 00 +GLYNCO: 00 +INOP (M) : 00 +TOA: 00 +EPO: 00 +TRAVEL: 00 +THE FOLLOWING OVERTIMES WERE HIRED: +E-1 OVERTIME: +Number of staff = 34 +E-1 COMPTIME: +Number of staff = 00 +Hours = 263.00 +60-2 OVERTIME (USM MEDICAL) : +Number of Staff = 00 + +SDNY_00008866 + + +B-2 OVERTIME: +Number of staff = 00 +09D OVERTIME (SPECIAL) : +Number of Staff = +00 +XXX OVERTIME (AIRLIFT) : +Number of Staff = 00 +87S OVERTIME (TREATY TRANS) : +Number of Staff = 03 +INSTITUTION TOTALS AT THE BEGINNING OF THE MORNING WATCH SHIFT: +08-10-2019 / 12:00 AM +UNIT B-A: +26 +UNIT E-N: +87 +UNIT E-S: +81 +UNIT G-N: +79 +UNIT G-S: +80 +UNIT H-A: +03 +UNIT I-N: +85 +UNIT K-N: 88 +UNIT K-S: 138 +UNIT Z-A: +77 +UNIT Z-B: +05 +TOTAL: +759 + +SDNY_00008867 + + +Shift-Day-Date: M/W Saturday, August 10, 2019 +Beginning Count: 758 +Daily Sensitive Information: +on Psych obs. w/inmate companion +M/W +on Psych Obs. w/inmate companion +on Psych Obs. w/inmate companion +Psych Obs. w/inmate companion +on Dry Cell w/inst. Staff (R-A) +TIME +CHRONOLOGICAL EVENTS +12:00 AM +assumes duties as the Morning +Watch +Operations +Lieutenant. +The +fire alarm and sprinkler system are +operational +w/exception of Control Center Fire Panel. +PREA +announcement conducted via the Institution Public Address System +and/or Radio. Restraint Equipment Cage +inventory conducted. All +equipment accounted +for. Metal +Detector checks conducted. All +operative w/the +exception of Rear Gate/Facilities/R&D. +Roof +Check completed. All +secure. Temporary Chit Inventory: #1:2; +#2:5; #3:5; #4:6; #5:5; #6:0; Hosp:0 +12:00 +Institution Count in progress +AM +12:00 +NYPD Phone Check #1283 +AM +12:15 +AM +Body Alarm testing in progress +12:23 +Body alarm testing completed +AM +12:30 +Watch Calls cont. +AM +12:35 +-1 SHU (correction): Fernandez #86824-054 (DRY CELL R-A) +AM +12:36 +Good Verbal count announced +AM +12:49 +Clear Institution count announced +AM +3:00 +3:19 +AM +3:24 +AM +5:00 +AM +5:29 +AM +5:30 +AM +Institution Count in progress +Good Verbal count announced +Clear Institution count announced +Institution Count in progress +Good Verbal count announced +Clear Institution count announced +on Board at approximately 5:30am relieving +6:33 +AM +6:35 AM +6:43 +AM +7:10 +AM +ot duty. +Medical +emergency announced for Unit 9 South +inmate Epstein +·76318-054 found unresponsive in cell Z06-220 CPR in progress +911 Emergençy service notified +E.M.S ambulance arrives to the Health +Service Area, continued +in progress by E.M.T. +E.M.S/BOP staff depart with +inmate +ambulance to +local hospital +continuation +Epstein +of +CPR +#76318-054 +is +still +via +in +progress by EMT. +SHU: 73/5 +BC +758 +SHU +73/5 +72/5 +758 +72/5 +758 +758 +72/5 +72/5 +757 +71/5 + +SDNY_00008868 + + +UNITED +STATES +DEPARTME +NT OF +JUSTICE +METROPOL +ITAN +CORRECTI +ONAL +CENTER, +NEW +YORK, NY +DAILY +LIEUTENA +NT'S LOG +7:36 +Bop staff called to notify institution that inmate Epstein +AM +STG International Terrorist phone calls monitored: +WITSEC inquiry (s) was/were received during my tour of duty: +The following Inmate (s) were placed in Administrative Detention: +Name +Reg: Number +Reason +Unit +Time +Ops +Ending Count: 758 SHU: 71; 10-South: 05; +SHU OBS: 007 +Local Hosp: 00; H/A OBS: 04; B/A OBS: 00; Dry Cell: 01; +H/A(PBS) ; 00; H/A (PCLAS); 00 +AD Order +SHIFT-DAY-DATE: D/W - Friday, August 09, 2019 +D/W +Beginning Count: 757 +Daily Sensitive Information: +INSTETUNION ON MODIF LED OBERATIONE +on Psych obs w/inmate companion +on Psych obs. w/inmate companion. +on DRY Cell w/staff watch in R&D. +8:00 +AM +assumes duties as the Day Watch Operations +Lieutenant. The fire alarm and pump system is inoperable at this +time. Fire Watch is in Progress. Unable to conduct PREA +announcement over the Institution Public Address System, due to, +system malfunction. Restraint Equipment Cage inventory conducted. +All equipment accounted for. Metal Detector checks conducted. +All operative w/the exception of Rear Gate. +Roof Check +completed. All secure. +Temporary Chit Inventory: #1:0; #2:5; +#3:5; #4:6; #5:6; #6:5; Hosp: 0 +Daily Hand Stamp :DJBE/LEFT HAND +8:00 AM +8:00 AM +8:20 AM +10:00 +AM +11:22 +AM +11:24 +AM +3:45 PM +3:57 +PM +3:58 PM +NYPD Phone Check #3371 +Body Alarm Test Initiated. +Body Alarm Testing Complete. +Institutional count in progress +Good verbal count announced +Clear institutional count +Institutional lockdown for count. ++1; I/M Mutimura #76329-054 +transferred to special housing (dry +cell) +| SHU: 71/5 +757 +71/5 +757 +71/5 +757 +| 71/5 +757 +| 71/5 +757 +72/5 + +SDNY_00008869 + + +3:59 PM +4:00 +PM +-1 Bail Bond; Carreon-Macias #82858-198 +Relieved of duties by +Inmates +Visitation: CANCELLED +Adults +756 72/5 +Children +Total +ION SCANNING TESTED HITS: 0 +STG/High Alert phone calls monitored: +WITSEC inquiry (s) was/were received during my tour of duty: O +The following Inmate (s) were placed in Administrative Detention: 0 +Name +Reg Number +Reason +Unit +TIME +Ops +Ending Count: 756 ; SHU: 72; 10-South: +05; +Local Hosp: 00; H/A OBS: 02; B/A OBS: +SHU +OBS: 00; +00; Dry Cell: 00 +A/D Order + +SDNY_00008870 + + +SHIFT-DAY-DATE: E/W - Saturday, August 10, 2019 +Beginning Count: 756 +Daily Sensitive Information. +INST CLINION ON MODIETED OPERATTONE +E/W +on Psych Obs w/inmate companion. +on PSYCH OBS. W/inmate companion. +on Suicide watch w/inmate companion. +I/M Wiliams #78640-054 on suicide watch w/ inmate companion. +TIME +CHRONOLOGICAL EVENTS +Lieutenant D. Medina assumes duties as the Evening Watch +Operations Lieutenant. Unable to conduct PREA announcement over +the Institution Public Address System, due to, system malfunction. +4:00 PM +Restraint Equipment Cage inventory conducted. All equipment +accounted for. Metal Detector checks conducted. +All operative +w/the exception of Rear Gate. +Roof Check +completed. All secure. +Temporary Chit Inventory: #1:4; #2:4; #3:5; #4:5; #5:5; #6:3; +4:00 PM Institution count in progress. +4:01 PM NYPD Phone Check #1980 +4:16 PM +Body alarm testing in progress. +4:32 PM +Body alarm testing completed +5:02 PM +Good verbal count +5:13 PM +Clear institutional count. +6:00 +PM +Watch call in progress +7:24 PM +SHU: 72/ +5 +B/C +SHU +756 +72/5 +756 +72/5 +7:45 PM +8:42 PM +10:00 +PM +and Felix #85775-054 transferred to +special housing (psych observation) +Trash run in progress +Trash run complete +Institutional count in progress. +756 +74/5 +10:21 +PM +10:38 +Good verbal count announced. +Clear institutional count announced. +756| 74/5 +12:00 +AM +Relieved of duties by G. +I as the M/W Lieutenant. +INMATES +VISITING: +ADULTS +CHILDREN +TOTAL +STG/High Alert phone calls monitored: +WITSEC inquiry (s) was/were received during my tour of duty: 0 +The following Inmate(s) were placed in Administrative Detention: 0 +NAME +REG NUMBER +REASON +UNIT +TIME +A/D ORDER +ops. +Act. +Ending Count: 756 ; SHU: 74; 10-South: 05; SHU OBS: 00; +Local Hosp: 00; #/A OBS: 02; B/A OBS: 00; Dry Cell: 00; +B/A SHU: 00 + +SDNY_00008871 + + +UNITED STATES DEPARIMENT OF JUSTICE + +SDNY_00008872 \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/187cc7bf34cf3bf86cd86f214e29cd110e73109e8f06e2c42ade2bd17cb68464.receipt.json b/vision-fixhub/ds9-parsed-01/187cc7bf34cf3bf86cd86f214e29cd110e73109e8f06e2c42ade2bd17cb68464.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..55c5fa61645d2c3113d46c01d548b7d009be22ad --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/187cc7bf34cf3bf86cd86f214e29cd110e73109e8f06e2c42ade2bd17cb68464.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -976, + "dataset": "marble-joined", + "doc_id": "187cc7bf34cf3bf86cd86f214e29cd110e73109e8f06e2c42ade2bd17cb68464", + "engine": "marble-apple-vision", + "event_count": 24, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "35cbf4a5a21131418d891a5a89451ac4ec5bc321c40557d550ef0b17946525ec", + "output_sha256": "47a4be1068f6ff1f88c8930b4c4782759b422417ff62b204361dc90ab9615900", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1899a54494574c589cb0c9b095c3aba322ca57797d9afc2ca86534d027cf2e73.md b/vision-fixhub/ds9-parsed-01/1899a54494574c589cb0c9b095c3aba322ca57797d9afc2ca86534d027cf2e73.md new file mode 100644 index 0000000000000000000000000000000000000000..0a70b2cce9835810a60ccc9c6d85df292771d920 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1899a54494574c589cb0c9b095c3aba322ca57797d9afc2ca86534d027cf2e73.md @@ -0,0 +1,41 @@ +Mod AO 442(09/13) Arrest Warrant +AUSA Name & Telno: +UNITED STATES DISTRICT COURT +for the +Southern District of New York +United States of America +V. +20 CR 330 +Case No. +Ghislaine Maxwell +Defendant +ARREST WARRANT +To: +Any authorized law enforcement officer +YOU ARE COMMANDED to arrest and bring before a United States magistrate judge without unnecessary delay +(name of person to be arrested)K Ghislaine Maxwell +who is accused of an offense or violation based on the following document filed with the court: +• Indictment +• Superseding Indictment • Information +• Probation Violation Petition • Supervised Release Violation Petition +• Superseding Information • Complaint +• Violation NoticeD Order of the Court +This offense is briefly described as follows: +Title 18, United States Code, Section 371 (conspiracy to entice minors) +Title 18, United States Code, Sections 2422 and 2 (enticement of a minor) +Tie 18, United States Code Section s2423(a ara to rapport minors) +Title 18, United States Code, Section 1623 (perjury) +Date: +City and state: +06/29/2020 +White Plains, NY +Issuing officer's signature +Hon. Lisa Margaret Smith, U.S. Magistrate Judge +Printed name and title +Return +This warrant was received on (date) +, and the person was arrested on (dase) +at (city and state) +Date: +Arresting officer's signature +Printed name and title diff --git a/vision-fixhub/ds9-parsed-01/1899a54494574c589cb0c9b095c3aba322ca57797d9afc2ca86534d027cf2e73.receipt.json b/vision-fixhub/ds9-parsed-01/1899a54494574c589cb0c9b095c3aba322ca57797d9afc2ca86534d027cf2e73.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..7c2b69060830d24f2c1619ea4981fe5b70d240cb --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1899a54494574c589cb0c9b095c3aba322ca57797d9afc2ca86534d027cf2e73.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "1899a54494574c589cb0c9b095c3aba322ca57797d9afc2ca86534d027cf2e73", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "0b3bc4e59af8dce61d67c5acdcf5b860ef652b088f810501c8e5aec1e09cc353", + "output_sha256": "3acea1875e3161b58fa46f7013ffadb2661da9de18dfc65c7bc08a935950f3fc", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/18cb3e8e6aa3025856bc2476ed8ab22d1f0c5df3c1525332940aba44efacb58b.md b/vision-fixhub/ds9-parsed-01/18cb3e8e6aa3025856bc2476ed8ab22d1f0c5df3c1525332940aba44efacb58b.md new file mode 100644 index 0000000000000000000000000000000000000000..607f8e17e16fd8abedbe8d4899017c0f17d21056 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/18cb3e8e6aa3025856bc2476ed8ab22d1f0c5df3c1525332940aba44efacb58b.md @@ -0,0 +1,24 @@ +LAW OFFICES OF BOBBI C. STERNHEIM +Main +Cell +Fax +33 West 19th Street - 4th Floor +New York, New York 10011 +April 13, 2021 +VIA Email +Honorable Alison J. Nathan +United States District Judge +United States Courthouse +40 Foley Square +New York, NY 10007 +Re: United States v. Ghislaine +S2 20 Cr. 330 (AJN) +Dear Judge Nathan: +I write to request that Court sign the attached proposed order directing the U.S. Marshal +to permit Ghislaine Maxwell to have access to her legal papers while in the cellblock at 500 +Your consideration is greatly appreciated. +Very truly yours, +Babbi C. Sternheim +BOBBI C. STERNHEIM +Enc. +ce: All counsel diff --git a/vision-fixhub/ds9-parsed-01/18cb3e8e6aa3025856bc2476ed8ab22d1f0c5df3c1525332940aba44efacb58b.receipt.json b/vision-fixhub/ds9-parsed-01/18cb3e8e6aa3025856bc2476ed8ab22d1f0c5df3c1525332940aba44efacb58b.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..6f79f14ca6b1957065b66e8fc77e87a1c2a7cf97 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/18cb3e8e6aa3025856bc2476ed8ab22d1f0c5df3c1525332940aba44efacb58b.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "18cb3e8e6aa3025856bc2476ed8ab22d1f0c5df3c1525332940aba44efacb58b", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "558a2dba1eb460f0e8c841deb456a01e0f50c58e9331c654ad84118d7238f4c7", + "output_sha256": "1dd2155fa9fc5a7103a63cca00221ef009861eb7681f7c100bbd89c20a5b9652", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/18f4639dee7728a29b7eac2453fc3e3bcba406595881befcee7a2c562986db8b.md b/vision-fixhub/ds9-parsed-01/18f4639dee7728a29b7eac2453fc3e3bcba406595881befcee7a2c562986db8b.md new file mode 100644 index 0000000000000000000000000000000000000000..9f772f66509c1ea5188f9e3d843ba01f288b5bdc --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/18f4639dee7728a29b7eac2453fc3e3bcba406595881befcee7a2c562986db8b.md @@ -0,0 +1,121 @@ +Nos. 20-2413 & +20-3061 +United States Court of Appeals +for the Second Circuit +Plaintiff-Appellee, +V. +GHISLAINE MAXWELL, +Defendant-Appellant. +UNITED STATES OF AMERICA, +Plaintiff-Appellee, +V. +GHISLAINE MAXWELL, +On Appeal from the U.S. District +Court for the Southern District of +New York +No. 15-CV-7433 (LAP) +The HOUs. Districtad. Preska, +On Appeal from the U.S. District +Court for the Southern District of +New York +No. 20-CR-330 (AJN) +The Honorable Alison J. Nathan, U.S. +District Judge +Defendant-Appellant. +Ghislaine Maxwell's Response to Opposition to Motion to Consolidate + + +The government and +insist this case and the criminal case are +unrelated. But that's not so. +The criminal case alleges that Ms. Maxwell committed perjury in the civil +case. Two of the six counts are expressly based on the civil case. +Moreover, the discovery in the criminal case includes 90,000 pages of +material produced by +attorneys, all of which comes from the civil +case. Those 90,000 pages comprise more than half of all the discovery produced to +Ms. Maxwell. It's fanciful to say the two cases aren't related. +The government says it "is not a party to the civil suit" (true), that it "has +never intervened or appeared in the civil suit" (also true), that it "has had no role +in the litigation that resulted in Judge Preska's order" (true again), and that it has +no "legal interest in the relief Maxwell seeks in the civil case" (true and +extraordinarily revealing). Doc. 113, 4 26. +The government has not intervened in the civil case and it does not have an +interest in the relief Ms. Maxwell seeks (keeping the deposition material sealed) +because the government wants to argue that its violation of Martindell was harmless +as soon as the April 2016 deposition transcript is released. After all, if the +government were being consistent, it would have moved to intervene in the civil +2 + + +case and to stay the unsealing process, just as it moved to intervene and to stay +discovery in Doe v. Indyke, a civil case in which Jane Doe alleges that Epstein and +Ms. Maxwell abused and exploited her as a minor. According to the government, a +stay of that case was necessary to "preserv[e] the integrity of the criminal +prosecution against [Ms.] Maxwell." Doe v. Indyke et al., No. 20-cv-00484, Doc. +81, p 4, 9/14/2020 Order Granting Motion to Stay. The court there agreed, and it +granted Ms. Maxwell's motion to stay. Id. at 12. This Court should not let the +government engage in such obvious gamesmanship. +The government insists that, in these two appeals, Ms. Maxwell is "ask[ing] +this Court to rule on .... the lawfulness of the Government's applications to modify +certain protective orders in other judicial proceedings. " Doc. 113, 9 27. That is not +so. The government's contention mischaracterizes Ms. Maxwell's argument. +As Ms. Maxwell said in her opening brief: +The civil case is not the appropriate forum to litigate the +government's apparent violation of Martindell. Ms. Maxwell intends +to make that argument to Judge Nathan in the criminal case. But if +Judge Preska's unsealing order is affirmed and Ms. Maxwell's +deposition is released, her ability to make that argument before Judge +Nathan will be prejudiced. Keeping the deposition material sealed will +preserve the status quo and protect Ms. Maxwell's right to litigate +Martindell and the Fifth Amendment in the criminal proceeding. +Doc. 69, p 33. Only by mischaracterizing Ms. Maxwell's argument can the +government contend that she is "ask[ing] this Court to rule on ... the lawfulness of +3 + + +the Government's applications to modify certain protective orders in other judicial +proceedings. " Ms. Maxwell's point is that, unless the unsealing order is reversed, +she might not ever be able to litigate "the lawfulness of the Government's +applications." +Moreover, the motion to consolidate is not an attempt to circumvent Judge +Nathan's order before this Court can reach the merits. The motion to consolidate +simply endeavors to ensure that this Court does not find itself in the same position +as the several judges below, where only some of the judges are privy to the relevant +facts. +There is no merit to +argument that consolidation will cause +meaningful delay. Doc. 123, pp 4-5. This Court has scheduled oral argument in +both cases on the same day, as well as an argument on the motion to consolidate. +Whether that motion is granted or not will have no effect on the dispatch with +which this Court addresses the issues. +This Court should grant the motion to consolidate. +September 23, 2020. +4 + + +Respectfully submitted, +s/ Adam Mueller +Ty Gee +Adam Mueller +HADDON, MORGAN AND FOREMAN, P.C. +150 East 10th Avenue +Denver, CO 80203 +Tel 303.831.7364 +Fax 303.832.2628 +tgee@hmflaw.com +amueller@hmflaw.com +Counsel for Defendant-Appellant Ghislaine +Maxwell +5 + + +Certificate of Compliance with Rule 32(g) +Counsel hereby certifies that this response brief complies with the typevolume limitation of Fed. R. App. P. 32(g) and it contains 670 words. +s/ Adam Mueller +Certificate of Service +I certify that on September 23, 2020, I filed Ghislaine Maxwell's Response to +Opposition to Motion to Consolidate with the Court via CM/ECF, which will send +notification of the filing to all counsel of record. +s/ Nicole Simmons +6 diff --git a/vision-fixhub/ds9-parsed-01/18f4639dee7728a29b7eac2453fc3e3bcba406595881befcee7a2c562986db8b.receipt.json b/vision-fixhub/ds9-parsed-01/18f4639dee7728a29b7eac2453fc3e3bcba406595881befcee7a2c562986db8b.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..cb1227062bea0f3b0011bdb6fce1787d1c228775 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/18f4639dee7728a29b7eac2453fc3e3bcba406595881befcee7a2c562986db8b.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -74, + "dataset": "marble-joined", + "doc_id": "18f4639dee7728a29b7eac2453fc3e3bcba406595881befcee7a2c562986db8b", + "engine": "marble-apple-vision", + "event_count": 7, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "3fd898c8f4c5091163988d5ea5314efd3cbccfe07628ceda7d20fa1ed9669233", + "output_sha256": "f45d319ff91e109101546523ff4b2a5da3916c50b6f86945bc0ed76922d74245", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/18f8670e9dcecd0a05b3b5d4be94bbfafc0982a4ed979698b5c8adb7795598be.md b/vision-fixhub/ds9-parsed-01/18f8670e9dcecd0a05b3b5d4be94bbfafc0982a4ed979698b5c8adb7795598be.md new file mode 100644 index 0000000000000000000000000000000000000000..401afcb6285c13a2d1632f2c7f9d5eadade0c18f --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/18f8670e9dcecd0a05b3b5d4be94bbfafc0982a4ed979698b5c8adb7795598be.md @@ -0,0 +1,21 @@ +yeah, i don't know what's been going on with him, but i just think in general we really allow the guys to abuse the use of SW, and i just +thought it was interesting to see the response of a chief at another detention center. i also agree that we don't let other inmates on SW +attend legal visits, so he shouldn't have either, and shouldn't have been in regular clothes even if he did. again, to the other chief's +point, if he can attend the legal visit that way, then he likely isn't suicidal and doesn't need to be on Sw. so, is the story that he has a +mark on his neck and he's saying he doesn't remember how it got there? +>>> +totally. i wonder if +7/24/2019 9:18 AM >>> +was embarrassed/introspective seeing a response like that. this is b/c of epstein. he was on SW but in regular +questioned it. i told when she asked that we have done it this way in the past. in light of the +huge scar on epstein's neck (granted a ton of ambiguity surrounding the incident), he did need to be on SW yesterday. i guess we +should have declined his legal visit if we were following this other chief's advice +>>> +7/24/2019 8:40 AM >>> +lol i love this guy's response. that if this is even a question, they probably shouldn't even be on watch. we put way too many people on +there. i'm even seeing the difference in BRO. they just don't function that way. guys come here from MCC and go to SHU, and tell staff +they want to go on SW, and the staff laugh at them, and the inmates tell them they were able to get on watch that way at MCC. and +the psych who responded to her is at Chicago, another detention center. so, I'm guessing they see a lot of the same things that we do, +and probably use SW less as an option. + +SDNY_00011773 \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/18f8670e9dcecd0a05b3b5d4be94bbfafc0982a4ed979698b5c8adb7795598be.receipt.json b/vision-fixhub/ds9-parsed-01/18f8670e9dcecd0a05b3b5d4be94bbfafc0982a4ed979698b5c8adb7795598be.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..d950b27caaad15ff2140572640eae1b4df21c40f --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/18f8670e9dcecd0a05b3b5d4be94bbfafc0982a4ed979698b5c8adb7795598be.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "18f8670e9dcecd0a05b3b5d4be94bbfafc0982a4ed979698b5c8adb7795598be", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.stamp-stripping.confidential\"]", + "idempotent": true, + "input_sha256": "5d431e6c5945d4b178a5179a005d367288afaf73a7ce55e381748046977cbf55", + "output_sha256": "986dbe86981e5bb3c43e137fcc80eac47914e2a7e1c5d75af4a57b657cdc74dd", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1910ce44de934c4d8dad7899bfeb245ec1fa15b4aa76d46b7b35af2782b78c6c.md b/vision-fixhub/ds9-parsed-01/1910ce44de934c4d8dad7899bfeb245ec1fa15b4aa76d46b7b35af2782b78c6c.md new file mode 100644 index 0000000000000000000000000000000000000000..3d7d3efa29a3176147cc22f44b9be81e5bc65d61 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1910ce44de934c4d8dad7899bfeb245ec1fa15b4aa76d46b7b35af2782b78c6c.md @@ -0,0 +1,53 @@ +To: +Cc: +Subject: RE: 90A-NY-3151227 (Epstein) --- UNCLASSIFIED +Date: Wed, 28 Aug 2019 19:07:57 +0000 +Importance: Normal +Current status: +All systems are powered up using clones of the original disks. +DVR Main Controller - The Administrator password is needed to gain access. +is working +on it. +DVR 1 System - This is up and running. The disk array appears to have assembled but we need +access to the DVR Main Controller for visibility. +DVR 2 System - This is our priority and is currently problematic. The system is up, but the disk +array is NOT assembling. It appears the configuration of these 16 disks in the array has been +lost (likely from being pulled out of the system live). 3 of the disks had to undergo repair before +being useable. We will have to attempt to reassemble this array manually (if possible). +Typically, we can look at the structure of the disks and find patterns that potentially give us +clues into how they were assembled but a review today did not prove insightful. +Important: Can you please reach out to MCC and request if there is any documentation +available there on the configuration of this disk array or a technician there that can speak to it? +In the meantime, I will review the operating system drives to see if there is any configuration +documentation there that might have been saved. +FYI, I will be away from the office Thursday and Friday. With the holiday on Monday, I won't be +back in the office until Tuesday, Sept 3'd +However, if you receive the Admin password and/or information on the disk array configuration +please respond to this email. My Lab Supervisor and a Senior Level Technician are copied. + + +To:! +Sent: Wednesday, August 28, 2019 1:37 PM +Subject: RE: 90A-NY-3151227 (Epstein) --- UNCLASSIFIED +Working on it. Hope to have the password by the end of the day. +FBI New York | Squad C-19 +To +Sent: Tuesday, August 27, 2019 2:40 PM +Subject: FW: 90A-NY-3151227 (Epstein) --- UNCLASSIFIED +Can you please request the password for the Administrator account on the main server +controller (Dell PowerEdge R420)? +We have DVR 1 up and it appears to see the disk array but we are determining access. +We have DVR 2 up but it is not currently seeing the disk array. We are working on the +connection. +We'd like to have the Administrator password from the main controller to get a full picture. +Thanks, + + +Sent: Tuesday, August 20, 2019 10:16 AM +To +Subject: 90A-NY-3151227 (Epstein) -- UNCLASSIFIED +I am a CART Examiner at Quantico and have received items for case 90A-NY-3151227 (Epstein). +From what I understand videos have been recovered from DVR 1 and my immediate focus here +will be on DVR 2. Some of the drives for DVR 2 are under repair. Once those are complete we +will be attempting to reassemble the disks and hopefully gain access to the data. +I will keep you posted on progress. \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/1910ce44de934c4d8dad7899bfeb245ec1fa15b4aa76d46b7b35af2782b78c6c.receipt.json b/vision-fixhub/ds9-parsed-01/1910ce44de934c4d8dad7899bfeb245ec1fa15b4aa76d46b7b35af2782b78c6c.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..3f63de614c8d0bc9f9d7833b2e1d89d0639764b3 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1910ce44de934c4d8dad7899bfeb245ec1fa15b4aa76d46b7b35af2782b78c6c.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -293, + "dataset": "marble-joined", + "doc_id": "1910ce44de934c4d8dad7899bfeb245ec1fa15b4aa76d46b7b35af2782b78c6c", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "d1b1f9a5db3da1fe975af45ab5e936404c18e70761a80f7eafd9d2215ed1326f", + "output_sha256": "b725704e96b503a8f2ebffd271430caebd630409e11a5c270c8770fa49578245", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1911252dcde19087fc42c5a67ce1065fcfd55b3736121f34a9168df4cdae56a6.md b/vision-fixhub/ds9-parsed-01/1911252dcde19087fc42c5a67ce1065fcfd55b3736121f34a9168df4cdae56a6.md new file mode 100644 index 0000000000000000000000000000000000000000..81e4f85a043876087b60621b50587b8bd29cd27e --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1911252dcde19087fc42c5a67ce1065fcfd55b3736121f34a9168df4cdae56a6.md @@ -0,0 +1,61 @@ +OFFICIAL RECORD +Intake (Rev. 5-23-17) +UNCLASSIFIED +FEDERAL BUREAU OF INVESTIGATION +Intake +Case ID #: 50D-NY-3027571 +Date: +(U) EPSTEIN, JEFFREY; CHILD SEX +TRAFFICKING +03/22/2021 +Drafted By: +Date/Time Received: 03/22/2021 11:40 AM EDT +Details: +On 03/22/2021, at 10:43 a.m. Eastern Time, +• date of birth +• cellular telephone number +, zip code +called the FBI National Threat Operations Center (NTOC), to report being +a victim of sex trafficker Jeffrey Epstein and to report websites that +contain child pornographic images. +provided the following information: +was given a contact number for someone who works for the FBI, +, by a NY Police Department Special Victims Unit for sexual +assault. NYPD informed her this information had to be referred to the FBI +and pertains to sex trafficking. Jeffery or Jeffrey (not sure of spelling +of first name) Epstein is a sex trafficker, and she was trafficked by +him. She was referred to him to receive money in exchange for sex. She +met him in 1998 when she was 16 in 1 +1. He took girls in l +as well. One of the girls is now a psychologist with the last name of +and this person has +a sister who is an artist. +voicemails. +claimed she has not talked to +was calling L +1, but has left several +because children were in danger. +UNCLASSIFIED + + +UNCLASSIFIED +Re: 50D-NY-3027571, 03/22/2021 +googled her name in relation to her modelling agency she was +given by the sex trafficker, and she found many pornographic images of +children, which she reported to the police and a government agency. +was unsure what government agency, but she got the number from +Safe Horizon. The URLs for the websites are portraitsofgirls.com, +vipergirls.com, imodelhouston.com, lovelygirl.cc, bobsvagene.club, +xgirlscollection.com, candydolll.com, and omxz8.com. +The images are of female girls in sexually explicit positions with barely +any clothing. The children are five years old to 17 years old. Most +appear to be under 14 years old. When she first looked the children had +no clothes on, but after she reported two of the websites, the children +had clothes on when she visited the website again. She reported more +images are coming up on the websites each day. She believes these +children are being sex trafficked, which is just a feeling she is getting +when she saw the websites. +states she is being harassed/stalked. +She has notified the NY police regarding this. +UNCLASSIFIED +2 diff --git a/vision-fixhub/ds9-parsed-01/1911252dcde19087fc42c5a67ce1065fcfd55b3736121f34a9168df4cdae56a6.receipt.json b/vision-fixhub/ds9-parsed-01/1911252dcde19087fc42c5a67ce1065fcfd55b3736121f34a9168df4cdae56a6.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..167d597fc19885f57f520f141fa12e6b7f71c2bb --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1911252dcde19087fc42c5a67ce1065fcfd55b3736121f34a9168df4cdae56a6.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "1911252dcde19087fc42c5a67ce1065fcfd55b3736121f34a9168df4cdae56a6", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "c428f44b097e53c800f4cce2e008de4338aba57b7ceca93f7c56e535e4670ff7", + "output_sha256": "6504d772639129f3b5786b57fe2107c8c44119a13f2f228df0246ec78f3089b5", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1913b780b51b98fae89801f7b70178cac54e51fa3910b5e4db5190c15becf7fa.md b/vision-fixhub/ds9-parsed-01/1913b780b51b98fae89801f7b70178cac54e51fa3910b5e4db5190c15becf7fa.md new file mode 100644 index 0000000000000000000000000000000000000000..65fb1235147a22963443ac30e565fa46cd837b4d --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1913b780b51b98fae89801f7b70178cac54e51fa3910b5e4db5190c15becf7fa.md @@ -0,0 +1,77 @@ +From: ' +To: Sigrid McCawley 4 +Cc: " +Subject: RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) +Date: Wed, 05 May 2021 21:56:30 +0000 +(USANYS)" +Hi Sigrid, +Thanks so much for making the time to talk. We're free at 6:45 tonight, if that still works. We can use this conference line: +Thanks, +From: Sigrid McCawley < +Sent: Wednesday, May 5, 2021 4:31 PM +To: +(USANYS) < +Cc: +Subject: RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) +Yes. I can talk anytime now until 5:30 and then from 6:00 - 7:15 if any of those times work? Tomorrow I am open from 9- +10 or 12-2. +Please let me know what works for you. +Best, +Sigrid +Sigrid McCawley +Partner +BOIES SCHILLER FLEXNER LLP +www.bsfllp.com +From: +(USANYS) < +Sent: Wednesday, May 5, 2021 4:27 PM +To: Sigrid McCawley < +Cc: +Subject: RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) +Sigrid, +P; + + +Do you have a few minutes to speak tonight or tomorrow? Please let us know when works for you. +Thanks, +From: Sigrid McCawley < +Sent: Tuesday, May 4, 2021 9:18 AM +To: +Cc: +SUSANS +Subject: RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) +Just as a follow up. I just heard back from +and she said her strong preference is as early as possible in the fall - early +September would be her preference. I +Tand her husband are going through the process of trying to adopt a baby and +the birth mother is due in early November (and of course babies can sometimes come a bit earlier). The birth mother has +not finalized the match so this is a fluid situation but +I wants to make sure she is able to be there when the baby is +born and of course care for her newborn immediately following the birth. I will keep you updated but L +preference is for as early as possible. +All my best, +Sigrid +Sigrid McCawley +Partner +BOIES SCHILLER FLEXNER LuP +www.bsfllp.com +From: +(USANYS) [mailto +Sent: Monday, May 3, 2021 6:34 PM +To: Sigrid McCawley < +Cc: +Pil +P: +Subject: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) +Sigrid, +Please see the attached order regarding the trial date in this case. We will update you when we have more information. +Thanks, +Assistant United States Attorney +United States Attorney's Office +Southern District of New York + + +Tel: | +of this communication is strictly prohibited and no privilege is waived. If you have received this communication in error, please immediately notify the sender by replying to this +electronic message and then deleting this electronic message from your computer. [v. 1 08201831BSF]| +electronic message and then deleting this electronic message from your computer. [v. 1 08201831BSF] diff --git a/vision-fixhub/ds9-parsed-01/1913b780b51b98fae89801f7b70178cac54e51fa3910b5e4db5190c15becf7fa.receipt.json b/vision-fixhub/ds9-parsed-01/1913b780b51b98fae89801f7b70178cac54e51fa3910b5e4db5190c15becf7fa.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..1b611ee1a09fd87ea6db1d35be0e49f2236de549 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1913b780b51b98fae89801f7b70178cac54e51fa3910b5e4db5190c15becf7fa.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -36, + "dataset": "marble-joined", + "doc_id": "1913b780b51b98fae89801f7b70178cac54e51fa3910b5e4db5190c15becf7fa", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "50db746339b18bcf4e4c3a97f7e649abbb5e68aaabff3e98f1504b463c9ef5a6", + "output_sha256": "15389adca80a43b06c582487d7fb929f6e054894a99e158f1c2ac3b992a92e08", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/198dcf880e96cb273a6f680c3ca80a57d69acdf3c30385b71227353188fd9fad.md b/vision-fixhub/ds9-parsed-01/198dcf880e96cb273a6f680c3ca80a57d69acdf3c30385b71227353188fd9fad.md new file mode 100644 index 0000000000000000000000000000000000000000..fa6fc3d637676dcdf0566f343ace1e20eb0330d6 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/198dcf880e96cb273a6f680c3ca80a57d69acdf3c30385b71227353188fd9fad.md @@ -0,0 +1,25 @@ +From: +To: +Subject: +Date: +RE: Camera Documentation +Friday, October 1, 2021 1:50:17 PM +I started in May 2019 | need sometime to get everything together so l am giving you the right information. +I do know that work did start right away just do remember exactly what it was and the dates, I do remember the +FBI coming here trying to pull information from the recorders. +>>> +Good morning Mr. +* 10/1/2021 11:32 AM > >> +Regarding the attached pdf which you provided in your below email, can you please confirm that this +is the documentation regarding the purchase of the camera system that was on site at the MCC in +August 2019, which was installed immediately after the Epstein incident on August 10, 2019? If so, +can you please confirm when the new camera system arrived at the MCC and when it was installed? +Thanks very much in advance. I hope you are well. +U.S. Department of Justice +OIG Boston Area Office +*Please note the above phone number change +From: | +Sent: Thursday, August 5, 2021 10:55 AM +To:| +Subject: Camera Documentation +Attached is the documentation you requested. diff --git a/vision-fixhub/ds9-parsed-01/198dcf880e96cb273a6f680c3ca80a57d69acdf3c30385b71227353188fd9fad.receipt.json b/vision-fixhub/ds9-parsed-01/198dcf880e96cb273a6f680c3ca80a57d69acdf3c30385b71227353188fd9fad.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..e01eb44edc8a550324969f696ba7380f020d7f2c --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/198dcf880e96cb273a6f680c3ca80a57d69acdf3c30385b71227353188fd9fad.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "198dcf880e96cb273a6f680c3ca80a57d69acdf3c30385b71227353188fd9fad", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "f2e324a4ff0a426034f4ed670f5b4475e7962f19974ad86441adef56839fb285", + "output_sha256": "5f7b525a7578c327942f7f6b13993120729c59a1d6bdc307d904115265c312a1", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/19bef6f5ab65d11869bc4f3c74205715d162c3dcc1021f8f8ef02e30c379c5d4.md b/vision-fixhub/ds9-parsed-01/19bef6f5ab65d11869bc4f3c74205715d162c3dcc1021f8f8ef02e30c379c5d4.md new file mode 100644 index 0000000000000000000000000000000000000000..514522fe75686d78ba2866be094ff2f4dd8f4909 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/19bef6f5ab65d11869bc4f3c74205715d162c3dcc1021f8f8ef02e30c379c5d4.md @@ -0,0 +1,70 @@ +From: +To: Jeff Pagliuca < +Ce: "ceverdell +», Brian Burns +≥ Laura Menninger +≥, Patrick Smith +(USANYS)" ≤ +Subject: RE: Subpoena for +Date: Thu, 18 Nov 2021 02:27:03 +0000 +Attachments: 2021.11.14 Mtn for_Order_Auth_a_Sub_Pursnt_to_F.R.Crim.P_17(c) +(3)_re.] +pdf; 2021.11.14_Ex._I.pdf +Inline-Images: image001. gif; image002.jpg +Thanks, Jeff. +Brian, in light of Jeff's email, attached is the unredacted defense motion. +Thanks, +From: Jeff Pagliuca +Sent: Wednesday, November 17, 2021 9:07 PM +To: Brian Burns • +Cc: ceverdell +; Patrick Smith < +besternheim +>; Laura Menninger +(USANYS) < +Subject: [EXTERNAL] Re: Subpoena for +Brian, I believe that we were waiting for any proposed redactions from the government. We have no problem with the +government sending you a copy of the motion. If the government does not object, we will send it. However, the +government has designated every production confidential, subject to its protective order, and the motion contains +information designated as confidential. Accordingly, we will defer to it as to what you should receive. +Best Regards, +Jeffrey S. Pagliuca. +On Nov 17, 2021, at 7:58 PM, Brian Burns +wrote: +Defense counsel - Would you please provide us a copy of your motion seeking the issuance of this subpoena? We +haven't seen a copy. Thank you. +Brian T. Burns +Smith Villazor LLP +250 West 55th Street, 30th Floor +New York, New York 10019 +Office | +Direct +Mobile + + +From: Christian Everdell +Sent: Tuesday, November 16, 2021 8:48 PM +To: Patrick Smith +Ce: Jeff Pagliucal +Brian Burns +Laura Menninger +(USANYS) 4 +BOBBI C STERNHEIM +P: +Subject: [EXTERNAL EMAIL] Subpoena for +Counsel - +Attached please find the signed subpoena for +Regards, +Please acknowledge receipt. +Christian R Everdell +COHEN & GRESSER LLP +800 Third Avenue +New York. NY 10022 +view bio +www.cohengresser.com +New York | Paris | Washington DC | London +CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only +the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient, you are hereby notified that any +review, dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error, please immediately notify +the sender by telephone and permanently delete this e-mail. Thank you. +PRIVACY: A complete copy of our privacy policy can be viewed at: https://www.cohengresser.com/privacy-policy diff --git a/vision-fixhub/ds9-parsed-01/19bef6f5ab65d11869bc4f3c74205715d162c3dcc1021f8f8ef02e30c379c5d4.receipt.json b/vision-fixhub/ds9-parsed-01/19bef6f5ab65d11869bc4f3c74205715d162c3dcc1021f8f8ef02e30c379c5d4.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..53e42120008610df0d5fc40faf5633755996714f --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/19bef6f5ab65d11869bc4f3c74205715d162c3dcc1021f8f8ef02e30c379c5d4.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "19bef6f5ab65d11869bc4f3c74205715d162c3dcc1021f8f8ef02e30c379c5d4", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "3c38824d65664de95453929e6543cecd97615af4e34556c2ec4cb8fdaa06e5e1", + "output_sha256": "52272e65fbb91ffe38b3a1fdf0db03b17c264bbaffeb47fc7e527abf097aa655", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/19d419675d096a75e744a2a6d66693c84b1ab564cdad3d74dcba47458c8ca319.md b/vision-fixhub/ds9-parsed-01/19d419675d096a75e744a2a6d66693c84b1ab564cdad3d74dcba47458c8ca319.md new file mode 100644 index 0000000000000000000000000000000000000000..84dfed8e19fb30275fbcaabb127aa4f4069b7c29 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/19d419675d096a75e744a2a6d66693c84b1ab564cdad3d74dcba47458c8ca319.md @@ -0,0 +1,50 @@ +FEDERAL BUREAU OF INVESTIGATION +Title: (U//FOUO) INTERVIEW RE: JULIO CESAR SUAREZ +Drafted By: Missing +Case ID #: 72-MM-113327 +Date: 11/02/2009 +SEE SUB +Details: +11/04/2009 +Julio Cesar Suarez, +date of birth +Social +Security Account Number +U.S. Permanent Resident, +employed as a kitchen cabinet +salesperson, cellular telephone +residence +was +interviewed in the vicinity of the Hilton Hotel, +Boca Raton, Florida. Suarez had a North Carolina Driver's License +in his possession which reflected a previous address of +Suarez was advised of +the identity of the interviewing agents and purpose of the +interview. Suarez was read an FD-395 Advice of Rights form which +he stated he understood and signed. Suarez provided the following +information: +Suarez traveled to the Hilton Hotel with his friend, +Alfredo Rodriguez. Suarez met Rodriguez through their wives. +Rodriguez picked Suarez up near his residence in Kendall and they + + +Title: +(U//FOUO) INTERVIEW RE: JULIO CESAR SUAREZ +Re: +72-MM-113327, 11/02/2009 +planned to have lunch together. Rodriguez told Suarez he needed to +stop in Boca Raton but did not give a reason why. Suarez +acknowledged that Rodriguez brought documents to the Hilton Hotel +but he denied having any knowledge of what the documents were +related to. Suarez advised that Rodriguez rents the El Cristo +restaurant located at 8th Street, Miami, Florida and had been +previously employed at another restaurant. +At the conclusion of the interview, +and +at the request of +Alfredo Rodriguez, Rodriguez' Chevrolet Trailblazer, +Florida tag +was released to Suarez. +The original FD-395 was placed in a lA envelope of case +file. +2 diff --git a/vision-fixhub/ds9-parsed-01/19d419675d096a75e744a2a6d66693c84b1ab564cdad3d74dcba47458c8ca319.receipt.json b/vision-fixhub/ds9-parsed-01/19d419675d096a75e744a2a6d66693c84b1ab564cdad3d74dcba47458c8ca319.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..403d12c91641c6cc0bce3c0aa71c9394aa0e23d8 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/19d419675d096a75e744a2a6d66693c84b1ab564cdad3d74dcba47458c8ca319.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "19d419675d096a75e744a2a6d66693c84b1ab564cdad3d74dcba47458c8ca319", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "a6167f2a5c70c9e15784130b6e2c89f49ed3f8fc6f806e603e3ba56fc14384f4", + "output_sha256": "b5f57ca76bb287d8de6e166233546fe7eae9b92339a210c9f91cd264a641b4cb", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/19dc4e028fe675781f0cd41c437fa339e7690a1e918641e514f60b986324b624.md b/vision-fixhub/ds9-parsed-01/19dc4e028fe675781f0cd41c437fa339e7690a1e918641e514f60b986324b624.md new file mode 100644 index 0000000000000000000000000000000000000000..b4764fb5fde9efd7b8209febf5b46ffd94169f09 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/19dc4e028fe675781f0cd41c437fa339e7690a1e918641e514f60b986324b624.md @@ -0,0 +1 @@ +No Images Produced diff --git a/vision-fixhub/ds9-parsed-01/19dc4e028fe675781f0cd41c437fa339e7690a1e918641e514f60b986324b624.receipt.json b/vision-fixhub/ds9-parsed-01/19dc4e028fe675781f0cd41c437fa339e7690a1e918641e514f60b986324b624.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..a8fa67f7509f2d08a10f2a74ffb4f77ca05a0845 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/19dc4e028fe675781f0cd41c437fa339e7690a1e918641e514f60b986324b624.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "19dc4e028fe675781f0cd41c437fa339e7690a1e918641e514f60b986324b624", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "c6ff5c4806b96bc4a1524faa5f3b7711c7fecb001313958385a71fe3a5e4a61b", + "output_sha256": "3874328764c818fba06683a6d5ddc2edc2d7850aaf4ba18646f81d3f8420a729", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/19e9a504b2291816499c6979e614ac2baa39fdd9c6f51afee22309848855687a.md b/vision-fixhub/ds9-parsed-01/19e9a504b2291816499c6979e614ac2baa39fdd9c6f51afee22309848855687a.md new file mode 100644 index 0000000000000000000000000000000000000000..5aee6b997eb79e55480e715ce208f2b0b59aceb1 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/19e9a504b2291816499c6979e614ac2baa39fdd9c6f51afee22309848855687a.md @@ -0,0 +1,93 @@ +Sent: +Mon 8/12/2019 11:15:25 AM +Subject: Fwd: RE: United States v. Jeffrey Epstein +IEXT.htm +Good morning, +Please see the below request for preservation and production of various documents, videos, and other +information. Please preserve the material requested below to prevent deletion. We will advise that they +need to request production of the requested documentation through FOIA. +Thank you, +Supervisory Staff Attorney +CLC New York +Metropolitan Correctional Center +150 Park Row +New York. New York 10007 +p: +f: +>>> "Martin G. Weinberg" < +> 8/11/2019 3:56 PM >>> +Mr. +Mr. Epstein's family has asked me to send to you and +at the MCC a +request for the preservation of any and all documents, records, reports, videos, pictures, physical +evidence, electronic communication data, tape recordings, logs, notes, papers, emails and any and +all other forms of information that would be in the possession of the MCC, its Warden, their legal +counsel, the USMS, the FBI, the Inspector General, the USAO for the SDNY or any other federal or +relevant state or city agency that relate to Jeffrey Epstein's imprisonment/detention since July 6, +2019 and that relate particularly but not exclusively to the July 23, 2019 occurrence which was +investigated as an attempted suicide by the MCC and the events relating to his death on August 10, +2019. The request encompasses but is not limited to any videos of the 9th floor area in the +proximity of his cell during the evening of August 9 through the time Mr. Epstein was taken out of +his cell for the last time on August 10, 2019, or videos of the cell itself during that time period, +records of the identities of (i.e. MCC employees or independent contractors or anyone else) who +were on duty from midnight through 8 AM on August 10, 2019 or otherwise had access to the 9th +floor unit where Mr. Epstein was incarcerated during this time period, records of any observations of +Mr. Epstein on August 9-10, 2019, any and all photographs of Mr. Epstein or his cell taken on August +10, 2019, any and all electronic or tape recordings or records of any internal communications within +the MCC or any external communciations by MCC staff on August 9 and August 10, 2019, records of +any mental health interviews or assessements of Mr. Epstein at anytime during his detention, +records of any decision to put him on or take Mr Epstein off suicide watch, photos of his cell taken + +SDNY_00013147 + + +on or before August 9 or on or after August 10, 2019, memoranda of interviews with any prisoners +who were in Mr. Epstein's SHU unit on the 9th floor on or about July 23 or on August 9-10, 2019 +relating to Mr. Epstein, the same request for interview memoranda of any MCC employee or +independent contractor or any other person in the MCC midnight-8 AM August 10, 2019, any and all +medical and EMS and hospital records from July 23 and/or August 10, 2019, and the future +pathology and toxicology and medical examiner's reports. Additionally, we would request the +preservation of any note or notes found in Mr. Epstein's cell on August 10, 2019, any ligature or +other physical evidence related to his cause of death, any bedding, any medication or vitamins, any +log showing who entered or were present in the MCC for the 12 hour period before 6:30 AM on +August 10, 2019, as well as a list of inmates who were in Mr. Epstein's unit during the evening of +August 9 and the morning of August 10, 2019. We would in addition to the preservation request ask +for the production of all of the above. We would receive and retain in subject any information +received in response to this request subject to the terms and conditions of our Protective Order. In +short, the family requests a preservation and production of any and all records and documents +relevant to his detention, treatment, and death. I will send an identical request to Mr L +well as to Mark Epstein's personal counsel +Thank you for your consideration of these requests and your ongoing assistance +Martin G. Weinberg, Esq. +Boston, MA 02116 +- Office +- Cell +Martin G. Weinberg, Esq. +Boston, MA 02116 +- Office +================== +====This Electronic Message contains information +from the Law Office of Martin G. Weinberg, P.C., and may be privileged. The information is +intended for the use of the addressee only. If you are not the addressee, please note that +any disclosure, copying, distribution, or use of the contents of this message is prohibited. +From: +Sent: Saturday, August 10, 2019 1:57 PM +To: + +SDNY_00013148 + + +Subject: United States v. Jeffrey Epstein +Good afternoon, +Enclosed please find official notification from Warden L +[regarding Mr. Epstein's passing. As +the investigation is ongoing, we have no further details at this time. We will continue to keep you +updated as more information is available. +Thank you, +Supervisory Staff Attorney +CLC New York +Metropolitan Correctional Center +150 Park Row +New York, New York 10007 + +SDNY_00013149 \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/19e9a504b2291816499c6979e614ac2baa39fdd9c6f51afee22309848855687a.receipt.json b/vision-fixhub/ds9-parsed-01/19e9a504b2291816499c6979e614ac2baa39fdd9c6f51afee22309848855687a.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..cf64ab50bf53cd1385d8ee60dc12441cd027c5d9 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/19e9a504b2291816499c6979e614ac2baa39fdd9c6f51afee22309848855687a.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -60, + "dataset": "marble-joined", + "doc_id": "19e9a504b2291816499c6979e614ac2baa39fdd9c6f51afee22309848855687a", + "engine": "marble-apple-vision", + "event_count": 5, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\"]", + "idempotent": true, + "input_sha256": "b6c0b12c7acdf0b56b0a70c0b9db97c2ced010aaaa1263860147ab2a48cf824f", + "output_sha256": "e24198bbd15924afe95ac0d5539e4ba68e443c27ce56bd077ec53c2e9009f24a", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1a06b929f1fb690420b7eac3ddc5249269df54ac551be7e7bb69bfdebcc46ce1.md b/vision-fixhub/ds9-parsed-01/1a06b929f1fb690420b7eac3ddc5249269df54ac551be7e7bb69bfdebcc46ce1.md new file mode 100644 index 0000000000000000000000000000000000000000..8f523c679fcd6e15814b8eb0083f82a90584fa88 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1a06b929f1fb690420b7eac3ddc5249269df54ac551be7e7bb69bfdebcc46ce1.md @@ -0,0 +1,3 @@ + +SDNY_00000869 +EFTA 00000093 \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/1a06b929f1fb690420b7eac3ddc5249269df54ac551be7e7bb69bfdebcc46ce1.receipt.json b/vision-fixhub/ds9-parsed-01/1a06b929f1fb690420b7eac3ddc5249269df54ac551be7e7bb69bfdebcc46ce1.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..0908274e193dc6e37b9879f7a94859f5560faacd --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1a06b929f1fb690420b7eac3ddc5249269df54ac551be7e7bb69bfdebcc46ce1.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "1a06b929f1fb690420b7eac3ddc5249269df54ac551be7e7bb69bfdebcc46ce1", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "6af3f8b248577e7bc5ce7f7ff370f573772699d1370be62e9f2ddecbe6fb7f4f", + "output_sha256": "b1c7bd63f22c64582618c3947f417f5badd17c98505a752222acdafa8b83f503", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1a0eb4d72a30c37f9d2d9ccfe8dc91fd3a16f6a60747cde06f14064548511fe0.md b/vision-fixhub/ds9-parsed-01/1a0eb4d72a30c37f9d2d9ccfe8dc91fd3a16f6a60747cde06f14064548511fe0.md new file mode 100644 index 0000000000000000000000000000000000000000..1495d474a7774d4a375de1fd4677e0bbe67d7b10 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1a0eb4d72a30c37f9d2d9ccfe8dc91fd3a16f6a60747cde06f14064548511fe0.md @@ -0,0 +1,51 @@ +From: " +To: +Subject: RE: SDNY case +Date: Fri, 10 Jul 2020 13:39:02 +0000 +Attachments: GEN_MEMORANDUM +_ON_ADVANCE_WAIVER_OF_EXTRADITION.doc +Hi, +French MOJ confirmed for me a that a dual French national is a French national, and extradition is not possible from +France. +Article 696-4 of the French Criminal Procedure Code prohibits the extradition of French nationals (here is the link: +https://www.legifrance.gouv.fr/affichCode.do:jsessionid=3C709E123E74AOD321F78FF9C7B84A77.tplgfr27s_1? +idSectionTA=LEGISCTA000006167511&cidTexte=LEGITEXT000006071154&date Texte=20200710) and that principle is also +found in our bilateral extradition treaty as well (in the sense that it does not obligate France to extradite its nationals). +The only quirk is here is if, somehow, she acquired French nationality after the time period of the criminal conduct...that +might allow her to be extradited, but I imagine that is the rare case. +l've also attached a write up with some cases on the question of advance waiver of extradition, in case that is offered as a +proposed bail condition. I would just caution that this a few years out of date at this point, and the cite checking might not +be perfect; but there are a few decisions cited that might be useful for you to cite directly. +Good luck! +From: +To: +Sent: Wednesday, July 8, 2020 5:46 PM +Subject: Re: SDNY case +Thanks very much, 9 a.m. on Friday would be great. What number should I call? +Sent from my iPhone +On Jul 8, 2020, at 11:44 AM, +Sure thing. Friday looks pretty open for me. Would 9am or 9:30am work for you? +> wrote: +From: | +Sent: Wednesday, July 8, 2020 5:38 PM +To: +Subject: Re: SDNY case +Hil + + +Do you have a moment this week for a quick call? I have a few questions about the extradition process in France +generally, and it would be helpful to discuss. +Thanks very much, +Assistant United States Attorney +Southern District of New York +One Saint Andrew's Plaza +New York, NY 10007 +(212) 637-2225 +Sent from my iPhone +On Jul 8, 2020, at 11:21 AM, +(CRM) < +> wrote: +I am putting you in touch with +who is working the Maxwell/ Epstein matter in SDNY. She +has some questions about the probably of extraditing someone from France who has dual +Thx, diff --git a/vision-fixhub/ds9-parsed-01/1a0eb4d72a30c37f9d2d9ccfe8dc91fd3a16f6a60747cde06f14064548511fe0.receipt.json b/vision-fixhub/ds9-parsed-01/1a0eb4d72a30c37f9d2d9ccfe8dc91fd3a16f6a60747cde06f14064548511fe0.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..e7c82d67638324ddc15b60a9f83a037b838640ad --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1a0eb4d72a30c37f9d2d9ccfe8dc91fd3a16f6a60747cde06f14064548511fe0.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "1a0eb4d72a30c37f9d2d9ccfe8dc91fd3a16f6a60747cde06f14064548511fe0", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "b8bc0beb902d1110def526cf6443e5c161ebbcd7cda1a9a27102fa786cd96ed2", + "output_sha256": "fe1188511efee060f745082e69458fd6e312382603529ab91f2f4459b60f7330", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1a69c09373a28170176b41ed5a4b6f719107e41ac94fac65325661085c8f76e7.md b/vision-fixhub/ds9-parsed-01/1a69c09373a28170176b41ed5a4b6f719107e41ac94fac65325661085c8f76e7.md new file mode 100644 index 0000000000000000000000000000000000000000..b4287ccd20c3328e73a4fe2ef79a94b5a5fe157a --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1a69c09373a28170176b41ed5a4b6f719107e41ac94fac65325661085c8f76e7.md @@ -0,0 +1,10 @@ +From: +To: +Subject: Epstein-Related Touhy Requests +Date: Tue, 20 Aug 2019 18:21:41 +0000 +All, +I'll be handling Epstein-related Touhy requests on the civil side. Could you please pass along the letters from Steptoe they +sent today? Thanks! +Assistant United States Attorney +Southern District of New York +New York, New York 10007 diff --git a/vision-fixhub/ds9-parsed-01/1a69c09373a28170176b41ed5a4b6f719107e41ac94fac65325661085c8f76e7.receipt.json b/vision-fixhub/ds9-parsed-01/1a69c09373a28170176b41ed5a4b6f719107e41ac94fac65325661085c8f76e7.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..b849d4cbcc1bba5e443fd40a2d96eabc04aecc8f --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1a69c09373a28170176b41ed5a4b6f719107e41ac94fac65325661085c8f76e7.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "1a69c09373a28170176b41ed5a4b6f719107e41ac94fac65325661085c8f76e7", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "21496a6a369eddd9c927d487cdb87a77e02f88aeb4e82b7bfe61c2b9163bcada", + "output_sha256": "9f0a9b8c210f3f19c2e4b612452f36f9c7238314e5231ec966adace194467dbb", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1a71a7ae2b9fb8edbd0b4c8f157c2adbf52aaf03b50911914d9ea1093310a13f.md b/vision-fixhub/ds9-parsed-01/1a71a7ae2b9fb8edbd0b4c8f157c2adbf52aaf03b50911914d9ea1093310a13f.md new file mode 100644 index 0000000000000000000000000000000000000000..e1afdf062724ce722334f11f430b082b29bbf9b5 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1a71a7ae2b9fb8edbd0b4c8f157c2adbf52aaf03b50911914d9ea1093310a13f.md @@ -0,0 +1,8 @@ +From: "I +(USANYS)" { +To: +(USANYS)" { +Subject: Accepted: Call with FBI (Epstein) +Date: Mon, 24 Jun 2019 22:36:48 +0000 +Importance: Normal +Attachments: unnamed diff --git a/vision-fixhub/ds9-parsed-01/1a71a7ae2b9fb8edbd0b4c8f157c2adbf52aaf03b50911914d9ea1093310a13f.receipt.json b/vision-fixhub/ds9-parsed-01/1a71a7ae2b9fb8edbd0b4c8f157c2adbf52aaf03b50911914d9ea1093310a13f.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..4b8a9278600eb099300a8033cee1431b70bcbb62 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1a71a7ae2b9fb8edbd0b4c8f157c2adbf52aaf03b50911914d9ea1093310a13f.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "1a71a7ae2b9fb8edbd0b4c8f157c2adbf52aaf03b50911914d9ea1093310a13f", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "c6b988a456603086d9007eb5d7da46cb61032957bf7201e34c03f512d9301a09", + "output_sha256": "0b94be1bd288d507626bb038efaf060db62677914b6fbaa6b814d689baa31328", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1a76c885fd397b466b1e0f52d7cc47e2adcd884ef81bd9fbfb7372f3511c70b5.md b/vision-fixhub/ds9-parsed-01/1a76c885fd397b466b1e0f52d7cc47e2adcd884ef81bd9fbfb7372f3511c70b5.md new file mode 100644 index 0000000000000000000000000000000000000000..62f25b44b292d03699c303664d236b87ebe749db --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1a76c885fd397b466b1e0f52d7cc47e2adcd884ef81bd9fbfb7372f3511c70b5.md @@ -0,0 +1,60 @@ +From: " +(USANYS) [Contractor]" < +To: " +Cc: " +(USANYS) [Contractor]" < +[Contractor]" +Subject: RE: CD with Maxwell files +Date: Tue, 06 Apr 2021 17:11:56 +0000 +(USANYS) +Just confirmed with +I that we'll need a replacement of the folder called "1B 1-14" since it won't copy for him either, +probably due to the files getting corrupted somehow when the disc was burned. The folder/its contents may be small +enough that the FBI could send it via USAfx rather than having to burn a new disc, but we'll need a replacement of this +folder either way. +From: +To: +Cc: +Sent: Monday, April 5, 2021 4:27 PM +| (USANYS) [Contractor] ‹ +(USANYS) [Contractor] < +(USANYS) [Contractor] +Subject: RE: CD with Maxwell files +Great, thank you! +From: +To: +Cc: +(USANYS) [Contractor] ‹ +Sent: Monday, April 5, 2021 4:20 PM +(USANYS) [Contractor] < +| (USANYS) [Contractor] +Subject: RE: CD with Maxwell files +Hi +Four of the five folders from the disc have successfully uploaded to the folder path linked below, but the fifth folder (1B 1- +14) contains at least one file that +I not copy off of the disc (not sure if the file is corrupted or what the issue is exactly). +I'll check with the IT folks and +I to see if they're able to copy the remaining folder off the disc or if we'll need the FBI +to recopy and resend it. I| +|keep you posted on the status of this last folder. +Thanks, +From: +(USANYS) [Contractor] < +Sent: Monday, April 5, 2021 2:04 PM +To: l +| (USANYS) [Contractor] " +Subject: FW: CD with Maxwell files +Thank you so much! +From: [ +Sent: Monday, April 5, 2021 1:55 PM +To: +| (USANYS) [Contractor] ‹ +Subject: CD with Maxwell files +• (USANYS) [Contractor] + + +Hi and +On Friday, the FBI brought me a CD containing additional files that I need to review for Maxwell. It should be sitting in my +office on the 4th floor on my keyboard at my desk. Would one of you (or another paralegal who is in the office) be able to +please grab the CD and load its contents onto the Epstein share? You can save everything from the CD here: +Thanks so much, diff --git a/vision-fixhub/ds9-parsed-01/1a76c885fd397b466b1e0f52d7cc47e2adcd884ef81bd9fbfb7372f3511c70b5.receipt.json b/vision-fixhub/ds9-parsed-01/1a76c885fd397b466b1e0f52d7cc47e2adcd884ef81bd9fbfb7372f3511c70b5.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..aca1220025bc1e162b2ead0c97fff62b6bfd6732 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1a76c885fd397b466b1e0f52d7cc47e2adcd884ef81bd9fbfb7372f3511c70b5.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "1a76c885fd397b466b1e0f52d7cc47e2adcd884ef81bd9fbfb7372f3511c70b5", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "8455b39fd98241e2d519915e26a61da1410a2716ceb38358d3e186addfd2f0ed", + "output_sha256": "a8d60a84b3864976c582563934177668c33a1d57190478d03c87da9061d1a8f2", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1ac1a1fab1c8bedf4273a769d7f6647a4ce5da0defe5967c3a2d205755254475.md b/vision-fixhub/ds9-parsed-01/1ac1a1fab1c8bedf4273a769d7f6647a4ce5da0defe5967c3a2d205755254475.md new file mode 100644 index 0000000000000000000000000000000000000000..947b0bc381309c98a6258502e0cd34604661ec0d --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1ac1a1fab1c8bedf4273a769d7f6647a4ce5da0defe5967c3a2d205755254475.md @@ -0,0 +1,10 @@ +From: +(USANYS)". +To: +USANYS)" < +Subject: Automatic reply: Epstein probate update +Date: Fri, 21 Feb 2020 14:21:33 +0000 +I will be out of the Office through February 21 and will be checking emails periodically. Please see +T&B review on Tuesday, and +for any review during the rest of the week. Thanks! +tor any diff --git a/vision-fixhub/ds9-parsed-01/1ac1a1fab1c8bedf4273a769d7f6647a4ce5da0defe5967c3a2d205755254475.receipt.json b/vision-fixhub/ds9-parsed-01/1ac1a1fab1c8bedf4273a769d7f6647a4ce5da0defe5967c3a2d205755254475.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..d1f80633c56b03b7fee1a99ece2d0efea1a6203c --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1ac1a1fab1c8bedf4273a769d7f6647a4ce5da0defe5967c3a2d205755254475.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "1ac1a1fab1c8bedf4273a769d7f6647a4ce5da0defe5967c3a2d205755254475", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "c892106d6914727a4531eb946f4c0eef6bc463898489c1cbda3908516a60e2ef", + "output_sha256": "c4d518a9ef8ce9bb8cbc1d8834eb1998ddbec9a6b15c563196fd5b6af5dad3a2", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1ac8840be959e5e796df94e3e2940a57cedf42096f7fd926cf25e88b20bb5d53.md b/vision-fixhub/ds9-parsed-01/1ac8840be959e5e796df94e3e2940a57cedf42096f7fd926cf25e88b20bb5d53.md new file mode 100644 index 0000000000000000000000000000000000000000..3aa0f0b91ec47cc0e2e5ba993f5c03260a843850 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1ac8840be959e5e796df94e3e2940a57cedf42096f7fd926cf25e88b20bb5d53.md @@ -0,0 +1,199 @@ +Case 1:20-cv-00833-PAE Document 1 Filed 01/30/20 Page 1 of 7 +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +THE NEW YORK TIMES COMPANY, +Plaintiff, +X +: +: +: +COMPLAINT +- against - +FEDERAL BUREAU OF PRISONS, +: +Defendant. +: +Plaintiff THE NEW YORK TIMES COMPANY ("The Times"), by its undersigned +attorneys, alleges as follows: +This is an action under the Freedom of Information Act, 5 U.S.C. § 552 +("FOIA"), to obtain an order for the production of agency records from Defendant Federal +Bureau of Prisons ("BOP") in response to requests properly made by Plaintiff. +The records concern Jeffrey Epstein, the wealthy financier charged with sex +trafficking of minors who died at the Metropolitan Correctional Center ("MCC") on August 10, +2019. Epstein's relationships with prominent figures in politics, business, and Hollywood +entertainment contribute to the public interest in Epstein and the circumstances surrounding his +death. +PARTIES +Plaintiff The New York Times Company publishes The New York Times +newspaper and www.nytimes.com. The New York Times Company is headquartered in this +judicial district at 620 Eighth Avenue, New York, New York, 10018. +1 + + +Case 1:20-cv-00833-PAE Document 1 Filed 01/30/20 Page 2 of 7 +4. +Defendant BOP is an agency of the federal government that has possession and +control of the records that Plaintiff seeks. +JURISDICTION AND VENUE +This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C. § +1331 and 5 U.S.C. § 552(a)(4)(B). +6. +Venue is premised on Plaintiff's place of business and is proper in this district +under 5 U.S.C. § 552(a)(4)(B). +FOIA requires that agencies respond to requests within 20 business days. See 5 +U.S.C. § 552(a)(6)(A). +8. +Defendant BOP has failed to meet the statutory deadlines set by FOIA. See 5 +U.S.C. § 552(a)(6)(A)-(B). Plaintiff is therefore deemed to have exhausted all administrative +remedies, pursuant to 5 U.S.C. § 552(a)(6)(C). +FACTS +The August 12, 2019 Requests +On August 12, 2019, The Times submitted two FOIA requests to BOP. +10. The first request sought information about the procedures followed in housing +Epstein at the MCC, as well as background information about Epstein as an inmate. +11. +One subset of that request centered on records relating to the designation of +Epstein as a suicide risk: "Documents showing when MCC staff held meetings regarding Jeffrey +Epstein, and who attended"; "All records generated from the meeting at MCC during which it +was decided that Jeffrey Epstein would be taken off suicide watch"; "The Post-Watch report +compiled in order to take Jeffrey Epstein off suicide watch"; and "All medical reports related to +Jeffrey Epstein at MCC." +2 + + +Case 1:20-cv-00833-PAE Document 1 Filed 01/30/20 Page 3 of 7 +12. A second subset focused on the operations of the MCC during the time of +Epstein's attempted suicide and, later, his death: "The signed log in the Special Housing Unit at +MCC that shows when prison staff did rounds on July 22 and 23, and Aug. 9 and 10"; "The +overtime sign-up sheets for the Special Housing Unit (9 South) at MCC for Aug. 9 and 10, and +on July 22 and 23"; and "Documents showing which staff were augmented at MCC and what +positions they worked in on Aug. 9 and 10, and on July 22 and 23." +13. +A third subset focused on Epstein's experience as an inmate: the intake screening +form, inmate profile, and chronological disciplinary records for Epstein at MCC; all quarter +entries showing which cells Epstein was housed in at MCC; incident reports related to Epstein at +MCC; the Central Inmate Monitoring (CIM) Clearance and Separatee data sheet for Epstein at +MCC; security designation records and chronological disciplinary records for Epstein at MCC; +and the signed visitor log for Epstein at MCC. +14. +The second request filed on August 12, 2019 sought video camera footage and +BOP documents pertaining to Epstein's suicide and to his first suicide attempt, as well as BOP +documents (including email correspondence and meeting minutes) pertaining to the decision to +remove Epstein from suicide watch, BOP special investigation reports mentioning Epstein, and +BOP correspondence with the U.S. Attorney's Office regarding Epstein. +15. +On September 23, 2019, BOP responded, providing tracking number 2019-05665 +(apparently consolidating the two August 2019 requests) and stating that all responsive records +"are categorically exempt from disclosure" under Exemptions 5, 6, 7(A), 7(C), 7(E), and 7(F), +and that, as a result, the agency was "not required to conduct a search for the requested records." +16. +On October 3, 2019, The Times sent via FedEx an administrative appeal of the +categorical denial of the two August 2019 requests. That appeal noted that agencies have a +3 + + +Case 1:20-cv-00833-PAE Document 1 Filed 01/30/20 Page 4 of 7 +statutory duty to "make reasonable efforts to search" for responsive records, 5 U.S.C. § +552(a)(3)(C), that BOP ought to have made a good faith effort to search for responsive records to +determine whether there are any non-exempt responsive records, and that it was implausible, +given the breadth of the requests, that all responsive records were properly withheld. On October +9, 2019, The Times received an e-mail indicating that the appeal was received and was assigned +appeal tracking number DOJ-AP-2020-000123. +17. +On November 27, 2019, The Times spoke by phone to the assigned FOIA officer, +who indicated that the agency was processing the appeal and hoped to provide a response within +2-3 weeks. +18. To date, The Times has not received any response to its administrative appeal, nor +any documents responsive to either of the August 2019 requests. +The December 12, 2019 Request +19. On December 12, 2019, The Times submitted a FOIA request by e-mail to BOP. +The request sought: "(1) The full log of Mr. Epstein's phone calls to and from the MCC; "(2) +All email correspondence to and from Mr. Epstein while he was at the MCC (including any +correspondence through the Corrlinks system or any other email system he had access to)"; "(3) +The full log of people who visited Mr. Epstein while he was at the MCC and when they visited"; +"(4) The full list of people that Mr. Epstein had requested to be on his approved visitor list"; "(5) +The full list of people that Mr. Epstein had requested to be on his approved email +correspondence list"; and "(6) The full list of people that Mr. Epstein had requested to be on his +approved call list." The December 12, 2019 request sought expedited processing and indicated +that records generated by BOP employees based in New York, Texas, and Washington, D.C. +should be searched. +4 + + +Case 1:20-cv-00833-PAE Document 1 Filed 01/30/20 Page 5 of 7 +20. +On December 16, 2019, BOP acknowledged receipt of The Times's December 12, +2019 request, and indicated that it was assigned FOIA/PA request number 2020-01336 and was +forwarded to processing office CO. The letter also stated that BOP had denied The Times's +request for expedited processing and assigned the request to the complex processing queue. +21. +BOP has failed to respond to the December 12, 2019 request within the statutory +time frame required under FOIA. +22. +The January 2, 2020 Request +On January 2, 2020, The Times submitted a FOIA request by e-mail to BOP.' +That request sought: "The full recordings of the last three phone conversations that Mr. Epstein +had." The Times's January 2, 2020 request again sought expedited processing and indicated that +records generated by BOP employees based in New York, Texas, and Washington, D.C. should +be searched. +23. +On January 9, 2020, The Times received a letter from BOP, explaining that the +agency determined the December 12, 2019 and the January 2, 2020 requests "should be +aggregated into one request, which is request number 2020-01336." That letter also denied The +Times's request for expedited processing of the January 2, 2020 request. +24. +BOP has failed to respond to The Times's January 2, 2020 request within the +statutory time frame required under FOIA. +25. +COUNT ONE +Plaintiff repeats, realleges, and reincorporates the allegations in the foregoing +paragraphs as though fully set forth herein. +' The Times also submitted a second FOLA request to BOP on January 2, 2020, which was +assigned tracking number 2020-01578. That request does not seek records specific to Epstein and +is not at issue in this suit. +5 + + +Case 1:20-cv-00833-PAE Document 1 Filed 01/30/20 Page 6 of 7 +26. +Defendant BOP is subject to FOIA and must therefore release in response to a +FOIA request any disclosable records in its possession at the time of the request and provide a +lawful reason for withholding any materials as to which it is claiming an exemption. +27. +BOP has failed to meet the statutory deadlines set by FOIA. See 5 U.S.C. § +552(a)(б)(A)-(B). Accordingly, Plaintiff is deemed to have exhausted its administrative remedies +under FOIA. +28. +BOP has no lawful basis for declining to release the records requested by Plaintiff +under FOIA. +29. Accordingly, Plaintiff is entitled to an order compelling BOP to produce records +responsive to its FOIA request. +REQUEST FOR RELIEF +WHEREFORE, Plaintiff respectfully requests that this Court: +30. Declare that the documents sought by its FOIA request, as described in the +foregoing paragraphs, are public under 5 U.S.C. § 552 and must be disclosed; +31. +Order BOP to provide the requested documents to Plaintiff within 20 business +days of the Court's order; +32. Award Plaintiff the costs of this proceeding, including reasonable attorney's fees, +as expressly permitted by FOIA; and +33. +Grant Plaintiff such other and further relief as this Court deems just and proper. +Dated: New York, New York +January 30, 2020 +Is/ David E. McCraw +David E. McCraw +Alexandra Perloff-Giles +6 + + +Case 1:20-cv-00833-PAE Document 1 Filed 01/30/20 Page 7 of 7 +Legal Department +The New York Times Company +620 8th Avenue +New York, NY 10018 +Phone: (212) 556-4031 +Fax: (212) 556-4634 +E-mail: mccraw@nytimes.com +Counsel for Plaintiff +7 diff --git a/vision-fixhub/ds9-parsed-01/1ac8840be959e5e796df94e3e2940a57cedf42096f7fd926cf25e88b20bb5d53.receipt.json b/vision-fixhub/ds9-parsed-01/1ac8840be959e5e796df94e3e2940a57cedf42096f7fd926cf25e88b20bb5d53.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..d6f7dcf686d383e0f20f2cdfbc2adf8a255c3bd7 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1ac8840be959e5e796df94e3e2940a57cedf42096f7fd926cf25e88b20bb5d53.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -84, + "dataset": "marble-joined", + "doc_id": "1ac8840be959e5e796df94e3e2940a57cedf42096f7fd926cf25e88b20bb5d53", + "engine": "marble-apple-vision", + "event_count": 7, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "b59e5aac293746c75253da2edc2efe641568751a8f946c3ba41e60de6c060d75", + "output_sha256": "18583fa25dd43ea729d98d141c01ff3bf5528dd48cc30a8885357dcd543c8e49", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1ad02502e2e7353bea3990496e1977568ba098bf8b199ce56e3c6501dff0a430.md b/vision-fixhub/ds9-parsed-01/1ad02502e2e7353bea3990496e1977568ba098bf8b199ce56e3c6501dff0a430.md new file mode 100644 index 0000000000000000000000000000000000000000..07a501d2f2c268ab86c4191d6750ce2fa98f9033 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1ad02502e2e7353bea3990496e1977568ba098bf8b199ce56e3c6501dff0a430.md @@ -0,0 +1,67 @@ +OFFICIAL RECORD +FD-1057 (Rev. 5-8-10) +UNCLASSIFIED +FEDERAL BUREAU OF INVESTIGATION +Electronic Communication +Title: (U) Kathryn Dee +From: ATLANTA +Contact: +Approved By: +Drafted By: +Case ID #: 305-AT-0 +Date: +03/16/2021 +(U) ZERO FILE +Synopsis: (U) NCMEC child trafficking reports related to +Enclosure (s): Enclosed are the following items: +1. (U) CT report # 87492334 +2. (U) CT report # 85757143 +3. (U) CT 83658616 +Details: +NCMEC CyberTipline (NCT) report # 87492334, submitted on +03/09/21, reported Child Sex Trafficking. Information was submitted +that +Gainesville, GA, was using +identity and may have obtained custody of a child using another child's +birth certificate and identity. +NCMEC identified two additional similar Child Sex Trafficking +reports that appeared to be reported by the same person. All three +reports had similar reported information and were submitted from IP +addresses located in Tampa, +Florida. +NCT report # 85757143, submitted on 10/31/19, by +phone +number +reported the use of cyber torture to gain access +to her personal thoughts to find and take children. +also stated that +UNCLASSIFIED + + +UNCLASSIFIED +Title: (U) Kathryn Dee +Re: 305-AT-O, 03/16/2021 +she was kidnapped in the Bermuda Triangle, had mental illness and people +were using time travel to steal from her. +Young was +identified as the culprit. +NCT report # 83658616, submitted on 12/15/20, by +number +still active and +reported that Epstein's group was +was the ringleader. +phone +as +telephone number +aka +social security number| +, was further identified +date of birth (DOB) +Tampa, +Florida. +was further identified as +Gainesville, +Georgia. +DOB +UNCLASSIFIED +2 diff --git a/vision-fixhub/ds9-parsed-01/1ad02502e2e7353bea3990496e1977568ba098bf8b199ce56e3c6501dff0a430.receipt.json b/vision-fixhub/ds9-parsed-01/1ad02502e2e7353bea3990496e1977568ba098bf8b199ce56e3c6501dff0a430.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..948eef8c1bfeee2db5c35a471a616fe254b044ae --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1ad02502e2e7353bea3990496e1977568ba098bf8b199ce56e3c6501dff0a430.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "1ad02502e2e7353bea3990496e1977568ba098bf8b199ce56e3c6501dff0a430", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "60a03838164c1efa89c9bbf87b3f1b4ab8358eb60b535461f4a92a7acdabb172", + "output_sha256": "619677d61e5e3750c361c289b60e2fd2d6ee2df019953804e72202839a210ccf", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1adb2d5877346692db2e8bcb2f282262278437b4bf8bf277d2b94f38e4c5e47b.md b/vision-fixhub/ds9-parsed-01/1adb2d5877346692db2e8bcb2f282262278437b4bf8bf277d2b94f38e4c5e47b.md new file mode 100644 index 0000000000000000000000000000000000000000..bf7e2ae7cbb01d90aa37593ed5b553be43bbdd99 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1adb2d5877346692db2e8bcb2f282262278437b4bf8bf277d2b94f38e4c5e47b.md @@ -0,0 +1,39 @@ +From: " +To: " +Subject: FW: Epstein +Date: Wed, 21 Oct 2020 23:41:06 +0000 +From: +Sent: Saturday, August 24, 2019 3:15 PM +To: +Cc: +Subject: RE: Epstein +That's great news, +Pil +. Thanks for the confirmation. Hope you have a good weekend, and hope all goes well next week. +From: +To: +Cc: +Sent: Saturday, August 24, 2019 1:53 PM +Subject: RE: Epstein +Pil +Yes, we have made extensive notifications to victims, including through the VNS as well as through direct calls and emails +to relevant counsel, as well as through a posting on our website that has ever Epstein-related update. Our notifications +have gone to every person who has been identified as a victim in the case, to our knowledge and to date, including +individuals we have not met with and including numerous Florida victims (and, to the extent we have been able to contact +them, each of the individuals identified as victims in connection with the NPA). +thanks, +From: +To: +Cc: +Sent: Saturday, August 24, 2019 13:47 +Subject: RE: Epstein +Hope you're doing well. We just learned about the hearing scheduled for next week in vour case. Would vou nlease let us +know if your office has informed counsel for Petitioners in our action +about +the opportunity to speak at this hearing and whether, more generally, you've been informing Florida victims? +Thanks, + + +United States Attorney's Office +Northern District of Georgia +Atlanta, GA 30303 diff --git a/vision-fixhub/ds9-parsed-01/1adb2d5877346692db2e8bcb2f282262278437b4bf8bf277d2b94f38e4c5e47b.receipt.json b/vision-fixhub/ds9-parsed-01/1adb2d5877346692db2e8bcb2f282262278437b4bf8bf277d2b94f38e4c5e47b.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..a9b7406dee7e5820ee1cc8458fec0e17f3919b98 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1adb2d5877346692db2e8bcb2f282262278437b4bf8bf277d2b94f38e4c5e47b.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "1adb2d5877346692db2e8bcb2f282262278437b4bf8bf277d2b94f38e4c5e47b", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": 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a/vision-fixhub/ds9-parsed-01/1ae1c7d3e3ea881b5aeeacae2ac3fbfd554b14bab23ca29e88b0e8d44afab5ea.md b/vision-fixhub/ds9-parsed-01/1ae1c7d3e3ea881b5aeeacae2ac3fbfd554b14bab23ca29e88b0e8d44afab5ea.md new file mode 100644 index 0000000000000000000000000000000000000000..86ce229fb02a07968a99aa7df74d919b55a239ad --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1ae1c7d3e3ea881b5aeeacae2ac3fbfd554b14bab23ca29e88b0e8d44afab5ea.md @@ -0,0 +1,1878 @@ +From: +To: +Subject: [EXTERNAL EMAIL] - FBI Public Affairs News Briefing Friday, November 20, 2020 +Importance: Normal +Priority: Normal +Sensitivity: None +Mobile version and searchable archives available at fbi.bulletinintelligence.com + + +TO: THE DIRECTOR AND SENIOR STAFF +DATE: FRIDAY, NOVEMBER 20, 2020 6:30 AM EST +TODAY'S TABLE OF CONTENTS +Leading the News +• US Charges Third Cincinnati Councilman With Corruption. +Protests +• NYTimes Analysis: Majority Of Cases Against Protesters Dismissed In Court. +• Federal Lawsuit Against Chicago Police Alleges "Brutal Attacks On Protesters." +• WPost Analysis: Rittenhouse, Rosenbaum's Encounter "Divided The Nation." +Counter-Terrorism +• Syrian IS Suspect Arrested By Greek Police After Migrant Camp Fight. +• Watchdog: EU Relying On Treasury Department Program To Track Terror Financing. +Counter-Intelligence +• Cybersecurity Community Worried About Political Pressure From White House On CISA. +• Voting Machine Company, State Officials Threatened, Harassed In Aftermath Of Election. +• Facebook: 180 Million Posts Debunked Ahead Of Election Day. +• Media: Delayed Transition Creating "Gap" Between Biden, Harris Classified Briefings. +• Six Finalists Announced For US Space Command Headquarters. +• Canadian Border Agent Says Huawei CFO Could Have Fled Country. +Criminal Investigations +• Men Accused In Whitmer Kidnapping Plot Allegedly Planned Executions. +• Louisville, Kentucky Sergeants Testify Explorer Records Could Have Been Accessed By Newspaper. +• US Charges 14 In Bust Of Wisconsin Drug Trafficking Ring. +• FBI Arrests Man Accused Of Colliding Drone With LAPD Helicopter. +• Three Former Philadelphia Revenue Employees Charged After FBI Sting. +• New York Man Charged With Sexual Exploitation Of A Minor. +• FBI Coordinating With Kentucky Police On Four-Year Old Murder Case. +• Ten Charged With Belonging To Cleveland Street Gang Implicated In Crimes. +• Serial Killer Blamed For Two Murders In Miami In 1970s. +• Kansas Man Indicted On Federal Fraud Charges. +• Trial Date For Suspects In 2017 Suisun City Murder Rescheduled. +• New York Man Arrested For Enticement Of A Minor Awaiting Further Legal Action. +• FBI: Reported Jet Pack Sightings In Los Angeles Unlikely To Involve Actual Jet Pack. +• Continuing Coverage: Man Accused Of Bank Robbery In Several States Arrested. +• Woman Wanted In Pittsburgh FBI Probe Taken Into Custody. +• Three Drug Conspirators Get Prison Time. + + +• Washington Man Charged Following FBI Child Exploitation Task Force Investigation. +• FBI, LAPD Investigation Results In 14 Arrests In Street Gang Case. +• Pain Clinic's Doctor, Manager Facing Drug Charges. +• Two Arrested After FBI Raid In Montana. +• FBI, Local Police Execute Drug Trafficking Search Warrants In Centralia, Illinois. +• New York Man Sentenced To 150 Months For Dealing Drugs. +• Two Arrested After Missing California Man's Body Found. +• Leader Of International Burglary Ring Pleads Guilty To Racketeering Charges. +• FBI Searching For "Berenstain Bandits" Crew After 14 Robberies Across Southern California. +• Pennsylvania Man Charged With Robbing Two New Jersey Banks. +• Boy Scouts Face More Than 95,000 Abuse Claims In Bankruptcy Case. +Financial Crime & Corporate Scandals +• Illinois House Speaker Madigan Responds To Bribery Charges Against Associates. +• Luxury Cars Seized In $16M Texas Coronavirus Fraud Case. +• Missouri Man Pleads Guilty In Landfill Fraud Probe. +• In Response To DOJ Suit, Realtors Group Agrees To Make Cost Of Broker Commissions More Transparent. +• Facebook Facing State And Federal Antitrust Charges Over Acquisitions. +• New York Fraud Investigations Said To Include Trump Tax Write-Offs. +Cyber Division +• Grand Jury Indicts California Man For Cyberstalking Airbnb Guest. +• GAO: Cyber Command's Vision For Developing Capabilities Lacks Clarity. +• Arizona Judicial Branch's Website Hit By Ransomware Attack. +Law Enforcement Services +• US Executes Man Convicted Of 1994 Kidnapping-Murder. +• Prince George's County, Maryland Will Use DNA Registries To Solve Cold Cases With New DOJ Grant. +International Relations +• Mexico Says Corruption Cases Involving Its Officials Will No Longer Be Tried In US. +Lawful Access +• Google To Test End-To-End Encryption In Android Messages. +Other FBI News +• Wray, Haspel May Be Next To Lose Jobs In Administration. +Other Washington News +• Trump Reaches Out To Michigan Legislators As State Prepares To Certify Biden Win. +• CDC Urges Americans Not To Travel Over Thanksgiving. +• Pence Hosts COVID News Briefing. +• Fauci Concerned Misinformation Will Hobble Vaccination Effort. +• Carson Says He Is Taking Oleander Extract As COVID Treatment. +• Trump Administration Facing Multiple Challenges Over Vaccine Distribution. +• Labs Warn Of COVID Test Delays. +• Newsom Announces Overnight Curfew In California. +• Ohio Legislature Passes Bill To Limit DeWine's Emergency Powers. +• New York City Parents Protest School Closures. +• Smithsonian Shuts Down All Facilities Indefinitely. +• Tyson Foods Suspends Iowa Plant Managers Over Alleged COVID Wagers. +• Older Americans Increasingly Challenged By Isolation Orders. +• Missed Census Deadline Could Impair Trump Effort To Block Migrants From Count. +• CBP Reports Record Arrests In October. +• Democrats Demand Release For Female Detainees In ICE Custody. +• Schumer Says McConnell Has Agreed To Resume COVID Relief Talks. +• Top Congressional Aides Meet To Discuss Averting Government Shutdown. +• Mnuchin Will Not Extend Emergency Lending Programs. +• EPA Administrator's Travel Plans Draw Scrutiny. +• Meadows Suggests Deal Over Military Policy Bill. +• Democrats, Republicans Seek Infrastructure Deal In Next Congress. + + +International News +• WHO: Situation In Europe Improving Due To Reimposition Of Lockdowns. +• WHO Says Evidence Lacking To Recommend Remdesivir For COVID Treatment. +• Japan's Suga Raises Alarm On Country's Third Wave. +• Jordan Becoming COVID Hot Spot After Early Success. +• WSJournal: WTO Proposal To Remove Vaccine Patent Protections Would Be Theft. +• Top Iranian Military Official: Any US Strike Could Spark "Full-Fledged War." +• McKenzie: Refugee Camps Are Breeding Ground For ISIS. +• WSJournal Analysis: Afghanistan Prepares For Insurgents After US Troop Removal. +• Report Finds Australian Soldiers Unlawfully Killed 39 Afghans. +• Pompeo Visits West Bank Settlement, Denounces BDS Movement. +• Johnson Announces Biggest Increase In UK Military Spending Since Cold War. +• French Journalists Say Government Is Cracking Down On Press Freedoms. +• Critics Say Maduro Is Targeting Disillusioned Allies. +• Leader Of Human Rights Group Arrested In Egypt. +• Arrests Of Two Presidential Candidates Spark Violent Demonstrations In Uganda. +• Official Says Ethiopian Airstrike Hit Tigray University. +• AP Analysis: Biden DOJ Unlikely To Ease Up On Chinese Targets. +• WPost: Biden Can Help Zelensky Reignite His Anti-Corruption Agenda. +The Big Picture +• Headlines From Today's Front Pages. +Washington's Schedule +• Today's Events In Washington. +Leading the News +US Charges Third Cincinnati Councilman With Corruption. +The AP (11/19, Sewell) reports from Cincinnati, "A +Cincinnati city councilman who has been planning to run for mayor has been indicted on federal corruption +charges." The AP adds, "An indictment Thursday shows that Democrat P.G. Sittenfeld faces six federal counts +related to bribery and extortion. It states that Sittenfeld solicited $40,000 in payments to his political action +committee to 'deliver the votes' in the city council for a proposed downtown real estate development." US +Attorney David DeVillers "discussed the case at a news conference late Thursday morning. He said FBI agents +had arrested Sittenfeld earlier. 'Mr. Sittenfeld was no longer working for the citizens of Cincinnati, but working +for Project 1,' DeVillers said, referencing the proposed real estate project. FBI agents disguised as developers +gave Sittenfeld the $40,000 bribe, which DeVillers said remained in the PAC fund." +The Cincinnati Enquirer (11/19, Knight, 223K) reports, "The Cincinnati office of the FBI has +had more impact on local politics in the last year than voters. On Thursday, a third member of the nine-person +Cincinnati City Council was arrested and indicted on federal bribery and corruption charges. Councilman P.G. +Sittenfeld, brother of novelist Curtis Sittenfeld, was arrested Thursday in a case involving fake developers and a +former Cincinnati Bengal who helped blow the whistle on the scandals. U.S. Attorney David De Villers, who is +leading the charge, has said there is a 'culture of corruption' in the city leaving political insiders asking who +might be next. Chris Hoffman, the FBI special agent-in-charge in Cincinnati, said his public corruption taskforce +remains in place. 'We're standing watch,' Hoffman said Thursday." +The Cleveland Plain Dealer < https://www.cleveland.com/open/2020/11/cincinnati-city-councilman-pg-sittenfeldarrested-on-federal-charges.html> (11/19, Tobias, 895K) reports, "Sittenfeld is the third Cincinnati council +member to be arrested on corruption charges this year. Earlier this month, federal officials arrested Republican + + +City Councilman Jeff Pastor, alleging he accepted tens of thousands of dollars of bribes from FBI agents posing +as local developers. The investigation had an overlap with a separate investigation into the Ohio Statehouse." +The Cincinnati Enquirer < https://www.cincinnati.com/story/news/politics/2020/11/19/p-g-sittenfeld-cincinnaticity-council-arrest-fbi/3775193001/> (11/19, Horn, 223K) reports, "FBI agents arrested Cincinnati City +Councilman P.G. Sittenfeld Thursday morning on federal charges accusing him of accepting bribes in exchange +for favorable votes on development deals, a source with knowledge of the arrest told The Enquirer." DeVillers +"said last week that the investigations have revealed "a culture of corruption' that's tolerated in city government. +He said the investigation that resulted in the charges against Pastor and Dennard is ongoing and is part of a +broader campaign to uproot public corruption in Cincinnati and other Ohio communities. "We are concerned +about this almost acceptance that this is how it's done,' DeVillers said last week. 'We're going to prosecute those +cases. Our goal is to make people nervous and stop them from doing this."* +WVXU-FM < https://www.wvxu.org/post/cranley-addresses-culture-corruption-after-third-council-memberarrest-less-year> Cincinnati (11/19, Sharber, 4K) reports, "On the steps of City Hall on Thursday, Cincinnati +Mayor John Cranley says it's not hard to argue that there's a 'culture of corruption' following the arrest of a third +City Council member. 'It's hard not to focus on the harms, the real harms that are done by these types of +scandals, Cranley said. "The people that are hurt are you, the taxpayer and the citizen.""' Sittenfeld "is charged +with two counts each of honest services wire fraud, bribery and attempted extortion by a government official. He +allegedly solicited bribes from a developer and accepted checks from undercover FBI agents from 2018 to 2019. +He's pleading not guilty to the charges. Fellow Council Member Jeff Pastor allegedly took $55,000 in bribes +over the course of about a year in exchange for 'official action' related to projects in the city. A federal grand jury +last week charged him with honest services wire fraud, bribery, attempted extortion by a government official and +money laundering. In February, former Council Member Tamaya Dennard was also arrested and charged with +wire fraud, bribery and attempted extortion. Between August and December of 2019, she offered to exchange her +votes for money. She plead guilty to one count of honest services wire fraud." Among news outlets also reporting +are the Cincinnati Business Courier (11/19, Subscription Publication, 840K), Cincinnati CityBeat + Dayton, OH (11/19, Rosi, 15K), WXIX-TV + Cincinnati (11/19, Riva, Baker, 42K), WVXU-FM Cincinnati (11/19, Almendarez, Rinehart, 4K), and WKRC-TV + (11/19,Al, +MacFarquhar, 18.61M) reports that "more than five months" after protests over the deaths of George Floyd and +Breonna Taylor, "a vast majority of cases against protesters are being dismissed" in the courtroom and "only +cases involving more substantial charges like property destruction or other violence remain." Prosecutors "called +the scale of both the mass arrests and mass dismissals... unrivaled, at least since the civil rights protests of the +early 1960s," testing "the limitations of the court system." Many cases have been dropped as prosecutors +"concluded that the protesters were exercising their basic civil rights," cases which "rarely succeed in court." +Federal Lawsuit Against Chicago Police Alleges "Brutal Attacks On Protesters." + + +USA Today (11/19, Hauck, 10.31M) reports that Chicago "police +officers used "brutal, violent and unconstitutional tactics' to quell protests over the killings of Black Americans +last summer, with victims claiming they were beaten with batons and sprayed with chemicals, a federal lawsuit +filed Thursday alleges." Civil rights attorneys "filed the 203-page suit on behalf of 60" plaintiffs, claiming +"violations of protesters' First, Fourth and fourteenth Amendment rights and more." The 17-count suit "names +Chicago Police Superintendent David Brown, along with 20 officers." Chicago's law department spokesperson +Kathleen Fieweger said, "It is important to remember that these are allegations at this stage and not proof." +WPost Analysis: Rittenhouse, Rosenbaum's Encounter "Divided The Nation." +The Washington Post (11/19, Lee, O'Harrow, Samuels, 14.2M) reports that an "examination of +video and police records, along with other documents, sheds new light on the mindsets" of 17-year-old Kyle +Rittenhouse and 36-year-old Joseph Rosenbaum during protests in Kenosha, Wisconsin following the police +shooting of Jacob Blake. The Post says Rittenhouse, "a gun enthusiast," thought "of himself as a medic." In his +first public comments "since his arrest," Rittenhouse "said he did not regret that he had a gun that night," despite +being too young to own a rifle. Rittenhouse said, "I feel I had to protect myself. I would have died that night if I +didn't." +Rittenhouse Says He Used Stimulus Money To Buy Gun. The Hill (11/19, Coleman, +2.98M) reports, "Accused Kenosha, Wis., shooter Kyle Rittenhouse told The Washington Post that he used +stimulus money from the government to buy his gun in an interview published Thursday." Rittenhouse, "who at +17 was too young to buy a rifle, had an adult friend purchase the AR-15 for him using stimulus money he got +through an Illinois unemployment program when he was furloughed due to the pandemic. 'I got my twelve +hundred dollars from the coronavirus Illinois unemployment 'cause I was on furlough from YMCA,' he said. +'And I got my first unemployment check, so I was like, "Oh, I'll use this to buy it." A family friend Dominick +Black bought the gun for Rittenhouse in the spring of 2020, the Post reported, citing Rittenhouse and statements +Black gave police." +Counter-Terrorism +Syrian IS Suspect Arrested By Greek Police After Migrant Camp Fight. +Reuters (11/19) reports that Greek police arrested an IS suspect "on Thursday +after a brawl at a migrant camp where he has been staying with his wife and children and said he was believed to +have been involved in a number of killings." The Syrian man, "who arrived in Greece in March 2018, was +detained after an argument on Wednesday between two groups at the camp, a police official said." He is +"accused of being a member of a terrorist group and participating in homicides." The man is "expected to appear +before a prosecutor later in the day, according to a police statement." Greece "promised on Wednesday to build +new reception centres for asylum seekers and cut the maximum stay in camps on its now-overcrowded islands." +Watchdog: EU Relying On Treasury Department Program To Track Terror Financing. + + +The Wall Street Journal (11/19, Tau, Subscription Publication, 7.57M) reports that the Treasury Department's +Terrorist Finance Tracking Program (IF IP) has become widely used by European countries to monitor global +financial transactions in an effort to track terror financing. According to the US Privacy and Civil Liberties +Oversight Board, about 40% of the database searches on TFTP were done on behalf of EU member countries or +Europol. The independent watchdog's chairman, Adam Klein, said, "though funded and operated by the United +States, provides a steady stream of valuable intelligence to EU member states. .. That should be welcome news +to every American." Klein added, "The EU has effectively deputized the U.S. Treasury to perform +counterterrorism searches of European data." +Counter-Intelligence +Cybersecurity Community Worried About Political Pressure From White House On CISA. +The Washington Post (11/19, Marks, 14.2M) reports, "Current and former +cybersecurity officials fear it will be far more difficult to withstand political pressure from the Trump White +House following a purge of its senior leadership." After the firing of former CISA Director Chris Krebs "and +other top leaders...it could be far easier for the White House to force the agency to stop fact-checking phony +claims about the election or to combat disinformation about other key issues such as coronavirus vaccine +distribution." Former DHS cybersecurity operations head Suzanne Spaulding said, "It's going to be a challenge +to overcome the chilling effect from having had a leader of the organization fired for telling the truth." It is +rumored "Brandon Wales, a longtime Department of Homeland Security official with extensive experience who +is well respected at CISA," will take Krebs" place. Spaulding said, "If Brandon Wales is allowed to stay in place +as acting director, I think CISA is in good hands." +Sources: Energy Official Eyeing CISA Job After Former Director's Ouster. CyberScoop + (11/19, Lyngaas) reports, +"Sean Plankey, currently a senior official at the Department of Energy, has in recent days contacted current and +former officials at DHS to discuss working" at CISA following the removal of the former director, according to +unnamed sources. The Energy official "indicated in one conversation that his move to CISA was "imminent,' one +source said." His security clearance, +"however, hangs in the balance," and its status "came up in the last year, +prompting a review of his status as a clearance holder." It is "unclear if those issues have been resolved, and if +Plankey still holds a clearance." Without a clearance, Plankey could not receive "the classified information that +CISA officials draw on to help protect government agencies and the private sector from hacking." +Opinion: Krebs Lost Job For "Standing His Ground." Opinion columnist David Ignatius writes in the +Washington Post (11/19, 14.2M) that former CISA +Director Chris Krebs "got fired for standing his ground," and his "story is a case study in how responsible +officials who work for Trump can resist being manipulated." As CISA director, 'his job was to coordinate +security for the 2020 elections," and while the "main threat seemed to be from abroad," it "turned out that the +real danger was at home." Krebs told Ignatius in August, "Election Day may look different than you've seen in +the past, and with more Americans voting absentee, it will take longer to tabulate and report complete results." In +addition to offering fact-checking on the CISA's website, Krebs' agency showed with evidence "the 2020 +election 'was the most secure in American history."" +Voting Machine Company, State Officials Threatened, Harassed In Aftermath Of Election. + + +ABC News (11/19, Rubin, Bruggeman, Mosk, 2.97M) reports that Dominion Voting Machines +"employees have been the subject of threats and online harassment" following "two weeks of false fraud claims +from President Donald Trump." Trump "has tweeted or retweeted more than a dozen false claims about +Dominion Voting Systems used across the country to his 89 million followers, calling the company 'horrible, +inaccurate and anything but secure,' despite no credible evidence to suggest its platforms were compromised in +any way."* The President has "resorted to promulgating progressively more outlandish claims online as part of +an effort to delegitimize the outcome of the election." +The Hill (11/19, Bowden, 2.98M) reports, "Election agencies or law enforcement organizations in five states, +Arizona, Georgia, Michigan, Nevada and Pennsylvania, have witnessed threats or 'acute security risks' to +officials" connected to the election. In Pennsylvania, the FBI "arrested two Virginia men on firearms charges +after receiving threats to 'straighten things out,' the Philadelphia Inquirer first reported." Other states have also +"been the site of protests against election officials in recent days following the results of the presidential +election." Election Assistance Commission Benjamin Hovland said, "I've heard from election officials that +they're concerned about the safety of their staff." Election Reform Program Director Lawrence Norden said, +"There's no question in my mind that this is unprecedented in the personal attacks on election officials." +Facebook: 180 Million Posts Debunked Ahead Of Election Day. +The Washington Post (11/19, Lerman, Kelly, 14.2M) reports, "Facebook on Thursday said it slapped warnings on more than +180 million pieces of content that were debunked by fact-checkers during the lead-up to the 2020 presidential +election." The social media giant "also removed more than 265,000 pieces of content" in the US "for voter +interference" between March 1 and November 3. It "did not reveal how effective its labels are, except to say that +when a label obscures a post, 95 percent of people do not click to see what is behind the warning screen." +Facebook's AI system "are getting significantly better at rooting out posts with hate speech, even as the content +continues to proliferate on its social media sites," according to the company. Its technology "now identifies 95 +percent of hate speech posts that the company eventually removes before a user reports them. Nearly three years +ago, the AI proactively found about 24 percent of the violating posts." +Media: Delayed Transition Creating "Gap" Between Biden, Harris Classified Briefings. +Politico (11/19, +Bertrand, 4.29M) reports, "President Donald Trump's refusal to concede to President-elect Joe Biden has +resulted in an unusual national security predicament." As Sen. Kamala Harris (D-CA) cannot discuss the +classified information she "is privy to" with former Vice President Biden, there is an "awkward gap between +what Biden and Harris know about the biggest national security threats facing the country." Harris, as "a member +of the Senate Intelligence Committee," has "access to regular classified briefings and documents up to the topsecret level, and can request intelligence briefings on specific topics," according to former CIA officer David +Priess. Biden "will not be allowed access to classified information or any members of the intelligence +community until the General Services Administration officially 'ascertains' him as the president-elect." +According to an unnamed transition official, "Harris's work on the Intelligence Committee 'is entirely separate +from her role as the Vice President-Elect. There is no co-mingling of those roles and responsibilities +whatsoever." +CNN (11/19, +Cohen, Wright, Herb, 83.16M) reports, "there's a world of difference between what Biden can learn from outside + + +experts and the depth of knowledge he would gain from even a limited classified briefing - which he has not +received since becoming President-elect," according to experts and advisers. DNI "could give a higher-level +briefing to the President-elect" if ascertainment had occurred, and during that briefing, "DNI could go into +greater detail about specific threats and underlying intelligence to support the analysis." Additionally, "Biden is +not currently receiving the President's Daily Brief." Former Associate White House Counsel Jamil N. Jaffer "told +CNN that Trump and [DNI] Ratcliffe could still limit Biden's access to certain classified material if they choose +to do so." Jaffer said "the President can decide to provide what ever he wants, and it is certainly likely that DNI +Ratcliffe, notwithstanding any prior commitments made, will abide by the President's wishes." +The Hill (11/19, Deese, 2.98M) reports, "Former Democratic presidential candidate Pete +Buttigieg called on the federal government to grant President-elect Joe Biden access to intelligence briefings." +Buttigieg said on MSNBC, "This just seems to be an exercise in trying to somehow protect the outgoing +president's ego and that's not worth undermining national security." Buttigieg "said it was a 'huge concern' that +Biden was not receiving classified intelligence briefings roughly two months out from Inauguration Day, noting +there are likely some intelligence briefings Biden 'needs some advanced planning on' before entering office." +Six Finalists Announced For US Space Command Headquarters. +Stars And Stripes (11/19, Dickstein, 30K) reports, "The Pentagon has narrowed its choices on +the permanent headquarters location for U.S. Space Command to six finalists, Air Force officials announced +Thursday." The six finalists are "Kirtland Air Force Base in New Mexico, Offutt Air Force Base in Nebraska, +Patrick Air Force Base in Florida, Peterson Air Force Base in Colorado, Port San Antonio in Texas, and Redstone +Arsenal in Alabama, according to the Air Force." The Pentagon is expected to make a final decision "in early +2021, said Ann Stefanek, a spokeswoman for the service charged with making the final basing decision for +SPACECOM." Stefanek said, "This assessment will be based on factors related to mission, infrastructure +capacity, community support, and costs to the Department of Defense." It could take the Air Force "some six +years to build the facilities necessary to house U.S. Space Command, once a location is chosen." +Fox News (11/19, Rogers, +27.59M) reports, "Self-nominated communities from across twenty-four states were evaluated as potential +locations for hosting the headquarters," said an Air Force statement. Until the announcement is made, "Peterson +Air Force Base in Colorado Springs will remain the Command's provisional headquarters." The Air Force has +"said that it wants the headquarters location to rate 50 or higher on the AARP livability index and be in the top +150 metro areas." Space Force "made its first launch earlier this year when it sent a military satellite into space +from Cape Canaveral Air Force Station in Florida." +The Albuquerque (NM) Journal (11/19, Robinson-Avila, 196K) reports that with Orion Group "planning to establish a major +manufacturing center near the Albuquerque International Sunport, the possibility of also landing the Space +Command headquarters could solidify the city and state's emerging national standing as a space industry +powerhouse, said Albuquerque Mayor Tim Keller." +The Omaha (NE) World-Herald (11/19, Liewer, 641K) reports, "Offutt +already is in the midst of the largest makeover in its history," with a new StratCom headquarters having opened, +recovery and reconstruction work that has to take place on part of the base, and, additionally, "next spring the Air +Force is beginning a 2-year, $176 million reconstruction of Offutt's single runway." +The AP (11/19, Farrington) reports from Florida that "Patrick Air Force Base in Brevard + + +County" is one of the finalists, and the "presence of NASA, private space companies like SpaceX and Blue +Origin, universities that focus on engineering, the military presence in central Florida and the Cape Canaveral +launch pads will make Florida competitive," according to Rep. Michael Waltz (R-FL). +The Colorado Springs (CO) Gazette (11/19, Roeder, 223K) +reports, "The biggest categories are military needs, which includes the command's proximity to space units, +having a solid civilian space work force, and quality of life for troops" - and Colorado Springs Chamber & EDC +defense program chief Reggie Ash "said Colorado Springs has all those boxes checked." The Denver Post + +(11/19, Tabachnik, 720K) also provides coverage about Colorado Springs' selection as one of the six finalists. +The San Antonio Express-News (11/19, Christenson, Jefferson, 762K) reports, "San Antonio had floated +several possible sites" - including "Port San Antonio, Joint Base San Antonio-Lackland, and the former Brooks +AFB, now a commercial development" - but "the Air Force narrowed them down to Port San Antonio, the +former Kelly AFB." +The Huntsville (AL) Times < https://www.al.com/news/huntsville/2020/11/huntsville-is-a-finalist-again-for-usspace-command-headquarters.html> (11/19, Roop, Gattis, 861K) reports that Huntsville's Redstone Arsenal "is +the only site on the new list that is not an Air Force base," though local officials have touted how the site +"handled earlier growth through Army base closing and realignment efforts (BRAC)." +Canadian Border Agent Says Huawei CFO Could Have Fled Country. +Reuters (11/19, Berman) reports that Canada Border +Services Agency Superintendent Sowmith Katragadda "told a court on Thursday" that Huawei CFO Meng +Wanzhou "was a flight risk and had the resources to escape the country without reporting to authorities." +Katragadda said Meng "has the resources to depart Canada and not report for an examination," adding she "is a +senior executive for one of the biggest companies in the world. And Canada is a very big country with a lot of +small airports." Prime Minister Justin Trudeau on Thursday "said he had no regrets about Meng's arrest +regardless of foreign policy implications, pointing to the 'longstanding extradition treaty with our closest ally? +and adding that Canada's laws can't only be followed 'when it's convenient or when it's easy."* +Criminal Investigations +Men Accused In Whitmer Kidnapping Plot Allegedly Planned Executions. +WLS-TV Chicago (11/19, 391K) reports that according to new filings, the 14 men charged in "the +alleged militia plot against" Michigan Gov. Gretchen Whitmer (D) drew up a Plan B "that involved a takeover of +the Michigan capitol building by 200 combatants who would state a week-long series of televised executions of +public officials." The documents also show a Plan C that involved "burning down the state house, leaving no +survivors." WLS-TV says that "in southern Wisconsin Wednesday afternoon the 14th man charged in the plot, +Brian Higgins, was closer to extradition to Michigan," though "several of the defendants have had bond +reductions and are now free." +McClatchy (11/19, Stunson, + + +19K) reports, "A militia group with plans to kidnap Michigan Gov. Gretchen Whitmer also considered executing +hostages on television before their plot was foiled, according to new court documents. The new information was +revealed by the Michigan Attorney General's Office, which was arguing against a bond reduction of one of the +militia men, Pete Musico. Fourteen men have been charged in the case, which the attorney general's office is +prosecuting, according to the Detroit Free Press." McClatchy adds, "Some of the accused extremists, known as +the Wolverine Watchmen, had two plans during a 2nd Amendment rally they attended at Michigan's Capitol +building in June, documents uploaded by WWMT revealed. The first plan involved them recruiting 200 men and +storming the Capitol building while Congress was in session. 'They were to take hostages, execute tyrants and +have it televised,' court documents show. 'It would take about one week and (said) that no one is coming out +alive. +599 +The Detroit Free Press < https://www.freep.com/story/news/local/michigan/2020/11/19/brian-higgins-deniedbail-whitmer-kidnap-case/3777410001/> (11/19, Guillen, Moran, 1.52M) reports, "A Wisconsin man accused of +helping with the alleged surveillance of Gov. Gretchen Whitmer's vacation home was denied bail on Thursday +while his lawyer prepares to fight his extradition to Michigan." Brian Higgins, 52, "will remain in custody in +Columbia County, Wisc., until an extradition hearing scheduled for Dec. 15. The hearing will focus on +extradition paperwork Whitmer signed. Higgins' lawyer, Christopher Van Wagner, said Wednesday that Whitmer +should not have signed the document because she has a conflict of interest as the potential victim in the alleged +kidnap plot." The Free Press adds, "A Columbia County prosecutor argued Thursday that Higgins should not be +released before the extradition hearing because Wisconsin Gov. Tony Evers - after receiving Whitmer's +paperwork - has now signed a warrant for his delivery to Michigan, changing his status in the eyes of the law." +The Portage (WI) Daily Register (11/19, 28K) reports, "Judge Todd Hepler ultimately decided that Higgins will be held +without bail until further proceedings. Van Wagner has indicated that he will pursue habeas corpus proceedings, +or a request that the court determine whether someone's detention is unlawful. Van Wagner has until Dec. 2 to +file motions and documents. The state has until Dec. 11 to respond. Van Wagner has until Dec. 14 to respond to +the state. A motion hearing is then scheduled for Dec. 15." Also reporting on their websites are WKOW-TV + Madison, WI (11/19, Cestkowski, 5K), WMTV-TV + Madison, WI (11/19, Tornabene, 56K), and WDIV-TV + Detroit (11/19, Hermes, 460K). +Louisville, Kentucky Sergeants Testify Explorer Records Could Have Been Accessed By Newspaper. +The Louisville (KY) Courier-Journal < https://www.courier-journal.com/story/news/crime/2020/11/19/piu-offpiuofficers-dispute-claims-of-Impd-county-attorneyicers-dispute-claims-Impd-county-attorney/6348494002/> +(11/19, Wolfson, 368K) reports, "A retired Louisville Metro Police sergeant and another still on the force +testified Thursday the investigative file on the scandal-plagued Explorer Scout program was available when The +Courier Journal requested it last year - despite LMPD and the Jefferson County attorney's office saying it had +been moved to the FBI. 'It was all there,' Sgt. Kristen Downs of the Public Integrity Unit testified in a +deposition." Downs "swore under oath she delivered copies of the file in 2017 to then-Chief Steve Conrad and to +the office of County Attorney Mike O'Connell. She and retired Sgt. Robert Banta testified as well they believe +the records still exist on the city's back-up computer server." +US Charges 14 In Bust Of Wisconsin Drug Trafficking Ring. + + +The Milwaukee Journal Sentinel (11/19, Hughes, 632K) reports, "Federal prosecutors +Thursday 14 people in connection with a Racine drug trafficking organization that distributed heroin, fentanyl +and crack cocaine." According to the Journal Sentinel, "Ten of the 14 individuals were arrested by law +enforcement Wednesday and face between five and 40 years in prison if convicted, according to a statement +released Thursday from the U.S. Attorney's Office in the Eastern District of Wisconsin. Officers seized seven +guns, 200 grams of heroin, 100 grams of crack cocaine, more than 50 grams of fentanyl and various quantities of +suboxone strips, oxycodone pills and PCP, and $8,000 in cash in the Wednesday operation, the statement said. +The organization also had Chicago connections." +The Racine (WI) Journal Times (11/19, 114K) reports, "FBI Special Agent in Charge Robert Hughes said, 'Shared +resources and intelligence among law enforcement partners led to the successful takedown of an organized drug +trafficking operation, and the arrests of multiple subjects. The FBI's Southeastern Wisconsin Regional Gang Task +Force in Racine will continue to work with our partners to keep our communities free of drugs and violence.*" +WITI-TV +Milwaukee (11/19, Jewell, 159K) reports, "Officials noted just two milligrams of fentanyl is a lethal dose - and +used a picture of a penny to illustrate just how little two milligrams is. 'Such small amounts of fentanyl can be +mixed with substances and then sold on the street as heroin. But it's incredibly lethal,' said Matt Krueger, U.S. +Attorney for the Eastern District of Wisconsin. 'Users don't know what's in a mix and it's taking lives. '" WISN- +TV < https://www.wisn.com/article/14-charged-in-drug-trafficking-operation/34729559> Milwaukee (11/19, +265K) also reports. +FBI Arrests Man Accused Of Colliding Drone With LAPD Helicopter. +The Los Angeles Times (11/19, Winton, 4.64M) reports Andrew Rene Hernandez, 22, accused +of "recklessly operating a drone and crashing it into a Los Angeles Police Department helicopter earlier this +year" was arrested by the FBI on Thursday. Hernandez was "charged with unsafe operation of an unmanned +aircraft after an investigation by the FBI, the LAPD and the Federal Aviation Administration." The incident took +place on September 18 after Los Angeles police officers "responding to a predawn burglary call at a Hollywood +pharmacy requested air support." +The AP (11/19) reports, "FBI special agents arrested...Hernandez...on a complaint charging +him with one count of unsafe operation of an unmanned aircraft, a statement said. The complaint states that +police officers responding to a burglary call at a Hollywood pharmacy on Sept. 18 requested air support. The +police helicopter was approaching the pharmacy when the pilot saw the drone and unsuccessfully attempted to +evade it. The helicopter's nose, antenna and bottom cowlings were damaged. The complaint states that if the +drone had struck the main rotor it could have brought down the helicopter." Officers "found parts of the drone on +the ground and a vehicle that had been damaged as it fell from the sky," and "the drone's camera and memory +card led to identification of Hernandez as the operator, the U.S. attorney's office said." +The Los Angeles Daily News (11/19, Escobar, 232K) reports, "Hernandez admitted to flying the +drone - controlled by a device attached to his smartphone - to "see what was going on,' according to the +department. There is no indication that Hernandez, who lives nearby, was involved in the pharmacy burglary, +according to Thom Mrozek, a spokesman for the U.S. Attorney's Office. Authorities are concerned about illegal +drone activity, he said." KTLA-TV Los Angeles (11/19, Wenzke, 766K) also reports on its website. + + +Three Former Philadelphia Revenue Employees Charged After FBI Sting. +The Inquirer (PA) (11/19, Steele, 347K) reports, "Three former employees of Philadelphia's Department of +Revenue were charged Thursday by federal prosecutors with soliciting and accepting bribes." The employees +"were caught in an FBI sting operation, according to charges outlined by federal prosecutors." They all +"accepted bribes in exchange for erasing fees owed by taxpayers, U.S. Attorney William MeSwain and +Philadelphia Inspector General Alexander DeSantis said in their announcement." FBI Philadelphia Division +Special Agent in Charge Michael J. Driscoll said, "When municipal employees decide to take bribes, they're +openly putting their own interests above those of the city they serve... The defendants' alleged actions benefited +themselves and those who paid them off, at the expense of Philadelphia's revenues and its residents." Also +reporting is WHYY-TV Philadelphia (11/19, Scott, 24K). +New York Man Charged With Sexual Exploitation Of A Minor. +The Middletown (NY) Times Herald-Record + (11/19, Randall, 147K) reports that a New York man "has been charged with sexual +exploitation of an 8-year-old girl and transporting child pornography," and the FBI "believes there are more +victims." FBI Agent Pao Mei Fisher said the tutor *mailed, transported and shipped' the child pornography +maintained on his iPhone from his home in Westchester County to Fairfield County in Connecticut, according to +the sworn statement." The man "has worked at several locations over the years," and has "done private tutoring +for more than 30 years in the Bronx, Westchester County and in Connecticut, according to the FBI." +FBI Coordinating With Kentucky Police On Four-Year Old Murder Case. +WHAS-TV Louisville, KY (11/19, McAlister, Weiter, +99K) reports on the ongoing investigation into a Kentucky man who was killed in 2016. Since that time, +Kentucky State Police "lead the investigation into Tommy Ballard's death with recent help from the FBI." State +Police "receives new tips on the case every week, but so far no lead has lead to Ballard's killer." Law +enforcement originally "called it a hunting accident." However, "Kentucky State Police said they were +investigating Tommy Ballard's death as a murder, but in the three and a half years since he was shot and killed, +police have shared no updates." An FBI task force "added Tommy Ballard's case to its website as well as" a few +others. +Ten Charged With Belonging To Cleveland Street Gang Implicated In Crimes. +The Cleveland Plain Dealer (11/19, Shaffer, +895K) reports that in Ohio, ten "are charged with belonging to a street gang that dealt drugs in the city's +southeast side, authorities announced Thursday." They are "members of the Percy Homies gang face charges +including drug trafficking, criminal gang activity and weapons violations, according to a joint news release from +Cleveland police, the Cleveland FBI and Cuyahoga County Prosecutor Michael O'Malley's Office." Prosecutors + + +on Thursday "filed a motion to unseal the secret indictment that a grand jury handed up on Tuesday in Cuyahoga +County Common Pleas Court." Local police, SWAT, and FBI task force members "arrested six of the men and +executed search warrants in which officers seized seven guns, drugs and an unspecified amount of cash." +Serial Killer Blamed For Two Murders In Miami In 1970s. +The AP (11/19, Lush) reports that serial killer Samuel Little has been blamed for two murders in +Miami in the 1970s. Little, who has "been behind bars since 2012," will not "be charged in the two Miami +murders." Little "told investigators he was responsible for about 90 killings nationwide between 1970 and 2005," +and the FBI "said its crime analysts believe all of his confessions are credible." The FBI has also provided +numerous drawings of his victims. +Kansas Man Indicted On Federal Fraud Charges. +The Hays (KS) Post (11/19) reports, "A +Kansas man who ran an autopsies-for-hire business was indicted Wednesday on federal fraud charges, according +to U.S. Attorney Stephen McAllister." Authorities seek "to recover more than $1 million in fees paid by the +defendant's clients." The man is accused of falsely leading clients "to believe they would receive an autopsy +report prepared by a pathologist." However, "in most of the cases, no pathologist was involved in the work on +the autopsies." He "offered private autopsy services through his business, National Autopsy Services, based in +Topeka." The FBI is looking for victims of the scheme. +Trial Date For Suspects In 2017 Suisun City Murder Rescheduled. +The East Bay (CA) Times (11/19, Bammer, 63K) reports, "The setting of a jury trial date has been +rescheduled again for two people connected to" a 2017 murder in Suisun City. The two suspects "were scheduled +to appear Monday in Department 15 for a readiness conference and to hear the trial date, but Judge Robert +Bowers reset the proceedings for 9 a.m. Jan. 20 in the Justice Building in Vallejo." The reschedulings come after +a defense attorney "asked Judge John B. Ellis during a late-January proceeding in the Hall of Justice in Fairfield +to consider a motion to dismiss all - or parts of - a June 2019 Solano County grand jury indictment of her +client." The two "face first-degree murder charges in connection to the death" of the daughter-in-law of one. +New York Man Arrested For Enticement Of A Minor Awaiting Further Legal Action. +The Greater Binghamton (NY) Press & Sun-Bulletin (11/19, +Borrelli, 85K) reports that a New York man "was arrested and charged Oct. 30 with felony counts of enticement +of a minor and traveling to engage in illicit sexual contact, which could mean at least 10 years in federal prison if +he's convicted." The US Attorney's Office investigation "leading to the federal charges involved a search of the +victim's cell phone and contact from Lettieri's Facebook account and phone number." The man "made an initial +appearance in federal court and on Nov. 13, he was detained to await further legal action." FBI is "still +investigating allegations involving" the man. + + +FBI: Reported Jet Pack Sightings In Los Angeles Unlikely To Involve Actual Jet Pack. +KCAL-TV Los Angeles (11/19) +reports from Los Angeles, "A series of reported jet pack sightings near LAX are unlikely to involve an actual +person with a jet pack, federal investigators said Thursday." KCAL-TV adds, Speaking to reporters Thursday, +Kristi Johnson, FBI assistant director in charge of the Los Angeles Field Office, said they've gotten reports about +multiple sightings in recent weeks." Johnson "said there are currently multiple theories as to what the objects +could be, but no conclusions yet. One theory is that it's a balloon possibly resembling 'a jet pack or person', or it +could be a 'a drone designed to look like a jet pack or person'. Lastly and most unlikely, Johnson said, it could +be an 'actual person with a jet pack.' The FAA and FBI are investigating to protect the airspace, Johnson added." +Continuing Coverage: Man Accused Of Bank Robbery In Several States Arrested. +The Pine Barrens (NJ) Tribune (11/19, Melegari) reports that a man "who is alleged to have +committed at least six bank robberies in New Jersey...is suspected in over a dozen others robberies in +Connecticut and Pennsylvania." He is also "believed to have been involved in a previous bank robbery in +Glenview, Illinois, is alleged to have robbed a Citizens Bank last week." On November 12, "the FBI Newark +Field Office advised area media that it added" the man to its website "for his alleged involvement in a series of +bank robberies." The agency also "created a fugitive wanted poster calling for his apprehension." +Woman Wanted In Pittsburgh FBI Probe Taken Into Custody. +KDKA-TV +Pittsburgh (11/19, 144K) reports, "FBI Pittsburgh says a woman wanted in connection with an 'ongoing +investigation' is in custody." KDKA-TV adds, "Earlier on Thursday, they asked anyone who knows where +Kristin Steffan is to call police or FBI Pittsburgh at 412-432-4000. FBI Pittsburgh did not release any +information about the investigation and said no other details are available at this time. Later in the day, they said +Steffan had been taken into custody." +Three Drug Conspirators Get Prison Time. +The McAllen (TX) Monitor +(11/19, Zazueta-Castro, 98K) reports a federal judge has "handed down punishments in a case involving a group +of men who allegedly conspired to transport drugs to the Midwest." Carlos Gonzalez and Reynaldo Lerma both +were sentenced to 70 months in prison, while Erasmo Gonzalez Jr. received a 30-month sentence. Each of those +defendants pleaded guilty to a drug conspiracy charge after they were arrested by FBI agents in Texas. Two +others who were arrested at that time, Fernando Lerma and Derrick Raul Lerma, have yet to be sentenced after +they "each pleaded guilty to a conspiracy charge." +Washington Man Charged Following FBI Child Exploitation Task Force Investigation. +The Spokane (WA) Spokesman-Review (11/19, Epperly, 183K) reports that a Washington man "was sentenced to 10 +years in prison after he pleaded guilty to two counts of first-degree promoting prostitution." He was "sentenced + + +to 120 months on Nov. 10 after an investigation" by the FBI's Child Exploitation Task Force "found evidence he +participated in human trafficking." In January, the man "transported a teen to an undercover human trafficking +operation conducted by the task force, according to court documents." In August 2018, he "was charged with one +count of second-degree promoting prostitution," and also "has a lengthy criminal history, including multiple +convictions for theft, assault, and violating no-contact and protection orders." Also reporting are KREM-TV + Spokane, WA (11/19, Riordan, 88K), and KXLY-TV + Spokane, WA +(11/19, 7K). +FBI, LAPD Investigation Results In 14 Arrests In Street Gang Case. +The Los Angeles Watts Times (11/19) reports, "An investigation led by the FBI and the Los Angeles Police +Department" has "resulted in the arrest of 14 defendants linked to a street gang on federal charges alleging the +distribution of narcotics, some of which were sold to customers out of two South Los Angeles storefronts." +Operation Hoover Dam "resulted in three indictments being returned over the past few weeks by a federal grand +jury in Los Angeles." They "allege that the defendants - all reputed members or associates of the gang, or +alleged drug dealers who operated in gang territory - sold methamphetamine, crack cocaine, cocaine and +phencyclidine." Ten defendants have been charged, "including two purported senior gang members who operated +stores where narcoties allegedly were peddled." +Pain Clinic's Doctor, Manager Facing Drug Charges. +In website coverage, WNBC-TV New York (11/19, Valiquette, 344K) New York +reports a doctor who ran a pain management clinic in New York City and the clinic's manager have been arrested +"on federal narcotics charges." Agents with the FBI arrested Dr. Howard Adelglass and Marcello Sansone. +The New York Daily News (11/19, Brown, 2.52M) quotes "FBI Assistant +Director William Sweeney Jr.," who stated, "The alleged behavior of" Adelglass, "a licensed physician, who held +a position of trust in our society, causes lasting harm to our communities." +Two Arrested After FBI Raid In Montana. +The Missoulian (MT) (11/19, Larson, 140K) reports that two +Montana men "are facing federal drug and firearms charges after they were arrested in a federal raid Wednesday +night in East Missoula. " The men "were booked into the Missoula County Detention Center late Wednesday +night after a standoff with law enforcement on the 500 block of Montana Avenue." One is "charged with +distribution of methamphetamine, as well as conspiracy to distribute methamphetamine," while the other is +"charged with conspiracy to distribute 500 grams or more of methamphetamine, possession of 500 grams or +more of methamphetamine and possession of a firearm in furthering a drug trafficking crime." Locals heard "the +FBI announce themselves over the loudspeaker Wednesday night," and one man "said he heard law enforcement +set off some sort of explosive device, like a flash or smoke grenade, several times in apprehending the people +inside." Also reporting is KGVO-FM Missoula, MT (11/19, Christian). +An online KFBB-TV Great +Falls, MT (11/19, Depping) report says Montana residents "Leon Paul Kavis, Jr., 36, and Dylan Roy Mace, 28," +are facing drug charges after they allegedly distributed large amounts of methamphetamine "in the Missoula +area." The charges are the result of an investigation that "was conducted by the FBI Montana Regional Violent +Crime Task Force, with the assistance of the...Missoula High Intensity Drug Trafficking Area (HIDTA) Task +Force" and the DEA. +This story is also covered by the KECI-TV Missoula, MT (11/19, 54K) and KPAX-TV + Missoula, MT (11/19, IK) websites. +FBI, Local Police Execute Drug Trafficking Search Warrants In Centralia, Illinois. +WJBD-AM Salem, IL (11/19, Kropp) reports that Centralia, Illinois Police Chief Greg Dodson "says the +police department in conjunction with the FBI Drug Task Force executed two coordinated simultaneous search +warrants Thursday morning. Dodson says the warrants are in relation to an on-going drug-trafficking +investigation inside the city of Centralia." According to WJBD-AM, "The Centralia Police Department's highrisk tactical team executed the search warrant at a residence located in the 600 block of Howard Street. At the +same time, the Springfield FBI SWAT team executed a search warrant in the 1000 block of North Maple Street. +During the search of the residences, a large quantity of drugs and cash were located as well as several firearms. A +52-year-old Centralia man was taken into custody and will be arraigned on charges stemming from the warrant +by the US Attorney for the Southern District of Illinois in East St. Louis on Friday or Monday." +New York Man Sentenced To 150 Months For Dealing Drugs. +The Batavia (NY) Daily News (11/20, DeSmit, 38K) reports +from Buffalo, New York, "He boasted of having a Mercedes and gold around his wrist and neck and money, cars +and toys," and "Anthony Allee once wrote on Facebook, his wife was the reason for his success in life. Drugs +were the reason and on Wednesday, Allee, of Ridgeway, was sentenced in U.S. District Court to serve 12 years +and six months in federal prison." Allee, 29, "pleaded guilty in July to possessing with intent to distribute and +distributing cocaine and unlawful possession of a short-barreled shotgun in furtherance of drug trafficking." +Allee "and his wife, Tashira, 37, were first arrested in July 2019 after local police raided their home on Ridge +Road. The case was taken over by the FBI and U.S. Attorney's Office, leading to the couple's arrest on federal +charges." +Two Arrested After Missing California Man's Body Found +KTLA-TV Los Angeles (11/20, 766K) reports, "Two people were arrested Thursday on +suspicion of murder after the body of a missing man from South Los Angeles was discovered in a shallow grave +in the San Bernardino County desert, officials said." Juan Hernandez, 21, "was last seen Sept. 22 when he left +home for his job at VIP Collective, a cannabis dispensary in South L.A. His family reported him missing after he + + +didn't return from work that night. His mother, Yajaira Hernandez, previously told KTLA the dispensary's +security guards said they parted ways with her son when they closed up the shop at 10 p.m. Within a week of his +disappearance, someone tried to extort money from the family for his safe return, according to the Los Angeles +Police Department. LAPD says it led them to determine Hernandez was most likely the victim of a crime, and +detectives enlisted the FBI's help in the case." +The Los Angeles Times (11/19, Ormseth, 4.64M) reports, "Hernández's family had +reported him missing the night of Sept. 22. A student at El Camino College in Torrance, Hernández, known to +family and friends as 'Cookie,' was a semester shy of transferring to USC, where he planned to study +engineering, his mother previously told The Times. Hernández was last seen at a marijuana dispensary on the +corner of Western Avenue and 81st Street, where on Sept. 22 he worked a shift from 3 p.m. to 10 p.m. A few +minutes before 10 p.m., he sent his mother a text message saying he'd be home soon. He'd driven her car, a 2020 +Honda Civic, to work. Police found the car two days later in the 6400 block of South Figueroa Street, about two +miles from the dispensary." +Leader Of International Burglary Ring Pleads Guilty To Racketeering Charges. +The New York Post (11/19, Rosenberg, Fitz-Gibbon, 4.57M) reports, 'The leader of an international burglary ring that +netted $10 million in jewel heists and bank jobs from Manhattan to Beverly Hills pleaded guilty to racketeering +charges in New York City federal court Thursday." The man "is the fourth member of the ring busted for +carrying out a 12-year crime spree that hit more than a half-dozen jewelry stores in Manhattan and Brooklyn," +according to the US Attorney's Office. The ring "even attempted to rob a jewelry store in Germany in 2008 and +almost made off with nearly $12 million in gold, prosecutors said." One was living in New York, "where +neighbors knew him as 'Damian from The Bronx,' when the FBI caught up with him in October 2018." +FBI Searching For "Berenstain Bandits" Crew After 14 Robberies Across Southern California. +KNSD-TV San Diego (11/19, 194K) reports, "Local law-enforcement is searching for a three-suspect crew +believed to have knocked over more than a dozen businesses all across Southern California. The robbers — two +men and a driver - go into businesses armed, one with a silver revolver and the other with a black handgun, +officials said." KNSD-TV adds, "On Wednesday night, the men entering the targeted buildings were wearing +yellow vests, yellow bandanas to cover their faces. The FBI is calling the crew the Berenstain Bandits, a +reference to the Berenstain Bears series of children's books in which the father always wears a bright yellow +shirt. Investigators, who believe the suspects are either from San Diego or have ties to the county, said three +businesses were robbed in San Bernardino County overnight:* +Pennsylvania Man Charged With Robbing Two New Jersey Banks. +NJ News (11/19, Cohen, 1.72M) reports, "A convicted bank robber was charged with robbing two Camden +County banks two days apart, authorities said Thursday." Leon Stanford, 51, of Wilkes Barre, Pennsylvania, +*was ordered detained without bail after a videoconference hearing in Camden federal court, according to the +U.S. Attorney's Office for New Jersey. Stanford is accused of two counts of bank robbery. He targeted a TD +Bank branch in Oaklyn on Feb. 22, when he passed a note to a teller announcing a robbery, a criminal complaint +stated. 'Small bills / no dye pack / this is a robbery,' the robber's note said, according to an FBI agent's account + + +in the complaint. Stanford fled with about $500, it said." +Boy Scouts Face More Than 95,000 Abuse Claims In Bankruptcy Case. +The Washington Post +(11/19, Schmidt, 14.2M) reports that the Boy Scouts of America "said it must reach a settlement in its ongoing +bankruptey case by next summer" after over 95,000 sex-abuse claims were filed "as part of the organization's +ongoing Chapter 11 bankruptcy case." The Post says, "The staggering volume of claims exceeded expectations +of the victims' lawyers and could further complicate a restructuring process that is coming at the worst possible +time for the Boy Scouts" during the pandemic that has exacerbated weakened membership and hit revenue. An +attorney for the organization, Jessica Boelter, said, "Simply stated, we're going to run out of money if we linger +any longer in bankruptcy." +Financial Crime & Corporate Scandals +Illinois House Speaker Madigan Responds To Bribery Charges Against Associates. +WGEM-TV Quincy, +IL (11/19, Roberts) reports from Chicago, "House Speaker Mike Madigan released a written statement Thursday +following the issuing of charges on Wednesday against several former executives and lobbyists for +Commonwealth Edison." WGEM-TV adds, "Prosecutors haven't charged Madigan and in the statement Madigan +maintains the indictment alleges no criminal misconduct or wrong doing on his part." According to WGEM-TV, +"Wednesday's indictment named five individuals including Mike MeClain, a former Quincy lawmaker, lobbyist, +and close confidant of Madigan. Each of the five individuals was charged with bribery conspiracy, bribery, and +willfully falsifying ComEd and Exelon books, records, and accounts. The indictment also names former ComEd +CEO Anne Pramaggiore, former executive John Hooker, and lobbyist Jay Doherty." +The Chicago Sun-Times (11/19, Hinton, 875K) reports, +"After members of Madigan's inner circle were indicted for an alleged bribery scheme designed to influence +him, four more state House Democrats say they won't be voting for Madigan to maintain his powerful position +in January, effectively blocking him from another term in that seat if they hold to their statements. Madigan said +in a lengthy, two-page statement that to the extent anyone at Commonwealth Edison thought they could +"influence my conduct as a legislator ... they were fundamentally mistaken. If they even harbored the thought +that they could bribe or influence me, they would have failed miserably,' Madigan said. 'I take offense at any +notion otherwise. To the extent anyone may have suggested to others that I could be influenced, then they, too, +were wrong. Had I known about it, I would have made every effort to put a stop to it."" +The Chicago Tribune (11/19, Pearson, Munks, Petrella, 2.65M) reports, +"Madigan, long undisputed in his role as Illinois' most powerful politician, now finds his leadership hanging on +the precipice as the state faces one of the most tumultuous periods in its history." The Tribune adds, "A day after +his closest political ally was indicted in a bribery and influence-buying scheme involving Commonwealth +Edison, Madigan on Thursday saw eight more of his rank-and-file House members pledge not to reelect him +when lawmakers reconvene in January," and "that left Madigan at least three votes shy of the 60 he'll need to +win another term in January." +Luxury Cars Seized In $16M Texas Coronavirus Fraud Case. + + +KKTX-AM Corpus Christi, TX (11/19, Galluccio) reports, "Federal authorities have arrested and +charged seven people for allegedly stealing $16 million from federal programs meant to help businesses +struggling with the coronavirus pandemic. Six of the individuals are from the Houston area, while the seventh +person is from Illinois. Amir Aqeel, 52, Pardeep Basra, 51, Rifat Bajwa, 51, Mayer Misak, 40, Mauricio Navia, +41, Richard Reuth, and Siddiq Azeemuddin were all charged with conspiracy to commit wire fraud and wire +fraud. Aqeel and Azeemuddin were also charged with money laundering. The charges were laid out in a 20-page +indictment released by the FBI." Officials "said the men falsified documents to apply for fraudulent loans from +the Paycheck Protection Program. They created fake tax documents and wrote checks to non-existent employees, +which they cashed themselves." +Missouri Man Pleads Guilty In Landfill Fraud Probe. +The Arkansas Democrat Gazette < https://www.arkansasonline.com/news/2020/nov/19/driver-pleads-guilty-inlandfill-fraud-case/?crime> (11/19, Satter, 307K) reports, "A Missouri man admitted Tuesday that he was the +driver of big yellow trucks that were caught dumping waste at the Mississippi County landfill for free in 2017 +and 2018, in exchange for paying bribes to landfill operator Wil Allen." US District Judge Kristine Baker +"accepted a guilty plea from Joe Harlon Hamlett to a charge of aiding and abetting honest-services wire fraud. +Hamlett faces up to 20 years in prison and a fine of up to $250,000 when sentenced next year. On Oct. 8, a +federal jury in Baker's court convicted Hamlett's boss, James David Ross, of the same charge, finding that he +defrauded Mississippi County and the state of $54,155 by bribing Allen to let him dump numerous loads of +demolition debris for free." Allen pleaded guilty in September "to accepting bribes to let Ross' trucks avoid a +weigh station and corresponding bills. He is awaiting sentencing." +In Response To DOJ Suit, Realtors Group Agrees To Make Cost Of Broker Commissions More Transparent. +The Wall Street Journal (11/19, Kendall, Subscription Publication, 7.57M) reports that as part of a settlement of a Justice +Department lawsuit, the National Association for Realtors agreed Thursday to make the cost of brokers" +commissions more transparent. A DOJ suit against the group alleged it maintained anticompetitive rules which +made it difficult for home buyers to determine how much commission an agent would earn. +Facebook Facing State And Federal Antitrust Charges Over Acquisitions. +Reuters (11/19, Bartz, Dave) reports the FTC "and a bipartisan group of +dozens of state attorneys general are in the final stages of filing one or more major antitrust complaints against +Facebook." FTC staff "has recommended to commissioners that they sue the social media company in federal +court, which would allow the group of states, led by New York, to join the lawsuit, according to one source. As +many as 41 states may sign on to the lawsuit, three sources said." Reuters says the action "is expected to focus +on Facebook's alleged violations of antitrust law to build and protect its gigantic market share in social media." +The Washington Post +(11/19, Romm, 14.2M) says state and federal investigators are preparing antitrust charges "that will challenge the +tech giant's acquisition of two rivals, Instagram and WhatsApp, alleging that the deals helped create an anticompetitive social networking juggernaut that has left users with few quality alternatives." The Post adds that + + +"government antitrust watchdogs have weighed whether to contend in lawsuits that these transactions have left +users with worse services - and fewer privacy protections - than they might have had if the companies had +remained independent." +New York Fraud Investigations Said To Include Trump Tax Write-Offs. +The New York Times +(11/19, Hakim, McIntire, Rashbaum, Protess, 18.61M) reports, "Two separate New York State fraud +investigations into President Trump and his businesses, one criminal and one civil, have expanded to include tax +write-offs on millions of dollars in consulting fees, some of which appear to have gone to Ivanka Trump, +according to people with knowledge of the matter." The Times says subpoenas issued to the Trump Organization +"for records related to the fees" highlight "the legal challenges awaiting the president when he leaves office in +January." Trump Organization general counsel Alan Garten called it "the latest fishing expedition in an ongoing +attempt to harass the company." +Politico < https://www.politico.com/news/2020/11/19/ivanka-trump-investigations-harassment-438561> (11/19, +Choi, 4.29M) reports, "Ivanka Trump on Thursday called New York state investigations into her father's business +dealings 'harassment,'" in comments "seeming to confirm that the probes now include tax write-offs that appear +to involve her." Ivanka Trump tweeted, "This "inquiry' by NYC democrats is 100% motivated by politics, +publicity and rage. They know very well that there's nothing here and that there was no tax benefit whatsoever. +These politicians are simply ruthless." Politico says the post "could signal the family's coming defense against +mounting inquiries by state authorities." +Cyber Division +Grand Jury Indicts California Man For Cyberstalking Airbnb Guest. +KPIX-TV San Francisco (11/19, 110K) reports the Department of Justice announced that a federal grand jury +indicted a Ceres, CA man for cyberstalking an Airbnb guest for most of this The grand jury indicted 49-year old +Kevin James Strutz, "for harassing the victim, who officials identified only as an adult woman who stayed at his +home in Ceres back in February of this year: year." If convicted, Strutz "faces a maximum sentence of five years +in prison and a $250,000-fine." +GAO: Cyber Command's Vision For Developing Capabilities Lacks Clarity. +C4ISR & Networks (11/19, Pomerleau) reports, "U.S. Cyber Command's vison for developing +its core cyber platforms and capabilities lacks clear goals and guidance," according to a GAO audit. The audit, +released November 19, "examined Cyber Command's Joint Cyber Warfighting Architecture, which was created +by the command to guide its capabilities." It was "broken up into five elements," including "common firing +platforms for a comprehensive suite of cyber tools" and "Unified Platform that will integrate and analyze data +from offensive and defensive operations with partners." The agency "was granted limited acquisition authority +but still relies on the armed services to act as executive agents for major programs." It "has been heavily reliant +on the tools, personnel and infrastructure" of the NSA. + + +Arizona Judicial Branch's Website Hit By Ransomware Attack. +The Arizona Republic (11/19, Castle, 869K) reports, "The Arizona +Judicial Branch is dealing with the aftermath of a ransomware attack against its internet service provider this +week." A court spokesperson, Aaron Nash, "said that the impact appears to be limited to information connected +with the azcourts. gov website and does not affect individual court or clerk's offices." Portals that allowed +"people to access protective orders, defensive driving classes," and other information was down "for periods of +time during the week." After Managed.com was attacked on Monday, the company "took down all of its servers +to deal with the attack and some of its clients' sites had their data encrypted." Managed.com is "working with +law enforcement to identify the attackers." +Law Enforcement Services +US Executes Man Convicted Of 1994 Kidnapping-Murder. +The New York Times (11/20, +Fuchs, 18.61M) reports, +"The Justice Department executed Orlando Cordia Hall on late Thursday for his role in +the 1994 kidnapping and killing of a 16-year-old girl, after the Supreme Court cleared the way earlier in the +night. His execution, by lethal injection at the penitentiary in Terre Haute, Ind., was the eighth by the Trump +administration since this summer, when it resumed use of capital punishment by the federal government after a +17-year hiatus." Hall, 49, "was the first of three federal prisoners scheduled for execution during the presidential +transition. President-elect Joseph R. Biden Jr. has said he will work to end the use of capital punishment by the +federal government, reversing President Trump's support for it. The Bureau of Prisons confirmed in a statement +that Mr. Hall was pronounced dead at 11:47 p.m." +The AP (11/18, Salter) reports that US District Judge Tanya Chutkan "halted the +scheduled execution Thursday of" Hall, who is "convicted of kidnapping and raping a 16-year-old Texas girl, +bludgeoning her with a shovel and burying her alive." Hall "would be the eighth federal inmate put to death +since the Trump administration resumed federal executions this year after a pause of nearly two decades without +one." Chutkan "said the execution must be put on hold as the court weighs constitutional questions raised by +Hall's attorneys, including concerns over the federal Bureau of Prisons' protocols for executions." The Justice +Department "filed an immediate appeal with a federal appeals court in Washington" against the decision. +The Washington Post (11/19, Marimow, +14.2M) reports that Chutkan's ruling is the latest in "a series of legal battles over the Justice Department's lethalinjection procedures announced by the Trump administration last year." The Post goes on to report that "in a +separate case, a federal judge on Thursday postponed until at least Dec. 31 the execution of a third death-row +inmate, Lisa Montgomery, who would be the first woman put to death by the federal government in nearly 70 +years" after her "longtime lawyers...became infected with the coronavirus," ruling they "should have time to +recover to prepare her clemency application." +Prince George's County, Maryland Will Use DNA Registries To Solve Cold Cases With New DOJ Grant. +The Washington Post (11/19, Mettler, 14.2M) reports, + + +"Prince George's County is one of 10 jurisdictions across the country that will receive a $470,000 grant from the +Department of Justice to reopen cold cases using forensic genetic genealogy - a new investigative technique that +draws on privately curated DNA databases from popular genealogy websites to compare with samples collected +from crimes." The Post adds, "The funding could help investigators reopen as many as 60 cold cases over the +next three years, Prince George's prosecutors and police said at a news conference Thursday." According to the +Post, "There are more than 600 cases of serious and violent crimes in the county in which DNA was collected +from the scene but the sample did not generate a match in the FBI's Combined DNA Index System, often +referred to as CODIS." +International Relations +Mexico Says Corruption Cases Involving Its Officials Will No Longer Be Tried In US. +The AP (11/19, Verza) reports that on Thursday, the government of Mexico +"said...it will no longer allow officials accused of corruption to be tried in the United States, a move that could +end a decades-old tradition in which most of Mexico's high-profile drug-trafficking and corruption cases have +been tried north of the border." Foreign Relations Secretary Marcelo Ebrard is quoted as saying, "Whoever is +culpable according to our laws will be tried, judged and if applicable sentenced in Mexico, and not in other +countries... That is what has been...agreed and what has been maintained with U.S. authorities." According to +the AP, "The announcement suggests the fallout from the arrest of former Gen. Salvador Cienfuegos - which +enraged Mexico when the Justice Department announced it last month - is far broader than previously known." +Mexican Officials Criticize US Over Flow Of Destructive Weapons Over Border. The Washington Post + (11/19, 14.2M) reports Mexico's "increasingly militarized drug cartels now command +arsenals that rival the weaponry of the country's security forces," and in "rare public criticism," Mexican +officials are "venting their frustration at what they say is the U.S. failure to stop the flow" over the border. While +"the United States is pushing Mexico to target cartels more aggressively, U.S. laws that make...destructive +weapons easy to buy, along with a lack of enforcement at the border, are enabling those groups to expand their +influence and activities in the country." +Lawful Access +Google To Test End-To-End Encryption In Android Messages. +TechCrunch (11/19, Whittaker, +605K) reports, "For the past year and a half, Google has been rolling out its next-generation messaging to +Android users to replace the old, clunky, and insecure SMS text messaging. Now the company says that rollout is +complete, and plans to bring end-to-end encryption to Android messages next year. Google's Rich +Communications Services is Android's answer to Apple's iMessage, and brings typing indicators, read receipts, +and you'd expect from most messaging apps these days." TechCrunch adds, "In a blog post Thursday, Google +said it plans to roll out end-to-end encryption - starting with one-on-one conversations - leaving open the +possibility of end-to-end encrypted group chats. It'll become available to beta testers, who can sign up here, +beginning later in November and continue into the new year." +Ars Technica (11/19, Goodin, 1.36M) reports, "Abbreviated as RCS, Rich Communication Service provides a, + + +well, richer user experience than the ancient SMS standard. Typing indicators, presence information, location +sharing, longer messages, and better media support are key selling points. They lead to things like better-quality +photos and videos, chat over Wi-Fi, knowing when a message is read, sharing reactions, and better capabilities +for group chats. As Ars Review Editor Ron Amadeo noted last year, RCS interest from carriers has been tepid, so +Google has been rolling it out with limited support. Google said on Thursday that it has now completed its +worldwide rollout of RCS and is moving to a new phase end-to-end encryption. Interest in end-to-end +encryption has mushroomed over the past decade, particularly with revelations from Edward Snowden of +indiscriminate spying of electronic communications by the NSA." +Other FBI News +Wray, Haspel May Be Next To Lose Jobs In Administration. +Fox Exclusive (11/19, +Sardana) reports, "FBI director Christopher Wray could be subsequently on the line of firing Trump," according +to US media. CIA Director Gina Haspel "has been increasingly irritated by Trump and its allies because they +repeatedly press on again to declassify records connected with Russian involvement during presidential elections +in 2016," reported CNN. Additionally, on Friday, DNI Ratcliffe "was allegedly not part of Trump's regular +intelligence briefing." Concerns over the potential ouster of these officials comes after President Trump has +dismissed other officials, such as former CISA Director Krebs and former Defense Secretary Esper. +Other Washington News +Trump Reaches Out To Michigan Legislators As State Prepares To Certify Biden Win. +Coverage of President Trump's post-election maneuvering grows increasingly harsh, with reports saying Trump +is trying "to subvert the election," is using the power of the presidency "to try to reverse the results of the +election," and is aiming at "retaining power despite losing." The AP (11/19, Miller, Cassidy, +Long) reports the President "and his allies are taking increasingly frantic steps to subvert the results of the 2020 +election, including summoning state legislators to the White House as part of a longshot bid to overturn Joe +Biden's victory. Among other last-ditch tactics: personally calling local election officials who are trying to +rescind their certification votes in Michigan, suggesting in a legal challenge that Pennsylvania set aside the +popular vote there and pressuring county officials in Arizona to delay certifying vote tallies." +On the CBS Evening News (11/19, story 5, +1:00, Muir, 7.26M), Mary Bruce said, "This is all part of a shockingly bold last ditch attempt by the President to +somehow change the election results." +The New York Times (11/19, +Haberman, Rutenberg, Corasaniti, Epstein, 18.61M) reports under the headline "Trump Targets Michigan In His +Ploy To Subvert The Election" that the President on Thursday "accelerated his efforts to interfere in the nation's + + +electoral process, taking the extraordinary step of reaching out directly to Republican state legislators from +Michigan and inviting them to the White House on Friday for discussions as the state prepares to certify" Biden +as the winner there. The Times says the President's allies "appear to be pursuing a highly dubious legal theory +that if the results are not certified, Republican legislatures could intervene and appoint pro-Trump electors in +states Mr. Biden won who would support the president when the Electoral College meets on Dec. 14." +Reuters (11/19, Martina, +Freifeld, Renshaw) says Trump's "strategy for retaining power despite losing the U.S. election is focused +increasingly on persuading Republican legislators to intervene on his behalf in battleground states [Biden] won." +David Sanger of the New York Times +(11/19, Sanger, 18.61M) writes in an analysis that Trump's attempts to overturn the 2020 election are +unprecedented in American history and an even more audacious use of brute political force to gain the White +House than when Congress gave Rutherford B. Hayes the presidency during Reconstruction." Trump's chances +of succeeding "are somewhere between remote and impossible...yet the fact that Mr. Trump is even trying has set +off widespread alarms." +The Washington Post +(11/19, Rucker, Gardner, Dawsey, 14.2M) writes in an analysis that Trump "is using the power of his office to try +to reverse the results of the election... After courts rejected the Trump campaign's baseless allegations of +widespread voter fraud, the president is now trying to remain in power with a wholesale assault on the integrity +of the vote by spreading misinformation and trying to persuade loyal Republicans to manipulate the electoral +system on his behalf." The Washington Post (11/19, Hamburger, Ruble, Elfrink, 14.2M) says in a second piece that +Trump and his allies are "continu[ing] an extraordinary campaign to overturn the results of an election he lost." +The Wall Street Journal (11/19, Ballhaus, Leary, Subscription Publication, 7.57M) similarly reports under the headline +"Trump Broadens His Efforts To Overturn Election Outcome" that the effort is without precedent and is aimed at +reversing a clear defeat. +The Detroit Free Press (11/19, 1.52M) reports Michigan Senate Majority Leader Mike Shirkey (R) +and House Speaker Lee Chatfield (R) are expected to meet with the President at the White House on Friday, +"though both have said they have no plans for any longshot maneuvers aimed at the Republican Legislature +naming an alternate set of pro-Trump electors for Michigan." The Detroit News + (11/19, 825K) reports Biden "won Michigan 51%-48% or by 154,000 votes, +according to the current unofficial results. All 83 counties have approved their tallies, according to the +Department of State. And the Board of State Canvassers is scheduled to meet Monday to consider statewide +certification." +Politico (11/19, +Cheney, 4.29M) reports Trump's campaign has withdrawn "its last remaining federal lawsuit in Michigan +Thursday, falsely claiming that local election officials had declined to certify the Detroit-area's vote tabulation +even though they voted unanimously to do so Tuesday night." Breitbart + (11/19, 673K) reports Michigan Secretary of State Jocelyn Benson (D) told +MSNBC "that there was "no legal avenue' for two members of the Wayne County Board of Canvassers to reverse +their votes" to certify the results there. Bloomberg < https://www.bloomberg.com/news/articles/2020-11- +19/trump-to-meet-with-michigan-republicans-in-bid-to-overturn-vote?srnd-premium> (11/19, Parker, 4.73M), +the New York Daily News (11/19, Samuels, 2.98M), and the CNN + (11/19, Grayer, Herb, +Liptak, 83.16M) and Fox News (11/19, Henney, 27.59M) websites are among the other outlets covering the actions in +Michigan. +Kristen Welker said on NBC Nightly News +https://playvideo.bulletinintelligence.com/b533200d73be4dc7aa7bdfcco6237af5?pubid-fbi> (11/19, story 2, +0:50, Holt, 5.84M) that "the Trump legal team [is] pressing ahead with challenges to the election." The AP + +(11/19, Long, Miller, Colvin, Eggert) says the President "and his allies are taking increasingly frantic steps to +subvert the results of the 2020 election... Election law experts see it as the last, dying gasps of the Trump +campaign and say Biden is certain to walk into the Oval Office come January. But there is great concern that +Trump's effort is doing real damage to public faith in the integrity of U.S. elections." The Washington Post + (11/19, Fahrenthold, Reinhard, +Viebeck, Brown, 14.2M) calls the moves a "chaotic effort to upend the U.S. presidential election," and the Los +Angeles Times (11/19, 4.64M) says Trump is "escalating his slapdash yet persistent attempts to overturn Joe Biden's +election victory." +CNN (11/19, Bash, Borger, +83.16M) reports on its website that Trump "told an ally that he knows he lost, but that he is delaying the +transition process and is aggressively trying to sow doubt about the election results in order to get back at +Democrats for questioning the legitimacy of his own election in 2016, especially with the Russia investigation, a +source familiar with the President's thinking told CNN on Thursday." +USA Today (11/19, 10.31M) editorializes, "No one expected [Trump] to be as +gracious in defeat as was George H. W. Bush in 1992, the last time an incumbent was defeated. And perhaps only +the starry-eyed would think Trump might implement a more aggressive pandemic response now that the numbers +are surging again. Even so, in the past couple of weeks, unable to face reality and unwilling to concede his +election loss to Joe Biden, Trump has sunk to new levels of depravity and narcissism." +The New York Times (11/19, 18.61M) +editorializes, "Lies have a long half-life, and Mr. Trump's misinformation campaign will undermine the +democratic legitimacy of the Biden administration. About half of all Republicans surveyed by a new +Reuters/Ipsos poll said they believed that Mr. Trump had rightfully won the election," and a Monmouth poll this +week found that 77% of Trump supporters "believe Mr. Biden won through fraud... Trump already has +persuaded millions of people to disregard the dangers of the coronavirus and has made refusing to wear masks a +point of pride for his supporters. Imagine what will happen when more Americans share his contempt for +democracy." +The Washington Post (11/19, 14.2M) editorializes, "Trump's efforts to overturn the results of a free and +fair election grow more brazen," and each day, Senate Majority Leader McConnell "and other so-called leaders +of the Republican Party grow more complicit in this banana-republic style assault on democracy. ... Trump is not +playing out legitimate legal options. He is maneuvering to undo his defeat through lies and chicanery. Let us all +remember who abetted this disgrace and who stood up to it." +Biden Remains Winner In Georgia Following Hand Recount. The AP < https://apnews.com/article/election-2020- +joe-biden-donald-trump-stacey-abrams-hillary-clinton-b845b51c32e3bc9392953af0a22f1141> (11/19) reports +Biden "has won Georgia and its 16 electoral votes, an extraordinary victory for Democrats who pushed to + + +expand their electoral map through the Sun Belt." The New York Times + (11/19, Fausset, 18.61M) says +Georgia's "statewide hand recount of more than five million ballots reaffirmed on Thursday that [Biden] notched +an upset in a state that has long been considered a Republican stronghold." Breitbart + (11/19, 673K) reports the elections board in Floyd County, Georgia, on Thursday "voted to +terminate its executive director after an audit found ballots left uncounted prior to the county's initial +certification." USA Today (11/19, Garrison, Rossman, 10.31M), the Wall Street +Journal +(11/19, McWhirter, Corse, Subscription Publication, 7.57M), and the Atlanta Journal-Constitution + (11/19, 895K) are among the other outlets covering the +Georgia results. +Arizona Judge Dismisses GOP Attempt To Halt Certification Of Biden Win. Reuters + (11/19, Wolfe) reports Arizona Judge John Hannah on +Thursday "dismissed a Republican-backed lawsuit seeking to halt Arizona officials from certifying [Biden] as +the winner of the state." Hannah "said in a brief order he was denying a request by the Arizona Republican Party +for an injunction blocking the Maricopa County Board of Supervisors from certifying the results in the county, +where the majority of Arizonans live." The Arizona Republic + (11/19, 869K) reports the state GOP "had filed its suit last week, +alleging Maricopa County officials violated state law when they conducted a hand-count audit based on vote +centers, open to any voter in the county, instead of assigned precincts." The Hill + (11/19, Neidig, 2.98M) also reports. +Recount In Two Wisconsin Counties Set To Get Underway. The AP (11/19, Bauer) reports that on Thursday, the +Wisconsin Elections Commission "issued an order...to recount more than 800,000 ballots cast in two heavily +liberal counties" at Trump's request. The order, +: "required by law after Trump paid $3 million for the recount, +was agreed to after rancorous debate for more than five hours Wednesday night that foreshadows the partisan +battle ahead." The recounts in Milwaukee and Dane counties, where Biden "outpolled Trump by a more than 2- +to-1 margin, will begin Friday and must be completed by Dec. 1." The Milwaukee Journal Sentinel + (11/19, 632K) reports Milwaukee County Clerk George Christenson +"said Thursday that the county is taking every precaution possible, including distancing tables from each other +and requiring that everyone who enters wear a mask." +Media Analyses: Giuliani News Conference Included "Outright Fabrications," Lacked "Hard Evidence." The +New York Times (11/19, Merchant) reports Giuliani and other Trump lawyers "berated +reporters for questioning their claims and cited a Michigan affidavit already dismissed by a judge. They also +argued a debunked conspiracy theory that Venezuela could have hacked election results through machines used +by local authorities. " Bloomberg (11/19, Wingrove, 4.73M) reports, 'Their +allegations ranged from complaints that Republican observers weren't allowed to observe vote-counting in +Philadelphia and Detroit to a claim by Trump lawyer Sidney Powell that U.S. voting machines made by + + +Dominion Voting Systems Inc. used software made in Venezuela at the direction of Hugo Chavez," who "died in +2013." +The Washington Post (11/19, Zak, Dawsey, 14.2M) says +that "for 90 minutes, an unmasked Rudy and four maskless colleagues - "an elite strike force team, according to +senior legal adviser Jenna Ellis - spun a confusing web of conspiracies that indicate Trump won the election that +he lost." The New York Daily News +(11/19, Sommerfeldt, 2.52M) says the event "was called to amplify Trump's completely unfounded claim that +Democratic officials used mail-in ballots to rig the election. +Townhall (11/19, Pavlich, 177K) reports Giuliani "presented evidence +he says suggests a pattern of planned voter fraud that was perpetrated in multiple states." But the Daily Caller + (11/19, +716K) reports Fox News White House correspondent Kristin Fisher said after the event, "Well, that was certainly +a colorful news conference from Rudy Giuliani but it was light on facts. So much of what he said was simply not +true or has already been thrown out in court.... He called it a nationwide conspiracy. And yet he failed to provide +any hard evidence to back up that one specific claim especially when you're dealing with a claim that really cuts +to the core of our democratic process." +Giuliani said on Fox News' Hannity < https://video.foxnews.com/v/6211099886001? +playlist_id-930909813001#sp=show-clips> (11/19, 535K), "It was a national conspiracy. More than just three +states, it was 10 states. It's impossible that in Pittsburgh, and in Philadelphia, and Detroit, and in Milwaukee, and +in Phoenix, the Democratic leaders woke up on November 3 and said, 'We are going to shut all the Republicans +out. We are going to put them in shoots. We are not going to let them see absentee ballots, when for 100 years, +we all look at absentee ballots. This had to come from someplace in the Biden campaign." USA Today + (11/19, Shannon, 10.31M), Politico (11/19, Forgey, Isenstadt, 4.29M), Breitbart + (11/19, 673K), and the Fox News (11/19, Blitzer, 27.59M) website also cover +the news conference. +Cornyn Says Biden Not Yet President-Elect, But Says He Has Seen No Evidence Of Fraud. The Dallas Morning +News < https://www.dallasnews.com/news/politics/2020/11/19/cornyn-says-joe-biden-is-not-president-elect-notuntil-the-votes-are-certified/> (11/19, Gillman, 946K) reports Sen. John Cornyn (R-TX) "said Thursday that he +does not consider Joe Biden to be the president-elect, arguing that it is premature to apply that title until votes are +certified and legal challenges are resolved. But Cornyn acknowledges that he is unaware of any evidence +backing up [Trump's] contention that the election has been stolen through fraud or ballot tampering." Cornyn +said, "He is not president-elect until the votes are certified. So the answer to that is no. And I don't know what +basis you or anybody else would claim that he's president-elect before the votes are certified and these contests +are resolved." +Boston Globe's Pindell Says Trump Could Decide To Resign. James Pindell of the Boston Globe + (11/19, 972K) writes, "The most logical ending to the Trump presidency isn't him hunkering down +inside of the West Wing forcing a constitutional crisis. The most logical thing is that he just quits, possibly even a +few days before Biden is sworn in. .. By quitting, he could make a deal with [Vice President] Pence: you get to +be the 46th president for a small stretch and, in return, you pardon me... The thing about quitting is that he +leaves entirely on his own terms... Sticking around or trying to use the levers of power to stay in office would + + +be dramatic but is a lot less predictable. Quitting is a script he would get to write." And Trump "isn't acting like +he is enjoying the job of president much anymore." +CDC Urges Americans Not To Travel Over Thanksgiving. +David Muir opened ABC World News Tonight + (11/19, lead story, +3:30, Muir, 7.26M) by reporting on a "blunt" new warning from the CDC "urging Americans not to travel this +Thanksgiving. With the nation having lost more than 250,000 American lives to this and given what they've seen +in just the last 24 hours, nearly 200,000 new cases, the numbers are simply accelerating too fast." Norah +O'Donnell said on the CBS Evening News + (11/19, lead story, +3:40, O'Donnell, 4.28M), 'In a blunt and ominous warning, the government's top health protection agency now +says ignoring those warnings and holding gatherings could lead directly to family members dying from COVID- +19." CBS' Kris Van Cleave: "That urgent warning not to travel comes as many as 50 million Americans are +preparing to do just that - travel for Thanksgiving. The CDC is urging anybody who hasn't been home for 14 +days, including college students coming from campus, not to participate in Thanksgiving plans unless they have +already quarantined." +Miguel Almaguer said on NBC Nightly News +https://playvideo.bulletinintelligence.com/f9cc2c56de7343e7bd77653a2cf8080?pubid-fbi> (11/19, story 3, +2:30, Holt, 5.84M), "With the US facing a crushing wave of patients and a growing number of fatalities, tonight +at this critical phase, the CDC is now urging all Americans to stay home for Thanksgiving. ... As our nation now +averages some 1,200 deaths a day, in the Midwest, home to the most dire surge in the nation, seven governors, +Democrats and Republicans, are sharing the same message" in a Thursday Washington Post op-ed +: "stay +home." +The Washington Post +(11/19, A1, Shammas, 14.2M) reports that in the agency's "first news briefing in months, officials said they were +alarmed to see 1 million new cases reported across the United States within the past week." The AP + (11/19, Stobbe, Hollingsworth) says the CDC "pleaded with Americans +on Thursday not to travel for Thanksgiving and not to spend the holiday with people from outside their +household." According to the AP, "It was some of the firmest guidance yet from the government on curtailing +traditional gatherings to fight the outbreak." +USA Today (11/19, Moniuszko, 10.31M) reports CDC COVID-19 +incident manager Henry Walke said those "who do decide to travel for the holiday should do so "as safely as +possible by following the same recommendations for everyday living,' including wearing a mask, staying six feet +apart and washing your hands." The New York Times (11/19, Tompkins, 18.61M) +says "the new guidance...contrasted sharply with recent White House efforts to downplay the threat." +Reuters (11/19, Caspani, Borter) reports that +"the number of patients hospitalized with COVID-19 in the United States has jumped nearly 50% in the last two +weeks, forcing states to impose new restrictions to curb the alarming viral spread as Americans face a potentially +grim winter and holiday season." Bloomberg < https://www.bloomberg.com/news/articles/2020-11-19/americasetting-covid-19-hospitalization-records-every-day?srnd-premium&sref-3IOEzKok> (11/19, Querolo, Annett, +4.73M) reports that "almost 80,000 patients are hospitalized with Covid-19 in the U.S. - another high in a week + + +that has pushed up the record every day since Nov. 10." +The New York Times (11/19, +Leatherby, Harris, 18.61M) reports, "Coronavirus cases are rising in almost every U.S. state. But the surge is +worst now in places where leaders neglected to keep up forceful virus containment efforts or failed to implement +basic measures like mask mandates in the first place, according to a New York Times analysis of data from the +University of Oxford." ABC World News Tonight +(11/19, story 6, +2:35, Muir, 7.26M) had a similar assessment. +In an appearance on CNN's Cuomo Prime Time + (11/19, 1.93M), +NIAID Director Fauci said, "You heard the numbers that we gave at the press conference today. They're +daunting, they're very serious. But we can do something about it... If we had everybody pulling together as a +country, doing the fundamental things that we've been speaking about - the mask-wearing, the keeping the +distance, the avoiding congregate settings and crowds, doing things outdoors much more preferential than +indoors - that's not big stuff. It's easy to do." +Reuters (11/19, Spalding, Maddipatla), the Wall Street Journal + +(11/19, A1, Korn, Calfas, Subscription Publication, 7.57M), the Los Angeles Times + (11/19, 4.64M), +Axios (11/19, Fernandez, 521K), Politico (11/19, Ehley, 4.29M), The Hill + (11/19, Fox, 83.16M), Fox News (11/19, Feuer, 3.62M) websites are among the other outlets covering the +guidance. +Pence Hosts COVID News Briefing. +The AP (11/19) +reports Vice President Pence spoke Thursday at the White House, where he "offer[ed] an upbeat assessment of +the status of the coronavirus in the U.S., despite a surge in cases, hospitalizations and more than a quarter of a +million deaths." He "[said] America 'has never been more prepared to combat this virus than we are today" +Reuters (11/19) reports that during his remarks, Pence +dismissed new calls for a nationwide lockdown or a return to shutting down schools. +The Washington Post (11/19, Gearan, Kim, 14.2M) reports +Pence and other federal task force members "touted encouraging news on vaccines, particularly on their efficacy, +and promised Americans that millions of doses could be distributed almost immediately upon approval by the +Food and Drug Administration." They also "urged the country to continue mitigation measures such as wearing +masks and social distancing," but Pence "did not wear a face covering at the White House podium." +Birx, Fauci Urge Americans To Continue Maintaining Best Practices. Bloomberg + + + (11/19, Higgins-Dunn, 3.62M) reports on its website that on +Thursday, NIAID Director Fauci "said... that convincing people who consider the coronavirus to be 'fake news' +to get vaccinated against the disease could become an issue as the nation seeks to achieve so-called herd +immunity to suppress the pandemic. "They actually don't think that this is a problem,' Fauci said during a +conversation with The Hastings Center." +Carson Says He Is Taking Oleander Extract As COVID Treatment. +In an interview with the Washington Post +(11/19, Terris, 14.2M), HUD Secretary Carson said he is taking oleander extract as a treatment for COVID after +hearing about it from MyPillow inventor Mike Lindell. Carson said, "I heard about the oleander extract from +Mike." Carson "said he took the extract, which has not been approved for such purposes by the FDA and which +experts say may be dangerous, and within hours his symptoms disappeared - to the delight of Lindell, who has a +financial stake in the company that makes the extract." +Trump Administration Facing Multiple Challenges Over Vaccine Distribution. +NBC Nightly News (11/19, Weise, 10.31M) reports that the National Academies of Sciences, + + +Engineering, and Medicine "has outlined a plan for fair distribution that's being used as a framework by the +Centers for Disease Control's Advisory Committee on Immunization Practices," and the CDC will "make the +final decision on when certain groups of Americans will have access to vaceine." The initial vaccination group +"includes frontline health care workers, first responders, cleaners and ambulance drivers," but full vaccination +"could take up to a year." +The Los Angeles Times (11/19, Levey, 4.64M) reports that regular Americans +"shouldn't expect to get a vaccine at their doctor's office or pharmacy for many months." Council on Foreign +Relations Global Heath Program Director Thomas J. Bollyky said of the distribution risks, "If we are going to +reach the levels of vaccination that we need to control the pandemic, which will be challenging, we have to +sustain the public's confidence." He added, "If we don't have a fair allocation of vaccines, that could undermine +the whole campaign in a way that would do lasting damage." +Oxford, AstraZeneca Laud Early Vaccine Results. On ABC World News Tonight + (11/19, story 2, +0:35, Muir, 7.26M), Whit Johnson reported, "Oxford and AstraZeneca say new results show their vaccine is safe, +and produce robust immune responses in healthy adults and people over the age of 70." The final result data is +not yet released, and it joins other positive vaccine test data from Pfizer and Moderna. +Fauci Lauds Early Vaccine Data. Asked on CNN's Cuomo Prime Time + (11/19, 1.93M) +whether he expects interim efficacy data on the vaccines to "hold," NIAID Director Fauci said, "l've seen the +numbers... Those numbers are not going to change. The issue is, how long does the immunity last? How long +does the protection last? We don't know that right now, but we know it works." When asked whether the +vaccines could prevent infections, Fauci said, "We don't know that now, but the impact of a vaccine that could +prevent somebody from getting ill and prevent somebody from getting seriously ill - that's huge...by anybody's +standard." +Labs Warn Of COVID Test Delays. +The AP (11/19, Perrone, Renault) reports that testing laboratories have "warned +that continuing shortages of key supplies are likely to create more bottlenecks and delays" in processing +outstanding COVID testing kits. Association of Public Health Laboratories CEO Scott Becker said in a +statement, "As those cases increase, demand increases and turnaround times may increase." However, Assistant +HHS Secretary for Health Adm. Brett Giroir has "downplayed reports of lines and delays earlier this week." The +US "is testing over 1.5 million people per day on average, more than double the rate in July, when many +Americans last faced long lines." +Asked about reports of test shortages on NPR +https://playvideo.bulletinintelligence.com/e26bf45e268946d5b77539d224706992?pubid=fbi» (11/19, 3.12M), +Giroir said, "We are absolutely able to support the testing of those who are symptomatic, to all the contacts they +have, to test asymptomatic individuals across the country in an unprecedented way. We have all of that, but the +lines you're seeing, primarily now, are the result of individuals who mistakenly believe that getting a test today +or tomorrow is going to make them safe over the holidays for travel." +Fauci Urges Development Of At-Home Testing Capability. Asked on CNN's Cuomo Prime Time + (11/19, 1.96M) +about what type of testing he would advocate going forward, NIAID Director Fauci said, "The thing I would be +pushing for is something that's a home test that's point-of-care, that you can do yourself." + + +Study Finds Employers Avoid Offering COVID Testing Over Cost. The New York Times + (11/19, Scheiber, 18.61M) +reports that a new World Economic Forum and Arizona State University study "has found that companies most +frequently cited cost and complexity as the biggest deterrents to testing their workers." The findings, which are +"based on responses from 1,141 facilities at over 1,100 companies worldwide from September through late +October," complement earlier news "suggesting that many employers have been able to obtain testing relatively +quickly if they absorb the expense." +Newsom Announces Overnight Curfew In California. +The AP (11/19, Thompson) reports California Gov. Gavin Newsom (D) +announced Thursday that the state "is imposing an overnight curfew on most residents as the most populous state +tries to head off a surge in coronavirus cases that it fears could tax the state's health care system." The Los +Angeles Times (11/19, 2.67M) says the measure "is similar to one New York imposed statewide +last week, and what other European countries and cities have experimented with to control new waves of the +virus. Newsom said this week he and officials were still combing through the research, but experts say the +science behind curfews during a pandemic is still relatively scant." +Politico (11/19, White, Colliver, 4.29M) says the order "will likely deepen resentment +among those opposed to Newsom's efforts to reimpose tough measures to contain the virus." Assemblymember +Devon Mathis (R) "excoriated Newsom for a 'huge overreach,' and Sacramento County Sheriff Scott Jones +"said in a statement Thursday afternoon that he would not enforce 'any health or emergency orders related to +curfews, staying at home, Thanksgiving or other social gatherings inside or outside the home, maximum +occupancy, or mask mandates."' +The Hill (11/19, Choi, 2.98M) reports California "reported nearly 200,000 on Nov. 12, the +most it has recorded in a single day since the pandemic was declared in March." The Wall Street Journal + (11/19, Subscription Publication, 7.57M), the San Jose +Mercury News (11/19, 456K), and Axios (11/19, Chen, Perano, 521K) also have reports. +Ohio Legislature Passes Bill To Limit DeWine's Emergency Powers. +The Cleveland Plain Dealer (11/19, 895K) reports that Ohio +legislators passed Thursday a bill to strip Gov. Mike DeWine (R) "of the authority to issue statewide coronavirus +orders, even though the governor said the measure would be 'a disaster" and vowed to veto it." The measure +would "ban the Ohio Department of Health from issuing mandatory quarantine orders enforced against people +who are not diagnosed as sick or directly exposed to disease." However, the bill "would not void existing +statewide orders, including the three-week 10 p.m. to 5 a.m. curfew announced by the governor earlier this week, + + +a renewed statewide mask mandate, and a 'stay-at-home' order like the one DeWine ordered the state health +director to issue last spring." +New York City Parents Protest School Closures. +The CBS Evening News (11/19, +McKinley, Ferré-Sadurni, 18.61M) reports that the school closures come as thousands of new cases "are +emerging every day statewide," and hospitalizations "have more than quintupled since early September, topping +2,200 on Wednesday." +The New York Times (11/19, Shapiro, +Kim, 18.61M) reports New York City Mayor Bill de Blasio (D) "defended his decision" to shut down the school +district on Thursday, "saying it was justified by the steady increase in test positivity, which again topped 3 +percent on Thursday." He said, "We see a gathering storm, and we're fighting back the second wave." He +"vowed to reopen the city's schools, but warned that it would require 'even more stringent rules,"" which could +"include expanding coronavirus testing in school buildings and possibly mandating that all students who want to +take in-person classes provide written consent to receive a coronavirus test." +Smithsonian Shuts Down All Facilities Indefinitely. +The AP (11/19, Khalil) reports, "In response to rising COVID-19 infection +numbers, the Smithsonian Institution is indefinitely shutting down operations at all its facilities, effective +Monday and affecting seven museums, plus the National Zoo." The Washington Post + (11/19, Hedgpeth, 14.2M) reports Smithsonian Secretary Lonnie G. +Bunch III "said the decision to close the museums and National Zoo was a precaution, adding that caseloads are +projected to rise after Thanksgiving, typically a busy time for the museums." The New York Times + (11/19, Bahr, +18.61M) reports that the Smithsonian's "New York City museums, the Cooper Hewitt, Smithsonian Design +Museum and the National Museum of the American Indian George Gustav Heye Center, have been closed to the +public since March 14.* +Tyson Foods Suspends Iowa Plant Managers Over Alleged COVID Wagers. +The AP (11/19, Foley) reports Tyson Foods "suspended top officials at its largest +pork plant on Thursday and launched an investigation into allegations that they bet on how many workers would +get infected during a widespread coronavirus outbreak." President/CEO Dean Banks "said he was 'extremely +upset' about the allegations against managers at its plant in Waterloo, Iowa, saying they do not represent the +company's values." + + +USA Today (11/19, Bote, 10.31M) reports an amended lawsuit filed Wednesday says +managers "placed bets on how many would end up getting sick." Tyson kept the plant open "even as local +officials urged for its shutdown early in the pandemic. As a result, around 1,000 employees contracted COVID- +19, five of whom died." The amended lawsuit claims plant managers "downplayed the severity of COVID-19 at +the plant to both supervisors and processing workers." The Wall Street Journal + (11/19, Bunge, Subscription Publication, 7.57M) reports Tyson said it suspended the managers +accused of wagering on the number of COVID cases. +Older Americans Increasingly Challenged By Isolation Orders. +NBC Nightly News (11/19, story 9, 2:55, Holt, 5.84M) reported that social isolation measures introduced to combat the +spread of COVID-19 are increasingly challenging older Americans, who continue to struggle with solitude. Kate +Snow interviewed Dr. Louise Erinson, who warned that continued isolation will undermine the mental health of +America's seniors. Erinson said, "I am seeing people having trouble sleeping, having trouble focusing, and +worried about will this go on forever." The mental health challenges are also burdening caregivers, and AARP's +latest report warns that one out of six caregivers "report a fair or poor mental heath state." +Missed Census Deadline Could Impair Trump Effort To Block Migrants From Count. +The AP +(11/19, Schneider) reports that on Thursday, Steven Dillingham, the Director of the Census Bureau, "said...that +irregularities have been found during the numbers-crunching phase of the 2020 census, a development that +jeopardizes the statistical agency's ability to meet a year-end deadline for handing in numbers used for divvying +up congressional seats." According to the AP, the Census Bureau "already was facing a shortened schedule of +two and a half months for processing the data collected during the 2020 census - about half the time originally +planned." The AP also reports that the Census Bureau "would not say... what the anomalies were or publicly state +if there would be a new deadline for the apportionment numbers." +The New York Times (11/19, Wines, Bazelon, +18.61M) says the announcement is "a blow to the Trump administration's efforts to strip unauthorized +immigrants from census totals used for reapportionment" because Census Bureau officials "have concluded that +they cannot produce the state population totals required to reallocate seats in the House of Representatives until +after President Trump leaves office in January " However, the Times goes on to report that Dillingham "did not +explicitly rule out delivering reapportionment totals before Mr. Trump's term ends." +The Washington Post (11/19, Bahrampour, 14.2M) says the delay presents "a new roadblock" to the Trump +Administration's "quest to exclude undocumented immigrants from being counted" after an attempt to "add a +citizenship question to the survey, which experts said could scare immigrants away and result in an inaccurate +count" was blocked by the Supreme Court. The Administration separately "in July announced plans to try to +exclude undocumented immigrants," sparking "several legal challenges" and a Supreme Court hearing set for +November 30, though "it is unclear how the delays communicated Wednesday will affect that case." +CNN (11/19, +Wallace, 83.16M) reports on its website that "if the issue delays the bureau's data processing steps, the incoming + + +Biden administration may be in a position to override the controversial decision by the Trump administration to +exclude undocumented immigrants from key tallies such as the apportionment count for how many +congressional districts states have." The Wall Street Journal (11/19, Overberg, Subscription Publication, 7.57M) +also reports. +CBP Reports Record Arrests In October. +The Washington Post (11/19, Miroff, 14.2M) reports that +authorities "made more than 69,000 arrests and detentions last month along the border with Mexico, a 21 percent +increase from September and the highest total for any October since 2005," according to Customs and Border +Protection figures released Thursday. The Post says the surge "was partly fueled by a soaring number of repeat +arrests along the border resulting from the Trump administration's practice of quickly 'expelling' people to +Mexico after they enter the country," with "at least one-third of those taken into custody each month..repeat +offenders." Acting CBP Commissioner Morgan "blamed the economie impacts of the pandemic for the latest +increase in border crossings, as well as [Joe Biden's] stated plans to reverse many of Trump's immigration +policies." +Democrats Demand Release For Female Detainees In ICE Custody. +The Washington Post (11/19, Armus, 14.2M) reports that "a group of more than 100 congressional Democrats +demanded Thursday" in a letter to Acting ICE Director Pham, the Justice Department, FBI, and DHS Office of +the Inspector General that ICE "release female detainees from a Georgia detention facility who allege they +received subpar gynecological care while detained there." The letter argues that the women could be witnesses in +a federal investigation into physician Mahendra Amin and "calls for the women to receive necessary +certifications for a chance to apply for U-visas." The lawmakers wrote, "Deporting these witnesses - especially +when none of them have received independent physical or mental health evaluations by medical experts - +amounts to a de facto destruction of evidence." +Schumer Says McConnell Has Agreed To Resume COVID Relief Talks. +Reuters (11/19) reports Senate Minority +Leader Schumer said Thursday that Senate Majority Leader McConnell has agreed to resume COVID relief +talks. According to CNBC, Schumer said, "[Wednesday] night, they've agreed to sit down and the staffs are +going to sit down today or tomorrow to try to begin to see if we can get a real good COVID relief bill. ... So +there's been a little bit of a breakthrough in that McConnell's folks are finally sitting down and talking to us." +Reuters cites a "senior Democratic aide" who "said there was a midafternoon meeting on Thursday of aides" +representing McConnell, Schumer, House Speaker Pelosi, and House Minority Leader McCarthy. However, +Politico (11/19, +Levine, 4.29M) says GOP aides "disputed Schumer's characterization and said that Democrats were conflating +the omnibus spending bill and a Covid relief bill." +The New York Post (11/19, Bowden, 4.57M) reports during his weekly news conference Thursday, McCarthy "ripped" +Pelosi over the ongoing impasse. McCarthy said, "Things are still at the same place. There's one road block. + + +There's one big wall that's stopped this the entire time and it's Speaker Pelosi. ... I would think after the politics +she played and the election being over, that she'd now put the American public first. She still seems to be in the +same position." +Stocks Close Higher On Word Of Renewed Stimulus Talks. Media reports stocks gains on Thursday to reports +that stimulus talks are going to resume. The Dow added 44.81 points to finish at 29,483.23, the S&P 500 rose +14.08 points to 3,581.87 and the Nasdaq ended the day 103.11 points higher at 11,904.71. The Wall Street +Journal (11/19, +Horner, Subscription Publication, 7.57M) says all three indexes started the day lower but seemed to gain +momentum on word that stimulus talks would resume. Similarly, Reuters (11/19, Scott) reports +stocks rose "following a report that U.S. lawmakers may restart negotiations on economic stimulus, which lifted +gloom that had persisted through most of the global day," while the AP (11/19, Choe, +Troise, Veiga) describes an ongoing "tug of war" between "worries about the worsening pandemic in the present +and optimism that a vaccine will rescue the economy in the future." +Top Congressional Aides Meet To Discuss Averting Government Shutdown. +The Washington Post (11/19, Stein, Kim, 14.2M) reports aides to Senate Majority Leader McConnell, Senate Minority +Leader Schumer, House Speaker Pelosi, and House Minority Leader McCarthy "met Thursday in an effort to +bridge differences and assemble a spending bill that would avert a government shutdown in December." The +aides held discussions shortly after Chief of Staff Meadows "said he couldn't guarantee a shutdown would be +averted." +Mnuchin Will Not Extend Emergency Lending Programs. +The Wall Street Journal (11/19, A1, Timiraos, Davidson, Subscription Publication, 7.57M) reports +Treasury Secretary Mnuchin said Thursday several emergency loan programs established with the Federal +Reserve will be allowed to expire on Dec. 31. Mnuchin said the Fed's corporate credit, municipal lending and +Main Street Lending programs will not be renewed. Reuters < https://www.reuters.com/article/us-usa-fedmnuchin/mnuchin-pulls-plug-on-some-of-feds-pandemic-lending-programs-idUSKBN27Z34P> (11/19, +Schneider, Saphir) says the lending programs "never got much use, but were an effort to spread a central bank +safety net under as much of American business as possible." The AP (11/19, +Crutsinger, Rugaber) reports Mnuchin "said that he is requesting that the Fed return to Treasury the unused funds +appropriated by Congress for operation of the programs. He said this would allow Congress to re-appropriate +$455 billion to other coronavirus programs." +The New York Times (11/19, Smialek, 18.61M) says the move could hinder Joe Biden's "ability to use the Federal +Reserve's vast powers to cushion the economic fallout from the virus." The Times says the programs "have +provided an important backstop that has calmed critical markets since the coronavirus took hold in March. +Removing them could leave crucial corners of the financial world vulnerable to the type of volatility that +cascaded through the financial system in March. And by asking the Fed to return unused funds, Mr. Mnuchin +could prevent Mr. Biden's incoming Treasury secretary from restarting the efforts in 2021." +The Hill (11/19, Elis, 2.98M) reports Fed Chairman Powell "says the programs...remain necessary," +and the Washington Post (11/19, Siegel, Stein, 14.2M) that the Fed "immediately criticized" the move, "citing the fragile +recovery." In a "rare statement," the Fed said, "The Federal Reserve would prefer that the full suite of emergency +facilities established during the coronavirus pandemic continue to serve their important role as a backstop for our +still-strained and vulnerable economy." The Post says the "exceedingly rare public rebuke" from the central bank +"reflected a government divided on how to respond, as the pandemic surges across the nation, threatening a new +wave of shutdowns and marking an inflection point of the recession." +EPA Administrator's Travel Plans Draw Scrutiny. +The New York Times (11/19, +Friedman, 18.61M) says EPA Administrator Wheeler "plans to squeeze in two taxpayer-funded trips abroad - to +Taiwan next month and to four Latin American countries in January." According to the Times, both trips "have +raised concerns about the taxpayer expense at a time when Mr. Wheeler no longer represents the direction of +E.P.A. policy, and he and top aides are supposed to be aiding the transition" to the next administration. +Meadows Suggests Deal Over Military Policy Bill. +The New York Times (11/19, Haberman, Edmondson, 18.61M) reports Chief of' +Staff Meadows "has privately hinted that President Trump would drop his objection to stripping Confederate +leaders' names from military bases, which is threatening to derail the annual military policy bill, if Democrats +agreed to repeal" Section 230 of the Communications Decency Act of 1996. House Armed Services Chairman +Adam Smith has been discussing potential compromises with the White House, but the proposed deal is "viewed +it as a nonstarter," according to an anonymous Democratic congressional aide. +Democrats, Republicans Seek Infrastructure Deal In Next Congress. +The Wall Street Journal (11/19, Duehren, Subscription Publication, 7.57M) reports that Democratic and Republican +congressional legislators are interested in discussing a new infrastructure bill in 2021. The potential bill is +viewed by both parties as a means to stimulate the economy as well as repair deficiencies located throughout the +country. The House of Representatives passed a $1.5 trillion infrastructure bill last summer, and Speaker Pelosi +predicted last week that the House would work on a new infrastructure bill next year. +International News +WHO: Situation In Europe Improving Due To Reimposition Of Lockdowns. +The Washington Post (11/19, Birnbaum, 14.2M) +reports that on Thursday, Hans Kluge, the World Health Organization's regional director for Europe, indicated +that Europe's "painful second coronavirus wave may be starting to ease...though its toll continues to be +staggering, with someone on the continent dying every 17 seconds from the virus this past week." According to + + +the Post, "The cautious assessment came after new diagnoses of the novel coronavirus slowed across Europe to +1.8 million cases, compared with 2 million the week before. Some of the worst-hit countries - including +Belgium, France and the Czech Republic - have seen significant declines, while in Germany and elsewhere the +curve is just beginning to bend." The Post says Kluge "attributed the decline to national lockdowns and other +restrictions imposed across much of Europe this past month." +The New York Times (11/19, Santora, Zraick, Minder, 18.61M) says, +"The restrictions, many of which were announced at the end of October, are less severe than in the spring," but, +nevertheless, "the approach stands in stark contrast to much of the United States, where responsibility for virus +policy has been largely left to the states." +WHO Says Evidence Lacking To Recommend Remdesivir For COVID Treatment. +The New York Times (11/19, Carey, +18.61M) reports that an expert panel from the World Health Organization on Thursday "concluded that +remdesivir has no meaningful effect on mortality or on other important outcomes for patients" in a review +published in The BMJ. While "the report did not rule out the use of the drug altogether as a Covid treatment," the +panel "said evidence was lacking to recommend its use." The Times says the use of "remdesivir had been the +subject of debate and skepticism for months, and especially in recent weeks, after the Food and Drug +Administration approved it as the first treatment for Covid-19." +Japan's Suga Raises Alarm On Country's Third Wave. +The New York Times (11/19, Dooley, 18.61M) reports that while "Japan +has managed to keep coronavirus numbers low," the country's "strategy for success is being tested as cases reach +record highs," leading Prime Minister Yoshihide Suga "to warn on Thursday that the country is on 'maximum +alert' in an effort to prevent infections from running out of control." Suga "requested that people be more vigilant +about wearing masks, especially while dining out, and said he might request stronger measures based on the +advice of a panel of experts." The Times says that Japan has "largely managed to avoid the large-scale +outbreaks" prevalent in the US and Europe, primarily as a result of widespread public education and social +compliance. +Jordan Becoming COVID Hot Spot After Early Success. +The New York Times (11/19, Sweis, 18.61M) reports that Jordan, once "commended worldwide for its early +efforts to counter the pandemic, has now become one of the hardest-hit countries in the region," averaging "more +than 5,000 coronavirus cases a day in the past two weeks." The country on Wednesday "recorded 7,933 cases, its +highest number since March," though "the government attributed the recent sharp increase to the infection of +1,893 people at two factories in the southern city of Aqaba. " International Rescue Committee vice president of +policy and practice Nazanin Ash said "crisis-affected countries" like Jordan "are already dealing with +unfathomable levels of hunger, economic distress, crippled health systems and infrastructure" and "now facing +second waves that could be even more devastating than the first." +WSJournal: WTO Proposal To Remove Vaccine Patent Protections Would Be Theft. + + +In an editorial, the Wall Street Journal (11/19, Subscription Publication, 7.57M) argues that a World Trade Organization proposal, led by +India and South Africa, that would relinquish patent protections on coronavirus vaccines would be theft against +the US and European companies that developed them. The Journal says the proposal would ultimately repress +further innovation in the space, making it more difficult to end the existing and future pandemics. +Top Iranian Military Official: Any US Strike Could Spark "Full-Fledged War." +The AP (11/19, Karimi, Gambrell) reports that Hossein Dehghan, "an adviser to +Iran's supreme leader who is a possible 2021 presidential candidate," is "warning that any American attack on +the Islamic Republic could set off a "full-fledged war" in the Mideast in the waning days of the Trump +administration." The AP says Dehghan "struck a hard-line tone familiar to those in Iran's paramilitary +Revolutionary Guard, a force he long served in," and "warned against any American military escalation in +Trump's final weeks in office. 'A limited, tactical conflict can turn into a full-fledged war,' he said." +NBC Nightly News (11/19, story 7, 0:50, Holt, 5.84M) reported, "A new report out from the UN today confirms Iran is +breaching the rules of the international nuclear agreement. It says Iran is stockpiling a much higher amount of +enriched uranium than agreed to." However, International Atomic Energy Agency Director General Rafael +Grossi "is urging America not to consider military action." Grossi said, "I would hope there would never be a +time for a military attack." +McKenzie: Refugee Camps Are Breeding Ground For ISIS. +The AP (11/19, Burns) reports that on Thursday, Marine Gen. Frank McKenzie, +Commander of US Central Command, warned that "although the Islamic State extremist group is battered and +scattered, it cannot be fully defeated until the world finds a way to reconcile and resettle the thousands of people +displaced by years of war in Iraq and Syria." According to the AP, McKenzie "said there is no military means of +solving the problem of Mideast refugees and internally displaced persons, or IDPs, who await repatriation or +resettlement and represent what he called an unfortunate byproduct of armed conflicts." McKenzie, speaking to +the National Council on US-Arab Relations, said, "The systemic indoctrination of IDP and refugee camp +populations who are hostage to the receipt of ISIS ideology is an alarming development with potentially +generational implications." +WSJournal Analysis: Afghanistan Prepares For Insurgents After US Troop Removal. +The Wall Street Journal (11/19, A1, Rasmussen, Amiri, Subscription Publication, 7.57M) reports that as the +US withdraws troops from Afghanistan, the national government's security forces are preparing for Taliban +insurgents amid stalled peace talks with the militant group. Despite a February agreement with the Trump +Administration to reduce violence in the region, the Taliban have carried out over 13,000 attacks nationwide in +the most violent months since the start of the war. + + +Report Finds Australian Soldiers Unlawfully Killed 39 Afghans. +The New York Times +(11/19, Zhuang, 18.61M) reports that the inspector general of the Australian Defense Force released on Thursday +"the findings of battlefield misconduct" discovered in a "four-year examination," including the unlawful killing +of 39 Afghans by Australian soldiers. The Times says the report marks "the first time that a member of the +American-led coalition in Afghanistan has so publicly, and at such a large scale, accused its troops of +wrongdoing," though it "stopped short of calling the killings war crimes." However, "the highly redacted report +singles out "possibly the most disgraceful episode in Australia's military history,' and calls for the criminal +investigation of 19 soldiers," presenting "a stark contrast to how the United States has examined its own +actions." +Pompeo Visits West Bank Settlement, Denounces BDS Movement. +NBC Nightly News (11/19, story 6, 1:35, Holt, 5.84M) said Secretary of State Pompeo on Thursday "stepped into +controversy, visiting the disputed West Bank and Golan Heights, firmly taking Israel's side in the long conflict +over the territories." NBC's Andrea Mitchell added that in an effort to "make it harder for [Joe Biden] to reverse +the Trump foreign policy," Pompeo became "the highest ranking US official to set foot in an Israeli settlement, +land the Palestinians also claim in the West Bank." +The AP (11/19, Krauss) reports that in a "major policy shift" the State Department +"announced that products from the settlements can be labeled 'Made in Israel."* To the AP, Pompeo's visit to the +settlement and the State Department announcement "reflected the Trump administration's acceptance of Israeli +settlements, which the Palestinians and most of the international community view as a violation of international +law and a major obstacle to peace." Axios (11/19, Ravid, 521K) reports, "Pompeo's +announcement - two months before the end of the Trump presidency - puts another hurdle in place for Biden if, +as expected, he seeks to roll back Trump's policies on settlements." +Townhall (11/19, Barkoukis, +177K) reports Pompeo "announced the U.S. will now consider the anti-Israel Boycott, Divestment, Sanctions +(BDS) movement as 'anti-Semitic' and will seek to defund organizations that support it." Speaking in Jerusalem +alongside Israeli Prime Minister Benjamin Netanyahu, Pompeo said, "Today, I want to make one announcement +with respect to a decision by the State Department that we will regard the global anti-Israel BDS campaign as +anti-Semitic. …. I know this sounds simple to you, Mr. Prime Minister, it seems. It seems like a statement of fact, +but I want you to know that we will immediately take steps to identify organizations that engage in hateful BDS +conduct and withdraw U.S. government support for such groups." +The Washington Post (11/19, Morello, Hendrix, 14.2M) +reports critics "said Pompeo's announcements were designed more to buttress support among pro-Israel +evangelicals should Pompeo run for president and may not survive after [Biden] is sworn into office." Similarly, +Reuters (11/19, Amichay, Sawafta) says it is "unclear how many of Trump's +decisions will be reversed by a Biden administration." The New York Times + (11/19, +Halbfinger, Kershner, 18.61M) and The Hill (11/19, 2.98M)provide similar coverage. + + +Palestinians Mull Stopping Payments To Terrorists In Bid To Win Biden's Favor, The New York Times + (11/19, +Rasgon, Halbfinger, 18.61M) says that "in a bold move to refurbish their sullied image in Washington, the +Palestinians are laying the groundwork for an overhaul to one of their most cherished but controversial practices, +officials say: compensating those who serve time in Israeli prisons, including for violent attacks." The Times +says Palestinian officials are "eager to make a fresh start with the incoming Biden administration," and are +"heeding the advice of sympathetic Democrats who have repeatedly warned that without an end to the payments, +it would be impossible for the new administration to do any heavy lifting on their behalf." +Johnson Announces Biggest Increase In UK Military Spending Since Cold War. +The Washington Post (11/19, Adam, 14.2M) says British +Prime Minister Boris Johnson announced "the biggest boost in spending on Britain's armed forces since the end +of the Cold War, vowing to end an 'era of retreat' and to "stand alongside our allies.' Over the next four years, the +British armed forces will receive an extra 16.5 billion pounds (S21 billion), helping it to develop cyber and space +capabilities, modernize weapons and create an artificial intelligence agency." The Wall Street Journal + (11/19, Subscription Publication, 7.57M) casts the announcement as an effort to solidify the UK +as the main US military ally in Europe after Brexit. +The New York Times +(11/19, Landler, 18.61M) says Johnson "rolled out ambitious, back-to-back initiatives on military spending and +climate change this week," both of which "are likely to please a very important new person" in Johnson's life: +Joe Biden. The Times says Johnson "is eager to show he can work with the incoming president as well as he did +with the outgoing one." +French Journalists Say Government Is Cracking Down On Press Freedoms. +The Washington Post (11/19, McAuley, 14.2M) reports +"French journalists and advocates condemn what they see as a government crackdown on press freedoms" by the +French government. A provision in a new security law prohibits filming police. During a protest of the provision +on Tuesday, a journalist "was arrested and detained by police for filming the demonstration, even after having +presented law enforcement with his media credentials, according to a statement from the channel's director." +Critics Say Maduro Is Targeting Disillusioned Allies. +The New York Times (11/19, A1, Herrera, Kurmanaev, Romero, Urdaneta, Fernandez., 18.61M) reports the death of +Venezuelan radio host José Carmelo Bislick, a "lifelong socialist" who accused local Socialist Party leaders of +siphoning fuel during gasoline shortages, "appears to be part of a wave of repression against leftist activists +alienated by President Nicolas Maduro, who seems intent on consolidating power in parliamentary elections in +December." Critics say Maduro, "having crushed the political parties opposed to his version of socialism," has +"trained the state's security apparatus on disillusioned ideological allies, repeating the path taken by leftist +autocrats from the Soviet Union to Cuba." + + +Leader Of Human Rights Group Arrested In Egypt. +The New York Times +(11/19, Yee, 18.61M) reports Gasser Abdel-Razek, executive director of the Egyptian Initiative for Personal +Rights, "one of Egypt's leading human rights organizations was arrested Thursday night, the group said, joining +two staff members detained earlier this week and thousands of opposition figures, protesters and activists already +in prison." The group said Abdel-Razek "was arrested at his home in Cairo on Thursday evening, four days after +the arrest of the group's office manager, Mohamed Basheer, and a day after that of its criminal justice director, +Kareem Ennarah." The Times Egypt's "government under President Abdel Fattah el-Sisi has silenced most +dissent over the past six years." +Arrests Of Two Presidential Candidates Spark Violent Demonstrations In Uganda. +The New York Times +(11/19, Dahir, 18.61M) reports Ugandan police say seven people were killed and 45 others were wounded in +violent demonstrations that erupted Wednesday "after two presidential candidates were arrested while trying to +campaign ahead of a highly anticipated January election." Police "said they had arrested one of the candidates, +the popular musician-turned-lawmaker Bobi Wine, in the eastern district of Luuka, on accusations that his rallies +had breached coronavirus rules." Another candidate, "Patrick Amuriat, was arrested in the northwestern town of +Gulu, accused of planning to hold an unauthorized assembly." the arrests "fueled protests in major cities like +Jinja and Masaka, and in the capital, Kampala, and its suburbs." +Official Says Ethiopian Airstrike Hit Tigray University. +The AP (11/19, Anna) +reports according to a "senior" university official, "the latest airstrike by Ethiopia's military has struck the school +in the capital of the defiant Tigray region and caused major damage, while the United States says neither side in +the conflict is heeding calls for de-escalation." The official "described Thursday's airstrike in an email shared +with The Associated Press... The AP is not naming the official because they could not be reached directly." +The Washington Post (11/19, O'Grady, 14.2M) reports on the causes and the international response to the conflict the UN +human rights office has warned "risks spiraling out of control." This week, "a spokesman for the United Nations +High Commissioner for Refugees, said the agency now views the situation as a 'full-scale humanitarian crisis.'" +AP Analysis: Biden DOJ Unlikely To Ease Up On Chinese Targets. +The AP «https://apnews.com/article/donald-trump-beijing-coronavirus-pandemic-china-intellectual-property- +07c4ba551790692b8757aa5d2218764e> (11/19, Tucker) says the Justice Department during the Trump +Administration has lodged "a drumbeat of cases against" Chinese targets "ranging from hackers accused of +targeting intellectual property to professors charged with grant fraud." The AP adds, "But even after Democrat +Joe Biden's administration arrives, the law enforcement focus on China may not look radically different, in part +because of actions by Beijing that U.S. officials, lawyers and analysts say run afoul of international norms. Even +if the anti-China rhetoric is cooled in the White House, cases against agents of the Chinese government may well +continue apace, especially since some of the focus - including against trade-secret theft - preceded the Trump +administration." + + +WPost: Biden Can Help Zelensky Reignite His Anti-Corruption Agenda. +A Washington Post +(11/19, 14.2M) editorial says Ukraine's President Volodymyr Zelensky was "elected on an anti-corruption +agenda," but he "has recently seen that cause badly damaged by the Constitutional Court of Ukraine, which since +August has issued several rulings hamstringing key reforms, including a registry of assets for government +officials. " The Post says Zelensky "could use some help," and Joe Biden "is well-equipped to provide it." The +Post adds, "Once inaugurated, the Biden administration could take several steps to strengthen Mr. Zelensky's +hand," including "prepar[ing] sanctions against the Constitutional Court judges who are complicit in tainted +rulings," and "renew[ing] efforts to pursue criminal corruption cases against key Ukrainian oligarchs." The Post +adds that Biden should also "resuscitate the political alliance between Washington and Kyiv, which enjoys strong +bipartisan support in Congress but was all but wrecked by Mr. Trump." +The Big Picture +Headlines From Today's Front Pages. +Wall Street Journal: +CDC Urges Americans Not To Travel For Thanksgiving +Mnuchin Declines To Extend Several Fed Emergency Lending Programs + +US Home Sales Rose To 14-Year High In October +Afghanistan Braces For Worst As US Troop Withdrawal Accelerates +GM Ups Bet On EVs As Investors Swoon For Electric Cars +America Taxed Your Favorite Bordeaux? Try One With More Alcohol. +New York Times: +Trump Targets Michigan in His Ploy to Subvert The Election + +Trump's Attempts To Overturn The Election Are Unparalleled In U.S. History + +C.D.C. Pleads With Americans To Stay Home On Thanksgiving + +Why Charges Against Protesters Are Being Dismissed By The Thousand +https://www.nvtimes.com/2020/11/19/us/protests-lawsuits-arrests.html: +Trump Tax Write-Offs Are Ensnared In 2 New York Fraud Investigations +< https://www.nytimes.com/2020/11/19/nyregion/trump-fraud-investigations-taxes.html> +Maduro Cracks Down On The Leftists Who Once Revered Him + +Washington Post: + + +Confident His Victory Will Stand, Biden Tries To Stay Above The Fray + +Escalating Attacks Target Vote Certification Process +Trump Wages Full Assault To Overturn Election +CDC Urges Nation To Stay Home For Holiday +University Job Losses Mirror Pain Of Unequal Recession +^ +This Is How We Treat Each Other? This Is Who We Are?' + +Financial Times: +CDC Urges Americans Not To Travel For Thanksgiving < https://www.ft.com/content/8b492b58-fe67-4a17-8f0d- +ca02dla9936f?FTCamp=engage/CAPl/email/Channel_Bulletin//B2B> +Wirecard's Braun Says Regulators Not To Blame In Scandal < https://www.ft.com/content/d5dacbe1-5a95-4ef2- +9370-a36ef4eeee14?FTCamp=engage/CAPI/email/Channel_Bulletin//B2B> +The 'Blood, Sweat And Tears' Behind Zambia's Default +Brexit Talks Go Online After EU Team Member Contracts Covid-19 +Washington Times: +Trump Will Ask State Legislators To Alter Electors + +Legal Team: Rectified Fraud Flips Vote Results +State, Local Officials Divided On Penalties +Biden Brings Back Obama Veterans +Danish Research On Face Masks Counters Messages Of Protection + +Palestinians Bank On Better Time With Biden + +Story Lineup From Last Night's Network News: +ABC: COVID Surge; Vaccines; COVID-Thanksgiving; Presidential Transition; Trump-Election Results; +COVID-Counties With Highest Death Toll; Prince William-Princess Di Interview; New York City-Woman +Shoved Onto Subway Tracks; Wife Brings Husband Home From Hospital To Celebration. +CBS: COVID-Thanksgiving; COVID Surge; Trump-Election Results; Presidential Transition; New York City- +Public Schools Shutdown; Prince William-Princess Di Interview; Utah-Patient Plays Violin As Thank You. +NBC: Presidential Transition; Trump-Election Results; COVID-Thanksgiving; Vaccines; COVID Surge; +Pompeo-Israel Visit; Iran-Uranium Stockpiles; Florida-Teens Shot By Deputy; COVID-Impact on Older Adults; +COVID-Disinfectants; Movies. +Network TV At A Glance: +COVID-Thanksgiving - 9 minutes, O seconds +COVID Surge - 7 minutes, 55 seconds +Presidential Transition - 7 minutes, 50 seconds + + +Trump-Election Results - 4 minutes, 5 seconds +Story Lineup From This Morning's Radio News Broadcasts: +ABC: White House Coronavirus Task Force Briefing; California-COVID Curfew; COVID-Thanksgiving; +Presidential Transition; House Dems-GSA Briefing. +CBS: Georgia-Recount Confirms Biden's Win; Giuliani-Press Conference; New York City-Public Schools +Shutdown; White House Coronavirus Task Force Briefing; Unemployment; SpaceX/NASA Crew. +FOX: Georgia-Recount Confirms Biden's Win; White House Coronavirus Task Force Briefing; COVID- +Pentagon Official Tests Positive; California-COVID Curfew. +NPR: Presidential Transition; White House Coronavirus Task Force Briefing; COVID-Thanksgiving; Georgia- +Recount Confirms Biden's Win. +Washington's Schedule +Today's Events In Washington. +White House: +* President Trump +- Participates in a virtual Asia-Pacific Economic Cooperation (APEC) Economic Leaders' +Meeting; delivers remarks on delivering lower prescription drug prices for all Americans. +* Vice President Pence — Delivers remarks at a Defend the Majority Rally in Canton, Georgia; delivers remarks +at a Defend the Majority Rally Gainesville, Georgia. +US Senate: +* Senates convenes for pro forma session - Senate convenes for pro forma session * Chamber on recess from 18 +Nov - 30 Nov +Location: U.S. Capitol, Washington, DC; 8:15 AM +US House: +* House Armed Services Committee hybrid hearing on the U.S. military mission in Afghanistan - Hybrid +hearing on "The US military mission in Afghanistan and implications of the peace process on US involvement', +with testimony from former U.S. Foreign Service career ambassador Ryan Crocker; Columbia University +International and Public Affairs Professor Dr Stephen Biddle; and Center for Strategic and International Studies +International Security Program Senior Adviser Dr Seth Jones * Held via WebEx and in Rm 2118, Rayburn House +Office Building; 9:00 AM +* House meets for legislative business - House of Representatives meets for legislative business, with agenda for +the week including 'H.R. 8294 - National Apprenticeship Act of 2020' +Location: U.S. Capitol, Washington, DC; 9:00 AM +* Oversight subcommittee hearing with testimony from Internal Revenue Service Commissioner Charles Rettig; +10:00 AM +* Tom Lantos Human Rights Commission virtual briefing on indigenous people in the Americas - Tom Lantos +Human Rights Commission online hearing on 'The Rights of Indigenous Peoples in the Americas", held via +Cisco Webex, with a panel of Amazon Watch Executive Director Leila Salazar-Lopez, EarthRights International + + +Strategic Impact and Campaigns Director Keith Slack, Organizacion Nacional de Mujeres Andinas y +Amazonicas del Peru President Melania Canales Poma, Indian Law Resource Center Senior Lawyer Leonardo +Crippa, Bank Information Center Policy Director Jolie Schwartz, and Land Is Life Chair Brian Keane; 10:00 AM +* House Speaker Nancy Pelosi holds weekly press conference +Location: HVC Studio A, U.S. Capitol Visitor Center, Washington, DC; 10:45 AM +* House breaks for Thanksgiving recess - House of Representatives breaks for Thanksgiving District Work +Period +Cabinet Officers: +* Secretary of State Pompeo continues France / Turkey / Georgia / Israel / UAE / Qatar / Saudi Arabia trip - +Secretary of State Mike Pompeo continues trip to France, Turkey, Georgia, Israel, the United Arab Emirates, +Qatar, and Saudi Arabia, with agenda, respectively, including meeting President Emmanuel Macron, Foreign +Minister Jean-Yves Le Drian, and other senior officials in Paris; meeting the Ecumenical Patriarch of +Constantinople, Bartholomew I, in Istanbul; meeting President Salome Zourabichvili, Prime Minister Giorgi +Gakharia, Foreign Minister David Zalkaliani, and the Patriarch of the Georgian Orthodox Church, Ilia II in +Tbilisi; meeting Prime Minister Benjamin Netanyahu in Israel; meeting Abu Dhabi Crown Prince Mohammed +bin Zayd in the United Arab Emirates; meeting Emir Tamim bin Hamad Al Thani and Deputy Prime Minister +and Foreign Affairs Minister Mohammed bin Abdulrahman Al Thani in Qatar; and meeting Crown Prince +Mohammed bin Salman in Saudi Arabia +Visitors: +*No visitors scheduled +This Town: +* CFR virtual discussion with European Commission president - Council on Foreign Relations hosts European +Commission President Ursula von der Leyen for an online event on her vision for a new transatlantic agenda, +prospects for cooperation between the EU and the U.S., and the future of multilateralism; 10:00 AM +* CCJ webinar on criminal justice and the 2020 election - Council on Criminal Justice 'On the Ballot: How +Criminal Justice Played in the 2020 Election' webinar, with former California Governor Jerry Brown, Florida +state Sen. Jeff Brandes, Cook County, IL, State's Attorney Kim Foxx, South Carolina state Sen. Gerald Malloy, +Washington state Rep.-elect Tarra Simmons, and CCJ Vice President Abby Walsh; 1:00 PM +* National College Fed Challenge winner announcement - National College Fed Challenge online winner +announcement, beginning with a greeting from Federal Reserve Board Chair Jerome Powell. The competition, +which is held virtually this year, aims to foster students' interest in economics and finance as fields for advanced +study and careers. Undergraduate student teams analyze economic and financial conditions and formulate a +monetary policy recommendation, modeling the Federal Open Market Committee; 3:00 PM +* NASA holds prelaunch briefings ahead of Sentinel-6 mission launch - NASA holds prelaunch briefings ahead +of the launch of the Sentinel-6 Michael Freilich satellite - currently scheduled for tomorrow - with a science +briefing (3:30 PM EST), and news conference (5:00 PM EST) * The satellite is part of the Sentinel-6/Jason-CS +mission (aka Jason Continuity of Service or Jason-CS), a partnership between NASA, the National Oceanic and +Atmospheric Administration, the European Space Agency, and European Organisation for the Exploitation of +Meteorological Satellites * Mission is designed to provide operational ocean altimetry to provide continuity of +ocean topography measurements and continue the long-term global sea surface height data record begun in 1992 +by the Topography Experiment (TOPEX)/Poseidon and Jason 1, the Ocean Surface Topography Mission +(OSTM)/Jason-2 and Jason-3 missions; 3:30 PM +* U.S. Supreme Court meets in private conference to discuss cases and vote on petitions for review + + +Copyright 2020 by Bulletin Intelligence LLC Reproduction or redistribution without permission prohibited. +Content is drawn from thousands of newspapers, national magazines, national and local television programs, +radio broadcasts, social-media platforms and additional forms of open-source data. Sources for Bulletin +Intelligence audience-size estimates include Scarborough, GfK MRI, comScore, Nielsen, and the Audit Bureau +of Circulation. Data from and access to third party social media platforms, including but not limited to Facebook, +Twitter, Instagram and others, is subject to the respective platform's terms of use. Services that include Factiva +content are governed by Factiva's terms of use . +Services including embedded Tweets are also subject to Twitter for Website's information and privacy policies +. The FBI News Briefing is published five days a week by +Bulletin Intelligence, which creates custom briefings for government and corporate leaders. We can be found on +the Web at Bulletinintelligence.com, or called at (703) 483-6100. diff --git a/vision-fixhub/ds9-parsed-01/1ae1c7d3e3ea881b5aeeacae2ac3fbfd554b14bab23ca29e88b0e8d44afab5ea.receipt.json b/vision-fixhub/ds9-parsed-01/1ae1c7d3e3ea881b5aeeacae2ac3fbfd554b14bab23ca29e88b0e8d44afab5ea.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..614bba60d4666ad52bb8cd0eeb72c642fbb9cd95 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1ae1c7d3e3ea881b5aeeacae2ac3fbfd554b14bab23ca29e88b0e8d44afab5ea.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -910, + "dataset": "marble-joined", + "doc_id": "1ae1c7d3e3ea881b5aeeacae2ac3fbfd554b14bab23ca29e88b0e8d44afab5ea", + "engine": "marble-apple-vision", + "event_count": 220, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "9369756a05aa093034c99e102b771b3c2c849e4fea6014533bdf58c53dc312e2", + "output_sha256": "933c2362b0fc1115c43ee6f7580de90bbde1faa881a4a68ebaa222593cd73e4d", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1ae2031f0ebce998164ab6dad80bb682b509f38f7ac19c45aae03ab34a22d276.md b/vision-fixhub/ds9-parsed-01/1ae2031f0ebce998164ab6dad80bb682b509f38f7ac19c45aae03ab34a22d276.md new file mode 100644 index 0000000000000000000000000000000000000000..6759e5aff9352a8bf194f73e9352458224f9ca0b --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1ae2031f0ebce998164ab6dad80bb682b509f38f7ac19c45aae03ab34a22d276.md @@ -0,0 +1,22 @@ +From: Nicole Simmons +To: 'Nathan NYSD Chambers' < +Cc: Jeff Pagliuca +Laura Menninger +'' C +2. " +Subject: [EXTERNAL] U.S. v. Maxwell, Case No. 20 Cr. 330 (AJN) [Joint Ltr. re. Rule 412 and 702 +Motions Hearing Date] +Date: Wed, 03 Nov 2021 03:32:23 +0000 +Attachments: 2021.11.02_Joint_Letter_re_defense_experts_and_Daubert_hearing_to_defense.pdf; +Ex._A_Def._Expert_Notice_[proposed_redactions] pdf +Inline-Images: image001.jpg +Dear Judge Nathan: +On behalf of the Parties, please see the attached correspondence and enclosure. +Regards, +Nicole Simmons +Nicole Simmons +Haddon, Morgan and +Foreman, P.C. +- +DIRECT: 720.287.5835 +www.hmflaw.com diff --git a/vision-fixhub/ds9-parsed-01/1ae2031f0ebce998164ab6dad80bb682b509f38f7ac19c45aae03ab34a22d276.receipt.json b/vision-fixhub/ds9-parsed-01/1ae2031f0ebce998164ab6dad80bb682b509f38f7ac19c45aae03ab34a22d276.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..e51ab23850aa74b999c1f4544459b9ea2b028631 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1ae2031f0ebce998164ab6dad80bb682b509f38f7ac19c45aae03ab34a22d276.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "1ae2031f0ebce998164ab6dad80bb682b509f38f7ac19c45aae03ab34a22d276", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "976cf089f8e915f2c11debecb15be9bbe96835e1397368a594bfe8540fdd5133", + "output_sha256": "4c0625c63d62bab1017cdd26afd28ac24472c97883ae6b68ed671856949e0c70", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1ae5df65472b05c846449ef6332e5e41488d28cfb65319f2ab37c654135ef89c.md b/vision-fixhub/ds9-parsed-01/1ae5df65472b05c846449ef6332e5e41488d28cfb65319f2ab37c654135ef89c.md new file mode 100644 index 0000000000000000000000000000000000000000..c10f2b1ed3e83b791f35884a554b2cbd28a7180a --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1ae5df65472b05c846449ef6332e5e41488d28cfb65319f2ab37c654135ef89c.md @@ -0,0 +1,23 @@ +, OFFICIAL RECORD +FD-1057 (Rev. 5-8-10) +UNCLASSIFIED +FEDERAL BUREAU OF INVESTIGATION +Electronic Communication +Title: (U) EC return of property to Alfredo +Rodriguez +Date: +From: MIAMI +MM-PB2 +Contact: +Approved By: +Drafted By: +Case ID #: 72-MM-113327 +(U) RODRIGUEZ, ALFREDO - SEE SUB +Synopsis: (U) Document return of property to ALFREDO RODRIGUEZ. +Full Investigation Initiated: 10/28/2009 +Enclosure (s): Enclosed are the following items: +1. (U) FD 597 return of property to ALFREDO RODRIGUEZ. +Details: +Document return of property to ALFREDO RODRIGUEZ. +06/17/2013 +UNCLASSIFIED diff --git a/vision-fixhub/ds9-parsed-01/1ae5df65472b05c846449ef6332e5e41488d28cfb65319f2ab37c654135ef89c.receipt.json b/vision-fixhub/ds9-parsed-01/1ae5df65472b05c846449ef6332e5e41488d28cfb65319f2ab37c654135ef89c.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..0fb69a1004c02a6b1f9ddcdbdd5c926e5269fbd1 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1ae5df65472b05c846449ef6332e5e41488d28cfb65319f2ab37c654135ef89c.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "1ae5df65472b05c846449ef6332e5e41488d28cfb65319f2ab37c654135ef89c", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "8052433fb5bfd79b2632ae2b55cdcd3c8c64b9216eba9f06e1b7065f78e007d2", + "output_sha256": "2f38b20fddab942aa76dbf6dbf43a40f0e8633d0479fba8514ad10058fb8a465", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1ae99e1dbdf0e2cdf4ef4869dc3b5691c83979095f0fab655e6cdfc264997434.md b/vision-fixhub/ds9-parsed-01/1ae99e1dbdf0e2cdf4ef4869dc3b5691c83979095f0fab655e6cdfc264997434.md new file mode 100644 index 0000000000000000000000000000000000000000..1be0adcfd3611240b9fd7896be6c96fb4f99069e --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1ae99e1dbdf0e2cdf4ef4869dc3b5691c83979095f0fab655e6cdfc264997434.md @@ -0,0 +1,42 @@ +From: Christian Everdell +To: " +Ce: " +I" < +≥. "Mark S. Cohen" « +, "Jeff Pagliuca" +(USANYS)" +Laura +Menninger +Subject: RE: Letter +Date: Tue, 22 Sep 2020 19:29:12 +0000 +6pm works. Can you circulate a dial-in? +From: +) [mailto: +Sent: Tuesday, September 22, 2020 11:14 AM +To: Christian Everdell +Cc: +Subject: Re: Letter +Hi Chris, +(USANYS); Mark S. Cohen; Laura Menninger; Jeff Pagliuca +Are you available for a call today? Our team is free at 5:30 p.m. or later today, if that works. +Thanks, +Sent from my iPhone +On Sep 21, 2020, at 10:34 PM, Christian Everdell < +wrote: +Please see the attached letter regarding Ghislaine Maxwell. Thank you in advance for your attention to these matters. +Regards, +Chris +Christian Everdell + +800 Third Avenue +New York NY 10022 +www.cohengresser.com +New York | Seoul | Paris | Washington DC | London +CONFIDENTIALITY NOTICE: The information contained in this e-mai may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only +the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient, you are hereby notified that any +review, dissemination or copying of this e-mail or the information contained herein is prohibiled. If you have received this e-mail in error, please immediately notify +the sender by telephone and permanently delete this e-mail. Thank you. + + +PRIVACY: A complete copy of our privacy policy can be viewed at: https://www.cohengresser.com/privacy-policy +< 2020.09.21 Letter to Government re Discovery and Prison Conditions. PDF> diff --git a/vision-fixhub/ds9-parsed-01/1ae99e1dbdf0e2cdf4ef4869dc3b5691c83979095f0fab655e6cdfc264997434.receipt.json b/vision-fixhub/ds9-parsed-01/1ae99e1dbdf0e2cdf4ef4869dc3b5691c83979095f0fab655e6cdfc264997434.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..2fd5ccd3258920173c73693b1b05ef5eaca9f60a --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1ae99e1dbdf0e2cdf4ef4869dc3b5691c83979095f0fab655e6cdfc264997434.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "1ae99e1dbdf0e2cdf4ef4869dc3b5691c83979095f0fab655e6cdfc264997434", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "2c76fc62845bcdf15888b7116344e14ee0e27c832d668497ca72b7e51498f53d", + "output_sha256": "8c8bcf4fff655b420d0c553279f3f7b4065e138270b7b2622647b37f69e68387", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1b1dbf4b928572a9166f564474d5f183f68befadc2d33b5e05e75e0e2dede9b6.md b/vision-fixhub/ds9-parsed-01/1b1dbf4b928572a9166f564474d5f183f68befadc2d33b5e05e75e0e2dede9b6.md new file mode 100644 index 0000000000000000000000000000000000000000..a127e9e536794047ae7f61393dc2d7452d62e68f --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1b1dbf4b928572a9166f564474d5f183f68befadc2d33b5e05e75e0e2dede9b6.md @@ -0,0 +1,9061 @@ +1 +DIGITALLY RECORDED +SWORN STATEMENT +OF +OIG CASE +2019-010614 +DEPARIMENT OF JUSTICE +OFFICE OF THE INSPECTOR GENERAL +SEPTEMBER 23, +RESOLUTE DOCUMENTATION SERVICES +Suite 285 +Agoura Hills, + + +APPEARANCES : +OFFICE OF THE INSPECTOR GENERAL +BY: +BY: +WITNESS: +OTHER APPEARANCES: +NONE +2 + + +1 +: This is Special Agent +Today is September 23, 2021. +The time +3 +is 9:20 a.m., and we are beginning the +interview. My name is | +Special Agent with the U.S. Department of +7 +8 +Justice, Office of the Inspector +General, +York Field Office, and these are my +credentials. +1: I see. +10 +: This interview with the +11 +Federal Bureau of Prisons correctional officer +12 +lieutenant, +• Did I +say +that +13 +right? +14 +: Yes. +15 +16 +17 +an official U.S. Department of Justice, +1 Department due gael eat rice +of the Inspector General, DOJ investigation. +18 +Today's date is September 23rd, 2021. +The time +19 +is 9:20 a.m. +This interview is beind conduced +20 +at the Metropolitan Correctional Center in New +21 +Also present is DOJ Senior Special +22 +Agent. +23 +And +24 +these +25 +are my +credentials. +Thank you. +This +interview will be + + +4 +1 +3 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +recorded by me, Special Agent +Could everyone please identify themselves for +the record, and spell your last name? +start, again, I am DOJ/OIG Special +Agent, +Senior Special Agent +I'm correctional lieutenant +Thank you. This is an +official DOJ/OIG investigation into the death +of inmate Jeffrey Epstein, and you are being +asked to voluntarily provide answers to our +questions. +Will you agree to a voluntary +interview with the DOJ/OIG? +Thank you. +Please review DOJ/OIG form +The form states, United States +Department of Justice, Office of +Inspector +General, Warnings and +Assurances +to Employee +Requested to Provide Information +on a Voluntary +"You are being asked to provide +information as part of an investigation being + + +3 +7 +9 +10 +11 +12 +1 +3 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +5 +conducted by the Office of the Inspector +General. +This investigation is being conducted +pursuant to the Inspector General Act of 1978, +as amended. This investigation pertains to job +performance failure, and security failure. +This is a voluntary +interview. +Accordingly, +you do not have to answer questions. +No +disciplinary action will be taken againsanyou +if you choose not to answer questions. +statement you furnish may be used as evidence +or agency +"I understand the Warnings and +Assurances stated above and I am willing to +make a statement and answer questions. +Marninge, a2ing to +The waiver +promises or threats have been made +to me, and +no pressure or coercion of any kind has been +used against me. " Please read the form, and if +you understand -- +: Okay. +-- can you please +sign +where +it says employee name, +signature? +1: +Need a pen? +Thank you. +Move that out of the +way. + + +6 +1 +2 +5 +6 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +(Indiscernible +*00:03:03) +Thank you. +Lieutenant +, do you +understand the form? +Yes, sir. +And you are signing +the +•form +also. +MS +MR +MS +MS +MR +Mm-hmm. +Thank you. +That's it. +Do my name? +I'll fill out the +-- that part. +No problem. +Thank you. +Thank you. +I can fill it out, +This is Agent +signing on the signature of the Office +Inspector General. +Thank you. +And I am +going to sign as the witness +and put + + +7 +3 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Thanks. +Before starting the +interview, I would like to place you under +oath. Lieutenant +1, can you please raise +your right hand? +Sure. +: Do you swear to tell the +truth +and nothing but the truth during this +interview? +Yes, sir. +Thank you. +Please let me +know +if you do not understand any questions, +and I will repeat it or try to rephrase it for +you. +: What is your current home +address? +A1B, Brooklyn, New York. +11209. +Thank you. What is your date +of birth? +What is your social +security +number? + + +8 +And what is your +1 +2 +: +Thank you. +current cell +phone number? +: What is your highest level of +5 +education? +College. +Bachelors. +Which college? +he College or New Rochelle +And what was your -? +That' +10 +in New York? +11 +12 +1: It's upstate New Rochelle, +New York. +13 +_: +And what was vour major in +14 +I was in psvcholoav, thouah i +15 +believe is liberal arts. +16 +What did +you do prior to +17 +working for the BOP? +18 +I worked for the New York +19 +City Police Department as a school safety +20 agent. +21 +And when did you start +22 +working for +the BOP? +23 +When did I start? +24 +Start. +25 +May 18, 2003. + + +9 +1 +2 +5 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +When did you graduate +college? +May of 2012. +Okay • +Thank you. Do you have any +military service? +started +with +the +-? +from +No, sir. +And you said in 2003, you +the BOP? +And when did you -? What was +When +did you first start? +MDC Brooklyn. +MDC Brooklyn? +And you started as a C.O.? +BOP training? +okay. When did you graduate +You don't remember the +answer? +after you started, correct? +It was probably +shortly + + +10 +to +MCC? +Okay. And when did you +I came to MCC January 31st, +And have you been here +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +in +the +a +And have you been +SIS +Shop since then? +I went into the SIS Shop in +2016? +And then, in 2019, were +lieutenant with the SIS Office? +Great. +That's the basic +round +we +to -- +Yeah, no -- +on that. +-- you can go +into the + + +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +11 +questions. +So, what we're going to talk +to you today about is Mr. -. +Are you aware of +who Jeffrey Epstein is? +: And was he an inmate +at the +MCC? +Were you familiar with him +while +he +was housed here at the MCC? +Yeah. I would say yes. +Let's start off. +Well, +were you familiar with his first suicide +attempt? +I did the first +investigation on that one. +Did that approximately, did +that +happen approximately around July 23rd, +20193 +happened? +Can you tell us what +Based on your investigation and what +you found. +MS. l +I: Based on my investigation, +once I found out about the suicide +attempt when + + +3 +5 +6 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +12 +I came to work, I spoke to the staff team, as +well as his cellmate, to try to get both of +their sides of the story. +1: Was that Tartaglione? +Yes. Mr. Tartaglione. +to Epstein in the R&D +area. +He was a little hesitant, at first, +about speaking to me. +le kept asking me whe +You know, what was I interviewing him +And I explained to him my position as the +SIS Lieutenant, to ensure his safety needs are +met, and, you know, I questioned him about the +alleged suicide attempt, and he said, I don't +remember what happened. +I remember him telling +me he went to get a drink of water, and all he +remembered is he was on the floor. +staff will come in and he wouldn't provide much +of anything else. +You know, +other? +You know, we were just cellmates at the +time. +You know, when you went to +get the drink +of water, and he would +-. +Either he +say he was +laying on the floor, or sitting on +the bed. + + +1 +2 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +13 +You know? I asked him, you know, are you +telling me the truth? +Is there anything that +you would like to volunteer? +You know, did you +intentionally try to harm yourself? +times, like, I didn't try to harm myself. +know what happened. I just got a drink +of water, and next thing you know, I was on the +floor. +Did you ask him if +attempted to harm him? +And what did he +say to +that? +And he said no. +And he said Tartaglione +did +not +- try to harm him? +He said he did not. +Was there a noose +at that point? +around his neck! think it was. +Do you know? +I think it +was. +At the time. +It was a rope, +I want to +say, or something to that effect. +They had + + +1 +3 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +brought down to the SIS Shop, that they found. +I can't tell you that they found it around his +neck because I can't remember. To be honest +with you. +: +And how did the C.O.s become +aware that he had possibly tried to +commit +suicide? +: To my knowledge, Mr. +Tartaglione is who alerted the +officers, by +banging on the door. +_: And +when the officers found +him, did they find a noose around his neck? +How did they find him, do you recall? +: I can't recall. +I know that +they found him on the floor. +But I can't +recall if it was around his neck. +And Mr. Epstein stated that +Tartaglione did not try to kill him. +1: Yes. +Except there was a noose. +Did he mention if +noose himself, or how +the noose came +he made the +about? +He didn't. +And what was your +impression + + +1 +2 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +15 +after talking to him? Did you believe that he +tried to take his own life? +I kind of had mixed feelings +about it because he was insistent on that he +didn't try to take his own life. +You know? +Normally, a person will say, okay, this was +going on, and he kept saying, no, +I didn't try +to kill myself. I didn't try to kill myself. +I don't know what happened. +Sor +I mean, during +the investigation and conclusion, I can't say +that he, you know, he did or he didn't, +to be +honest with you. +From the answers +that I was +getting back from him. +But he +stated himself that +Tartaglione didn't try to kill him? +: So, the only other option +would +have possibly been that he +tried to +commit suicide himself? +: Right. +or do you believe +that +inmate Tartaglione attempted to harm +him? +don't. + + +16 +1 +2 +3 +4 +8 +9 +10 +11 +1 +2 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +I don't. +: +So, was it inconclusive? +It was pretty inconclusive +hat is vour feeling of +what happened, though? Being a trained +investigator. +: I don't know if it was, you +know, looking back, I kind of felt, like, okay, +was this, like, did he intentionally try to do +something to get our attention? +You know, then +I leaned to, maybe he didn't. +You know? +You +have two inmates in the cell. +And I'm, you +know, I'm also looking at did, you know, did +Tartaglione tell me the truth. +You know, I +really can't say what happened because you +nave, you know, Mr. Epstein saying, you know, +no, he didn't try to do anything to me, and I +asked about them interacting. Do they talk? +And he's, like, yes, we talk. +You know, we're cellmates. +read books. +reason for me to believe that +you know? +Mr. Tartaglione, +you know, tried to harm him because Epstein +didn't give me that impression. +And was he placed +on + + +17 +1 +3 +4 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +suicide watch as a result? +: Yes. +only be placed on suicide watch if the thought +was that he was attempting to self-harm? +: If that was the thought made +thought made +by the psychology department -- +1: Okay. +- they would definitely +place you on suicide watch. Even if you said +it out of playing, they would place you on a +suicide watch. +made that determination that he would be placed +inason do you know ho el placed +on suicide watch? +I don't know. +1: Okay. +I don't know. +I: But it wasn't based upon +your investigation? +Was it actually your +investigations conclusions, which +actually +brought him off of suicide watch? + + +18 +1 +2 +3 +4 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: No? +No. I wouldn't say that. +Normally, they do their evaluation, the +psychology department, and when I guess they +determined that the inmates could return to the +general population, then they will release them +from the suicide watch. +So, the SIS +determination of inconclusive doesn't actually +play into if he's on or off of suicide watch. +I don't think it did. +I don't think it did. +Inmate Tartaglione. +Had he +been at the MCC for a long time? +He's been at the MCC +for quite some time. +Did he have any history of +violence with any of the inmates? +: +Not violence. +He was more of +a +cellphone +carrier. +I think I caught him with +a cellphone at a time. +Is -- +You know +-- is that why -- + + +1 +3 +7 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +-- something to that effect. +-- he was in the SHU? +:. I think that's why he +was in +SHU at +that time. +Do you recall how +Tartaglione +got chosen to be Epstein's inmate? +Cellmate. +Cellmate. Sorry. +Oh. +Sorry. +Actually, I don't. +I don't +know +how they put the two of them together. +Normally, if it's, you know, if we're vetting +cellmates for, say, that they would ask me, you +know, who do you think would be more suitable! +in Epstein's case, nobody asked +don't know how they became cellmates. +You don't know if +any +decisions were made by the higher ups, in +regards to him? +_: I don't know. +And after this +incident happened, was Tartaglione removed from +the cell? +Or was inmate Epstein removed +from +the cell? + + +1 +3 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +20 +: I'm not sure which one were +removed, or if they both was placed in +different cells, with different cellmates. +I'm +not sure. +: Well -. +Well, inmate Epstein was +actually placed on suicide watch. +But I'm not sure if +Mr. Tartaglione remained in that same cell. +But he was +in the SHU +after +that meeting with him? +Were there any issues +with +him after that incident? +With? +With Tartaglione. +: Not that I'm aware of. +Okay. And we asked about the +suicide watch. +Now, being that if an inmate +was - an incident like this happened, +skip the fact that it was inmate +Epstein +let's +I: -- if an inmate was found +with a noose, +and there was a possibility of a +suicide, +what's the normal procedure + + +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +21 +happens? What happens to the inmate? +What +does the MCC do with the inmate? +MS. I +•: If it was an incident where +he was found, let's say, while I was +bin trom the cell, dorse mediate move +him from the cell, of course, +Notify psychology of what occurred. +point, I would be placing him on suicide watch, +with an inmate companion watching him, but I +would make sure, you know, we take all of his +clothing, everything, and he would get nothing +but a suicide snog. +And a suicide blanket. +And how long does that normal +suicide watch last? +: It can vary. +ever +seen somebody put om suicide watch? +nate the ingree your ye +can't tell you a, you know, one or two days, or +three. But maybe a couple of days. +1: +Based on what we've +out, it looks like this attempt was on +23rd, and 24th morning, he was removed +from +suicide watch and placed in psych observation. + + +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +22 +: Do you think that was too +early to remove him from suicide watch? I know +this is -. +What is the difference between +psych op and suicide watch? +It's the same area. +Psych +ops is, they just get their clothing back. +But +they +are still being watched. +It's the same thing, +right? +It's the same thing. +They're still being watched +by an +inmate +companion. +Is there any other benefit to +being in suicide watch - in terms of suicide +watch versus psych observation - any benefits +to being in psych ops? +: Yeah. You have your +clothes. +You get your clothes. +Your clothes. +I mean -. +Was it +- if it was any +• other +inmate +- would they have given back his clothes +that fast? + + +1 +2 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +23 +: I don't know. +That would be +the psychology department determination. +: Okay. Did you - now, +forward, I think around July 30th, I believe, +that he was removed from psych observation, and +he was placed back in the SHU - do you recall +hearing why he was removed from psych +observation +: No. +: -- and placed back in the +SHU? +: No. +: Do you have any questions? +Just to go back, +file back to Nicholas Tartaglione. +I knew +you - when asked - you said you weren't, +you +knew he was more of a cellmate carrier kind of +a guy, but do you know of any instances where +he actually did harm another inmate? +: +I: No? +1: +Great. Thank you. +All right. +Anything +else on +the -? + + +24 +1 +2 +4 +8 +9 +3 +4 +Nope. +You can go ahead. +Now, let's go to August +9th. +Were you working on August 9th, 2019? +I think I was off August 9th. +Let me just -. +Would +you be +Would your name be on +the +-? +On the roster? +On the roster. +I would be on the +roster. +I think I was off, or maybe I left +early August 9th. +Or something. +I can't +remember. +I'm going to provide you a +copy +of August 9th +-- roster. MCC SHU roster. +If you can take a look at it +and let me know if you were on +schedule. +No. I'm not on it. +: +And who +-- + + +1 +2 +4 +00 0 +9 +1 +2 +3 +4 +5 +25 +: Oh, sorry. +-- where would that be +listed? +Sorry. +: I thought you were going +to -. +I thought we were just talking about +this. This next one. +just going back, before we talk about the +suicide watch, psychological observation room, +we'll go - did you hear anything about anyone +contacting the MCC and requesting that he be +removed from psychological observation? +_: +NO. +that, like, for instance, his attorneys were +trying to get him off of psychological +observation, so that they could continue with +their attorney/client visits? +No. I didn't hear. +•: You never heard +that? +Perfect. +Now, +we +can move to the +actual +So, +I showed you the August +9th roster. +You said you are not on there? +Can +I -• +Actually -- + + +26 +1 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Where -? +-- I would be under the SIS +Lieutenant, +if you -. +Under the SHU +Lieutenant. I would be under the SIS +Lieutenant +1: +And there is - on that 9th, +what +does +it +state there? It savs unassianed? +Unassigned. +: So, no one +was working that +day? +1: +No. I was the only SIS +Lieutenant. +I'm trying to think. +Nobody was in there that day. +1: Can you just circle that for +us? +Sure. +So, you were not here on +the 9th, +is +what you are saying? +And no one was? +Not in the SIS Shop. +Oh, wow. Is that +abnormal, for being a Friday, without anyone + + +27 +1 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +being in SIS? +Actually, the SIS Technician, +her days off is Friday and Saturday. +Oh, wow. +And at the time, it was only +two of us working in the whole +area. +So, there was only one +tech +and lieutenant? +One tech and one lieutenant. +1: Would the SIA have been +on? +: We didn't have one +at +the +time. +: Oh, so it was +literally +just +the two of you? +Okay. So, this +wasn't, +then, abnormal that, on a Friday, +working? +No. I normally -- +: +(Indiscernible +*00:19:28). +-- on a Friday, I would nave +been on because she would have been off. +took +off -- +So, I + + +28 +1 +3 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +(Indiscernible *00:19:36). +-- on Friday. I can't recall +why. +MS +(Phonetic Sp. +Sure. +But -. +And who was the SIS tech? +Her name is +*00:19:43). +All +right. +But she wasn't here? +No. She wasn't here. +And do you recall +that +you actually - I know that the schedule says +that +- but do you recall not being here? +Thinking that it was the day before. +Put this here just in +case we +need to go back. +1: Okay. +: When did you first become +aware that Epstein's cellmate, +inmate Reyes, +was +removed as his cellmate? + + +29 +1 +The day of the actual +suicide. +When you say actual +suicide, +which +would be -- +5 +August 10th. +-- August 10th. +Saturday, when you came in, +that' +when you learned -? +10 +When I came in. Mm-hmm. +11 +12 +Were you aware that, +when you came in, +what were you aware of why +13 +Reyes was removed from the institution? +14 +MS. I +liter speaking to him, thei +15 +told me he got released from court. +16 +17 +what I was told. +Who told you that he was -? +18 +Not sure. +19 +20 +Not sure. +I can't remember. +21 +So, your understanding +was, +22 +Reyes went to +court +and he just didn't come +23 back? +24 +MS. I +25 +understand. +That's what I + + +1 +2 +5 +7 +8 +9 +1 +0 +1 +2 +1 +3 +1 +4 +1 +5 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +30 +What's a normal procedure, +how do the MCC find out if an inmate is being +moved to court, or being transferred +out? +From court, you're saying? +: From court. +Let's say -- +You're talking about court. +-- Reyes was +-. +Well, no, in this case, +did you ever hear that Reyes actually never +went to court, he actually was transferred to +another institution? +: +I heard he went to +court. +So, even to this date -- +And was released from court. +- to this date, did you +ever hear that, +that he never went to court? +He actually was +transferred? +No. I've never heard that. +Oh, you've never even +heard +that? +MR +that's what happened. +sorry. +He never went +Because +to court. +He was transferred. + + +31 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: I still don't know. +1: +That's what +(Indiscernible *00:21:24). +: +That's news to me, right. +I +have +Sure. +assumed that he went to +court, +and, you know, maybe, I thought maybe he +made bail or something +1: +- and he got released from +court. +But that's what everybody +was saying, that he actually went to +court? +" Yes. +So, based on what we - our +investigation, I'll show you an email. +This +email is dated -. +This is from +from the U.S. Marshals Service. +And it went to, it looks +like +the employees at the R&D. +Mm-hmm. +And it says, transfer + + +1 +2 +3 +4 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +32 +inmates on August 8th, 2019, at 10:33 a.m. +This email was sent to them. +If you take a +look at the title, the subject, it says, +"Transfer of inmates." +I: Yeah. +: And it says, "Transfer of +prisoners +from -- +: I see it. +-- to GEO. +TO GEO. +And inmate Efrain Reyes is +stated on this. +So, he never -. +It's +not that +he went to court. +He actually was transferred +to GEO. Do you know what the procedure is for +something like that? If an inmate is to be +transferred, how do they pull the inmate out? +How do they let the SHU know that +the inmate +needs to be pulled out: +: Normally, R&D would get in +touch with the SHU officers, pretty early in +the morning, 6:00 in the morning, +courts, and whoever is leaving, ready. +: Is that known as a +court +list? +A court list. + + +1 +4 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +33 +And that list comes +they +let +the +SHU officers know? +over, +and +S0, +they prepare them. +And +on that - if that he was leaving +- what would +it state on the -? Have you ever heard the +term, +WAB? +What does -- +-- +WAB mean to you? +With All Belongings. +And what is your +understanding if it states that? +To me, With All Belongings +can mean anything. +stateh All Belonging. +going? +You know, where +To Brooklyn? Is he going home? +But does it mean that he's +coming +back? +To me, no. +And your understanding +is, if +it says WAB, he's leaving for +certain? +: Right. + + +34 +would +: And when, as an SIS, +you get a copy of those court production +lists +-- or productions? +No? +1: Okay. +Do you know, I mean, it's on +the top, do you ever -. Do you recall, +after +this investigation started, after Epstein's +death, ever seeing that court list for that +day? +: No. I've never seen it. +: If we wanted to obtain a copy +of it, do you know if there's any way we can +obtain a copy of that? +I would think it should be in +the Receiving and Discharge area. +And that's something that +they +•• +The R&D. +if we asked, and +based on +it, it said no one seems to have +maintained a +copy of that. +It looks like they've printed +off for the day, and then they disposed of it. + + +35 +1 +2 +I don't know. +: Okay. +Was it kept, though, +under your investigation, for when you went in +on the 10th? +Do you know if that was, +part of, like, anything that you would have +collected? +8 +1: Did I? I don't think I had +9 +the court list. +10 +11 +I had +12 +a lot +To be honest with you. +of stuff. But I don't recall seeing the +13 +court +list. +14 +: So, in the stuff -- +15 +Oh. +16 +17 +-- that you did, on the +10th, did you involve at all, did you look into +18 +19 +it at all, Reyes leaving and Epstein +not having +a cellmate? +20 +21 +I think I did. +I think I did +run his SENTRY paperwork, once I +22 +see where was Reyes. +What happened with +ned where Reyes. +23 +24 +I think I did run his SENTRY paperwork +But you didn't,". +25 +You didn't ever maintain, you know, obtain that + + +1 +3 +8 +9 +10 +11 +1 +2 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +36 +court +list, though? +I didn't have the court list. +: +I don't recall having a court +list. +: +And so, do you - if R&D +doesn't maintain it - do you know if there is +any way that we could get our hands on one of +these court lists? +_: I don't know. +I don't know, +in SENTRY, because I don't deal with +their +functions. +So, +I don't even know if +they were +able to - be able to go back. +Yeah, no, they can't. +They +replace it every day. +Every (Indiscernible +*00:25:14), +so no one +See, I don't -- +- it's only maintained +in SENTRY for 24 hours. Do you have +the other +email? +-: Which one? +The one that they +sent +everybody else of in R&D. +Saying that +he was + + +37 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +being transferred. +Oh, no. I don't have that +email. +I think that's separate. +I didn't +print +that one out. +›kay. And do you know +are vou familiar with how the U.S. Marshals +Service - at least back then, I don't know if +they still do this - but they would send out an +email the day before, which would be sent to, +ker +he +ay, +Are +you familiar with that email that's sent by +the Marshals Service? +I've probably seen it. +But you don't +really know what I'm talking about? +Oh, it -- +•: okay. +-- I would have to see it. +To be +honest with +you. +1: I'm going to take +step +back. +When Epstein was brought out of +psych +observation, he was placed in the +SHU. +Do you + + +1 +recall that anyone from upper management, +even psych, mentioning that he was required to +3 +have a cellmate? +I didn't hear it, per +But normally, when they come off +of suicide +watch, or a psych observation, they have to +have +cellmate. And psychology, +usually +8 +harbor on that. You know? They have to -- +9 +Why is it - +10 +-- have a cellmate. +11 +12 +: - why is it that they need a +cellmate? +13 +•: I don't want to guess, +but I +14 +would say, even though, you know, +15 +possibly was made, you want to prevent +16 +17 +something happening going forward. +Formanaven tempte +And do you recall +- but you +18 +said you're not sure - but do you recall that +19 +there was a requirement for Epstein to have a +20 cellmate? +21 +22 +he sad to have a cel made. +I do recall them +saying +23 +24 +And that was by word of +mouth? +25 +By word of mouth. + + +1 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +39 +it +from? +: Do you recall who you heard +Let's see. +I want to +say Dr. +who is the psychologist. +I want to say +DI• +said that he has to have a cellmate. +So, she probably came down. +Do you recall if she told other people in the +SHU, in regards to that? +I don't know because I +wouldn't have been in the SHU. +.. +All right. +: Sorry. +: The reason I ask is, now that +we know that Reyes is leaving the SHU, right? +And he's WAB, that, and the court list comes +down, and our understanding is, on that court +list, it states WAB +Mm-hmm. +: - and he's brought down to +R&D. +And he's removed from the facility. +Whose responsibility would it have +been, +that point, to make sure that Epstein had a +cellmate? +: I would say the supervisor. +That was the SHU Lieutenant, whoever +was +on, + + +3 +4 +01 [ +7 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +because he would know that he's leaving out of +the SHU. +And this is the August 9th +roster again. If you take -. +: So, SHU Lieutenant I +was actually off +-- +•• +-- on the 9th, +as +well. +okay • +: So, if he is off, then +who would then become +• the next person +The next person -- +: —- moving up? +-- would be the Operations +Lieutenant, should have been notified. +And who should have +notified the Operations Lieutenant? +Normally, the SHU staff would +say, you know, this guy left, and, you know, +Epstein doesn't have a bunkie. +: +And at what point -- +5o, I'm sorry -- +: +-- should the -- +-- cellmate. +That's fine. + + +At what point should the +SHU staff have notified the Operations +Lieutenant? +Immediately. +So, as soon as that +person is being -? +As soon as Mr. Reyes came out +that cell. +Okay. And is it one +10 +11 +person over another, within the SHU, that +should have told him? Or is it any one of +12 +them? +13 +14 +Or all of them? +15 +I would say any one. +16 +17 +Was there a person referred +to as the officer in charge, in the SHU, during +18 +19 +that time? Like, one specific -- +: Yes. +20 +21 +-- person. +They do have, yes, the +SHU +22 OIC, yes. +23 +24 +1, SHU-2, SHU-3. +I know this roster +shows +But - +SHU- +25 + + +42 +1 +- was there any specific +person, during that time period, +who was +3 +considered - it might not be listed as the SHU- +1 - but was considered to be the officer in +charge? +: +It would been the SHU +number one, +which would be Officer +: +we +heard other people refer to as M +10 +though, the officer in charge. +Because he's +11 +been +12 +. in there the longest, at +that point. +: +13 +: Have you ever heard that? +14 +15 +He would be the OIC? +16 +17 +was the OIC, probably for +the quarter, I would say, he was. +18 +19 +And why wouldn't he be +listed as SHU-1, if he was the OIC for the +20 +quarter? Do you know? +21 +1: +He could have been +on his day +22 off. +I don't know. +23 +MR. L +No, no. +He was +there. +24 +And we heard that -- +25 +Oh, he was? + + +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +43 +- he actually was the +OIC. +But he's not listed as one. +: Oh, I don't know. +even see him as the number three. +I didn't +I don't -. +I don't know. +But he should have been +listed as one, because he was the +quarter +-- +If that was his +-: +-- post? +-- if that was his post for +the quarter, he should have been +listed as the +SHU number one. +Unless they did a switch, or +a mutual thing, or something to that effect. +And +at that point, +in 2019, had enough experience in the SHU, as +the SHU OIC, from your recollection? +So, the morning of, what +happened based on +our investigation, +is Epstein +and his cellmate, +Reyes, were removed +same time. +So, Officer | +the court order. + + +44 +3 +4 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +knew +-- +: Court list. +-- court list, and he +that Reyes was leaving. +stuff in a little brown paper bag, +retrieved Epstein from his cell, +also, +and they +both were transported on the elevator +down +together. +Epstein to attorney conference, and +Reyes out. +: And we know, in the elevator, +too, +there was a conversation about Epstein +needing a cellmate. +: Okay - +I: Now, being that • +escorted him down, and down, +he was in the +elevator, and | +I was in the elevator, +knowing that Reyes is leaving, out of them two, +should either of them have made a +notification +immediately? +Do you think they +would have +known that it was important that +they made the +notification? + + +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +45 +Why do you think that? +: If you had a conversation +about him +needing a cellmate, that +means - to +me - you know that it was important for him to +have one. And you knew that his - obviously - +Mr. Reyes was leaving WAB. +a cellmate. +So, or I feel, like, +right then +and there, the notification should have been +made. +Even though he's in attorney conference, +but his cellmate is leaving, lieutenant, we +need a cellmate for him. +E +Is there any reason for them +to believe that, even though it showed WAB, +that Reyes - that for them to believe that +Reyes would be coming back? +: +I would say no. +If it says +WAB, that's what it is. +I would assume that +he's not com back. +Now, if, let's say they've +mentioned sometimes they bring inmates down to +R&D, and the bus doesn't come. +Or they're not +going to court, and sometimes +they come +back +up. +How long does that process normally take? +It happens. +Hmm. +I've +seen +it be a couple of hours, +before the inmates + + +46 +will come back up. +So, this is, they were +brought down any time between 8:00 +a.m. and +8:30 +a.In . +: Mm-hmm. +So, when you say a couple +hours, we're talking about anywhere between +10:00 and 10:30 a.m.? +I've seen inmates come +up later. +You know, an hour and a half, you +know, +he didn't -. +He's not leaving +a bus. +Once they get everybody on the bus, they will +go back up to Special Housing. +•: Now, if the inmate was not +brought back up to the SHU, let's say by even +11:00 a.m., right? +Because if they're +expecting that there is a possibility that the +inmate might come back up, and it doesn't +happen by 11:00 a.m., should they have made a +notification? +They normally would. +because they - I'm going to reach +chme Dasumed he was leaving, because he didn't +I should clarify that -- + + +47 +1 +-- come by then. +-- I mean, I meant +3 +4 +notification, should I +or anybody in the +SHU, at that point, at 11:00, notified the +superior, hey, listen - supervisors - hey, +listen, Reyes is gone, and Epstein is +-- +7 +And not 11:00. +8 +during their shift. +At some point, if they +9 +left their shift at 2:00 p.m. without making a +10 +11 +notification, should have they known by 2:00 +12 +back? +at the very least, that he was +not coming +1 +3 +Absolutely. +1 +4 +15 +So, at some point, +16 +prior to 2:00 p.m., a notification should have +been made? +17 +Yes. Yes. +18 +And you mentioned that it +19 +should have been to the SHU Lieutenant. +20 +Lieutenant +is not there. +And it should +21 +have been the ops +lieutenant +Who was the ops +22 lieutenant during that shift? +23 +The +morning +24 +shift. +25 +And he +should have been + + +48 +3 +5 +6 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +notified, and what should have • +done? +He should have notified, of +course, his chain of command, which is +captain, hey, Epstein's cellmate has left, and +he needs a cellmate. +And that, also, we would +have told psychology, you know, Epstein' s +cellmate left. +He needs a cellmate because +somebody vetted the cellmates. +So, I would +say, I guess, they would go back to that +process of seeing who was a good fit for him. +And if - what is your +understanding - if that notification was never +made up the chain of command? +•: What's your question? +: What +is your understanding, +if they never made -? Was somebody at fault, +in terms of -. I should clarify that. +If that +notification never got -. If +told the ops lieutenant, and the ops +never told the captain, right? +When was the +next time they would have caught onto the fact +Epstein needed a cellmate? +I would say somewhere + + +1 +3 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +between that shift, they should have made that +notification. +If not, it would have +went onto +the evening shift, that he still was +without a +cellmate. +And you said that the inmate +was vetted. +So, could anyone have +assigned a +cellmate to Epstein? Anyone in the SHU +assigned somebody to be Epstein's cellmate? +Normally, in a case where +they try to get that good fit, they would talk +to the captain, who would talk to psychology, +and they'll go through the SHU roster to see +who they think would be suitable to put him in +with. +1: Okay. Do you have anything +else on that? +So, when you go to +you've saying that, siter - 50, who +So, +you're saying that, after | +left, and +his shift left, then the next shift in the SHU +should have, then, made the same +notifications +up the chain of command? +MS. I +_: If they're saying +he didn't +have a cellmate. +Okay. And then, would + + +1 +2 +3 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +50 +that go on again to the morning watch? +Because, again, he didn't have a shift for 24 +hours. +So, every shift, should have they made +that notification up? +And is it vour +understanding that the operations lieutenant +actually has that same court list, that they +would have had, that would have shown him as +WAB? +Usually, It's inhe e lieutenant's office, in +the mornings. +: okay. So, if D +says +that he actually knows that Reyes left, or +thought he went to court, and didn't know if he +wasn't going to come back, if he had that court +list, that said WAB, should have he referenced +that, or looked at it? +Yes? +Yesr +sir. +1: +Okay • +So, is that a kind +of an excuse to say, for the operations +lieutenant, hey, I know Reyes left, but I + + +1 +3 +7 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +51 +thought he was coming back, and he - or I +didn't know if he wasn't coming back +- and he +did not pass that information onto the next ops +lieutenant. Is there - what is your opinion of +nat matter +_: My opinion of that i +definitely, you know, +something is +wrong, +because if you have the court list sitting in +front of you, it says WAB. +And it means he +took all his belongings. +You know, if it was +court, it would say court. +And do you know +how, do the operations lieutenants actually +look at that list? +I can't speak for -. +: +Are they supposed to? +I +would say yes. +Because you know who's moving +from the Special Housing. +inmates that move actually are lieutenant +moves, where you have to go up and get them. +So, you're going to look at the court list to +see who is moving. +Okay. And then, +as far + + +3 +7 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +as Reyes. +Did everyone know who Reyes was at +that time? Do you believe that, if, +for +instance, someone like al +ne sees +Reyes on the list, sees that he's WAB. Would +he know that's Epstein's cellmate? +It says +he's from +the SHU. +He's WAB. +Would he know +that that's Epstein's cellmate? +Or do you +think that that notification would still need +to be made from the SHU, for him to be able to +kind of recognize that? +I can't even say he should +have +known that that was his cellmate because +he's +in a different area than the Special +Housing. +: Okay. +So, sometimes, you wouldn't +know whose cell that up there, you know, up in +•: Okay. But if he says, +because I +had the court list, +have he known, at that point, yes, +and it says WAB, knew this +guy was gone, and he was not coming back? + + +53 +1 +: I can agree with that. +: +Great. +What do +3 +you think the -? Would that court list stay in +4 +he operations, or the lieutenants office, +throughout the duration of the day, would the +next operation lieutenant that came on - which +I believe is +he that care +- would that person have +8 +also had that court list? +9 +It normally stay in +10 +the day. +On a clipboard. It usually would be +11 +on a clipboard in +12 +the lieutenant's office. +I don't -. +I can't say that +, you know, +13 +looked at it, but it should have been there +14 +when he came on. +15 +1: Should have he looked at +16 +17 +it? +: I could -. +18 +19 +And I'm asking you this +as the SIS lieutenant. We don't know the +20 +answer to that. +So, that's why we're asking +21 you. +22 +23 +A good lieutenant +would. +1: +24 +25 +: +Because you would know +who is +not in your jail. + + +1 +3 +LO 00 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +54 +Right. As far as other +people that could have made this notification, +what would the unit teams' responsibility be +for if one of their people who was assigned to +SHU, left the institution? Should have they +been coordinating, or making any notifications? +I'm not sure what +role they +play when the inmates leave the Special +housing, to be honest with you. +You don't? +1: +Yeah. I don't know what role +they +'play. +MS . +: +With their inmates. +That's +an issue, as far as them leaving. +L: +All right. +So, +for you, +though, you feel, like, the primary person that +would be responsible would be the person who +was actually with the inmate, who brought him +down, and knew that he was leaving? +MS +So, in this case, +• should have made +notifications, it falls primarily +on +the +him. +Is +that what you would say? + + +1 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +other +: I would say him and whatever +officer did the escort with him. +Fair enough. +Because they know the +SHU +inmates. +Right. Okay. +What about the officers in +the SHU, at that point? Let's say there was - +how many officers that you mentioned? +and who else were in the SHU? +In the morning shift. +Should they have -. +Would +they +have +known that Epstein needed a cellmate? +Yes. If they're working up - +yeah +- I would say yes. +: And let's say, during +shift, +should they have understood +I know he +asked +already - should they have understood the +fact that, hey, Epstein needed a +cellmate -- +-- could they have made + + +56 +1 +3 +5 +6 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +notification? +that? +And who came to the SHU after +Ms. Noel. +And +MR +And during this shift, should +they have known also? +Should they have made +notification? +known, +Anything else on that? +And they would have +'m assuming, Irom doing rounds +'rom doina their rounds +And if they were -- +would +- doing rounds, they +know there's no one in that +cell? +SOr +we can go into the +rounds? +: Mm-hmm. +And the counts. +So, based on +our - based on what we - in our investigation, + + +1 +2 +4 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +we understood is, the 4:00 p.m. count, +on the +9th. +The 10:00 p.m. count. +MS. I +Mm-hmm. +: The midnight. +The 3:00 +and the 5:00 +a.m. counts were not done. +And if the counts +were done, +as Agent +just asked, if the counts were +done at 4:00 p.m., would they have known that +was not there, and Epstein needed a +cellmate? +What +about at 10:00 p.m.? +: All right. And the reason +that we were able to determine it, +is also +because of the fact that inmate T +I was +removed from the SHU by +He was +actually in the SHU visiting room, and there +was an incident where +I witnessed him +possibly having +contraband, so he +removed him. +He called for a +lieutenant, and put him +into +a +dry cell in R&D. +Mm-hmm. +Except he was not +keyed +out. + + +1 +2 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +58 +This happened around 1:45 on August 9th, after +Except he was not keyed until after +midnight on August 10th. +So, if he was removed +from the SHU, and he was placed in R&D dry +cell, who should have -? Who had the +responsibility to key him out, +at that point? +off the SHU and place him in +R&D? +: It would have been the counts +and +assignment, to walk those in. +That's a CNA? +: Yes. +: I see. Counts and +assignment. +And how would CNA have known that +he got moved? +•: Well, normally, they would +when he got +no Bad, Chat, nerve have to inmate here in +the dry cell. +1: So, R&D should have notified +counts and assignments? +L: +Was there any responsibility +for the officer who removed him from +the SHU, +and brought him down? +He could have, as +well. + + +1 +3 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +59 +Because you brought him down. And he's coming +off of the SHU base count. +: What is -? +He's coming off +the count -- +: Right. +- so, at 4:00 p.m., the +count should have been adjusted on the El, and +also +: Absolutely. +: -- okay. +Have you ever heard +of inmates pre-filling the rounds +and count +sheets? +: Inmates? +: oh. +Sorry. Sorry. I +apologize. +Have you ever heard of the C.O.s +pre-filling the rounds and count sheets? +When, +let's just say the rounds at the start of their +shift. +: Right? And they go in, they +have their round sheet. +They expect +rounds during the certain times, +so they go in +and they fill it out for the whole +shift. +they try to do it during those times +that they +filled out. + + +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +60 +: I've never seen it, to be +honest with you. I've never seen +that. +1: Have you ever heard of C.O.s +doing that? +: No. +incidents +: Has there ever been any +in +MCC regarding C.O.s +pre-filling -? +Not that I know of. +What about the count sheets? +Would they start the shift, they already know +what count is supposed to be there? +|: I've seen that. +: And what have you seen? +: Well, my experience +being a +lieutenant, and being in the control +center, +taking the count, I have seen count slips come +down to the control center, and I'm monitoring +the camera because I'm physically watching you +count. So, if I have your count +haven't seen you count yet, I'm discarding it, +and I'm calling you on the phone. +have your count +yet? +lieutenant, +when you're doing +when thate doing pre count arm +the count + + +1 +2 +3 +5 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +61 +the control room, you pay attention to the +monitor, and you watch +-? +I could only speak for +myself. +So, as your practice. +I do. +MR +And +you watch the C.O.s to +make +sure that they're doing the +counts. +MS +Absolutely. +Which C.O.s have you seen +that haven't done that? +That haven't done the +counts, but send their count slips in. +Pfft. +I can't give you exact +names because I've been on all of the shifts. +And what happens if, in a +situation like that, if you see that, that they +didn't do the count, but they send the slip +down? +What do you do? +MS +I'm pulling. +I'm doing +verbal counseling. +- Yes. +Verbal counselina +I'm doing +verbal +counseling. +Basically, listen, don't +send me + + +3 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +your count slip until you do your count. +time, I'm going to go to the next +step, +62 +Next +which +is discipline. +And have you ever told them +to go +back and count? +: Yes. +: And they followed it? +: Yes. +What is a lieutenant round? +You understand it, you just mentioned that, +when you do a count +-- +In the SHU. What is a +lieutenant round in the SHU? +-- yeah. +: In the SHU, with the +lieutenant rounds, you go up to SHU, +as well as +every other area, you see if there's +anything +abnormal going on in the SHU, you're going to +ask a question. +You know, anything we should +know about, anything you got going on up there. +You're just making sure that the +doing their job for the shift, the inmates are +getting their phone calls, if there's any +inmates that haven't been showered, +1eni it there so may +shower. +You're making sure those +are done. + + +3 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +63 +Normally, when you go in the SHU, you have +inmates calling you, once you get there. +→ once the door open. +you're going on the ranges and seeing what's +going on with the inmates on the ranges. +Now, are you supposed to +go from door to door, when your lieutenant does +a round, though? Is the lieutenant supposed to +lo a round just as, like, a C.o. +that's working +che SHU does a round, go to each +cell, to check +and see -- +-- what's going on? +-- I don't think there's +nothing in policy stating that we have to go +door to door, and see each inmate, but you - +most of the time - you will go on a range, +would assume, because you want to see what'g +going on. +With the inmates. Especially since +it's the Special Housing. +So, this is where we get +a lot of discrepancies. +So, most +the +lieutenants say absolutely, you have +to go door +to door, and that's what a round +A select + + +64 +1 +2 +3 +4 +few of the lieutenants say, like, no, no, no, +no, that's not -. +It's your discretion, if you +do that or not. +So, are you kind of more of +that, that kind of side of it, it's their +discretion? +7 +8 +when +9 +sign +10 +1: I'm more of -. +Because they have to sign +they - is it correct - that they +have to +the round sheet -- +— Yes. +11 +12 +round? +-- saying they did a +13 +so, normally, like myseli, I +14 +would be on the range, because the +round sheets +15 +are on the range. +So, you have to go on the +16 +range to sign the round sheets. +17 +1: But do you have - but +18 +19 +just to go on the range, I guess you don't +necessarily have to 1o0k in - +20 +21 +-- their window. +22 Correct? +23 +MS. I +1: +But if you go +24 +on, +you're going to look door to door. +I would +25 +think. + + +1 +2 +3 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +65 +: But this time, our +understanding is the round sheets were actually +kept on the officer's desks. +On the desk out - +So, not on the range. +They all did it right +from where the desk was. Do you know if that's +the case? +•: I don't. I don't know. This +is the first I'm hearing of it. +Because +normally, they're at the end of the range. +…: Right. +that's +going to force your es a supervison, to go on +each range because you have to go to the end of +The rang to sign +_: Okay. +Do you know if +there is maybe, MCC didn't have this practice, +but do you know, as the BOP, as a lieutenant +round that's conducted in the SHU, and that the +lieutenant that actually signs the round sheet, +saying that they conducted the round in the +SHU, +do you know if BOP policy says that +they're supposed to go from cell, door to door, +and that's the reason why they put these sheets +at the end of the ranges? + + +66 +the policy says. +3 +4 +1710m do +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: And just as far as +clarification, do you know if BOP policy states +where the count sheets, or the round +sheets are +supposed to be kept? +Forget the +fact that you +have to look at it, but does it state that it +should be either kept on the officer's desk, or +at the end of the -? +I've never seen -- +: Okay- +-- yeah. +I've never seen +that policy where it should be kept that. +Okay. That's just practice? +MS . +: Yes. +Okay. Do you have +anything +MRhe Founds and counts? +vou think if the lieutenants that did the +Do unts queen bet ene +rounds within the +on August +9th, have any +exposure to the fact that Reyes was +gone, and +should have they - when they did +their rounds - +should have they known that, +hey, this cell is +Epstein's down at attorney conference, + + +3 +7 +8 +9 +10 +11 +12 +1 +3 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +67 +and Reyes isn't here, so there's no one in that +cell. +Should have they been, you know, +should +have they known -? +slip +: If you knew that on the count +- I'm sorry - on the court roster that he +was WAB, and you see Epstein downstairs, then +if you're paying attention, you would just -. +That's something you would have asked. +Hey, we +got a cellmate for him yet? +Who he's +going +with. +That type of thing. +So, those +lieutenants that actually did do +the rounds in +the SHU, on that date, then they do have some +fault in this, that Reyes was never replaced? +I'm going to say yes. +: Okay. +Anything else on rounds and +counts? I'm moving onto cameras. +Perfect. +When +did you +learn +that the cameras were not working +at +the MCC? +August +8th. +August +8th. Okay. + + +68 +1 +2 +3 +4 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: Can you tell us what +transpired? +: I actually was reviewing the +cameras from the SIS office, with one of the +associate wardens. +We were +looking for an +inmate, to see what time +he was released, +cadre (Phonetic Sp. *00:50:30) inmate. +a +We were +looking to see what time he was released +because I was trying to backtrack, because I +was going to interview the inmate, +with an OIC +officer, about an incident. +And +• learned +he's gone. And I said, gone where? +release date - which, he was scheduled to be +released - so, that made me go back to look to +see, +well, let me +see what time they released +him. And we were trying to pinpoint when he +got released, so we could get in touch with +that halfway house. +So, we - myself and the +a +gen +to interview him. +terwas going to go to the halfway house +And upon me going back to +the cameras, I +said, wait a minute, we don't have +cameras. +I can't go back. +So, of course, +I clicked on +several cameras, just to see if I could play it + + +1 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +back on the cameras, and I noticed the cameras +are down. +I can't go back and rewind anything. +At that time, +I called the communications shop, +and told them, I don't have no cameras up here. +You know, I can't go. +I can't play it back. +gentleman came upstairs and said, okay, I'm +going to come +and check tne camera system, +which he has the keys for, as well. +check it out, and he said, okay, the cameras is +not working. +I'm going to fix them. +to do overtime or something to that effect. +fix the cameras. At that time, I notified the +captain. +: Oh, you notified the +captain? +That the cameras were +down? +: That the cameras was down. +And I wrote a memo - a memorandum +you please give +it to us? +oh, if you have +that car +: It's - I can't get in my home +drive +- it would be on my home drive. +And when will +you be able + + +1 +3 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +70 +to get access to that? +I: I'm out of work. +So, I can't +access it. +: +Oh, we have heard +that +you were back this week. Is that not the case? +Oh. +I'm not back this week. +I +only came for the interview. +I won't +be back +or maybe, like, another two to three weeks. +hen vou come back in two +or three weeks, could you - I'll +send you an +email, just as far as, like -- +I was going to say. +If you +email +me where to send it to, yes. +Fantastic. +So, at that point, I did type +the memo that the cameras was done. +: This is on the 8th? +On the 8th. +And I assumed +that the +gentleman was going to stay and fix the +cameras +that day. +So, and when you say "the + + +71 +1 +3 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +gentleman, " are you talking about +: Yes. +? +person who came in and checked? +So, +that's the +Is it true that ne can +only obtain access to the camera room, +SIS employee actually lets him in? +Absolutely not. He has the +keys. +At that time, he did? +The first door, which is the +steel +door with the Folger Adams (Phonetic Sp. +*00:53:21), I have to let him into that. +•: That's what I mean. +he can't actually get +-- +: Right. +part. +the 8th, +he +was +into the SIS -- +Unless I -- +-- area +let him into that +Correct. +So, he had told +you, +actually going to stay +and fix + + +72 +1 +2 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +it? +: And do overtime to fix it. +: Because +Okayi let him into the +office, so he can go see what I was telling +him, the cameras is down. I can't play back. +And do you know if +that's the first time it was noticed, that +those cameras were down? +1: I can't say that that was the +first +time that was noticed. +: Because our investigation +shows +that, as early as 7/29/2019, those +cameras stopped recording. So, there is about +half of the cameras in the institution that +were +recording, and half that weren't. +were all live monitoring. +But did you find anything +about +that, or do you know anything about that? +1: No. +It's not +until I +was +actually in the phone room, with the +agents, going through the cameras, that we +realized that they +stopped recording. +Oh, +so, you knew +this on + + +73 +1 +3 +5 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +the 10th or something, you -- +-- realized this -- +It was -- +-- after the +investigation? +Mm-hmm. +So, you had heard, later, +that +at +7/29 +MS +is when -? Okay. +Mm-hmm. +So, you know that +now, +is +what you mean by +-- between 7/29 +and +August +8th +-- +The 10th. +-- you never -? +: +1: So, the 8th was +the first +time you found out? + + +1 +3 +4 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: Do you remember if, prior +to the 8th, you ever were on the camera system, +trying to rewind and watch? +think that's something you do kind of +regularly. +I can't remember if it was +myself, or the SIS Tech l +•, to be honest with +you, because normally, if it's an incident and +I need some video footage, I'll ask her to pull +the footage for me. +You know? So, I can see +it. +So, I can't recall if we had +an incident +where we need to pull any camera footage. +So, you don't +remember if there was footage before that. +_: No. +Was there a Tech +I, or +or something like that? +Phone monitor. +He was on +was the phone +monitor, +which is +a regular correctional +officers. +Ohr +so, he's not an +SIS +tech? +Hmm-mm. + + +~ 0 +LO 00 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +75 +: +All right. But would he +work +in the SIS room? +In the phone room. +•: Okay. +He would be assigned, for the +quarter, +to the phone room. +That's in the SIS office? +It's not in my office, +but +it's +a part of SIS. +The phone room. +It's kind +of, like, next door to SIS. +Is that +the room where +the camera servers are located? +Okay. So, does he also +need +someone from SIS to let him in, to be able +to do phone monitors? +How does he get +in and +out? +He has the phone monitor +keys, +half the kevring for him to get into the +door. +To get into -- +I'm sorry. +The key. +- the primary +area? + + +1 +2 +76 +_: Yes. +So, do you know if +he was working on the 9th? +I don't know if he was +working because he hadn't been in the phone +room for some -- +1: Would he be listed on the +-? +8 +9 +-- let me look. Because they +10 +11 +were actually pulling him every day, re- +12 +assigning him to different posts. +So, he is +working, but they re-assigned him to +another +13 +post. +14 +Okay. So, he wasn't - on +15 +the 9th - he wasn't actually working? +16 +17 +If you see three [ +you'll see him there. +18 +19 +And would that be because +there was no SIS tech or lieutenant to allow +20 him into that room? +21 +MS. l +22 +It would be because they +were short-staffed. +23 +24 +And they just re-assigned him +25 +to another post. + + +1 +2 +4 +8 +9 +10 +11 +12 +1 +3 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +77 +: Okay. +. So, if l +says +that he wasn't able to fix the cameras on the +8th because he didn't have the proper +equipment, and then he couldn't gain access on +the 9th. +Does that make sense? +He wasn't able +to get in on the 9th because neither you or the +tech were here. +He would be able to get in +because my keys don't go home with me. +He +would have just had to ask the captain for +access to the SIS keys, +and he would have been +able to go into the office. +And like you said, the +captain actually knew that the cameras were +down? +And you are positive of +that? +I'm positive. +conversation +with him you have a verbal +I had a verbal conversation. +And can you recall what +that +conversation entailed? +I remember stepping +to his + + +1 +2 +7 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +78 +olice, which was right next door to mine, and +notifying him that the cameras was down, that +I'm trying to go back and look at the footage, +and I can't. Actually, I had one of the +associate wardens with me, as well. +happens to be his supervisor, so. +Who was that? +Associate Warden I +was there? +It was me and her together, +looking at the cameras. +Okay. So, and it wasn't +it was actually +It was me and AW +: And that was +with +captain +Okay. So then, the two +of them knew that the +cameras were +All right. And do you +know if they had any conversations +with +about a need to get them back up? + + +1 +3 +5 +7 +8 +9 +10 +11 +1 +2 +1 +3 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +79 +: I don't know if they had a +separate conversation, but when I called Mr. +I over to radio, Ms. L +standing there with me in the office. And she +was there with me when he came up to check, +because we thought it was something that maybe +he can just go in, and it allow us +camera, and look for what we were looking for. +7: And when he mentioned the +whole I'll stay overtime, was she there when - +was +there - when he +mentioned that he +would stay to work overtime? +MS. I +: I can't remember because I +know he had to get in touch with his boss +first. +Oh, okay. So -- +Mm-hmm. +-- +so, +told us +that he was approved to work overtime +on +Saturday, to come in on saturday and won order +you know who he would have contacted, +to get that approval to work overtime? +I don't know. +I would assume +his boss, +which was Mr. +Now, +i is out, +and + + +1 +2 +3 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +80 +he has acting in his place, +a Both say, he didn and +talk to me about working overtime. +anyone else that he would have been -? +because you said that he told you he +to work overtime. +Would you be an approving +official for that? +-: No. +Would +be an +approving official, though? +: I'm not sure if she was +over +facilities, that department. So, +I'm +- no - +I'm not sure. +L: +So, how did he +know he would be able to work overtime to fix +it? +: I don't know. +: +You don't know? +He just +said I'll work overtime. +Okay. So, I'm assuming +this was some time prior to 2:00 p.m. on the +8th, that +you learned of this incident, +since + + +81 +1 +3 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +his shift typically ends at 2:00 p.m.? +Yeah. It was a little after +1:00 p.m. +: Okay. And that was the +8th. +But again, on the 8th was the first that +you found out the cameras -- +_: Yes. +-- were down? Do you +know +if there is anyway anyone could +have +tampered with that system, to intentionally +take the cameras offline? +I don't know. I don't know +because nobody normally goes into - with the +service are - besides him. +Or there's one more +communication tech, Mr. l +Was he there, though, +the time? +So -- +: +time +it was only +: +access to that server +-- +it was just - at the +Correct? +It was just | +So, who would +have had +room? +In the MCC as a + + +1 +3 +5 +7 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +whole, who could have had access to that server +room, +and potentially taken it offline? +I don't know who would +intentionally take it off, but I can tell you +the access would have been us, from the SIS +shop. +Hmm. +The comm +shop, which is Mr. +and Mr. +And I'm not sure if their key +if that key is on, in the other key ring. +So, is it really only the +two of you, then, with SIS, then also the phone +monitor individual, +Is it M +1? +Is that +1? +: +Just +I don't think Mr. +had the +key on his ring because, if I needed to go, my +ink cartridges for my printer and stuff was in +there, as well. +So, I would always lock the +door back, because we don't allow +officer to +just +walk where the +server is at. +So +-. +SOr +the server, +actually, +was in +a locked door? + + +83 +1 +access +to +So, really, +didn't +it? +But the tech would have? +She would. +So, yourself, the tech, +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +were really the only +people? +Mr. +on +up +Well, +time, +though. +Correct? +Probably Mr. +his +key +ring. +was not -- +I wasn't here +I think +But - but just to clear +22 +23 +the time, though? +24 +25 +wasn't +here +at +Is that right? + + +84 +1 +2 +7 +8 +9 +1 +0 +1 +2 +1 +3 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +I -— +1: Oh, you don't know? +I really don't know. +Oh, okay. No. +That's +why I +was asking you. +My understanding +I don't know. +-- was that +was +the only tech at the time. +: +I don't know if +was in the building, but I know I +dealt with at the time. +•: Okay. And then, +would +have? +is who +I +I think it may be on +. Mr. +key because he's the facilities +manager. +But again, I'm not sure what keys +they have. +What about the captain? +don't know. +Now, when you +I don't know what's +on his +keyrings +- now, you say +you don't + + +85 +ever leave the institution with these keys, did +you give them to the captain, or where are the +keys? +: No. They're located in the +control center, behind a locked box. +So, I have to give them the +key to open my locked box in order for me to +retrieve my SIS keys. +•: Okay. And then, does +anybody else have that key, to open +locked +box, to get those keys? +What are -? You said the +captain does, +though? +I thought you said he +could have gone to the captain to get the keys. +: He can't get into my +Locked box. He has his own locked box. +•: So, how would -. +I think +you +-. +could have allowed • +• to get in +He would have had them +allowed to break the glass, and get my key out. +Thev would have +had +If it was another -- + + +86 +1 +2 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +- actually break it? +-- they would have to +actually break the keys. +Myself, the sIs tech, +all of our keys are in a locked box. So, if +it's an emergency, you would have to break the +glass to retrieve our keys. +And in this case, you +belleve that would be an emergency, that they +were to break the glass to fix the +cameras or +the 9th? +would +|: Normally, yes. +So, you think that that +have been appropriate action, to break +it? +1: +And then, the +captain does not actually have a key to get +into the SIS office, though? +1: No. +Does anyone else? +or -? +No. I think it's +only on the +SIs stati, the phone monitor, tne SIA, which we +didn't have one at the time. +: +Okay. But you're certain + + +3 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +87 +that +and +, on the 8th, were aware +that there was a camera issue, and not +recording? +Do you know if they +notified the warden? +I don't recall. +Because +• I notified the +warden. +And he seemed a little -- +: +Notified the warden, +when? +-- on the 10th. +On the 10th. Once I came in, +once the incident happened. And me and him was +having a conversation, and he was saying, +you mean there's no cameras working? +there's no cameras working, and I said, said, +what do +was supposed to fix the cameras on the +8th, and, you know, he was +surprised, +like, +what are you talking about? +said, the +cameras went down on the 8th. +Warden and I +notified +that the cameras +was down. +And +I said, I wrote a memo. + + +88 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: +And what happened with +your memo? +Who gets that memo? +: My memo, I usually give it to +the captain. +Okay. And do you know, +n this case, did vou give it to the captain +I did give it to him. +might have emailed it, as well, to +the -. +I +would have to look at my email. +might have +emailed it, as well. +And would have you -? +And I might have emailed it +Again, I can't remember +: Can you -- +- exactly who I sent it to. +- you know, when you +come in, can you check your sent box, and see +if on the - you would have done this +on the +8th, though? +1: It would have been on the +8th. +Yesr +So, you would +have - it +sounds, +like, potentially - hand-delivered to + + +89 +1 +2 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +him? +_: Mm-hmm. +And emailed, or both? Or +I mean, one or the other? +: +Normally, because he's next +door, +I would hand deliver him stuff. +: Okay. +: To be honest. +And sometime, +I would email it to him if his door is +closed, +and I don't see him. +Or don't know if +going to see him before I leave. +Okay. But you are +positive, on the 8th, you gave him that memo, +one way or the other? +•: Yeah. I'm almost - though, +I'm not going to say 100 percent +sure - but I +know I verbally told him that the +cameras was +down. +Are vour 100 percent sure +that there was a memo, though? +But you may - when you +sould are not potently some th +when +have you potentially done that memo? +: +I did the memo +else + + +90 +8th. +Oh. +So, that's where, +when you say you're not 100 percent sure +-- +If I +-- right, you're not -- +-- emailed it to him, +I'm +saying to you. +-- but you're 100 percent +sure you provided it to him? +10 +: Yes. And I notified him, +11 +word +12 +of mouth, that the cameras was +Okay, and that - sorry - +13 +that's where I just want to make sure I'm +14 +clearing that up. +So, you know for a +fact you +15 +gave him that memo. +You just don't know if you +16 +17 +gave +it to him, either by hand -- +Or email. +18 +19 +-- or email. +20 +21 +22 +But it's definitely, +he +23 got it? +24 +25 +Perfect. +But + + +91 +1 +2 +7 +8 +9 +10 +11 +1 +2 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +regardless, both L +and +knew -- +: That the cameras -- +-- verbally, and +knew +specifically, because she was +Because she was with me. +-- involved. +Right. She was +with me. +: Okay. And was she +involved, at all, with those discussions with +? +.. +I can't remember if +she +stayed +with me. +I think she walked away. +1: Okay. +Because we couldn't get what +we needed, as far as footage. +: Were they both under the +impression that +was actually working on +the camera system? +Hmm. +1: +Like, did they +ask, well, +are you going to take care of this, +or anything +like that? +MS. I +I don't remember them +speaking to +I just know -- + + +1 +2 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +92 +When you verbally +spoke with +though, and +• about the +situation, +did you say, +I notified +said he'll take care of it, or anything +like +that? +: Yes. +So, you did tell +them that, +that he would be fixing it. +Well, she was on the +phone -. +She was standing next to me when I +was on the phone, talking to Mr. +Mm-hmm. +What about the captain, +though? +Did he know? +I: No. +He wasn't near me. +: Did he ask, like, is +going to fix it, or anything like that? +I: No. He didn't -- +Did he say anything? +Well, +what +-- he didn't ask. +-- what was his +response +to you telling him that the cameras +were down? +asked me, did I +notify + + +1 +3 +5 +6 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +93 +them, +and I said, yes. +That was my question. +I'm sorry. +okay • +MR +So +apologize. +- so, he did know that +MR +-- was notified? +MS +Okay. Go ahead. +Was the captain surprised the +cameras were down? +I don't know if he was +surprised because it's not, like, +normal. +Sometimes, they do go down. You know? +It's our job to notify who we need to notify to +bring them back up. +But - . +Like, +did he state, oh, yeah, it +Do you recall his reaction fixed +must +today? Make sure +I takes care of it. +What was his exact reaction to that +notification? +I: I can't recall. + + +94 +1 +2 +8 +9 +10 +11 +1 +2 +1 +3 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +I can't recall. +And did +ever +come +back +and tell you that he couldn't fix +it that +day, +on the 8th? +No. He told me that on the +10th. +: What did he tell you on +the 10th? +I: Once I walked into the +Special Housing area on the 1otn, +he was there. +I don't know if he was working that day. +But +he was there, and when the door opened, you +know, my response was, well, what happened to +the cameras? +And he said, +oh, that's what I'm +here for today. +I'm +nere today to i1x it. +him, and put him on the post, or something to +that effect. +And I said, but you told me you +was going to fix them on the 8th. +like, +I couldn't fix them on the +8th. +And he canst +remember why he said he couldn't. +But I think +he responded to me before I could even +ask the +question, once he saw me because +I was a little +taken back that the cameras were +down. +Because + + +1 +2 +4 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +95 +I assumed they was going to be fixed on the +8th. +: Can I ask you, when you guys +were - you and AW +• - were reviewing +footage, and you realized it wasn't working, +you called I +What was +reaction +to finding out the cameras were not working? +He said he was going +to come +down and take a look at it. +1: Did he mention it was +ongoing - it was already an issue, +he was aware +of it, or was that the first he was hearing +about +it? +Do you recall? +He didn't -- +: No? +: - he didn't say. +said, +it. +okay, I'm going to come take +He just +look at +of you guys +And then, he came down, +both +were in the room, and he +tried to - +? +him. +in. +No. I wasn't in there with +I just opened the door so he could get +And he went in, and he came +back, +and he + + +1 +2 +4 +7 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +said, yeah, they're not recording, and he made +a phone call, or he walked away one, +said, +I'm going to stay and do overtime, +tonight. +And he did specifically +say +"tonight"? +And if he did stay, stay +overtime, +that would be on his webTA? +Well +-- +It should be. +It should be. +- well, no, we know he +didn't +But +as far as, if both you +and the other SIS tech left, would he have been +able to still stay in, on the 8th, +in the +camera room, +to be able to work on +it? +1: Yes. +Because it's been times +that he needed to +do work, +and I +needed to go + + +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +97 +nome. And the captain would say, okay, well, +leave your keys with me, you know, so he could +: Okay. +To the room. +So, when you left that +did you check back in with +at all, +like +I +sure didn't. +-- hey. You did not? +I didn't. +And do you know +he did after you told him I'm going to +care of? +Do you know what he did? +-: No. +No. Did he stay in the +Did he -? +No. He left out the room. +All right. +And then, +did +(D +the +oth +(D +te +0 +on the +8th? +I would have left probably +because she leaves at +2: 00 +Uh-huh. +What +ime? +I can't remember what + + +98 +3 +4 +• 00 01 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +happened that day. +And what -? +Normally, I'm there between +2:00 +More closer to 3:00, I'm leaving. So. +So, if you both +left, though, at 2:00 or 3:00, and he said he +was coming back that day to fix it, +how would +have he done that? +MS. l +Because I would have spoken +to the captain and said, hey, l +needs to +get in the com room. +: +Do you remember, +did that +conversation occur? +MS . +honestly don't remember. +•: Okay. You don't +remember. +Nice Vision has that +administrative feature. Nice Vision +is the +camera +1: Mm-hmm. +system, right? +administrative feature is called +Supervision. +Do you recall that? + + +99 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Hmm. +Well -. +: There was a couple +different +_: Name +: +applications, but there is one application +called Supervision, and that you might be able +to log into Supervision and see if the recorder +errors are actually recording. Do you know if +you got access to that? +No. I have - mine is SIS +lieutenant access, so. +: +Who had administrative access +to the camera system? +: Meaning that Supervision? +: Supervision. Who could go +in, control the cameras, or take cameras +offline? And mess with the cameras +I don't know. +I would say +computer services have access, and probably, I +would say, facilities managers should have +Supervision access. +But not the SIS Shop? + + +100 +1 +3 +So -- +and +is +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +basically who you're saying? +I don't know. I don't even +know if +would have Supervision +because - +don't know. I would think, +you say Supervision, it would be upper +Supervision +doesn't mean super -. It's not a title for, +like, somebody in the -. It's a title for the +So, like, there's an app that says, like, +you know, these people are granted access to be +able to review and rewind, but then +there's +another app +Oh. +- that allows you to +20 actually check to see if things are running +properly, and recording, and it's +just +22 +23 +24 +25 +Oh, okay. +That doesn't mean - +Then that would be + + +101 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +- that you're a +supervisor. +- that would be - +I would +say - that would be +I, because that's his +area, the cameras. +Okay. And do you know if +anybody else would have the ability to do +things like that, to take, you know, recorders +on or offline, or to at least check +their +status with the camera system? +I don't know. +If it is, +it +would +be facilities shop. +So, but primarily, +would +be the person? +Mm-hmm. +okay• +Not you, though? +And in no way, while you +were +Although, +the only thing that would be +able to tip you off, if things weren't +recording, is if you started trying to +rewind, +and it wasn't rewinding. +If I tried to rewind, it + + +102 +1 +2 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +wouldn't rewind. Or if they were red. +would have, like, a red X on a camera. +that it's a problem, even if it's not working +at all. +Or something is wrong with it. +Did that - on the 8th, +when you were looking - were there any red X's? +I don't recall if -. +it's a lot of cameras, and they're in different +places. +So, I don't recall there being a red +X. +But just to -- +On any of them. +-- circle back. +What +tipped you off was with you and • +trying to +go back and review? +And that's where you +said +- why can't I do it? +Mm-hmm. +Gotcha. +And prior to that day, you +don't recall when the last time you +guys tried +to review it was, +right? + + +1 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +103 +little +bit +No. I don't recall. +: Okay. +So, but it had been a +It had been a little while? +: Okay. Anything else on | +the +cameras? +I think that's all. +That's great information, +that we didn't know that before. +I didn't know +that that's how we found out that the cameras +were offline +Mm-hmm. +-- was basically your +review. +How often should +have been +going in to check those servers to +make sure +that they were online? +Daily. +•: So then, would you know +if he +was? +I can't say he was +checking +daily. +I know that he was up there quite +often. But I can't even say that he was +checking the cameras because, one I let him in, +to do whatever he's doing with the +servers, you + + +1 +3 +4 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +know, I wasn't standing there, you know, +104 +saying +what are you doing, or, so -- +And I know we're talk -- +1: - but daily, they +should +have checked. +1: -- I know we're +talking a +long time ago now, but do you remember, +prior +to the 8th, if he was in -? +Because +again, I +think the information that we have suggests +that the camera servers went down +the actual +July 29th -- +_ : Hmm. +-- of 2019. So, +there +i5, +like, almost a - more than a +: Week. +-- week +-- +Yeah. Yeah. +-- do you know if he was +actually going in, at that time, +for that week +period, checking in on the servers at all, at +chis - ? +I know he entered the +area. +But I don't know if he checked the +servers +while he were back there. +But I know he was +entering the area. + + +105 +1 +2 +4 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +What else is in that area? +Just the servers in +there. +And ink cartridges. At the top. +And that's on the third +floor? +It's on the third floor. +And then, nothing +else is +stored. +Is there evidence stored in +there? +For some reason, we +were +under +the impression that SIS stored +evidence +there. +There's no evidence in there. +It's +some old file cabinets from, maybe before +I was born. +that there was maybe, it's like a hallway, and +there's, like, some evidence, some +a ta, come olay, and +evidence, or evidence there. +MS. I +: Not where the servers +are. +But it's some file cabinets, where +the +servers +are. +And I think that's maybe some archive SIS +cases from -- + + +1 +106 +5 +7 +40 00 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +okay - +-- a long time ago. +So, next topic? +Mm-hmm. +: +So, what was your +understanding about why Epstein was not in his +assigned cell? +Were vou aware that he was - +when they found him - and he was not in the +cell that he was assigned to in the system? +: +No. I learned that later on, +that +What did you learn? +- that he was keyed to one +cell: but he dost we canted his +cell at. +rotations +And is this because the cell +that happen in the SHu? +: And who would have been +responsible to make sure that this, +once the +cell rotation happened -. +That's not the reason. +So, let's not go down that path. +did you + + +1 +3 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +107 +learn how that happened? How he was keyed into +one, +and not in another? +_: No. +No? Okay. Did you hear +-? Does this refresh your memory at all, like, +he was initially placed into one cell, when he +came back from suicide watch, around July 30th, +bet hinto there cheye dd to sactual him to +reach into there, so they had to +another? +No? So, you never heard +anything about that? +NO. +: Okay. Go ahead. +So - . +: Who would have been +responsible for making those +changes in the +system, to make sure that he's in the actual +cell where he's supposed to be there? +MS. I +Normally, the SHU OIC make +the changes. +lieutenant? +It +: So, it wouldn't be the +would be the OIC? +It would be the OIC. + + +108 +: Okay. +be -? +Is there an OIC for each shift, or is +there +one overall OIC? +or to ago fee, that +There is one for each shift. +Okay. So, on that note, +is it more for, like, the morning watch, the +day watch, or the evening watch that would be +responsible for that change? +shift he was +10 +11 +moved on, that OIC should have made the change. +_: Okay. +And at this +12 +point, if the change wasnet made, is there a +1 +3 +way for us to know when that occurred? When +14 +they actually moved him from one cell to +15 +another cell? +16 +17 +The only way you would +know is to rely on the cameras to, you know, +18 +rewind and see. +19 +20 +21 +22 +happened. +: To see, you know -- +Mm-hmm. +- when that actually +But the cameras weren't +actually +23 +working +24 +25 +- from 7/29, +and +this + + +1 +3 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +happened on 7/30. There's no way, +109 +at this +point? +Okay• +NO. +: +Go ahead. +Next level? +: Sure. +Cell searches. +How often are +they +supposed to do cell searches in the SHU? +MS +You're taking me back-back. +There is - I want to say they +have to do a set amount. I don't know if it's +three or five. +It was five when I was an +officer. +Per shift. +They should be random +cell searches. +Is it of the general area, or +actual cells that they're supposed to be +searching? +MS +Actual cell searches. +MS +And is that five -? +midnight shift. +With the exception of the +They usually do +the +general +areas. + + +1 +2 +5 +6 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +110 +But there should have been +cell searches done, by the C.O.s, +least five +times? +Per shift? +On day watch - +-- and night watch? +No. On day watch +Day watch and evening -- +-- an evening watch. +-- watch. +All right. +Well, +evening. +Evening watch, right? +So, if they're doing +those, is it just as important to +log those +searches into the system? +MR +So, if there is +cell +searches actually being +• logged into the system, +on those dates, +is that a problem? +Okay. And would you + + +111 +1 +3 +4 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +consider that, like, a policy violation? +_: Yes. +If it's not logged into +the system, is it almost as if they never +happened? +Go ahead. +I: That's all I have. +I know +you looked into the monitor, the +phone call +that Epstein made the night before, on August +9th, right? +And what is your understanding +of +what transpired? Like, how did he +make that +phone call? +MS. | +•: My understanding is that his +unit manager gave him the phone call. +On an +unsecured line. +He placed Epstein +in the +shower area - that's what my understanding - +and he plugged the phone into an +Iine, and gave him à phone call. +And based on what we - based +on the interviews +- it looks like Epstein asked +to speak to his mother. +And he asked for, +his pack +and PIN was not +set up. + + +112 +Well, let's ask her. +What is your understanding of what happened? +That was my understanding, +that he made a phone call to his mother. +Have you learned anything +since then? +I: No. Well, I did learn that +his mother was deceased on the 10th. +And do you know who +he +10 +11 +actually called? +: +I don't. +I don't. +actually was present when we did get the +13 +number, and the NYPD guy called the number +14 +back, +15 +but I don't know who it was. +He actually dialed the +16 +phone? +17 +Mm-hmm. +18 +To check to -? +Rather +19 +than doing a search, he called the +number that +20 +they -- +21 +I think he did a search. +22 +1: +-- okay. +23 +24 +25 +he called the number. +I think he did a search. +And +From here? At the BOP? + + +113 +1 +2 +No. I want to say he might +have called from his phone he had. +•: He had a cell phone? +Yeah. Mm-hmm. +I want to say +he called from his phone. +Was this in your +presence? +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +22 +23 +24 +25 +Yeah. It was. Yeah. I was +there. +: Did they bring their cell +phones into the institution? +We had - we got approval for +them to bring their phones in, because they was +doing an investigation. +Oh, okay. +And do you know if +someone answered when he called? +I want to say a female +20 answered, but hung up. +: +okay. Did he identify +himself? +I can't remember. +I can't remember. + + +114 +1 +2 +5 +6 +7 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +22 +23 +24 +25 +person, +one NYPD +MR +: +And is that the +though, +that -- +You think? +same +-- NYPD --- +-- detective. +Because - yes - it was only +at the time. +Okay. And it's l +you +call? +I think it was +Great. +Who did +say that actually provided him the phone +His unit manager. +And who was that? +His name is +: +And what is your +understanding of what should have transpired if +ne gave him that phone call? How +should have +that process worked? + + +1 +3 +5 +6 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +115 +: II ne gave him a phone call, +it should have been on a secure line. +the inmate's line. +Because when +inmate line, you can listen to the phone call. +You know, go back. +nd it should have been recorded in the logboo +mater, you can you can monitor +Meaning, +You can monitor it live +that he received the phone call to the number +he received the phone call to. +And should +have he sat +there with him, while the call was being +placed? +: Yes. +AlL right. And do you +know +anything about there not being a +logbook +in the SHU, for those telephone calls? +I know +it was +We +were +looking for logbooks. I can't remember if that +book was one of them, to be honest +with +you, +because I collected so many. +So, I can't +remember if that actual book was missknow if +And do +actually did monitor the +call, +and 1og +it? +I don't know. +You don't know +he did + + +116 +1 +2 +4 +• | +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +or not? +: I don't know. +: Okay. Do you know +anything -? +Did your investigation reveal +anything +that transpired during that call? +_: No. +I don't know. +: No. So, you never found +anything more? +I never found anything +How serious of a +more. +violation do you consider it, +if the inmate had +- in this specific instance - both provided +opstein the phone call, and put nım ın the G- +cler snower, walked away, and not only walkec +away, but left the unit? +And the inmate could +then +talk by himself. +Is that a pretty +significant thing, or -? +It is. Because it was on a - +again - it was on an unsecured line. +know, you can't get the recording back, +even if +you an emergency and you neded to +for a minute, you know, you still can go and +listen back to that phone call, to +anything transpired. +Sure. And why is +it? +Is + + +3 +5 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +it, like, a potential danger to other inmates +in the facility, by being able to provide +inmates these unsecured phone calls? +I would say yes. +So, it's a security +matter? +It's a security issue. +: +Okay. And what is your +opinion on if, when +- Epstein +says he's +calling his mother, and Mr. +calls the +number that he gives him, which we don't have +the number for at the time, there's no list, +and a male answers the phone. And then, he +provides Epstein with that call. +What is your +thoughts on that as an SIS lieutenant? +: +Can I -? +Just +rephrase it. He gave him the phone call, and a +male answered the ho, cater +•: So, Epstein says, I'm +calling my mother. This is the numbermale +calls the number. +answers the phone. And then provides the phone +to Epstein. +At that point, I wouldn't +have provided the phone to Epstein. +would + + +118 +3 +5 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +have hung the call up. +Right. So, is that also +a pretty bad security violation? +Should he have verified who +was on +the phone? +Should he have asked for a +name? +Was there a logbook, +at that +point, +in the SHU? +MS . +I don't know. +I don't know. +Is there something called +endogen (Phonetic Sp. +*01:24:39) inmates? +Inmates. +Now, if -- +-- can you -? +What does that mean? +What does that mean? +Endogen is inmates that, you +now, don't have any money on tneir accounts +H +hev don't have no tvpe of resources +No type +mo +in, through family +members, or + + +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +119 +anything to that effect. +Now, if an endogen inmate +wanted to make a phone call, what +is the +procedure for that? +I'm not too sure how unit +team deal with endogen inmate. +: Okay. +: I'm not too sure. +: Is it - have you +ever heard +the procedure that, if an inmate doesn't any +money in the pack and PIN, they can't make any +phone calls, the unit team sometimes allows +them to make a phone call on the legal line? +: I've never heard of that. +Regardless, if an inmate +is speaking on the legal line, it's always +supposed to be -- +: A legal +-- monitored? +- a legal phone cal this +Where if it's +case, that an inmate that doesn't actually have +money, if they do allow it, they have to +monitor it. +Correct? +They have +to sit there +and listen to it with them? + + +8 +9 +10 +11 +1 +2 +1 +3 +1 +4 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +120 +: They +do, but they shouldn't +allow +it because it's a legal line. +1: Okay. So, really, the +legal +line is only supposed to be +i only for legal: +-- okay. +So, not only +was this not done properly, they should have +never provided Epstein a call from +the legal +line, +is what you're +saying? +- Right. +Is there another line, or, +like, +a pack and PIN set up to utilize for +inmates that don't have any money, that want to +make calls? Like, you know how pack and PINs +are assigned to each inmate. Right? +she, and PING +1: Yes. +: Now, if it's an endogen +inmate, and they wanted to make a phone call +that's not legal, is there a special code that +the +unit team can +use? +I don't know. +: And if the captain, +I don't know. +if there +was a +conversation between the captain and the +unit, +Nathaniel +and the +captain + + +1 +10 +11 +12 +1 +3 +1 +1 +5 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +121 +instructed him to monitor it, and log the call, +what does that mean to you? +: That mean you should be +standing there, listening to the phone call. +: And you should be recording +it in +the +logbook. +All right. Anything +else +on +that? +: Nope. +Now, let's talk about August +10th. +Right? When did you find out about Mr. +Epstein's death? +Maybe about 6:00 in the +morning. +I got a call at home. +I +got a call +at home, by the captain called me. +Captain +Captain +called me. +Mm-hmm. +And he said we have an +emergency. +I need you to come up to the +institution. And I said, okay. +What happened? +You know, I'm getting up now. +And he said, +it's Epstein again. +And I said, +What +happened? +You know, with Epstein. +And he + + +1 +3 +4 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +122 +said, Epstein tried to kill himself. +So, I +said, okay. +I got dressed, and I came up to +the institution. +It's not until maybe I was +here maybe about 45 minutes, when I learned +that he was deceased, and then, everybody said, +wait, you didn't know? +And I said, no, because +I heard tried. So, and I remember +he go to the hospital because try mean, okay, +did we take him here? +when I got to there, +like, no, he's in the hospital. Like, he's +deceased, +and I was, like, +_: Mm-hmm. So, when +Do you know if he was +alive +when the first officer responded to him? +— Oh, I don't know. +Do you have +anything, any +investigative steps that you took reveal +anything about that? Like, life-saving +measures, like, to keep him alive versus bring +him back? +: I don't know. +overhearing +that they did some CPR measures. +But I don't really know who did what. +When you arrived at the + + +123 +1 +3 +4 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +facility, around what time was it, +approximately? +Maybe, I know it was before +7:30. +: And was he already gone, at +that point? +Yes. He was already gone. +And when you came in, what is +the first step you did? +1: +I just started gathering +evidence. +You know -? +1: Did you go up to the SHU? +: Yes. I went up to the SHU to +take whatever logbooks that was up there, and +that I could find. +I went to the control +center to look for the count slips, from the +night before, the 9th and the 10th. | +• 1088: +The warden +nad took some of the count slips. +He beat me +co the puncn. +So, he did give me what he took +because it was -. +Everybody was just trying to +gather i +up evidence, just +-. +We're just trying +get a -- +On -- +sorry. +-- and on the +count + + +1 +3 +5 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +slips, did you find anything out about the +counts that were conducted, or not conducted, +that night? +On the count slips, I just +seen that they were filled out. +They were +filled out. +And I think, I want to say the +10th was missing. Because everybody would run +around, looking for the 10th count +can't remember what time. I think the 3:00 and +the 5:00, they were looking for. On the count +slips. +When you said they were +looking for it, where were they looking for it? +In the control center. +: I see. +: Because that's where the +count slips would be. +: So, they went to -. +the captain, or the warden, went down to the +control center, they were looking for the 3:00 +a.m. and the 5:00 a.m. count slips, and they +couldn't find them? +•: I don't know who actually +went in the control center because +it's +understanding they were looking for the count + + +1 +2 +3 +4 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +125 +slips before I arrived. +So, what -. +Did you do any vetting of +the counts, though, to notice, like, +if the +count slips matched up with the institutional +counts, or anything like that? +Did I do any? +1: Yeah. +No. I didn't. +So, you didn't notice. +Did you notice any of the count slips having, +like, +any extra writing on them? +or 73+1. Or anything like that? +Hmm. I can't remember. +writing ke that? +Like, +95+1, +So, you don't remember. +I can't remember. +okay • +Do you want to show +that? +I mean, yeah, +if you +want +to, if you have it. +Sure. +We' 11 come back. +So, I'11 +come back to that. +I just had a +few +So, when you came in, people were +questions. +already in +the SHU, +looking for stuff? +Pulling stuff up? + + +1 +N M +7 +8 +9 +10 +11 +1 +2 +1 +3 +1 +4 +1 +5 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: That, it was only the captain +gave me a few things. +He was looking for his +folder. His 292s and stuff to that effect. +-- +: That would be Epstein's +folder? +: -- Epstein's. +: Okay. +So, whatever he found +with Epstein, he did give it to me. +Whatever +he found in the SHU. +Again, the count slips +were in the warden's office, what they +found. +So, I did get those from him. +What is the normal procedure +if an inmate dies in prison, or, you know, a +suicide happens in prison, +procedure on the actions to be taken? +Well, prior to we get +into that, why were you all looking for the +count slips? +1: That's, like, +a procedure, +what +we do, you know, we look at the count +slips to make sure - especially with +a suicide +in . +SHU - you want to make sure that the count +was conducted. +You're going to review + + +3 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +cameras and see that the count was conducted. +You know, it's just to make sure, basically +everybody is accountable, and do +what they +needed to do. +: +And did you do any of +that, trying to ensure that those counts were +conducted? +: Well, it was no cameras, +and +I didn't do an investigation, because +at that +point, once we notify OIG and FBI, we knew that +it would be their investigation. +So +-- I did no investigation. +: And do you know +if the +counts were conducted? +I don't know. +_: Okay. +Okay. i +So, now the procedures. +Well, on the same note, then. +Did they eventually find the count slips? +They found -. +-. +ME; don't think the 10th was i +They did find +ever located. +It could have been. +I can't recall. +But I +know the 10th was the missing count +slip. +One + + +1 +2 +4 +LO 00 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +of them went missing or something to that +effect, that, you know, OIG kept calling me, +and I'm, like, I'm looking for them, +I'm going +through everything, I'm going through, you +know, we were trying to find. +It was something +missing. +I can't remember the timeframe, +but +it definitely was something missing, +at the +time. +But you didn't say, it +eventually was found? +I -- +: Okay. +And do you know -- +: -- I +can't remember. +: -- so, when you came in, +right after you found out about the incident, +did you come right to the SHU? +Who was in the SHU, at that +point? +I don't remember. It was a +lot of people. +When you say a lot of +people, +like -? +administration. +: In and out of the +Like, +Like, the captain, +in, i thine, + + +129 +1 +2 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +was up there at the time. Or I -- +Was -. +-- I can't even remember what +officers was up there, to be honest with you. +point? +Who was in the cell, at that +Epstein's cell. +Nobody. +Nobody. +Was that +sealed off? +The door was locked. +Do you know who locked it? +I don't know who locked it. +And why was the door +locked? +I don't know, but I'm +assuming somebody locked it +because they knew +it would be -. +You know, we would do an +investigation on it. +Do you think it was +a +possible crime scene? +MR +And they sealed it up +so no +one came in and out? +1: Nobody came in and +out. +When +I got up there, it was locked. +We took the +CPAP machine, +and different stuff +out of it, we + + +130 +did. And we inventoried it in SIS. +: +So, that's a question. +when you -. +It was locked. Since did +go in, at that point, to take stuff out? +We didn't go in +right +then and there. +No. We roped it off with the +yellow tape. +We roped it off with +the +10 +yellow tape. +11 +: And then, of course, +what +12 +about the stuff inside the - before we go in +13 +this room - what about the stuff in the +14 +officer's desk? +Was stuff inventoried out of +15 +16 +the desks? Taken stuff, taken out. +Like, any +-- +17 +18 +19 +-- anything related to +Epstein. +Like, you mentioned that +the captain +20 took the folder. +Where was that folder +21 +22 +: +-- taken? +23 +We couldn't find -. +They +24 +couldn't find the folder. +25 +Oh, they couldn't find + + +131 +folder? +They couldn't find the folder +at all. +So, whatever paperwork he got was +stuff laying around. +So, +desks, +and things like that? +* Ike that stuff off the +I'm - yeah - I'm assuming +that's +where he got it from. +Was an inventory made of +those +stuff that he took out of the SHU? +: Okay. What are the steps - +as an +SIS lieutenant - did you guys take any +naterials out of the SHU, as evidence? +I: What do you mean? +: Like, did -- +: Find something? +- any paperwork related to +Epstein, things like that, did you guys +inventory anything? +Everything related to +him. +Because we brought +it down +to +SIS. +We +turned it over to OIG. +So, the +And we +inventoried it. + + +N M +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +132 +: -- inventory was done by you, +not the FBI? +_: No. +It was done by me +They +signed off on it, well, as I was handing it to +them. I had everything on an inventory list, +of course. +So, they were double checking what +I was giving them, and they signed off on the +chain of custody. +And that morning, the round +sheets, where did you find the round +sheets? +So, someone gave me the round +sheets. +: So, it was not -? +It wasn't +in the SHU? +: okay. +And Epstein paper. +You said you took anything Epstein related, +right? +In paperwork. +: And, like, what kind of +paperwork did you take? +00f. +I think I got, like, +one or two 292s. I may have. +Whatever +it was, +was very little. +Do you recall taking +this + + +1 +3 +5 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +orange sign, mandatory -? It says mandatory +rounds must be conducted every 30 minutes on +Epstein. +1: Not, I've never even seen +that +sign. +So, you've never seen that? +: No. +And do you recall any +signs +being up in the SHU, regarding Epstein? +No. I don't recall. +Him needing a cellmate, and +your rounds being -. So, you don't recall this +in there, either? +: +No. I've never seen that +sign. +Do you know who collected +that, +by any chance? +I don't. +So, if you -. +Was it the captain that +went in and collected a lot of this +the one that +-? +He did, but - +And was he the one -- +-- that was never + + +1 +3 +5 +6 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +134 +: -- that provided -? +He +provided you with some of this stuff, though, +like, +the 292s that you're talking +about ? +1: Yes. +He gave me the 292s. +And what is that? +that, +like, +the feeding +-- +The feeding. +-- and the showers? +The showers. Yes. +: Okay. +But you +don't recall this? +I've never seen that. +Was there any lists +kept in +the SHU, to say any special needs for +the inmates? +Like, if they are suicidal watch, +and things like that, is there any +special +lists in the SHU for +It should have been +list. +What we call a hot list, that psychology +would have put up there. Do you recall if +there was one in the SHU, at that +: I don't know. +I don't know. +And if there was one, +where + + +1 +3 +4 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +135 +would it have been kept? +I would think it would have +been posted somewhere near the officer's +station. +: +Okay. And what about the - +now, let's go to his cell - who inventoried +everything out of his cell? +1: My SIS tech went in, and she +took what was in there, which was, +like, some +letters he had. I think some pill bottles. +And the CPAP machine was in there. +Did you assist your - sorry, +I wrote the person's name. +Did you assist +1? +Yeah. I was up there. +How do you spell her last +name? +so, +it's, +I wrote +it m +And first name is +? +Like, our -- + + +136 +1 +3 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +...... +th +•H +and +linens +our country? +Mm-hmm. +okay • +Cool. +So, did you assist her when - +Yeah. i +I was there. +-- when she walked in -. +were. +What was your impression when +Like, what did you see when you +Just, it wasn't much +in the +It was just more, linen sheets, +linen +Was there an excessive -- +-- excessive amount of +she +00 +Did you inventory +• that? +I didn't. +Do you know around how +sheets were in there? + + +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +137 +No. I don't. +: But it seemed excessive, +though, +for +For Special Housing. +-- right. +more +So, there were definitely +than should have been in there? +I would say. +would +be the case? +What about the pill bottles? +All those pill bottles, and you said you saw +medication, things like that. +I don't remember if they were +empty, or if medication was in them. +I know we +just took them. +I: Can you start going +through the pictures? +I think -- +- let me show you pictures. +Sorry about that. +Because we have pictures +from + + +138 +1 +W N +Who took the pictures? +Do you know? +Ms. +7 +8 +9 +the pictures +10 +MS +11 +12 +MS +13 +14 +MS +15 +MR +That's okay. +So, +what I'm showing you are +taken +inside the SHU. +Is that Epstein's cell? +This is +On the top. +-- yes. +And that's the -. +You guys +16 +put the +17 +MS +18 +19 +The tape on it. +- the tape on it, to make +sure. +20 +21 +That's it. When +you say you guys, sIs did? +22 +23 +24 +25 +Sorry. + + +139 +1 +2 +7 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Oh. +No, no, no. +So, is this from the outside +of his +cell, the second picture? +With l +_? +This is the outside. +So, what is this wire +coming +up? +Is +that +the CPAP machine? +removed it from the cell? +• the ce 1i you said you +Yeah. We took the +CPAP +machine. +And the CPAP machine +only extends +to right there? +I can't remember where it was +located at. +I just know she went, you know, +took it out. +So, what +was there - on the CPAP +machine and that cord specifically - was there +any indication that he may have used that to +strangle, +to attempt to harm himself, or +someone else attempt to harm him? + + +1 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +140 +: No. +Just the, like, the - +just the CPAP machine with the cord. +: So, was the cord not, +like, disheveled, or out of place? Was it +straight from the machine, all the way to where +it was plugged in? +I can't remember. +: Okay. But there was +nothing +I can't. +: +- that indicated that he +was strangled by anything other than the noose +that they found in there? +: +Nothing indicated that +the CPAP machine or cord was used? +No. Hmm-mm. +No. Okay. +What happened to the CPAP +machine? +It's in the SIS shop. +In the +inventory• +Oh, it's still there? +should be still there. +I've been gone for a while. +But +yes. + + +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +141 +Okay. But that was taken as +-- evidence? +okay. Now, +seen a lot of the orange. What is that? ++ +00) +They look like sheets. +And if you notice, there's a +03 +on the floor. +Is that where Epstein slept? +I don't know. +Do you know if that's +they found his body? +I don't know. +So, this might +de +3 +00 +So, they were -- +I'll just -. +- were all the lines and +were +they, then, if they +weren't +H +•H +they +all discarded? +I don't know. +I don't know. +You don't know. +Now, +this picture +- sorry, I + + +1 +3 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +142 +had to flip it a couple of times - it 1ooks +like it's from the corner -- +- Right. +-- looking into the cell. +What are these things that's tied up on? +This, and like these? +: Yeah. Is that just to hang +clothes? +They're clothes lines. +use them normally. +They +Mm-hmm. +Well, what about this? +: I don't know. +: So, there's a ladder here +that +goes up to the second floor. +: Right. +: okay• +And it looks like +there's a whole bunch of items on top. +between the materials that's on the floor, and +the materials on the bed, you said there was ar +bes you at the was ar +excessive amount of linen and -- +: +Linen. +-- linen. +окау. +: Who would be responsible +for +providing a +linen, +or removing +linen? +That would be the + + +143 +1 +2 +4 +00 ~ 0 ( / +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +officers. +Okay. So, people in the +SHU? +And was that at all +questioned, like, hey, why was there so much +linen +in there? +: I don't. I didn't question +them. +: Okay. +So, I can't -. I don't know +if anybody else did. +searches were being conducted, would +ted, wound Coat +that be +the time that they would actually take - +Take everything. +-- the linen out? +5o, what are we looking at, +at this picture? +Is that the AED machine? +And what is this right here? +: I don't want to say +the word +noose, but, you know, that's what +it looks like + + +144 +1 +to me. +Okay. And where exactly on +it, is this on the floor? Is that +on the +corner? +I don't know from the angle. +: But you know of, would +you know if this was the noose that +actually +1: +This was -. +-- used -? +don't know. +I don't know. +Do you know if there were +multiple nooses? +I don't know. I don't recall +seeing. +I don't recall. No. +•* +And where is -? +What +happened to the noose? +It's in the SIS shop. +Okav. +Yeah. The SIS. +: +Still to this day? +It should be. +saw it there? +When was the last time you +It's been a while. +I've been + + +145 +1 +2 +out of work for some time. +: Okay. +4 +understanding of how the noose -? How they got +pstein down? Do you know if it was ripped, or +if it was cut? Or do vou know anything about +that? +8 +|: I don't know. Nobody never +9 +said. +10 +11 +1ooked +at +12 +it. +•• +: okay. So, you never +Because no one said it to +13 +you? +14 +: Right. +15 +16 +But not when you were +17 +wasn't +18 +19 +Sit hanging rom here he was hung trong was +20 +do you know if it was taken off of him after +21 +they -? +22 +23 +1: +I don't know. +_: m +You don't know. +And who +24 +would be the person to talk to about +that? +25 +•• +The responders. + + +1 +2 +3 +146 +7 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Like, the first +d +(D +00 ++J +As in, like, Noel and +The responders would +seen the condition of the cell. +Now, this is a picture. +It +like +The bottom of that. +-- what is this right here? +is +a +A mattress. +-- is that +another mattress? +It look like it. +So, there is two mattresses +of each other? +Mm-hmm. +: Okay. +Let's go back +another mattress on the floor? +Because +see, two mattresses here. +Right? +NO. +That's only one. +: Oh, that's the + + +147 +1 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Again -- +-- bottom one here. +-- I don't know who took the +pictures. +I know +she took a set of pictures, +and then when the FBI came in, they were +searching the cell, and they took a set of +pictures. +So, I really don't know +whose +pictures those are. +Is +that two mattresses, or +just one mattress? +It looks like one. +: One. +But so, I +thought this picture taken, another mattress +was put on top? +: +This look like two. +Of course, well, it is two. +SOr +I don't know +And 1ook at this pill +bottles. +There's different medications sitting +on the top bunk? +Are those things +allowed +in +the SHU? +MS. l +: +The inmates, I think, are +allowed to have their medications. +It's not something where the + + +1 +2 +7 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +medical comes by? It's because they're in the +SHU, medical comes by daily and gives them the +medication? +line daily. +They normally do, do a pill +I don't know why he +had - . +Well, it's dependent on +the medication. +It is. +Correct? Some +-- +- some medication can be +provided +-- +Because I've seen +-- through self-care. +-- yes. +Some needs to be provided +by the +noose. +medical staff. +And that's the picture of the +Something you guys took, +The one that we took. +Do you know if this is +the same + + +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +149 +1: Let me see. +-- one that we looked in +the other picture, though? +Not that. +I don't know. +It looks like that. +There's +different pictures of the noose. +All right. +And we've got a +picture of bed. +With all the linen on it. +And that's all the materials +that was on the top bunk. +1: Did you -• +You didn't take these +pictures, +though. Correct? +: No. +Did you even go into the +cell, +at the time, to see all of this? +No. They -. +When the other +agencies +was there, +and we were out. +On +outside. +: Okay. So, but +the one who took +these pictures? +I don't know if these +are her + + +1 +2 +4 +7 +8 +9 +10 +11 +12 +1 +3 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +150 +set of pictures because the FBI took pictures, +as well. So, I don't know -- +-- if you have hers +OI +theirs. +I gotcha. +Before the FBI got in, +was +anything moved in the cell? +NO. +Okay. So, yeah. +This is +the kind of overall picture, +and this is where +it kind of, you know, looks like +there's +definitely an excessive amount of linens. +Correct? +issue, +On these pictures, yes. +: +And is that a security +if there is an excessive -- +-- amount of linen? And +what is that reason that that would be a +security issue? +MS. O +The inmates been +known, you know, and to start fires. +Suicide +inmates, that's excessive for them. +Definitely. + + +1 +2 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +151 +: +SOr +inmates that came off of +suicide watch, or is, like, an observation, +they shouldn't have +-? +1: No. They shouldn't have that +much linen. +: Okay. +You would - I know +you've been speaking - but you don't know where +exactly he hung himself, or where the body was +found, or anything like that? +—: No. I don't know. +Do you know if - for +instance, this, +this looks like potentially +where he hung himself from - do you know if +this was placed back up there, or if that +remained there, undisturbed? +I don't know. +You don't know. +SOr +where is +now? +I'm assuming she's here +Okay. So, she +stili +works +here? +Oh +that's what you mean. + + +1 +2 +3 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +152 +And she's still an -- +SIS. +-- an SIS? +Okay. So, she would be +really the person - she took photos - she would +be +the person to ask about -- +Yes. She did take photos. +-- these things? +Thank you. +Mm-hmm. +No problem. +: Did she have any +involvement with investigation? +she here +prior to your arrival? +I don't know if she +was here. +Was that -? +No. She wasn't here. +She wasn't here. +So, she came after -- +-- you arrived. +And did +you immediately say, go take photographs, or +what did you tell her to do? +went up to do the photo -. + + +3 +• 00 01 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +153 +Tape the door up. +We went up to tape the door +up. +I don't remember at what point she took +photographs of the cell. +: But it wasn't that day? +No. I don't think she went +inside -. +Because it was blocked off. +SOr +nobody went inside that day. +We just took the +angle you see of the door. +Just +so we could +show that we taped it off. +I: Did the FBI go in that +day? +When they came, yes. +Okay. SIS did not go in +that +day? +Just the FBI? +Was there video taken, +oI +just pictures? +I don't know. We +didn't take +any videos. +Nothing? +Oh, no. +It sounds + + +1 +2 +4 +LO 00 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +154 +like the FBI is the people to talk about, with +the - as far as who went in there first, +to -- +They went in +-- +-- to take pictures. +-- we just escorted them up. +I escorted them up there, and -. +Do you know if anything - +alter they removed Epstein's body from the cell +- do you know if they, anybody went back into +that cell? +I don't know. +You don't know? +I don't know. +Prior to the FBI going +in? +When Epstein was brought up +to the hospital, do you know what he was +wearing? +Do vou know if there was an inventory +stuff on the +.? You know, the clothes that was +on him. +What +happened to the stuff +that +inventoried? +I don't know. +Was anything brought back? +Nothing was brought + + +back. +155 +But the disk with the pictures they took +out there. +Do you know, did you hear of +when R&D, was any R&D officers sent to the +hospital? +1: I don't know if the officers +was there. +The supervisor, Mr. +went out +to the hospital. +And when they go out on a +10 +11 +situation like this, do they go to the hospital +with anything with them? Like cameras +12 +You took the pictures. +13 +And he - I think he did the fingerprints. +14 +So, he did take pictures? +15 +16 +: It's on a camera provided by +17 +MCC? +18 +19 +And he took fingerprints +20 +also? +21 +: I think he did fingerprints +22 +also. +23 +24 +: Did he also take +a +video, +or just camera pictures? +25 +Just pictures. + + +1 +2 +3 +5 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +156 +: Do you know where those +pictures are? +on my home drive. +Okay. Is that another +thing that we can ask you to send to us, as +well +less, +-- to make it a little +and then we'll send in an email +out. +Mm-hmm. +Is there a reason +(Indiscernible *01:49:37). +Oh, it's (Indiscernible +*01:49:39) +I was -. +Because I had a binder, too. I was -• +just trying to brainstorm, +see if I could get +it to you guys while you're here. +That's what +-. +: Is there a reason why +- sorry - that L +went to the hospital, +took pictures on his personal phone, and textec +that over to the AW? +•: I didn't even know he went to +the hospital. This is the first +I'm +hearing he +went to the hospital. + + +1 +2 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +157 +: He said he was under the +impression that the R&D did come in with the +camera, but they left without taking +any +pictures, and they took the camera with them. +I don't know why he was under +the impression because he brought the camera +back, +and I downloaded the pictures off of it. +1: Is there any policy about +just anyone, you know, C.O.s, any BOP employees +taking pictures on their personal phone, for +suicide, or anyone like that? +You shouldn't be taking +any. +Are you familiar -- +Any pictures. +: - if there's any policy like +that? +: I don't know if it's +a +policy. +I don't know. +1: But as far as you know, you +never got those pictures? +From Mr. +Do you have +questions +in regards to that topic? + + +10 +11 +1 +4 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +158 +Nope. +Have you heard - did you hear +anything about doors in the SHU being left +unlocked? +about C.O.s possibly leaving the SHU doors +unlocked, the tiers doors unlocked, so it's +easier to walk in and out? +I don't know. +: Okay. +What about cell doors? +Did you ever hear any rumors about possibly +that cell doors in Epstein's tier was left +unlocked? +: No. I never heard it. +What is your +understanding of how Epstein -? Of what +psened Wall? My understanding was, they +found him, +I guess sitting on the floor, +with a +rope around his +neck. +And I don't know +went in the cell first. +But I did hear was +Mr. Thomas, Ms. Noel. +I heard Lieutenant , +and I don't remember who it was from medical. +As far as when he + + +1 +2 +4 +LO 00 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +found, though, was it your understanding that +he did whatever happened to him, to himself? +That's what my understanding +Was. +: Do you have any +information at all that would suggest that +Epstein did not harm himself, and that someone +else harmed him? +Did he have any threats from +other +inmates? +I don't know. +Okay. Anything else? +Nope. +Did you ever interact with +Epstein while he was at the -? +When I did the first suicide +attempt, allegedly. +interactions? +After that. Have there been +No interaction. +I just seen +him in attorney area because he did his +attorney visits pretty much all day. +would walk by and see him, +I will step in and + + +1 +2 +4 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +160 +ask him was he okay. Normally, he will just +give the thumbs up, +and you know, +I will walk +away. +But if I see him, +I definitely will ask. +You +know, you okay, anything you need? And he +Was he given any special +privileges here at the MCC? +Not that I know of. +Being that -. +What is your +understanding about him having attorney +conference every day? Did you know that he was +in attorney conference pretty much +every +day, +from 8:00 a.m. to 8:00 p.m.? +1: Yes. +: Was that something that was +afforded to other inmates? +I've seen it done before. +So, it's happened in the +past? +So, it's not just him? +Mm-hmm. +Do you know which + + +161 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +other inmates? +: No. We don't need to -. +I don't know. +I got nothing else on the -. +: +So, these are +- when we +were +talking about count slips previously - +this +is what I was talking about. +see, all these other counts, this was +as the 10:00 +p.m. count on August 9th. +All these other +count slips have crosses all over them. +They're checking, you know, say, +understanding, it says as one, different things +come +in, they check them off. +-: Mm-hmm. +: +Well, these two that one +is from R&D, and one is +from the SHU, one) they +don't have the check marks coming off of; +two) they ZA one, which is the SHU, says 73+1. +And the R&D says 9S+1. Do you know anything +about that? +I don't know what the +plus one stands for. +No. Do you know anything +about, like, ghost counting, or anything + + +1 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +162 +that nature? +I've heard them ghost count +before. If an inmate was in medical +during a +count. +Would they put, like - +One. +-- a plus one on the slip +if they're ghost +counting? +I've never seen. +seen +a plus one, when I've taken +I've never +count. +To be honest with you. I've +never +seen a plus one. +I: And when you said that +you were handling the count slips, +collecting them, did you remember +anything like that, with the 9S+1, or the -? +I don't remember. +•: You don't remember? +I don't remember. +Is that very abnormal to +you, +that those things are on there? +I would have +sent this + + +1 +3 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +163 +count slip back because plus one -- +: Or it -- +-- doesn't tell me -. +: +people that were doing the count, that +wrote +it, +is actually where the thought is. +Oh, I don't know. +But you don't know. +I've never seen a +plus +one. +: Okay. +In terms +of, if there is +possibly a suicide, is there, during +training, +are C.O.s taught what actions to take if they +think that there's a possible suicide attempt +in a cell? +Yeat is the training? +We get suicide prevention +training yearly, during annual' refresher +training, the psychology conduct mock +exercises. +MR. C +And what do they teach you? +Like, if you see something. +If you +see +possible suicide. +What is the C.O. supposed to +do? + + +1 +2 +• 00 01 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +164 +First, you're going to yell +for help, +or for a supervisor, but when you +have another staff member with you, you could +open the door and +attempt to free that person, +if - for instance - if it's a noose or +something to that effect. +They don't have to wait for +other C.o.s to respond? +Well, it is recommended that +you have somebody with you. +: +It is recommended that you +have somebody with you. +Recommended, not +required? +I: I don't think it's required. +Is there part of the +security part where it could be a rouse to get +you in, and then they could overthrow you? +Absolutely. Absolutely. +So, is that why +our understanding was that it was +actually a +requirement that you're not supposed +go in - +By yourself. + + +165 +1 +3 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: -- by yourself. +Just in case there is a fake +attempt or something to get in you. +Anything else? +Nope. +I got nothing else in my line +of questioning. +: Great. Yeah, no. +there is no, nothing for you to believe that +Epstein did anything other than take his own +life? +: No. +And then, that +these other things were just systematic +failures. +What do you think overall led to +Epstein being able to take his own +life? +1: I want to say the systematic +failures, the breakdown with, you know, +although we don't know the previous attempt, we +don't know the logistics, right? +know we had this inmate, we should have been +watching him a little bit better, +I think. +So, do you think the main +reasons would be, if counts and rounds weren't +being conducted, would that be a big + + +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +166 +into why he was able to kill himself? +Yes. i +I would say so, +because +if you know nobody is walking around. +What about the fact that +he didn't have a cellmate, and he was supposed +to have a cellmate? +That, as well. +: Do you think one +is more +important than the other? +of them +Or do they +go hand in hand? +I think they go hand in hand. +Okay. So, they're both +: +as equally +-- as important. +there anything else, aside from those +two main +issues, that you think led to Epstein's death? +I really can't say. +I don't +know. +Okay. Anything that we +didn't ask you, +that we should know +about? +No. You guys pretty much +-- +much +asked -- +I know we -- + + +167 +1 +2 +5 +6 +10 +11 +1 +2 +1 +3 +1 +4 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +everything. +-- we covered a lot. +Great. +Well, thank you for taking +the time to talk to us today. +Can we just have +No problem. +-- her +initial? +Okay. So, the thing +that, +we just - so that we know we talked, that +all these have to get attached to the +recording. +If you could just initial. For +instance, this pack. +Just initial the top +photograph, because +there's anything +attached " ripe, +-- +so you don't have to +go through none of those. +But the things that +we discussed, if you don't mind just - +No problem. +-- initialing +and +dating. +And today's date is +The 23rd. +Correct? +-- correct. +So, 9/23/21. + + +1 +4 +7 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +168 +Oh, I feel special. +I got a +new pen. +Oh. +Oh. +There goes that. +had the other pen. +Okay, there you +go, +I just +sir. +I apologize. +And it goes government pens. +Anything else? +MS +(Indiscernible *01:59:01). +(Indiscernible *01:59:15). +Okay. Thank you very +much. +Yeah. No problem. +Is that all of it? +The +things +we covered. +I'm just looking for +You have the most -- +oh, that's everything. +- beautiful handwritinc +I think I've ever seen. +ele calligrapy. +MS. I +Oh, +really? I thought it +was, like, chicken scratch and all +over the +place. + + +H N +3 +4 +was, +like, +wow. +it? +the interview. +September 23rd, +2021. +And once I +it, I +That is pretty impressive. +Okay. You want to end +So, we're going to end +time +11:19 a.m. on +This is Special Agent +ending the interview. +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 + + +170 +CERTIFICATE +I hereby certify that the foregoing pages +represent an accurate transcript of the +electronic sound recording of the proceedings +before the Department of Justice, Office of the +Inspector General in the matter of: +Interview of | +Transcriber \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/1b1dbf4b928572a9166f564474d5f183f68befadc2d33b5e05e75e0e2dede9b6.receipt.json b/vision-fixhub/ds9-parsed-01/1b1dbf4b928572a9166f564474d5f183f68befadc2d33b5e05e75e0e2dede9b6.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..a14d6e1d9b4f8d3440ed6062583b2f7fc2252c69 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1b1dbf4b928572a9166f564474d5f183f68befadc2d33b5e05e75e0e2dede9b6.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -11347, + "dataset": "marble-joined", + "doc_id": "1b1dbf4b928572a9166f564474d5f183f68befadc2d33b5e05e75e0e2dede9b6", + "engine": "marble-apple-vision", + "event_count": 171, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "3e5e9327f7fa19b5081bcb88e674aead006a8aee261eb27dac4ca00edc8b021f", + "output_sha256": "ab82bfb0b3a4a0a22b3fe8450b6a3bc8253e856b77330ae7888589bde6eabe80", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1b26025dad0cb7aca005ecd30ad8dc6ccacd4b0433aaa717185296c6026e5082.md b/vision-fixhub/ds9-parsed-01/1b26025dad0cb7aca005ecd30ad8dc6ccacd4b0433aaa717185296c6026e5082.md new file mode 100644 index 0000000000000000000000000000000000000000..ef24d33b68ecc20e8768dcbce404f2076b875875 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1b26025dad0cb7aca005ecd30ad8dc6ccacd4b0433aaa717185296c6026e5082.md @@ -0,0 +1,110 @@ +(Page 1 of 1) +Bank +NEW PERSONAL ACCOUNT +REGION: Central/Cuasial Jersey (14) +TYPE OF ACCOUNT: Young Saver Stmt +DATE OPENED: +OPENED BY: +ACCOUNT TITLING / MAILING ADDRESS: +STORE NUMBER: 377 +ACCOUNT NUMBER: +TYPE CODE: 107 +USA +CUSTOMER #1 +2 +TIN +TIN TIPE +DATE OF BIRTH +HOME PHONE +Primary +IDENTIFICATION (Describe beice) +D Type it. Stare Drivers License wihoto and Signat +ID Tipe k2: +Stale Country of issu +Sumer Courty of shutt: +Number: +Number: +Expiration Date: +Expiration Dame: +VERIFICATION +07203 +CUSTOMER #2 +4/16/201. +ATE OF NIRT +Minor and Student ID +IDENTIFICATION (Descrite below) +D Tube v1: Social Security Card +She Country of laun +Number: +Expiration Dame: +ST +04004 +ACCOUNT RELATIONSHIP: +1D Type N2: +Some Country of issuance: +Number. +Expiraten Date: +VERIFICATION +SIGNATURE +CUSTOMER BI EMAR +CUSTOMER #3 +DATE OF BIRTH +HOME PHONE +IDENTIPICATION (Descibe Deow) +ID Type A1: +Hurries. +Expiration Date: +LEGAL ADORESS (No PO Bones: +1. - DATE +TIN +TIN TIPE +1D Type R2 +Number: +Expiraion Date: +VERIFICATION +CUSTOMER #4 +DATE OF BIRTH +HOME PHONE +IDENTIFICATION (DESCe DROW) +• Type er: +Draining of innoce +PATENT: +Expiration Dose: +LEGAL ADDRESS (No PO Banesi: +- 2/8/17 +TIN: +TIN TYPE +9 Туре н. +sa/Country of tavan +NUmber. +Expiration Dale: +VERIFICATION +SIGNATURE +DATE +SIGNATURE +DATE +CUSTOMER 83 EMAIL. +CUSTOMER $4 EMAIL +IMPORTANT INFORMATION +Federal law requires all financial institutions to obtain, verify and record information inat identines each person who opens an account. +/We acknowledge receipt of the Deposit Account Agreement, Account Maintenance Information grid, Fee Schedule and Rales, which govern mylour accounts with the Bank, Mylcur use of this account shall evidence +mylour acceptance of the terms and conditions set forth in the Deposit Account Agreement, Account Maintenance Information grid, Fee Schedule and any Addendums as the same may be amended from time to time. +Joint accounts are owned as joint lenants with right of survivorship. +/We, both individually and on behalf of the account owner. if different. hereby authorize the Bank lo. from lime to time, request consumer reports containing references about maus from thind parties, such as a +consumer reporting agency, in connection with opening and maintaining this account. If vou ithe Bank) are unable to oben a deposit account. vou will orovide maius with an addional notice megarding the consumer +reporting agency. +By signing this signature card, we acknowiedge that the deposit acount in which we am/are being added as a co-owner may have an existing Moneyline account aflached. I undersland that a Moneyline account +is a line of credit for overdraft protection. We acknowledge receipt of the Moneyline Agreement and disclosures and agree to their terms and conditions. We undersiand and agree that, as a co-owner of the deposit +account, we wil be fully responsible for payments on the Moneyline account including any outstanding balances at this lime) and that payment history and other credit information may be reported to consumer +reporting agencies. +This section does not apply to U.S. non-resident aliens. Linder penalty of perjury, each customer signing aboue cartilies that- +The number shrun on this from is my comert tavgayer irantifratinn rumhar for i am waiting fe a rumhar in ha idead is mal. anat +2. I am not subject to backup withholding because: (a) I am exempt thom backup withholding. or (b) I have not been noified by the inlernal Revenue Service (IRS) that I am subject to backup withhoiding as a result +of a failure to report all interest or dividends, or (c) the IRS has noified me that i am no langer subject to backup withholding, and +3. I am a U.S. person (including a U.S. resident alien). +Certification instructions. You must cross cut lem 2 above if you have been nollied by the IS that you are currently subject io backup wilhholding because you have failed to report all interest and dividends on your +tax retur or for any other reason. Forreal estate transactions, Item 2 does not apply. For mortgage interest paid, acquisition or abandonment of secured property, cancellation of debt, contributions lo an individual +a pe to a to ves are i required to signine Cernicaton, out you must provide your correct 1IN. +The internal Revenue Service does not require your consent to any provision of this document other than the certifications required to avoid backup withholding. +Rav 070011 I TO Rak NA +L Instructions for Store Team Members: If faxing to CIF, please insert in this direction diff --git a/vision-fixhub/ds9-parsed-01/1b26025dad0cb7aca005ecd30ad8dc6ccacd4b0433aaa717185296c6026e5082.receipt.json b/vision-fixhub/ds9-parsed-01/1b26025dad0cb7aca005ecd30ad8dc6ccacd4b0433aaa717185296c6026e5082.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..83b5d6ad14d12516b179ae3cccb800eb3246352d --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1b26025dad0cb7aca005ecd30ad8dc6ccacd4b0433aaa717185296c6026e5082.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "1b26025dad0cb7aca005ecd30ad8dc6ccacd4b0433aaa717185296c6026e5082", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "0ae124a8db1727a1208234c14267795fed3b3a386248d3930b859a9cd1556461", + "output_sha256": "1231eb14b442f9096bbc0c4d9f5ce8fe6c4fbc8099f489a18ab199dd9b6a6409", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1b465dc8f7f36acb677e6e675f6b8cb6f2c20971c1cb738cf518953c8c5ddef8.md b/vision-fixhub/ds9-parsed-01/1b465dc8f7f36acb677e6e675f6b8cb6f2c20971c1cb738cf518953c8c5ddef8.md new file mode 100644 index 0000000000000000000000000000000000000000..c542ca3fb026f57a202778e3b3ac9610c23419da --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1b465dc8f7f36acb677e6e675f6b8cb6f2c20971c1cb738cf518953c8c5ddef8.md @@ -0,0 +1,2 @@ +SDNY_00000867 + diff --git a/vision-fixhub/ds9-parsed-01/1b465dc8f7f36acb677e6e675f6b8cb6f2c20971c1cb738cf518953c8c5ddef8.receipt.json b/vision-fixhub/ds9-parsed-01/1b465dc8f7f36acb677e6e675f6b8cb6f2c20971c1cb738cf518953c8c5ddef8.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..ebfa5025619939e18a3b7600f80c3959ccb40b23 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1b465dc8f7f36acb677e6e675f6b8cb6f2c20971c1cb738cf518953c8c5ddef8.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -25, + "dataset": "marble-joined", + "doc_id": "1b465dc8f7f36acb677e6e675f6b8cb6f2c20971c1cb738cf518953c8c5ddef8", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "ce0dba915d5e57a54f4971942b1aa22cc4c20ff046998bffe2c655f34075f89e", + "output_sha256": "f7ebc511a49d9214c260b95ef939b95ce3c0da10184d09b85db44d5a6784d47b", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1b5ef96d9ea184411eb23e665e31446062750ef9e6c38843a3a1fd95528263bf.md b/vision-fixhub/ds9-parsed-01/1b5ef96d9ea184411eb23e665e31446062750ef9e6c38843a3a1fd95528263bf.md new file mode 100644 index 0000000000000000000000000000000000000000..bf0b40d6c7762364f62790524e83aee82ad79f7d --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1b5ef96d9ea184411eb23e665e31446062750ef9e6c38843a3a1fd95528263bf.md @@ -0,0 +1,49 @@ +From: +To: +Subject: RE: you'll enjoy this +Date: Thu, 28 May 2020 21:27:53 +0000 +Totally amazing, right? To be so behind that the Times writes an article about it is just completely mind-blowing. +From: +To: +Sent: Wednesday, May 27, 2020 19:42 +Subject: RE: you'll enjoy this +Amazing. +I guess we still have a few years to go before we can complain. +From: +Sent: Wednesday, May 27, 2020 7:37 PM +To: +Subject: RE: you'll enjoy this +You perhaps have never encountered this classic ... +https://www.nytimes.com/2004/12/06/nyregion/judges-decisions-are-conspicuously-late.html +From: +Sent: Wednesday, May 27, 2020 17:54 +To: +Subject: RE: you'll enjoy this +Btw, +What do you think is going on with +and Mazer? +It's over a year now since our 2255 hearing. +From: +Sent: Wednesday, May 27, 2020 5:13 PM +To: Gentile, Dominic (USANYS) +Subject: RE: you'll enjoy this +Utterly! So, so insane. +From: +To: +Sent: Wednesday, May 27, 2020 17:12 +Subject: RE: you'll enjoy this + + +He "asked me to take over the whole case" and called Jay Lefkowitz a "numbskull." +A one man shop is going to replace an entire of lawyers from Kirkland? Delusional. +From: +Sent: Wednesday, May 27, 2020 10:15 AM +To: +Subject: you'll enjoy this +https://www.dailymail.co.uk/news/article-8347883/Jeffrey-Epsteins-lawyer-believes-pedophile-did-not-commitsuicide.html +I mean basically all of this is totally false - I don't believe for a single second that Epstein had told Schoen he would be +coming on to replace the entire defense team (all of whom had represented Epstein for years and years). But beyond +that, why would you brag about that even if it were true?? And brag that you had a strategy for smearing the victims? +It's all completely insane. +Assistant U.S. Attorney +Southern District of New York diff --git a/vision-fixhub/ds9-parsed-01/1b5ef96d9ea184411eb23e665e31446062750ef9e6c38843a3a1fd95528263bf.receipt.json b/vision-fixhub/ds9-parsed-01/1b5ef96d9ea184411eb23e665e31446062750ef9e6c38843a3a1fd95528263bf.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..f2ff291709e4ff0f27c5290412b13e1ae5d677cc --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1b5ef96d9ea184411eb23e665e31446062750ef9e6c38843a3a1fd95528263bf.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -26, + "dataset": "marble-joined", + "doc_id": "1b5ef96d9ea184411eb23e665e31446062750ef9e6c38843a3a1fd95528263bf", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "84d075f8c5db125eadec5ec46c03af7277275abefbad09eb4e67cc5586015003", + "output_sha256": "b9831af9c0749e4aa85f0e5abbce38bd40c4368fe251d432eec11d5775ec9184", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1b88f7f41d34b57599b9a288c1f3eb6abbffd1fa1eeb37782ff11706a04d79e5.md b/vision-fixhub/ds9-parsed-01/1b88f7f41d34b57599b9a288c1f3eb6abbffd1fa1eeb37782ff11706a04d79e5.md new file mode 100644 index 0000000000000000000000000000000000000000..7984c03afa1ad41732d3d7d6f905b80dc137401e --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1b88f7f41d34b57599b9a288c1f3eb6abbffd1fa1eeb37782ff11706a04d79e5.md @@ -0,0 +1,644 @@ +NYC DEPARTMENT OF FINANCE +OFFICE OF THE CITY REGISTER +This page is part of the instrument. The City +Register will rely on the information provided +by you on this page for purposes of indexing +this instrument. The information on this page +will control for indexing purposes in the event +of any conflict with the rest of the document. +2011122700736001004E0B2B +RECORDING AND ENDORSEMENT COVER PAGE +Document Date: 12-23-2011 + +Preparation Date: 12-28-2011 +Document ID: 2011122700736001 +Document Type: DEED +Document Page Count: 3 +PRESENTER: +TITLEASSOCIATES - PICK-UP/ AGUSTIN +AS AGENT FOR STEWART TITLE +RETURN TO: +ERIKA KELLERHALS, ESQ +INEW YORK NY 10002 +VIRGIN ISLANDS, US +PROPERTY DATA +Unit +Address +Borough +Block Lot +MANHATTAN +Entire Lot +Property Type: DWELLING ONLY - 1 FAMILY +CREN +or Document ID +GRANTOR/SELLER: +NINE EAST 7IST STREET CORPORATION +NEW YORK, NY 10065 +Mortgage +Mortgage Amount: +Taxable Mortgage Amount: +Exemption: +TAXES: County (Basic): +City (Additional): +Spec (Additional): +TASE: +MTA: +NYCTA: +Additional MRT: +TOTAL: +Recording Fee: +Affidavit Fee: +S +S +S +S +S +un us +CROSS REFERENCE DATA +Year_ +- Reel +Page +or File Number. +PARTIES +GRANTEE/BUYER: +MAPLE, INC. +ST. THOMAS 00802 +VIRGIN ISLANDS, US +FEES AND TAXES +Filing Fee: +0.00 +0.00 +NYC Real Property Transfer Tax: +S +S +125.00 +0.00 +NYS Real Estate Transfer Tax: +S +0.00 +RECORDED OR FILED IN THE OFFICE +OF THE CITY REGISTER OF THE +CITY OF NEW YORK +Recorded/Filed +01-10-2012 10:00 +City Register File No. (CRFN): + +City Register Official Signature + + +Block: +Lot: +Address: +DEED +New York, NY +THIS INDENTURE, made the 2580 day of December, 2011, between NINE EAST 71ST +STREET CORPORATION, a New York corporation, with an address of +WITNESSETH: +ALL that certain plot, place or parcel of land, with the buildings and improvements thereon erected, +situate, lying and being in the Borough of Manhattan, City, County and State of New York, bounded +and described as follows: +BEGINNING at a point on the northerly side of * Street distant 225 feet easterly from the corner +formed by the intersection of the easterly side of +with the northerly side of Street; +running +thence Easterly along the northerly side of Street 50 feet; +thence Northerly and parallel with +between +102 feet 2 inches to the center line of the block +and +Streets; +thence Westerly along the said center line and parallel with Street 50 feet; +thence Southerly and parallel with +102 feet 2 inches to the northerly side of * Street at +the point or place of beginning. +TOGETHER with all right, title and interest, if any, of the party of the first part in and to any +AnDing preo the said precies hate bet the pay of chian a as not deer rule e +aforesaid. +AND the party of the fitst part, in compliance with Section 13 of the Lien Law, covenants that the + + +before using any part of the total of the same for any other purpose. The word "party" shall be +construed as if it read "parties" wherever the sense of this indenture so requires. +IN WITNESS WHEREOF, the party of the first part has duly executed this deed the day and year +first above written. +WITNESSES +GRANTOR: +NINE EAST +CORDAR ATE +STREET +BY: JEFFREY E. EPSTEIN, +President + + +TERRITORY OF THE U.S. VIRGIN ISLANDS +DIVISION OF ST. THOMAS/ ST. JOHN +) 85: +On the 230 day of December in the year 2011, before me, the undersigned, a Notaty Public, +Notary Public +) +Erlka A. Kellerhals +NOTARY PUBI +Commiss +xpire 305/02/2014 +Territory on +Arginislande +TERRITORY OF THE U.S. VIRGIN ISLANDS +DIVISION OF ST: THOMAS/ ST. JOHN +) +) +ss: +On the 258Dday of December in the year 2011, before me, the undersigned, a Notary Public, +personally appeared GREN. FerGusON personally known to me or proved to me on the +basis of satisfactory evidence to be a subscribing witness to the within instrument, who being by me +duly sworn, did depose and say that HE resides in the United States Virgin Islands; that HE knows +Jeffrey E. Epstein to be the individual who executed the within instrument; that said subscribing +witness was present and saw Jeffrey E. Epstein execute the same; and that said subscribing witness +at the same time subscribed HaS, name as a witness thereto. +Notary Public +Erika A. Kellemais +NOTARY PUBLIC +Commission Expires 05/02/2014 +Territory of if +S. Virgin Islands +TERRITORY OF THE U.S. VIRGIN ISLANDS +DIVISION OF ST. THOMAS/ ST. JOHN +) +) ss: +On the 2380day of December in the year 2011, before me, the undersigned, a Notary Public, +personally appeared Beer GeRRy +• personally known to me or proved to me on the +basis of satisfactory evidence to be a subscribing witness to the within instrument, who being by me +duly sworn, did depose and say that 9k.. resides in the United States Virgin Islands; that site knows +Series 8. 5 percin to ld she jaire al pot execured the wiie, antrume said hat said sud cribing. +at the ma time suhscribed HOR name as a witness thereto. +Notary Pablic | +Erika A. Kellerals +NOTARY PUBLIC +Commission Expires 05/02/2014 +Territory of the U.S. HAD stands + + +NYC DEPARTMENT OF FINANCE +OFFICE OF THE CITY REGISTER +: +2011122700736001004SC5AA +SUPPORTING DOCUMENT COVER PAGE +Document ID: 2011122700736001 +Document Date: 12-23-2011 +Document Type: DEED +ASSOCIATED TAX FORM ID: 2011122700132 +SUPPORTING DOCUMENTS SUBMITTED: +RP - 5217 REAL PROPERTY TRANSFER REPORT + +Preparation Date: 12-28-2011 + + +Affidavit of Compliance with Smoke Detector Requirement for One and-Two Family Dwellings +AFFIDAVIT OF COMPLIANCE +WITH SMOKE DETECTOR REQUIREMENT +FOR ONE- AND TWO-FAMILY DWELLINGS +State of New York +County of +The undersigned, being duly sworn, depose and say under penalty of perjury that they are the grantor and grantee of +the real property or of the cooperative shares in a cooperative corporation owning real property located at +Street Address +MANHATTAN +New York, +Unit/Apt. +(the "Premises"); +Borough +Block +Lot +That the Premises is a one or two family dwelling, or a cooperative apartment or condominium unit in a one-or +two-family dwelling, and that installed in the Premises is an approved and operational smoke detecting device in +compliance with the provisions of Article 6 of Subchapter 17 of Chapter 1 of Title 27 of the Administrative Code of +the City of New York concerning smoke detecting devices; +That they make affidavit in compliance with New York City Administrative Code Section I1-2105 (g). (The +signatures of at least one grantor and one grantee are required, and must be notarized). +Name of Grantor (Type or Print) +Signature of Grantor +Sworn to before me +this +date of +_ 20 +Name of Grantee (Type or Print) +Signature of Grantee +Sworn to before me +this +date of +- 20 +See ove +These statements are made with the knowledge that a willfully false representation is unlawful and is punishable as +a crime of perjury under Article 210 of the Penal Law. +NEW YORK CITY REAL PROPERTY TRANSFER TAX RETURNS FILED ON OR AFTER FEBRUARY +6th, 1990, WITH RESPECT TO THE CONVEYANCE OF A ONE- OR TWO-FAMILY DWELLING, OR A +COOPERATIVE APARTMENT OR A CONDOMINIUM UNIT IN A ONE- OR TWO-FAMILY DWELLING, +WILL NOT BE ACCEPTED FOR FILING UNLESS ACCOMPANIED BY THIS AFFIDAVIT. + + + +Alfidavit of Compilanco with Smoke Detector Requirement for One and-Two Family Dwellings. +AFFIDAVIT OF COMPLIANCE +WITH SMOKE DETECTOR REQUIREMENT +FOR ONE- AND TWO-FAMILY DWELLINGS +State of New York +County of +he undersigned, being duly sworn, depose and say under penalty of perjury that they are the grantor and grantee o +ne real property of of the cooperative shares in a cooperative corporation owning real property located at +Street Address +Manhattan +New York, +xxXXxx. +Unit/Apt. +(the "Premises"): +Borough +Block +Lot +That the Premises is a one or two family dwelling, or a cooperative apartment or condominium unit in a one- or +two-family dwelling, and that installed in the Premises is an approved and operational smoke detecting device in +compliance with the provisions of Article 6 of Subchapter 17 of Chapter 1 of Title 27 of the Administrative Code of +the City of New York concerning smoke detecting devices; +That they make affidavit in compliance with New York City Administrative Code Section 11-2105 (g). (The +signatures of at least one grantor and one grantee are required, and must be notarized). +Nine East 71st Street Corporation +_ Maple, Inc. +Signature of Grantor +Name all rantee-cypoor Print) +Signame on Grante +Sworn to before me +16R0 +December +(2011 +m to before me +2280 +December +2011 +Erike A. Kellerhals +& arka A. Kellerhals +NOTARY PUBLIC +* Commission Expires 05/02/2014 +STARY PUBLIC +Commission Expires 05702/2014 +a Teritory of the U.S. Virgin Islande +These statements are rhas +the knowleage that a willfully false representation i Territory of the U.S. Virgin Islands +Unlawtul and is punis +a crime of perjury under Article 210 of the Penal Law. +NEW YORK CITY REAL PROPERTY TRANSFER TAX RETURNS FILED ON OR AFTER FEBRUARY +6th, 1990, WITH RESPECT TO THE CONVEYANCE OF A ONE. OR TWO-FAMILY DWELLING, OR A +COOPERATIVE APARTMENT OR A CONDOMINIUM UNIT IN A ONE- OR TWO-FAMILY DWELLING, +WILL NOT BE ACCEPTED FOR FILING UNLESS ACCOMPANIED BY THIS AFFIDAVIT. + + +The City of New York +Department of Environmental Protection +DEP +Bureau of Customer Services +59-17 Junction Boulevard +Flushing, NY 11373-5108 +W.w.076.#0v/08p +Customer Registration Form for Water and Sewer Billing +Property and Owner Information: +(1) Property receiving service: BOROUGH: MANHATTAN +BLOCK: +(2) +Property Address +NEW YORK, NY 10021 +(3) Owner's Name: +Additional Name: +MAPLE, INC. +Affirmation: +Your water & sewer bills will be sent to the property address shown above. +Customer Billing Information: +Please Note: +being placed in a lien sale by the City or Service Termination. +Owner's Approval: +Print Name of Owner: +Signature: +Name and Title of Person Signing for Owner, if applicable: +BCS-7CRF-ACRIS REV. B/OB +Date (mm/dd/yyyy) += Seeove + + + +The City of New York +DEP +NTAL MON +Department of Environmental Protection +Bureau of Customer Services +59-17 Junction Boulevard +Flushing, NY 11373-5108 +Customer Registration Form for Water and Sewer Billing +Property and Owner Information: +(1) Property receiving service: BOROUGH: MANHATTAN +BLOCK: +LOT: +(2) Property Address: +NEW YORK, NY 10021 +(3) Owner's Name: +Additional Name: +MAPLE, INC. +Affirmation: +Your water & sewer bills will be sent to the property address shown above. +Customer Billing Information: +Please Note: +being placed in a lien sale by the City or Service Termination. +Owner's Approval: +Print Name of Owner: +Signature: +Name and Title of Person Signing for Owner, If applicable: +Date (mm/dd/yyyy) 12.27.11. +JEFFEY E. EPSTEIN, PRES. +BCS-7CRF-ACRIS REV. 8/08 +2 + + + +FOR CITY USE ONLY +C1. County Code +I CZ. Date Deed L +Recorded +*TEC 2% 201T +C3. Book +OR +C5. CRFN +PROPERTY INFORMATION +I CA. Page +REAL PROPERTY TRANSFER REPORT +STATE OF NEW YORK +STATE BOARD OF REAL PROPERTY SERVICES +RP - 5217NYC +1. Property +Location +1 MANHATTAN +2. Buyer +Name +STREET NUMBER +MAPLE, INC. +LAST NAME / COMPANY +STREET HAME +| 10021 +IF COSE +FIRST NAME +LAST NAME / COMPANT +3. Tax +Indicate where future Tax Bills are to be sent +Billing +if other than buyer address (at bottom of form) L +Address +FIRST NAME +LAST NAME / COMPANY +FIRST NAME +STREET NUMBER AND STREET NAME +4. Indicate the number of Assessment +Roll parcels transferred on the deed +CITY OR TOWN +L # of Parcels OR +Part of a Parcel +'ACHES +STATE +4A. Planning Board Approval - NIA for NYC +4B. Agricultural District Notiog - NIA. for NYC +Check the boxes below as they apply: +6. Ownership Type is Condominium +7. New Construction on Vacant Land +ZP CODE +5. Deed +Property PRONET SEPT +_JOR L +NINE EAST 71ST STREET CORPORATION +8. Seller L +Name +LAST MAME / COMPANY +FIRST NAME +TAST NAME T COMPANT +TORSY NAME +9. Chack the box below which most accurataly describes the use of the property at the time of sale: +AL +/ One Family Residential +C +Residential Vacant Land +E +Commercial +Entertainment / Amusement +Industrial +B +| 2 or 3 Family Residential +D +Non-Residential Vacant Land +Apartment +Community Service +Public Service +SALE INFORMATION +14. Check one or more of these conditions as applicable to transfer: +10, Sale Contract Date +12 +Mont +23 +Day +12011 +A +Sale Between Relatives or Former Relatives +Sale Between Related Companies or Partners in Business +One of the Buyers is also a Seller +11. Date of Sale / Transfer +23 +1 2011J +Buyer or Seller is Govemment Agency or Lending Institution +Month +Day +Year +E +Deed Type not Warranty or Bargain and Sale (Specity Below) +F +12. Full Sale Price $ +Sale of Fractional or Less than Fee Interest (Specify Below) +Significant Change in Property Between Taxable Status and Sale Dates +(Full Sale Price is the total amount paid for the property including personal property. +H +Sale of Business is Included in Sale Price +This payment may be in the form of cash, other property or goods, or the assumption of +Other Unusual Factors Affecting Sale Price (Specify Below) +mortgages or other obligations.) Please round to the nearest whole dollar amount. +None +13. Indicate the value of personal L +property included in the sale +ASSESSMENT INFORMATION - Data should reflect the latest Final Assessment Roll and Tax Bill +15. Bulking Class LA, 5J +16. Total Assessed Value (of all parcels in transfor) L +1 +9 +.4 +17. Borough, Block and Lot / Roll Identifier(s) ( If more than threo, attach sheat with additional identifiers) | +MANHATTAN 1386 10 +sceove + + + +Ci.l: GuERi +FOR CITY USE ONLY +C1. County Code | +ecorded +C3. Book +OR +C5. CRFN +PROPERTYINFORMATION +REAL PROPERTY TRANSFERREPORT +STATE OF NEW YORK +STATE BOARD OF REAL PROPERTY SERVICES +RP - 5217NYC +1. Property +Location +1 MANHATTAN +SOROUGH +1 10021 +2. Buyer +Mamo +STREET NUMBER +MAPLE, INC. +LAST HASE! 7 COMPANY +FIRST NAME +LAST HAME 7 COMPARY +3. Tax +Billing +Indicate where future Tax Bills are to be sent +I other than buyer address (at bottom of form) L +Address +THAT NAME +LAST HAME 7 GOUPRAY +FIRST HAME +TREET NUMBER AHO STREET HAME +4. Indicate the number of Assesament +Foll parcats traneformed on the deed L # of Parcals Of +CITY OR TOWN +Part of a Parcel +6. Deed +Property +Siza +AGREES +L +WATE +4A. Planning Board Approval - NIA for NYC +4B. Agricultural District Notice - NIA for NYC +Check the boxes below as they apply: +5. Ownership Type is Condominium +7. New Construction on Vacant Land +8. Seller +Name +NINE EAST 7IST STREET CORPORATION +LAST NAME / COMPANY +FROST NAME +LAST NAME 7 COMPANY +FIRST HAME +9. Chack the box below which most accurataly describes the use of the property at the time of sale: +MOna Family Residential +Residental Vacant Land +Commercial +G +Entertainment / Amusement +Industrial +2 or 3 Family Residentlal +Non-Residential Vacant Land +Apartment +H +Community Service +Public Sarvice +SALE INFORMATION +10. Sale Contract Date +LIZ +Month +23 +Day +12011 +14. Check one or more of these conditions as applicable to transfer: +A +Sale Between Relatives or Former Relatives +Sale Between Related Companies or Partners In Business +C +One of the Buyers is aiso a Seller +11. Date of Sale / Tranafer +L 12 1 +23 +Mont +Day + +D +Buyer or Seller is Govermont Agency or Lending Institution +E +Deed Type not Warranty or Bargain and Sale (Specily Below) +Sale of Fractional or Less than Fee Interest (Specify Below) +12. Full Sala Price S +0 +T +Significant Change In Property Between Taxable Status and Sale Dates +(Full Sale Price is the total amount paid for the property including personal property. +H +Sale of Business is Included in Sale Price +This payment may be in the form of cash, other property or goods, or the assumption of +Other Unusual Factors Affecting Sale Price (Specify Below ) +mortgages or other obligations.) +Please round to the nearest whole dollar emount. +None +13. Indicato the value of personal +property Included in the sale +ASSESSMENT INFORMATION - Data should reflect the latest Final Assassment Roll and Tax Bill +18. Bullding Class LA, 5J +16. Total Assessed Value (of all parcela In tranafer)L. +12.9.4,3,8,71 +17. Borough, Block and Lot / Roll Identifierts) (If more than three, attach sheet with additional identifierta)) +MANHATTAN + + + +CERTIFICATION +nean al the hang of any milton intered oment to mater a hero i l the at of me prelate one pa ter relate to +the making and fling of false instruments. +BUYER +SATE +TETREET NAME (AFTER SALES +ERIKA KELLERHALSUYERS ATORNEY +LAST NAME +TIRST NAME +AREA CODE +DRESSURE +STREET HUMBER +ST. THOMAS +CITYOR TOWN +COUNTRY +TELEPHONE NUMBER +SELLER +STATE +/PROVINCE +VIRGIN ISLANDS, US +00802 +IP CODE +POSTAL CODE +seeove +SELLER SIGNATURE +BATE + + + +CERTIFICATION +the making and filing of false Instruments. +112/27/11 +STREET HOTHER +"TREET HAME CAFTER LET +ST. THOMAS +BUYER'S ATTORNEY +ERIKA KELLERHALS, ESQ +LAST NAME +POET NAE +AHEADE +TELEPHONE NUMBER +SELLER +STATE +PROVINCE +00802 +2P CODE +MOSTAL CODS +BELLER SONATLA +- 12/27/11 +COUNTRY +VIRGIN ISLANDS, US diff --git a/vision-fixhub/ds9-parsed-01/1b88f7f41d34b57599b9a288c1f3eb6abbffd1fa1eeb37782ff11706a04d79e5.receipt.json b/vision-fixhub/ds9-parsed-01/1b88f7f41d34b57599b9a288c1f3eb6abbffd1fa1eeb37782ff11706a04d79e5.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..7360f4a622c70b5acfc6d6f0cb51b3dda4bc89df --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1b88f7f41d34b57599b9a288c1f3eb6abbffd1fa1eeb37782ff11706a04d79e5.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -494, + "dataset": "marble-joined", + "doc_id": "1b88f7f41d34b57599b9a288c1f3eb6abbffd1fa1eeb37782ff11706a04d79e5", + "engine": "marble-apple-vision", + "event_count": 25, + "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "43fddee19cbcfee1abaf380ac8723327ba21916ea209540de64dab4a48e96b69", + "output_sha256": "f760715b806ff1b685b6d3f053420166cb15c43a51cf8c33c3971449a6c66602", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1ba400741cd2bb8b64c3a12378e7d4713c5976f4537275557364e33444ffbe4d.md b/vision-fixhub/ds9-parsed-01/1ba400741cd2bb8b64c3a12378e7d4713c5976f4537275557364e33444ffbe4d.md new file mode 100644 index 0000000000000000000000000000000000000000..e9147c447669a9cf99b95214354d2047db990991 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1ba400741cd2bb8b64c3a12378e7d4713c5976f4537275557364e33444ffbe4d.md @@ -0,0 +1,10 @@ +From: +To: +(USANYS)" ‹ +Subject: civilian contacts +Date: Mon, 12 Aug 2019 18:37:21 +0000 +Embedded: Case_1:19-cr-00490-RMB-1_Interim_relief.msg; Case_1:19-cr-00490-RMB-1.msg +I received the two attached emails from an individual—I don't know who she is, she appears to be referencing the Epstein +case but she's not a victim or witness. Wanted to let you know. +thanks, +Assistant U.S. Attorney diff --git a/vision-fixhub/ds9-parsed-01/1ba400741cd2bb8b64c3a12378e7d4713c5976f4537275557364e33444ffbe4d.receipt.json b/vision-fixhub/ds9-parsed-01/1ba400741cd2bb8b64c3a12378e7d4713c5976f4537275557364e33444ffbe4d.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..52efe37d05be2231638b0baaeb758e76918494b5 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1ba400741cd2bb8b64c3a12378e7d4713c5976f4537275557364e33444ffbe4d.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "1ba400741cd2bb8b64c3a12378e7d4713c5976f4537275557364e33444ffbe4d", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "d0bc62f3c9cd1a4768667a25ba4e96e3123674b2c98c9f903c1691e4a006f7d2", + "output_sha256": "dd3fc32334dc15532caa79da67e5d1547a55efbd294f354276e1ad1a4d527fad", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1bb9cc497725096e58a22d6da45048774e2353c0f25678f642a1693356e29fdb.md b/vision-fixhub/ds9-parsed-01/1bb9cc497725096e58a22d6da45048774e2353c0f25678f642a1693356e29fdb.md new file mode 100644 index 0000000000000000000000000000000000000000..a9fe973f5dbd73c602e3d5bda4a6115b6fe87d0a --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1bb9cc497725096e58a22d6da45048774e2353c0f25678f642a1693356e29fdb.md @@ -0,0 +1,51 @@ +Additional Inquiry Response +ORI: NYFBINYOO +Federal Bureau of Investigation - New York +New York State Division of Criminal Justice Services +Alfred E. Smith Building, 80 South Swan St. +Albany, New York 12210. Tel: 1-800-262-DCJS +Michael C.Green, Executive Deputy Commissioner of the NYS Division of Criminal Justice Services +• FBI Information +***** +**** +Introduction **************************** +This rap sheet was produced in response to the following request: +The information in this rap sheet is subject to the following caveats: +This record is based only on the FBI number in your request-UCN: +Because additions or deletions may be made at any time, a new +copy should be requested when needed for subsequent use. (US; +2021-10-06) +All entries contained in this FBI record are based on fingerprint +comparisons and pertain to the same individual. (US; 2021-10-06) +The use of this record is regulated by law. It is provided for official +use only and may be used only for the purpose requested. (US; +2021-10-06) +- - - - (US; 2021-10-06) +****** +IDENTIFICATION +****-** +******* +1/3 + + +Ill/FBI/State Delayed Response +Fingerprint Images +(No Fingerprint Image Transmitted +Comment:) +(No Fingerprint Image Transmitted +Comment:) +Photo Images +(No Photo Image Transmitted) +************************** CRIMINAL HISTORY +•************************** +************************* +INDEX OF AGENCIES +Agency +Agency Email Address +************************** +213 + + +Address +* * * END OF RECORD * * * +3/3 \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/1bb9cc497725096e58a22d6da45048774e2353c0f25678f642a1693356e29fdb.receipt.json b/vision-fixhub/ds9-parsed-01/1bb9cc497725096e58a22d6da45048774e2353c0f25678f642a1693356e29fdb.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..7341e49d8b62188b467e4e4c868937dd35f596bd --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1bb9cc497725096e58a22d6da45048774e2353c0f25678f642a1693356e29fdb.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -153, + "dataset": "marble-joined", + "doc_id": "1bb9cc497725096e58a22d6da45048774e2353c0f25678f642a1693356e29fdb", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "e0b92a7d00192de7e9a233966db589fec3dca54a0654011de62f9755f050641a", + "output_sha256": "deb6caf2a7351a9fa46064d3d095a81148606a36feb48b8d1360d53e7a4b308b", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1bc1c63b8adc7ac7b882ac8b05bb3611440f2e4ba639f5ca824568f35dd94a94.md b/vision-fixhub/ds9-parsed-01/1bc1c63b8adc7ac7b882ac8b05bb3611440f2e4ba639f5ca824568f35dd94a94.md new file mode 100644 index 0000000000000000000000000000000000000000..50b0c516ee1a4beb1491ac781bb97be38eb6489f --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1bc1c63b8adc7ac7b882ac8b05bb3611440f2e4ba639f5ca824568f35dd94a94.md @@ -0,0 +1,911 @@ +Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 1 of 33 +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF FLORIDA +CASE NO. 08-80736-CIV-MARRA +JANE DOE 1 AND JANE DOE 2, +Petitioners, +VS. +UNITED STATES, +Respondent. +OPINION AND ORDER +This cause is before the Court upon Jane Doe 1 and Jane Doe 2's Motion for Partial +Summary Judgment (DE 361); the United States's Cross-Motion for Summary Judgment (DE +408); Jane Doe 1 and Jane Doe 2's Motion to Compel Answers (DE 348) and Jane Doe 1 and +Jane Doe 2's Motion for Finding Waiver of Work Product and Similar Protections by +Government and for Production of Documents (DE 414). The Motions are fully briefed and ripe +for review. The Court has carefully considered the Motions and is otherwise fully advised in the +premises. +I. Background +The facts, as culled from affidavits, exhibits, depositions, answers to interrogatories and +reasonably inferred, for the purpose of these motions, are as follows: +From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor +girls, including Petitioners Jane Doe 1 and Jane Doe 2 (hereinafter, "Petitioners"), at his mansion +in Palm Beach, Florida, and elsewhere in the United States and overseas. (Government Resp. to +Petitioner's Statement of Undisputed Material Facts (hereinafter, "DE 407" at 9 1.) Because + + +Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 2 of 33 +Epstein and his co-conspirators knowingly traveled in interstate and international commerce to +sexually abuse Jane Doe 1, Jane Doe 2 and others, they committed violations of not only Florida +law, but also federal law. (DE 407 at 9| 2.) In addition to his own sexual abuse of the victims, +Epstein directed other persons to abuse the girls sexually. (DE 407 at 9| 3.) Epstein used paid +employees to find and bring minor girls to him. Epstein worked in concert with others to obtain +minors not only for his own sexual gratification, but also for the sexual gratification of others. +(DE 407 at 1 8.) +In 2005, the Town of Palm Beach Police Department ("PBPD") received a complaint +from the parents of a 14 year old girl about her sexual abuse by Jeffery Epstein. The PBPD +ultimately identified approximately 20 girls between the ages of 14 and 17 who were sexually +abused by Epstein. (DE 407 at 1 4.) In 2006, at the request of the PBPD, the Federal Bureau of +Investigation ("FBI") opened an investigation into allegations that Epstein and his personal +assistants used the facilities of interstate commerce to induce girls between the ages of 14 and 17 +to engage in illegal sexual activities. (DE 407 at 9| 5.) The FBI ultimately determined that both +Jane Doe 1 and Jane Doe 2 were victims of sexual abuse by Epstein while they were minors. Jane +Doe 1 provided information about her abuse and Jane Doe 2's abuse to the FBI on August 7, +2007. (DE 407 at 9 6.) +From January of 2007 through September of 2007, discussions took place between the +U.S. Attorney's Office for the Southern District of Florida ("the Office") and Jeffrey Epstein's +attorneys. (DE 407 at 9| 9.) On February 1, 2007, Epstein's defense team sent a 24-page letter to +the Office going over what they intended to present during a meeting at the Office the same day. +(DE 407 at 1 10.) +2 + + +Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 3 of 33 +By March 15, 2007, the Office was sending letters to victims informing them of their +rights pursuant to the Crime Victims' Rights Act ("CVRA"). (DE 407 at 9| 11.) By May of 2007, +the Office had drafted an 82-page prosecution memorandum and a 53-page indictment outlining +numerous federal sexual offenses committed by Epstein. (DE 407 at "| 12.) On or about June 7, +2007, FBI agents had delivered to Jane Doe 1 a standard CVRA victim notification letter.' The +notification letter promised that the Justice Department would make its "best efforts" to protect +Jane Doe I's rights, including "the reasonable right to confer with the attorney for the United +States in the case" and " to be reasonably heard at any public proceeding in the district court +involving [a] ... plea." The notification further stated that, "[a]t this time, your case is under +investigation." (DE 407 at 9| 13.) Jane Doe 1 relied on those representations and believed that the +Government would protect those rights and keep her informed about the progress of her case. +(DE 407 at 1 14.) +On July 6, 2007, Epstein's lawyers sent a 23-page letter lodging numerous arguments to +persuade the Office that no federal crimes had been committed by him. (DE 407 at 9 15) By +August 3, 2007, the Government had rejected Epstein's various arguments against federal +' On or about August 11, 2006, Jane Doe 2 received the same CVRA letter. (DE 407 at 9| +7.) +Initially, Jane Doe 2 was unwilling to provide any information to the FBI or the Office +unless she was assured her statements would not be used against her. She also described Epstein +as "an awesome man" and stated that she hoped "nothing happens to" him. (DE 415 at 11 14- +15.) This was during the time period where Jane Doe 2 had obtained counsel paid for by Epstein. +(Jane Doe 2 Decl. 11 5-7.) +Assistant United States Attorney ("AUSA") | +("line prosecutor" +1) testified that both Jane Doe 1 and Jane Doe 2 received letters describing their rights +under the CVRA. Although Jane Doe 1 and 2 were given Ms. +and the FBI agent's +name and phone number, neither contacted either of them. ( +¡ Decl. 15, DE 403-19.) +3 + + +Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 4 of 33 +charges and sent a letter to Epstein's counsel stating, "[wle would reiterate that the agreement to +Section 2255 [a civil restitution provision] hability applies to all of the minor girls identified +during the federal investigation, not just the 12 that form the basis of an initial planned charging +instrument." (DE 407 at 9| 17.) On September 10, 2007, multiple drafts of a non-prosecution +agreement ("NPA") had been exchanged between Epstein's counsel and the Office. (DE 407 at 1 +18.) +On September 12, 2007, while attempting to create alternative charges against Epstein, +the Office expressed concern about "the effect of taking the position that Mr. Epstein's house is +in the special maritime and territorial jurisdiction of the United States" because the Government +had "no evidence of any assaults occurring either on Mr. Epstein's plane or offshore from his +residence." (DE 407 at 9| 19.) On September 13, 2007, the line prosecutor emailed Epstein's +counsel indicating an effort to come up with a solution to the aforementioned concern and she +stated that she had been "spending some quality time with Title 18 looking for misdemeanors." +The line prosecutor further indicated, "I know that someone mentioned there being activity on an +airplane. I just want to make sure that there is a factual basis for the plea that the agents can +confirm." Epstein's counsel responded, "[a]lready thinking about the same statutes." (DE 407 at +91 20.) +On September 14, 2007, after having spoken on the telephone about the subject matter +of the September 13 emails, Epstein's counsel and the line prosecutor exchanged emails +including a proposed plea agreement for Epstein to plead guilty to assaulting one of his +coconspirators. (DE 407 at 921.) On September 15, 2007, the line prosecutor sent an email to +the Epstein defense team raising concerns about a resolution that would not involve one of +4 + + +Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 5 of 33 +Epstein's minor victims and stating: +I have gotten some negative reaction to the assault charge with [a +co-conspirator] as the victim, since she is considered one of the main +perpetrators of the oftenses that we planned to charge in the +indictment. Can you talk to Mr. Epstein about a young woman named +[Jane Doe]? We have hearsay evidence that she traveled on Mr. +Epstein's airplane when she was under 18, in around the 2000 or +2001 time frame. +(DE 407 at 1 22.) +On September 16, 2007, the line prosecutor corresponded with Epstein's counsel +about having Epstein plead guilty to obstruction of justice for pressuring one of his co-conspirators +not to turn over evidence or complying with a previously-served grand jury subpoena. (DE 407 at +123.) The Office also stated, "On an 'avoid the press' note, I believe that Mr. Epstein's airplane was +in Miami on the day of the [co-conspirator] telephone call. If he was in Miami-Dade County at the +time, then I can file the charge in the District Court in Miami, which will hopefully cut the press +coverage significantly." They also discussed having Epstein plead guilty to a second charge of +assaulting a different co-conspirator. (DE 407 at | 24.) +On September 16, 2007, the line prosecutor wrote to Epstein's counsel indicating that +the Office did not like the factual basis for the proposed charges as the Office was "not +investigating Mr. Epstein [for] abusing his girlfriend." (DE 407 at 9 25.) The correspondence +further stated: +Andy [i.e., AUSA +1] recommended that some of the timing issues be +addressed only in the state agreement, so that it isn't obvious to the judge that we are +trying to create federal jurisdiction for prison purposes. +I will include our standard language regarding resolving all criminal liability and I +will mention 'co-conspirators,' but I would prefer not to highlight for the judge all +of the other crimes and all of the other persons that we could charge. Also, we do not +5 + + +Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 6 of 33 +have the power to bind Immigration ... there is no plan to try to proceed on any +immigration charges against either Ms. [co-conspirator] or Ms. [coconspirator] +(Ex. 7, DE 361-7.) +In the same email, the line prosecutor wrote to defense counsel about a meeting +outside the U.S. Attorney's Office: "Maybe we can set a time to meet. If you want to meet off +campus" somewhere, that is fine." (DE 407 at 9| 27.) On about September 16, 2007, Epstein's +counsel provided a proposed NPA to the Government that extended immunity from federal +prosecution not only to Epstein, but also to certain co-conspirators. (DE 407 at | 28.) +On September 17, 2007, the line prosecutor wrote to defense counsel Jay Lefkowitz: +"Please send [a document] to my home e-mail address - [redacted] and give me a call on my cell +[redacted] so I can be ready for some discussions tomorrow." (DE 407 at 1 29.) On September 17, +2007, Lefkowitz responded: "[DJo you have another obstruction proffer I can review that you have +drafted? Also, if we go that route, would you intend to make the deferred prosecution agreement +public?" (DE 407 at 9| 30.) +On September 18, 2007, the Office responded: "A non-prosecution agreement would +not be made public or filed with the Court, but it would remain part of our case file. It probably +would be subject to a FOIA request, but it is not something that we would distribute without +compulsory process." (DE 407 at 9| 31.) On September 20, 2007, the U.S. Attorney's Office wrote: +"On the issue about 18 USC 2255, we seem to be miles apart. Your most recent version not only had +me binding the girls to a trust fund administered by the state court, but also promising that they will +give up their 2255 rights.... In the context of a non-prosecution agreement, the office may be more +willing to be specific about not pursuing charges against others." (DE 407 at 9 32.) +6 + + +Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 7 of 33 +On September 21, 2007, Palm Beach County State Attorney Barry Krischer wrote the line +prosecutor about the proposed agreement and added: "Glad we could get this worked out for reasons +I won't put in writing. After this is resolved I would love to buy you a cup at Starbucks and have a +conversation." (DE 407 at 1 33) On September 21, 2007, the line prosecutor emailed Epstein's +counsel stating, "I think that the attached addresses the concerns about having an unlimited number +of claimed victims, without me trying to bind girls whom I do not represent." (DE 407 at 9| 34.) On +September 23, 2007, the U.S. Attorney's Office sent an email to Lefkowitz stating: "It is factually +accurate that the list we are going to give you are persons we have identified as victims. If we did +not think they were victims, they would have no right to bring suit." (DE 407 at 9 35.) +On September 24, 2007, the line prosecutor sent an e-mail to a prospective representative for +the Epstein victims, entitled "Conflict Check." The email confirmed the girls" status as victims, +stating: "Please keep this confidential because these are minor victims. This is a preliminary list." +Later on September 24, 2007, the line prosecutor sent an email to Lefkowitz stating: "I have +compiled a list of 34 confirmed minors." (DE 407 at | 36.) As correspondence continued on +September 24, 2007, and the NPA was being executed, Lefkowitz sent an email to the line +prosecutor stating: "l +- Please do whatever you can to keep this [i.e., the NPA] from becoming +public." (DE 407 at 9 37.) +On September 24, 2007, Epstein and the Office formally reached an agreement whereby the +United States would defer federal prosecution in favor of prosecution by the State of Florida. +Epstein and the Office accordingly entered into a NPA reflecting such an agreement. (DE 407 at 9 +38.) The NPA provided that "the United States, in consultation with and subject to the good faith +approval of Epstein's counsel, shall select an attorney representative for [the vietims], who shall be +7 + + +Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 8 of 33 +paid for by Epstein." The NPA also provided that if any of the victims elected to bring suit under +18 U.S.C. § 2255, they must agree to waive any other claim for damages. As part of the NPA, +Epstein would not contest the jurisdiction of the United States District Court and waived his right +to contest liability and damages. (NPA, DE 361-62.) +Among other provisions, the NPA expanded immunity to any "potential coconspirator" +of Epstein's: "In consideration of Epstein's agreement to plead guilty and to provide compensation +in the manner described above, if Epstein successfully fulfills all of the terms and conditions of this +agreement, the United States also agrees that it will not institute any criminal charges against any +potential co-conspirators of Epstein, including but not limited to +(DE 407 at 9| 40.) The NPA also provided that: "The parties +anticipate that this agreement will not be made part of any public record. If the United States receives +a Freedom of Information Act request or any compulsory process commanding the disclosure of the +agreement, it will provide notice to Epstein before making that disclosure." (DE 407 at 9| 41.) +From the time the FBI began investigating Epstein until September 24, 2007—when +the NPA was concluded the Office never conferred with the victims about a NPA or told the +victims that such an agreement was under consideration. (1 +Decl. 17, DE 361-64; DE +407 at 9| 43.) Many, if not all, other similarly-situated victims received standard CVRA victim +notification letters substantively identical to those sent to Jane Doe 1 and Jane Doe 2. (DE 407 at +" 44.) The Office did not consult or confer with any of the victims about the NPA before it was +signed. (DE 407 at 1°l 45-46.) +Epstein's counsel was aware that the Office was deliberately keeping the NPA secret from +the victims and, indeed, had sought assurances to that effect. (DE 407 at 9 48.) After the NPA was +8 + + +Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 9 of 33 +signed, Epstein's counsel and the Office began negotiations about whether the victims would be told +about the NPA. (DE 407 at | 49.) It was a deviation from the Government's standard practice to +negotiate with defense counsel about the extent of crime victim notifications. (DE 407 at 9 50.) +On September 24, 2007, the Office sent an email to Lefkowitz: +Thank you, Jay. I have forwarded your message only to [United States Attorney] +Alex [Acosta], Andy, and Roland. I don't anticipate it going any further than that. +When I receive the originals, I will sign and return one copy to you. The other will +be placed in the case file, which will be kept confidential since it also contains +identifying information about the girls. +When we reach an agreement about the attorney representative for the girls, we can +discuss what I can tell him and the girls about the agreement. I know that Andy +promised Chief Reiter an update when a resolution was achieved.... Rolando is +calling, but Rolando knows not to tell Chief Reiter about the money issue, just about +what crimes Mr. Epstein is pleading guilty to and the amount of time that has been +agreed to. Rolando also is telling Chief Reiter not to disclose the outcome to anyone. +(DE 407 at | 52.) +On September 25, 2007, the line prosecutor sent an e-mail to Lefkowitz stating: "And +can we have a conference call to discuss what I may disclose to ... the girls regarding the +agreement." (DE 407 at 9 53) Also on September 25, 2007, the line prosecutor sent an email to +Lefkowitz which stated in part: "They [Ted Babbitt, Stuart Grossman, Chris Searcy, [LJake +Lytal] are all very good personal injury lawyers, but I have concerns about whether there would +be an inherent tension because they may feel that THEY might make more money (and get a lot +more press coverage) if they proceed outside the Terms of the plea agreement. (Sorry - I just +have a bias against plaintiffs" attorneys.) One nice thing about Bert is that he is in Miami where +there has been almost no coverage of this case." (DE 407 at 9| 54.) +On September 26, 2007, the line prosecutor sent an e-mail to Lefkowitz in which she +9 + + +Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 10 of 33 +stated: "Hi Jay - Can you give me a call at 561-[xxx-xxxx] this morning? I am meeting with the +agents and want to give them their marching orders regarding what they can tell the girls." (DE +407 at 9 55) On September 27, 2007, the attorney representative for the victims emailed the +Office and asked whether he could get a copy of the indictment or plea agreement to find out +"exactly what Epstein concedes to in the civil case." (Sept. 27, 2007 email, DE 362-2.) Upon +inquiry from the Office, Lefkowitz responded by stating that the attorney representative +"certainly [] should not get a copy of any indictment." (DE 407 at 9 57.) That same day, the line +prosecutor informed Epstein's counsel of concerns raised by the attorney representative for the +girls. Specifically, "It ]he concern is, if all 40 girls decide they want to sue, they don't want to be +in a situation where Mr. Epstein says this is getting too expensive, we won't pay anymore +attorneys' fees." (DE 407 at 9| 58.) +Also on that same day, the line prosecutor sent an email to state prosecutors Lanna +Belohlavek and Barry Krischer: "Can you let me know when Mr. Epstein is going to enter his +guilty plea and what judge that will be in front of? I know the agents and I would really like to +be there, "incognito."" (DE 407 at 1 59.) +On October 3, 2007, the Office sent a proposed letter that would have gone to a special +master for selecting an attorney representative for the victims under the NPA's compensation +procedure. The letter described the facts of the Epstein case as follows: "Mr. Epstein, through his +assistants, would recruit underage females to travel to his home in Palm Beach to engage in lewd +conduct in exchange for money. Based upon the investigation, the United States has identified 40 +young women who can be characterized as victims pursuant to 18 U.S.C. § 2255. Some of those +women went to Mr. Epstein's home only once, some went there as many as 100 times or more. Some +10 + + +Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 11 of 33 +of the women's conduct was limited to performing a topless or nude massage while Mr. Epstein +masturbated himself. For other women, the conduet escalated to full sexual intercourse." (DE 407 +at 9| 60.) +On October 10, 2007, Lefkowitz sent a letter to U.S. Attorney Alex Acosta stating, in +pertinent part: "Neither federal agents nor anyone from your Office should contact the identified +individuals to inform them of the resolution of the case, including appointment of the attorney +representative and the settlement process. Not only would that violate the confidentiality of the +agreement, but Mr. Epstein also will have no control over what is communicated to the identified +individuals at this most critical stage. We believe it is essential that we participate in crafting +mutually acceptable communication to the identified individuals." The letter further proposed +that the attorney representative for the victims be instructed that "[t]he details regarding the +United States's investigation of this matter and its resolution with Mr. Epstein is confidential. +You may not make public statements regarding this matter." (DE 407 at 9 61.) +U.S. Attorney Acosta then met with Lefkowitz for breakfast and Lefkowitz followed up with +a letter stating, "I also want to thank you for the commitment you made to me during our October +12 meeting in which you ... assured me that your Office would not... contact any of the identified +individuals, potential witnesses, or potential civil claimants and their respective counsel in this +matter." (DE 407 at | 63.) +On October 24, 2007, AUSA Jeff Sloman sent a letter to Jay Lefkowitz, proposing an +addendum to the NPA clarifying the procedures for the third-party representative for the victims +under the NPA's compensation provisions. (DE 407 at 9| 64.) On October 25, 2007, AUSA Sloman +sent a letter to Retired Judge Davis about selecting an attorney to represent the victims under the + + +Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 12 of 33 +NPA's compensation procedure. (DE 407 at 9| 65.) +On about October 26 or 27, 2007, Special Agents +and +met in person with Jane Doe 1. They explained that Epstein would plead guilty to state charges, he +would be required to register as a sex offender for life, and he had made certain concessions related +to the payment of damages. (DE 407 at | 70.) According to Jane Doe 1, the Agents did not explain +that the NPA had already been signed. (Jane Doe 1 Decl. 1 5, DE 361-26.) Jane Doe I's +understanding was that the federal investigation would continue. (Jane Doe 1 Decl. 9| 6.) In contrast, +Special Agent +stated that the meeting with Jane Doe 1 was to advise her of the main +terms of the NPA.? (Kuykendall Decl. 91 8, DE 403-18.) After the meeting, Special Agent +became concerned about what would happen if Epstein breached the NPA, and thought +that if the victims were aware of the NPA, the provision about monetary damages could be grounds +for impeachment of the victims and herself. (Kuykendall Decl. 1|9.) According to Special Agent +the investigation of Epstein continued through 2008. (Kuykendall Decl. 9 11.) +In addition to Jane Doe 1, FBI agents only talked to two other victims out of the 34 +identified victims about the "general terms" of the NPA, including the provision providing a +federal civil remedy to the victims. (DE 407 at 9| 76.) After these meetings with three victims, +Epstein's defense team complained. (DE 407 at 9 77.) +On about November 27, 2007, AUSA Sloman sent an e-mail to Lefkowitz, (with a +copy to U.S. Attorney Acosta) stating that the Office had a statutory obligation to notify the victims +about Epstein's plea to state charges that was part of the NPA: +' Special Agent | +I also stated that on August 7, 2007, Jane Doe 1 never asked to +confer with anyone from the government about charging decisions or any resolution of the +matter. +Decl. "| 7.) +12 + + +Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 13 of 33 +The United States has a statutory obligation (Justice for All Act of 2004) to notify the +victims of the anticipated upcoming events and their rights associated with the +agreement entered into by the United States and Mr. Epstein in a timely fashion. +Tomorrow will make one full week since you were formally notified of the selection. +I must insist that the vetting process come to an end. Therefore, unless you provide +me with a good faith objection to Judge Davis's selection [as special master for +selecting legal counsel for victims pursuing claims against Epstein] by COB +tomorrow, November 28, 2007, I will authorize the notification of the victims. +Should you give me the go-head on [victim representative]... selection by COB +tomorrow, I will simultaneously send you a draft of the letter. I intend to notify the +victims by letter after COB Thursday, November 29th. +(DE 407 at | 79.) +On November 28, 2007, the Government sent an email to Lefkowitz attaching a letter +dated November 29, 2007 (the apparent date upon which it was intended to be mailed) and +explained that "I am writing to inform you that the federal investigation of Jeffrey Epstein has +been completed, and Mr. Epstein and the U.S. Attorney's Office have reached an agreement +containing the following terms." The proposed letter then spelled out a number of the provisions +in the NPA, including that because Epstein's plea of guilty to state charges was "part of the +resolution of the federal investigation," the victims were "entitled to be present and to make a +statement under oath at the state sentencing." (DE 407 at 9| 80.) +On November 29, 2007, Lefkowitz sent a letter to U.S. Attorney Acosta objecting to the +proposed victim notification letter, stating that it is inappropriate for any letter to be sent to the +victims before Epstein entered his plea or had been sentenced. Lefkowitz also told the Government +that the victims should not be invited to the state sentencing, that they should not be encouraged to +contact law enforcement officials, and that encouraging the attorney representative to do anything +other than get paid by Epstein to settle the cases was to encourage an ethical conflict. (DE 407 at 1 +13 + + +Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 14 of 33 +82.) +On about November 30, 2007, U.S. Attorney Acosta sent a letter to one of Epstein's +defense attorneys, Kenneth Starr, stating: "I am directing our prosecutors not to issue victim +notification letters until this Friday at 5 p.m., to provide you with time to review these options +with your client." The letter also explained that the line prosecutor had informed U.S. Attorney +Acosta "that the victims were not told of the availability of Section 2255 relief during the +investigation phase of this matter" despite the fact that the "[r]ule of law ... now requires this +District to consider the victims' rights under this statute in negotiating this Agreement." (DE 407 at +1 83.) On December 5, 2007, Starr sent a letter to U.S. Attorney Acosta (with copy to AUSA +Sloman) asking about issuance of vietim notification letters and stating: "While we believe that it +is wholly inappropriate for your Office to send this letter under any circumstances, it is certainly +inappropriate to issue this letter without affording us the right to review it." (DE 407 at 9| 85.) +On about December 6, 2007, AUSA Sloman sent a letter to Lefkowitz stating in part: +[E]ach of the listed individuals are persons whom the Office identified as victims. +[T]he Office is prepared to indict Mr. Epstein based upon Mr. Epstein's "interactions" +with these individuals. This conclusion is based upon a thorough and proper +investigation - one in which none of the victims was informed of any right to receive +damages of any amount prior to the investigation of her claim. +[T]he Office can say, without hesitation, that the evidence demonstrates that each +person on the list was a victim of Mr. Epstein's criminal behavior. +Finally, let me address your objections to the draft Victim Notification Letter. You +write that you don't understand the basis for the Office's belief that it is appropriate +to notify the victims. Pursuant to the 'Justice for All Act of 2004, crime victims are +proceeding ….. involving the crime* +public court proceeding....' 18 U.S.C. § 3771(a)(2) & (3). Section 3771 also +commands that 'employees of the Department of Justice... engaged in the detection, +investigation, or prosecution of crime shall make their best efforts to see that crime +14 + + +Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 15 of 33 +victims are notified of, and accorded, the rights described in subsection (a).' 18 +U.S.C. § 3771(c)(1).... +With respect to notification of the other information that we propose to disclose, the +statute requires that we provide a victim with the earliest possible notice of: the status +of the investigation, the filing of charges against a suspected offender, and the +acceptance of a plea. 42 U.S.C. 10607(c)(3). Just as in 18 U.S.C. 3771, these sections +are not limited to proceedings in a federal district court. Our Non-Prosecution +Agreement resolves the federal investigation by allowing Mr. Epstein to plead to a +state offense. The victims identified through the federal investigation should be +appropriately informed, and our Non-Prosecution Agreement does not require the +U.S. Attorney's Office to forego its legal obligations. [T]he Office believes that it has +proof beyond a reasonable doubt that each listed individual was a victim of Mr. +Epstein's criminal conduct while the victim was a minor. The law requires us to treat +all victims "with fairness and with respect for the victim's dignity and privacy." 18 +U.S.C. 3771(a)(8). +The letter included a footnote stating: "Unlike the State's investigation, the federal investigation +shows criminal conduct by Mr. Epstein at least as early as 2001, so all of the victims were +minors at the time of the offense." (DE 407 at 9| 83.) +On December 7, 2007, defense attorney Lilly Ann Sanchez sent a letter to AUSA +I, requesting "that the Office hold off on sending any victim notification letters." No letters +were sent in December of 2007. (DE 407 at 9| 88.) On December 13, 2007, the line prosecutor sent +a letter to Lefkowitz stating that "You raised objections to any victim notification, and no +further notifications were done." (DE 407 at 9| 89.) On December 19, 2007, U.S. Attorney Acosta +sent a letter to Lilly Ann Sanchez stating, "I understand that the defense objects to the victims being +given notice of time and place of Mr. Epstein's state court sentencing hearing. We intend to provide +victims with notice of the federal resolution, as required by law. We will defer to the discretion of +the State Attorney regarding whether he wishes to provide victims with notices of the state +proceedings. (DE 407 at 9, 90.) +15 + + +Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 16 of 33 +In January of 2008, any requirement that Epstein carry out his obligations under the NPA was +delayed while he sought higher level review within the Justice Department. (DE 407 at 9 92.) On +January 10, 2008, Jane Doe 1 and Jane Doe 2 were sent victim notification letters from the FBI +advising them that "It]his case is currently under investigation. This can be a lengthy process and +we request your continued patience while we conduct a thorough investigation." (DE 407 at 9 93.) +The January 10, 2008 notification letters did not disclose that the Jane Doe 1 and Jane Doe 2 case +in the Southern District of Florida was the subject of the NPA entered into by Epstein and the Office, +or that there had been any potentially binding resolution. (DE 407 at 9| 94.) Other victims received +the same letters as sent to Jane Doe 1 and Jane Doe 2. (DE 407 at 1 95.) +According to the declaration of Jane Doe 1, she believed that criminal prosecution of Epstein +was important and she wanted to be consulted by prosecutors before any resolution. Based on the +letters received, she believed the Government would contact her before reaching any final +resolution. (Jane Doe 1 Decl. 9|9.) On January 31, 2008, Jane Doe 1 met with FBI Agents and an +AUSA from the U.S. Attorney's Office. She provided additional details of Epstein's sexual abuse +of her. The AUSA did not disclose to Jane Doe 1 at this meeting that they had already negotiated +a NPA with Epstein. (DE 407 at 9| 97) According to the declaration of Jane Doe 2, while she +recognizes she did not initially help the investigation, she later tried to cooperate with the +investigation but was never given an opportunity to cooperate with the investigation. (Jane Doe 2 +3 The Government believed that a negotiated resolution was in the best interest of the +Office and the victims as a whole based on information obtained from the victims and the agents +assigned to the case. (Villataña Decl. " 19.) The Government also believed that Epstein was +trying to set aside the NPA and therefore the Government needed to be prepared for a +prosecution. (Villafaña Decl. 9| 34.) Petitioners object to this evidence, claiming the Government +previously claimed work product and similar protections over internal materials. Given that the +Court is ruling in favor of Petitioners on the present motions, the Court need not address this +16 + + +Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 17 of 33 +Decl. 19 13-14, DE 361-27.) +On March 19, 2008, the line prosecutor sent a lengthy email to a prospective pro bono +attorney for one of Epstein's vietims who had been subpoenaed to appear at a deposition. The email +listed the attorneys representing Epstein, the targets of the investigation, and recounted in detail the +investigation that had been conducted to that point. The email did not reveal the fact that Epstein had +signed the NPA in September 2007. (DE 407 at 1 98.) +On May 30, 2008, Jane Doe 5, who was recognized as an Epstein victim by the Office, +received a letter from the FBI advising her that "It]his case is currently under investigation. This can +be a lengthy process and we request your continued patience while we conduct a thorough +investigation." (DE 407 at 9| 99.) The May 30, 2008 vietim letter to Jane Doe 5 also acknowledged +the victims' rights under the CVRA. (DE 407 at 9| 100.) +In mid-June of 2008, Mr. Bradley Edwards, the attorney for Petitioners, contacted the line +prosecutor to inform her that he represented Jane Doe 1 and, later, Jane Doe 2. Edwards asked to +meet to provide information about the federal crimes committed by Epstein against these victims. +The line prosecutor and Edwards discussed the possibility of federal charges being filed in the future. +Edwards was led to believe federal charges could still be filed, with no mention whatsoever of the +existence of the NPA or any other possible resolution to the case. (DE 407 at 9| 101.) +At the end of the call, the line prosecutor asked Edwards to send any information +that he wanted considered by the Office in determining whether to file federal charges. The line +prosecutor did not inform Edwards about the NPA. (DE 407 at 9| 102.) On June 19, 2008, Edwards +issue. To the extent it might have an impact on future rulings, Petitioners may reassert this +argument if and when appropriate. +17 + + +Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 18 of 33 +sent an email to the line prosecutor requesting to meet and discuss plans. (DE 407 at " 103.) +On June 23, 2008, the line prosecutor sent an email to Lefkowitz stating that the +Deputy Attorney General had completed his review of the Epstein matter and "determined that +federal prosecution of Mr. Epstein's case [wals appropriate. Accordingly, Mr. Epstein ha[d] until +the close of business on Monday, June 30, 2008, to comply with the terms and conditions of the +agreement between the United States and Mr. Epstein." (DE 407 at 9 105.) +On or about June 27, 2008, the Office called Edwards to provide notice to his clients +regarding the entry of Epstein's guilty plea in state court. (DE 407 at 9| 107) According to Edwards, +the line prosecutor only told him that Epstein was pleading guilty to state solicitation of prosecution. +He was not told that the state plea was related to the federal investigation or that the state plea would +resolve the federal crimes. Edwards claims he was not told his clients could address the state court. +(Edwards Decl. 91917-18, DE 416-1.) In contrast, the line prosecutor claims she told Edwards that +his clients could address the state court. (Villafaña Decl. 1 38, DE 403-19.) +On or before June 30, 2008, the Office prepared a draft victim notification to be sent +to the victims. The notification was designed to inform the victims of the provisions of the deferral +of federal prosecution in favor of state charges. The notification letter began by describing Epstein's +guilty plea in the past tense: "On June 30, 2008, Jeffrey Epstein ... entered a plea of guilty to +violations of Florida statutes forbidding the solicitation of minors to engage in prostitution and +felony solicitation of prostitution." Later, a substantively identical letter was prepared for Epstein's +and his counsel's review. (DE 407 at | 110.) +On June 30, 2008, the Office sent an e-mail to Epstein's counsel: "The FBI has received +several calls regarding the Non-Prosecution Agreement. I do not know whether the title of the +18 + + +Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 19 of 33 +document was disclosed when the Agreement was filed under seal, but the FBI and our office are +declining comment if asked." (DE 407 at 9| 111.) That same day, Epstein pled guilty to state law +solicitation of prostitution charges. (DE 407 at 9 112.) Immediately following the June 30, 2008 +hearing, the line prosecutor told one of the victims' attorneys that Epstein had "pled guilty today in +state court." (DE 407 at 9| 113.) Also after the plea, the line prosecutor emailed the assistant state +attorney a copy of the NPA to be filed under seal. (July 1, 2008 email, DE 362-38.) +On June 30, 2008, based on what she had been told by the Government, Jane Doe 1 +thought that the Office was still investigating and pursuing her case. She did not receive notice +that Epstein's state guilty plea affected her rights in any way. If she had been told that the state +plea had some connection to blocking the prosecution of her case, she would have attended and +tried to object to the judge to prevent that plea from going forward. (Jane Doe 1 Decl. 9 13.) +According to the line prosecutor, Edwards did not tell her that Jane Doe 1 wanted to meet with her +before a resolution was reached. (Villafaña Decl. 1 37, DE 403-19.) +On July 3, 2008, as specifically directed by the Office, Edwards sent a letter to the Office +communicating the wishes of Jane Doe 1, Jane Doe 2, and Jane Doe 5 that federal charges be filed +against Epstein: "We urge the Attorney General and our United States Attorney to consider the +fundamental import of the vigorous enforcement of our Federal laws. We urge you to move forward +with the traditional indictments and criminal prosecution commensurate with the crimes Mr. Epstein +has committed, and we further urge you to take the steps necessary to protect our children from this +very dangerous sexual predator." (DE 407 at 9| 118.) +On July 7, 2008, the line prosecutor corresponded with Epstein's counsel seeking his signed +agreement concerning a notification letter to the victims before beginning the distribution of that +19 + + +Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 20 of 33 +letter. (DE 407 at 1 120.) That same day, Jane Doe 1 filed an emergency petition for enforcement +of her rights under the CVRA. (DE 407 at 9| 126.) On July 9, 2008, Edwards saw the first reference +to the NPA when the Government filed its responsive pleading to Jane Doe's emergency petition. +(Edwards Decl. 1| 21.) +On July 8, 2008, the line prosecutor sent a letter to Epstein's counsel stating that +victims would be informed about the civil compensation provision of the NPA the next day: +In accordance with the terms of the Non-Prosecution Agreement, on June 30, +2008, the United States Attorney's Office provided you with a list of thirty-one +individuals "whom it was prepared to name in an Indictment as victims of an +enumerated offense by Mr. Epstein." +... In deference to your vacation, we +allowed you a week to provide us with any objections or requested modifications +of the list and/or the Notification language. Yesterday, I contacted you via +telephone and e-mail, but received no response. Accordingly, the United States +hereby notifies you that it will distribute the victim notifications tomorrow, July 9, +2008, to each of the thirty-two identified victims, either directly or via their +counsel. +(DE 407 at 1 127.) +On July 9, 2008, Epstein's counsel sent a letter to the line prosecutor raising concerns +about the notifications, and suggesting modifications to the notification letter. Epstein's counsel +also objected to the victim notification letters containing certain information about the NPA. (DE +407 at 9| 128.) The line prosecutor responded: "Without such an express Acknowledgment by +Mr. Epstein that the notice contains the substance of that Agreement, I believe that the victims +will have justification to petition for the entire agreement, which is contrary to the confidentiality +clause that the parties have signed." (DE 407 at 9| 129.) That same day, the U.S. Attorney's +Office sent victim notification letters to Jane Doe 1 and Jane Doe 5, via their attorney, Edwards, +and to other identified victims of Epstein. That notification contained a written explanation of +20 + + +Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 21 of 33 +some of the civil compensation provisions of the NPA. The notification did not provide the full +terms of the NPA. +On July 10, 2008, Epstein's counsel continued to protest victim notification as +evidenced by an email to the line prosecutor stating, "we respectfully request a reasonable +opportunity to review and comment on a draft of the modified notification letter you intend to +mail before you send it." (DE 407 at 1 131.) +On August 10, 2008, Jane Doe 1 and Jane Doe 2 filed a motion seeking release of the +NPA. (DE 407 at 1 136.) On August 14, 2008, the line prosecutor emailed Epstein's counsel +stating that the court has "ordered us to make the Agreement available to the plaintiffs." (DE 407 +at 9| 141.) +On August 18, 2008, Lefkowitz wrote the line prosecutor that Epstein objected to +disclosure of the terms of the NPA, but that Epstein would "cooperate with the government to +reach an agreement as to substance of the notification to be sent to the government's list of +individuals. Based on the Agreement, the information contained in the notification should be +limited to (1) the language provided in the Agreement dealing with civil restitution (paragraphs +7-10) and (2) the contact information of the selected attorney representative. We object to the +inclusion of additional information about the investigation of Mr. Epstein, the terms of the +Agreement other than paragraphs 7-10 and the identity of other identified individuals." (DE 407 +at 9| 143.) On August 21, 2008, the Government sent a letter to Epstein's counsel stating that, +"[clopies of the victim notifications will continue to be provided to counsel for Mr. Epstein." +Jane Doe 2 was not informed of the contents of the NPA until August 28, 2008, when the +line prosecutor provided a copy to Edwards. (DE 407 at 9| 146.) On September 2, 2008, the line +21 + + +Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 22 of 33 +prosecutor sent an email to Epstein's counsel stating, "I will start sending out the victim +notifications today. In accordance with your request, I have changed the language regarding the +victims' right to receive a copy of the Agreement." (DE 407 at 9| 147) On September 2 and 3, +2008, the Office sent to Jane Doe 1 and other identified victims amended notification letters, +stating "the United States has agreed to defer federal prosecution in favor of this state plea and +sentence." (Sept. 3, 2008 letter, DE 363-66; (DE 407 at 9 148.) +On September 16, 2008, attorney Jeffrey Herman, who represented several Epstein +victims, wrote to the line prosecutor to object to the restitution procedures established in the +NPA after learning that another attorney, established through the NPA, would be making +unsolicited contacts to the victims. Mr. Herman explained that the notification letters were +"misleading" because they referred generally to a waiver of "any other claim for damages," +without informing them that this waiver might include a valuable punitive damages claim against +an alleged billionaire. (DE 407 at 9| 152) On September 17, 2008, the line prosecutor sent an +email to State Attorney Barry Krischer, explaining that the NPA "contain[ed] a confidentiality +provision that require[ed] us to inform Mr. Epstein's counsel before making any disclosure." +(DE 407 at | 153.) +Around this same time period, Jane Doe 1 and Jane Doe 2 filed actions in Palm Beach +County, seeking money damages from Epstein from sexually abusing them. (Petitioners' Resp. to +Gov't's Statement of Undisputed Material Facts (hereinafter "DE 415") at 9 91 8-9.) Eventually, +they received monetary settlements of their lawsuits. (DE 415 at 1 12.) +In moving for summary judgment, the Petitioners make the following arguments in +support of their contention that the Government violated their CVRA rights. The Government +22 + + +Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 23 of 33 +violated Petitioners' right to confer under the CVRA: (1) when the Government was negotiating +and signing the NPA; (2) when the Government sent letters telling Petitioners to be patient while +the Government completed its investigation and (3) when the Government did not tell the victims +that the state plea would extinguish the federal case. Petitioners also claim the Government +violated their right to be treated with fairness under the CVRA by concealing the negotiations of +the NPA. Additionally, Petitioners contend the Government violated their rights to reasonable +and accurate notice when it concealed that the NPA and the federal investigation were implicated +in the state court proceeding. +In moving for and responding to summary judgment, the Government contends that there +is no right to notice or conferral about a NPA; it was reasonable for the Government to send +letters to victims while continuing to investigate the case because the Government could not +assume that Epstein would plead guilty; and the line prosecutor contacted Petitioners' attorneys +about the state court plea hearing. The Government also claims it did not violate the right to +reasonable, accurate and timely notice because the CVRA does not create any right to notice of +state court proceedings and, in any event, the Government gave notice. The Government asserts +it did not treat the victims unfairly and used its best efforts to comply with the CVRA, including +complying with the Attorney General's guidelines for victim assistance. Furthermore, the +Government argues that Petitioners are equitably estopped from challenging the NPA because +they relied upon the NPA in their state court civil actions against Epstein. Lastly, the +Government contends that Petitioners are judicially estopped from challenging the validity of the +NPA because they have asserted mutually inconsistent positions; namely, that the NPA is invalid +in federal court but was binding on Epstein in state court. +23 + + +Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 24 of 33 +I. Summary Judgment Standard +The Court may grant summary judgment "if the movant shows that there is no genuine +dispute as to any material fact and the movant is entitled to judgment as a matter of law." Fed. +R. Civ. P. 56(a). The stringent burden of establishing the absence of a genuine issue of material +fact lies with the moving party. Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986). The Court +should not grant summary judgment unless it is clear that a trial is unnecessary, Anderson v. +Liberty Lobby, Inc., 477 U.S. 242, 255 (1986), and any doubts in this regard should be resolved +against the moving party. Adickes v. S.H. Kress & Co., 398 U.S. 144, 157 (1970). +The movant "bears the initial responsibility of informing the district court of the basis for +its motion, and identifying those portions of [the record] which it believes demonstrate the +absence of a genuine issue of material fact." Celotex Corp., 477 U.S. at 323. To discharge this +burden, the movant must point out to the Court that there is an absence of evidence to support the +nonmoving party's case. Id. at 325. +After the movant has met its burden under Rule 56(a), the burden of production shifts and +the nonmoving party "must do more than simply show that there is some metaphysical doubt as +to the material facts." Matsushita Electronic Industrial Co. v. Zenith Radio Corp., 475 U.S. 574, +586 (1986). "A party asserting that a fact cannot be or is genuinely disputed must support the +assertion by citing to particular parts of materials in the record ... or showing that the materials +cited do not establish the absence or presence of a genuine dispute, or that an adverse party +cannot produce admissible evidence to support the fact." Fed. R. Civ. P. 56(c)(1)(A) and (B). +Essentially, so long as the non-moving party has had an ample opportunity to conduct +discovery, it must come forward with affirmative evidence to support its claim. Anderson, 477 +24 + + +Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 25 of 33 +U.S. at 257. "A mere 'scintilla' of evidence supporting the opposing party's position will not +suffice; there must be enough of a showing that the jury could reasonably find for that party." +Walker v. Darby, 911 F.2d 1573, 1577 (11th Cir. 1990). If the evidence advanced by the nonmoving party "is merely colorable, or is not significantly probative, then summary judgment may +be granted." Anderson, 477 U.S. 242, 249-50. +III. Discussion +The CVRA was designed to protect victims' rights and ensure their involvement in the +criminal justice process. +United States v. Moussaoui, 483 F.3d 220, 234 (4th Cir. 2007); Kenna +v. U.S. Dist. Court, 435 F.3d 1011, 1016 (9th Cir. 2006) ("The [CVRA] was enacted to make +crime victims full participants in the criminal justice system."). The statute enumerates the +following ten rights: +(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 clearand 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 +25 + + +Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 26 of 33 +privacy. +(9) The right to be informed in a timely manner of any plea bargain or deferred +prosecution agreement. +(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 (42 +U.S.C. 10607(c)) and provided contact information for the Office of the Victims' +Rights Ombudsman of the Department of Justice. +18 U.S.C. § 3771(a). +This Court previously held the following with respect to the CVRA: First, the rights +under the CVRA attach before the Government brings formal charges against a defendant. Does +v. United States, 817 F. Supp. 2d 1337, 1341 (S.D. Fla. 2011). Second, the CVRA authorizes the +rescission or "reopening" of a prosecutorial agreement, including a non-prosecution agreement, +reached in violation of a prosecutor's conferral obligations under the statute. Doe v. United +States, 950 F. Supp. 2d 1262, 1267 (S.D. Fla. 2013). Third, section 3771(d)(5) of the CVRA +authorizes the setting aside of pre-charge prosecutorial agreements, despite the fact that the +particular statutory enforcement provision expressly refers to the reopening of a plea or sentence. +Id. at 1267. Fourth, the "reasonable right to confer ... in the case" extends to the pre-charge +state of criminal investigations and proceedings. Id. Fifth, the federal sex offense crimes +involving minors allegedly committed by Epstein renders these Petitioners crime victims under +the CVRA. Id. at 1269. Sixth, "questions pertaining to [the] equitable defense[s] are properly +left for resolution after development of a full evidentiary record." Id. at 1269 n. 6. +Here, it is undisputed that the Government entered into a NPA with Epstein without +conferring with Petitioners during its negotiation and signing. Instead, the Government sent +letters to the victims requesting their "patience" with the investigation even after the Government +26 + + +Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 27 of 33 +entered into the NPA. At a bare minimum, the CVRA required the Government to inform +Petitioners that it intended to enter into an agreement not to prosecute Epstein. Although the +binding effect of the NPA was contingent upon Epstein pleading guilty to the state charges, that +contingency was out of the control of the Government. The Government's hands were +permanently tied if Epstein fulfilled his obligations under the NPA. Thus, Petitioners and the +other victims should have been notified of the Government's intention to take that course of +action before it bound itself under the NPA. Had the Petitioners been informed about the +Government's intention to forego federal prosecution of Epstein in deference to him pleading +guilty to state charges, Petitioners could have conferred with the attorney for the Government and +provided input. In re Dean, 527 F.3d 391, 394 (5" Cir. 2008) (there are rights under the CVRA +including the "reasonable right to confer with the attorney for the Government"). Hence, the +Government would have been able to "ascertain the victims' views on the possible details of the +[non-prosecution agreement]." Id. Indeed, it is this type of communication between prosecutors +and victims that was intended by the passage of the CVRA. See United States v. Heaton, 458 F. +Supp. 2d 1271 (D. Utah 2006)(government motion to dismiss charge of using facility of +interstate commerce to entice minors to engage in unlawful sexual activity would not be granted +until government consulted with victim; United States v. Ingrassia, No. CR-04-0455ADSJO, +2005 WL 2875220, at *17 n. 11 (E.D.N.Y. Sept. 7, 2005) (Senate debate supports the view that +the contemplated mechanism for victims to obtain information on which to base their input was +conferral with the prosecutor concerning any critical stage or disposition of the case). +Particularly problematic was the Government's decision to conceal the existence of the +27 + + +Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 28 of 33 +NPA and mislead the victims to believe that federal prosecution was still a possibility.' When +the Government gives information to vietims, it cannot be misleading. While the Government +spent untold hours negotiating the terms and implications of the NPA with Epstein's attorneys, +scant information was shared with vietims. Instead, the victims were told to be "patient" while +the investigation proceeded. +The Government, however, interprets the CVRA as only obligating the prosecutor to +answer inquiries by a crime victim and does not impose a duty on the prosecutor to give notice +about case developments, other than what is required in section 3771(a)(2). Such an +interpretation is in direct contravention of the intent of the CVRA. See Ingrassia, 2005 WL +2875220, at *17 n. 11 (Senate debate explaining the right to confer is "intended to be expansive" +including the right of victim to confer "concerning any critical state of disposition of the case"). +In any event, no meaningful conferral could take place as long as the Government chose to +conceal the existence of the NPA from the victims.S +Nor does the Court agree with the Government that the 2015 amendment to the CVRA, +section 3771(a)(9), which gave victims the "right to be informed in a timely manner of any plea +* Even if the Court accepted the Government's version of the facts relative to the Agent +having told Jane Doe 1 the "main terms" of the NPA (which is left undefined), the victims were +not told about it until after it was signed and the Government was bound. This precluded the +Government from obtaining any input from the victims. +' The Government devotes time to distinguishing between the words "confer" and +"notice" and suggesting that "confer" is more limited in scope than "notice." Nothing about the +definition of confer, however, suggests it is limited to one party bearing the burden of +communication. See Merriam-Webster Online Dictionary, https://www.merram-webster.com/ +dictionary (last visited January 7, 2019) ("to compare views or take counsel"); Blacks Law +Dictionary (10" ed. 2014) ("to hold a conference, to consult with one another"). +28 + + +Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 29 of 33 +bargain or deferred prosecution agreement" specifically excluded the right of victims to be +informed of a non-prosecution agreement. Prior to this amendment, this Court held that the right +to confer extended to the pre-charge state of criminal investigations and proceedings. Doe, 950 +F. Supp. 2d at 1267; see also 157 Cong. Rec. S7060-01, 157 Cong. Rec. S7060-01, S7060 +(CVRA co-sponsor Senator Jon Kyl's 2011 letter to the Attorney General, explaining that +"Congress intended the CVRA to broadly protect crime victims throughout the criminal justice +process-from the investigative phases to the final conclusion of a case.") +The 2015 amendment did not serve to repeal or restrict the obligations of the Government +to confer with victims in the early stages of a case. Instead, the 2015 amendment clarified that +certain events, such as plea agreements or deferred prosecution agreements, must be conveyed to +the crime victim. Put another way, the 2015 amendment codified what the courts had been +interpreting the CVRA to require, such as entitlement to notice of a plea bargain. See In re Dean, +527 F.3d at 394 ("the government should have fashioned a reasonable way to inform the victims +of the likelihood of criminal charges and to ascertain the victims' views on the possible details of +a plea bargain"); United States v. Okun, No. CRIM. 3:08CR132, 2009 WL 790042, at *2 (E.D. +Va. Mar. 24, 2009) (the statutory language of the CVRA gives the vietims' rights before the +accepting of plea agreements). +To the extent the Government relies upon the "interpretive canon, expressio unius est +exclusio alterius, 'expressing one item of [an] associated group or series excludes another left +unmentioned'" the Court is not persuaded. Chevron U.S.A. Inc. v. Echazabal, 536 U.S. 73, 80 +(2002) (quoting United States v. Vonn, 535 U.S. 55, 65 (2002)). "The force of any negative +implication ... depends on context." Marx v. General Revenue Corp., 568 U.S. 371, 381 (2013). +29 + + +Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 30 of 33 +"IT]he expressio unius canon does not apply unless it is fair to suppose that Congress considered +the unnamed possibility and meant to say no to it, and that the canon can be overcome by +contrary indications that adopting a particular rule or statute was probably not meant to signal +any exclusion." Id. (internal citations and quotation marks omitted). +The expansive context of the CVRA lends itself to only one interpretation; namely, that +victims should be notified of significant events resulting in resolution of their case without a +trial. See Kenna v. U.S. Dist. Court for C.D.Cal., 435 F.3d 1011, 1016 (9th Cir. 2006) ("[t]he +statute was enacted to make crime victims full participants in the criminal justice system"); +Heaton, 458 F. Supp. 2d at 1273 (the right to confer is "not limited to particular proceedings" but +is "expansive" and applies broadly to "any critical stage or disposition of the case"). Reading +into the statute a negative implication that victims need not be informed of non-prosecution +agreements, and only informed of the more common events of plea bargains or deferred +prosecution agreements, would be inconsistent with the goal of the CVRA." In the context of +plea agreements, the CVRA provides victims with rights prior to the acceptance of plea +agreements. See In re Dean, 527 F.3d at 394; United States v. Okun, No. CRIM. 3:08CR132, +2009 WL 790042, at *2 (E.D. Va. Mar. 24, 2009). Furthermore, victims obtain rights under the +CVRA even before prosecution. Okum, 2009 WL 790042, at *2 (citing In re Dean, 527 F.3d at +394). Based on this authority, the Court concludes that the CVRA must extend to conferral about +non-prosecution agreements. +"A NPA entered into without notice has a more damaging impact on the victims than a +plea agreement entered into without notice. When a plea agreement is entered into without +notice, the victims will at least have an opportunity to provide input to a judge at sentencing +Once a NPA is entered into without notice, the matter is closed and the victims have no +30 + + +Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 31 of 33 +Next, the Government claims it did not violate the right to confer when, in January of +2008, it sent letters to the victims counseling patience because, at that time, Epstein's attorneys +were seeking review of the NPA at higher levels within the Department of Justice. As indicated +previously, however, at this point, the Government had bound itself to the terms of the NPA +unless Epstein failed to comply with its terms. It was a material omission for the Government to +suggest to the victims that they have patience relative to an investigation about which it had +already bound itself not to prosecute. While Epstein was within his rights to attempt to persuade +higher authorities within the Department of Justice to overrule the prosecutorial decisions of the +U. S. Attorney's Office in the Southern District of Florida, the CVRA was designed to give the +victims the same opportunity to attempt to affect prosecutorial decisions before they became +final. Instead, the Office engaged in lengthy negotiations with Epstein that included repeated +assurances that the NPA would not be "made public or filed with the Court." (DE 407 at 9 31.) +Nor did the Justice Department guidelines create an exemption from the CRVA's +statutory requirements. Although the Government points to guidelines that conflicted with the +requirements of the CVRA (by restricting CVRA rights until after a formal indictment), the +Court is not persuaded that the guidelines were the basis for the Government's decision to +withhold information about the NPA from the victims. If that had been the case, the Government +would not have sent the victim letters telling them that they had rights protected under the +CVRA. Nor would they have told Epstein's attorneys that it had obligations to notify the victims. +In any event, an agency's own ""interpretation' of a statute cannot supersede the language chosen +by Congress." Mohasco Corp. v. Silver, 447 U.S. 807, 825 (1980). +Next, the Court rejects the Government's contention that Jane Doe 2 is not protected by +31 + + +Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 32 of 33 +the CVRA because she made statements favorable to Epstein early in the investigation.? There is +no dispute that Epstein sexually abused Jane Doe 2 while she was a minor. Therefore, regardless +of her comments to the prosecutor, she was a victim. See 18 U.S.C. § 3771(e) (the CVRA +defines a victim as "a person directly and proximately harmed as a result of the commission of a +Federal offense"); In re Stewart, 552 F.3d 1285, 1288 (11'" Cir. 2008) ("to determine a crime +victim, then, first, we identify the behavior constituting 'commission of a Federal offense.' +Second, we identify the direct and proximate effects of that behavior on parties other than the +United States. If the criminal behavior causes a party direct and proximate harmful effects, the +party is a victim under the CVRA."). +The Court need not resolve the factual questions surrounding what and when the victims +were told about the state court proceeding and whether a state court proceeding is covered by the +CVRA. Under the facts of this case, once the Government failed to advise the victims about its +intention to enter into the NPA, a violation of the CVRA occurred. +Nor does the Court need to consider the Government's estoppel arguments at this time. +These arguments relate only to the remedy, and not the determination of whether there was a +CVRA violation. Therefore, the Court will address this issue at the appropriate juncture. +Lastly, the Court will address the Government's argument that its prosecutorial discretion +permitted it to enter into the NPA. The Government correctly notes that the CVRA provides that +"EnJothing in this chapter shall be construed to impair the prosecutorial discretion of the Attorney +General or any officer under his direction." 18 U.S.C.A. § 3771(d)(6). The Court is not ruling +' In fact, the Office considered Jane Doe 2 a victim as early as August of 2006 when it +sent her a CVRA letter. +32 + + +Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 33 of 33 +that the decision not to prosecute was improper. The Court is simply ruling that, under the facts +of this case, there was a violation of the victims rights under the CVRA. +IV. Conclusion +Accordingly, it is hereby ORDERED AND ADJUDGED as follows: +1) +2) +3) +Jane Doe 1 and Jane Doe 2's Motion for Partial Summary Judgment (DE 361) is +GRANTED to the extent that Petitioners' right to conferral under the CVRA was +violated. +The United States's Cross-Motion for Summary Judgment (DE 408) is DENIED. +Jane Doe 1 and Jane Doe 2's Motion to Compel Answers (DE 348) is DENIED +WITHOUT PREJUDICE. +Jane Doe 1 and Jane Doe 2's Motion for Finding Waiver of Work Product and +Similar Protections by Government and for Production of Documents (DE 414) is +DENIED WITHOUT PREJUDICE. +The parties should confer and inform the Court within 15 days of the date of +entry of this Order how they wish to proceed on determining the issue of what +remedy, if any, should be applied in view of the violation. +DONE AND ORDERED in Chambers at West Palm Beach, Palm Beach County, +Florida, this 21" day of February, 2019. +2 +KENNETH A. MARRA +United States District Judge diff --git a/vision-fixhub/ds9-parsed-01/1bc1c63b8adc7ac7b882ac8b05bb3611440f2e4ba639f5ca824568f35dd94a94.receipt.json b/vision-fixhub/ds9-parsed-01/1bc1c63b8adc7ac7b882ac8b05bb3611440f2e4ba639f5ca824568f35dd94a94.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..4a5c139b962077114cbc54c2051452bc1b5f144b --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1bc1c63b8adc7ac7b882ac8b05bb3611440f2e4ba639f5ca824568f35dd94a94.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -398, + "dataset": "marble-joined", + "doc_id": "1bc1c63b8adc7ac7b882ac8b05bb3611440f2e4ba639f5ca824568f35dd94a94", + "engine": "marble-apple-vision", + "event_count": 34, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "e70d8ca5c6391e20f3e98a0234333fa0a1e8e70c4797cfbb3d111ea04ddb49f4", + "output_sha256": "46da3c2dc60b825ff27282f9e1c58d387830a6534c283f7a76e41d200caaf2bc", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1bcfe69f367875480ca2ea29b4dbfdcb86a10fd77e94039383f757634ccca374.md b/vision-fixhub/ds9-parsed-01/1bcfe69f367875480ca2ea29b4dbfdcb86a10fd77e94039383f757634ccca374.md new file mode 100644 index 0000000000000000000000000000000000000000..48536462853c76803a7dbbfab19a296ed7d8788b --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1bcfe69f367875480ca2ea29b4dbfdcb86a10fd77e94039383f757634ccca374.md @@ -0,0 +1,24 @@ +From: +To: "Berman, Geoffrey (USANYS)" +Ce:' +Subject: FW: USANet Carousel +Date: Mon, 27 Jan 2020 22:15:32 +0000 +FYI. +From: +Subject: Re: USANet Carousel +Hey, +Thanks! I kept searching today before heading out for a good article on your announcement from earlier. +We'll run a USANet carousel and run the article from @USAttorneys. +Thanks! +Sent from my iPhone +On Jan 27, 2020, at 4:55 PM, +wrote: +H +Not sure if this falls under your purview not (it seems like everything else does), but this made pretty big news +today, might be good for the carousel: https://www.nytimes.com/2020/01/27/nyregion/jeffrey-epstein-princeandrew.html +Thanks! +Public Affairs +United States Department of Justice +U,S, Attornev's Office Southern District of New York +Mobile: +| Press Office: diff --git a/vision-fixhub/ds9-parsed-01/1bcfe69f367875480ca2ea29b4dbfdcb86a10fd77e94039383f757634ccca374.receipt.json b/vision-fixhub/ds9-parsed-01/1bcfe69f367875480ca2ea29b4dbfdcb86a10fd77e94039383f757634ccca374.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..01d109c61f001f0c6719d82d3579bd8f4817f3b7 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1bcfe69f367875480ca2ea29b4dbfdcb86a10fd77e94039383f757634ccca374.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -14, + "dataset": "marble-joined", + "doc_id": "1bcfe69f367875480ca2ea29b4dbfdcb86a10fd77e94039383f757634ccca374", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "718d009c4e452f6fb800d4a954eb842060d5ec6eece0c86873ae179df44ba965", + "output_sha256": "0cfbb180e5a083aa3193ea35a7470a7faad49460af1f748c4ff1dfb62d4812d9", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1be0146ee51bdf289a12f3b7aa6562ecc49b62edf40124d02799ab945c61a83e.md b/vision-fixhub/ds9-parsed-01/1be0146ee51bdf289a12f3b7aa6562ecc49b62edf40124d02799ab945c61a83e.md new file mode 100644 index 0000000000000000000000000000000000000000..cb674206db2629d041c42049d24db5042111338d --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1be0146ee51bdf289a12f3b7aa6562ecc49b62edf40124d02799ab945c61a83e.md @@ -0,0 +1,154 @@ +FD-302 (Rev. 5-8-10) +- 1 of 3- +FEDERAL BUREAU OF INVESTIGATION +OFFICIAL RECORD +Date of entry +09/06/2019 +EMPLOYEE 27 +• at Bureau of Prison's (BOP) +METROPOLITAN CORRECTIONAL CENTER (MCC), 150 Park Row, New York, New +York, +was interviewed at the United States +Attorneys Office (USAO), Southern District of New York (SDNY), I St. Andrews +Plaza, New York, New York. Present for the interview were FBI Special Agent +(SA) +FBI Task Force Officer (TFO) +Office of +the Inspector General (OIG) +SA +• Assistant United States Attorney +(AUSA) +1, AUSA +• and ENFLOYDa 21 +attorney, Natali +Todd. AUSA +advised +ERFLOSEE 27 +that the interview was in lieu of an +appearance before the Federal Grand Jury and is voluntary. AUSA +also +went over a standard proffer agreement. After being advised of the identity +of the interviewing investigators and the nature of the interview, and +provided the following information: +started working for the BOP in February 2011 at Allenwood. i +SHPLOYEE +transferred to MCC in October 2013. +MELOTEE 21 +is a Senior Officer Specialist +(SOS) but also serves as a Lieutenant. This usually happens when +EMPLOREE 2 +is +working overtime and is in the capacity of an acting activities Lieutenant. +stated that in order to do a round, an officer has to physically +go inside the area that is occupied by inmates. As an activities Lieutenant, +SHIPLOTEL 21 +makes a round through the Special Housing Unit (SHU) and asks the +officers in the SHU if things are good. She is usually called numerous times +to the SHU for certain issues like when an inmate complains that he hasn't +received something, i.e. property. +ERPLOTEL 21 +then takes note of the issue and +advises the Captain. +As +an +activities Lieutenant, +sees a sampling of tiers at MCC +during her shift. +uses her PIV Card at a computer terminal to log +rounds. Each unit at MCC has a different log. +Investigation on +08/20/2019 +at New York, New York, United States (In Person) +File # +Date drafted 08/23/2019 +by +This distinent outains noite recommendations nor conclusions of the FBI. I is the property of the FBI and is loaned to your agency; it and is content toe not +to be distributed outside your agency. + + + +FD-302a (Rev. 5-8-10) +Continuation of FD-302 of +(U) Interview of +EMPLOYED 27 +, On +08/20/2019 +_, Page +2 of 3 +ERETOYEE 27 +works as an SOS during her normal shift, which is usually the day +watch, 8am-4pm. If +works overtime, she acts as activities Lieutenant +from 4pm-10pm. +has worked as a Corrections Officer in the SHU, +usually on overtime and on evening watch. During her shifts in the SHU, +has responsibilities pertaining to the inmates such as phone calls, +showers, and the library. The 30 minute rounds are recorded in TruScope and +on paper logs. +SHPLOTEE 2 +stated that she has not worked with anyone who didn't +do the rounds. +SHPLOYEE Z +participates in the 10am count on the weekends but +during the week, a count is not done during her regular shift, 8am-4pm. +During the week, +leaves before the 10pm count is conducted. +During a count, all inmates have to be seen. The inmates are counted by +one officer, then another officer. If there are only two officers working +during a count, one officer will count the inmates, then the officers switch +and the other officer will count the inmates. The officers are to only count +inmates that are physically in their unit. +In the Control Center, an employee gets information from the person that +he or she relieves. While in the control center, one has various +responsibilities such as +a fire security check, equipment and key checks, +and watching the cameras. The person that is designated as Control #2 is +responsible for preparing the paperwork for the count. +On August 9, 2019, +worked in the capacity of Lieutenant from 4pm- +10pm. During this time, +stopped by the SHU. She recalled that regular +activities and operations were occurring at the time of her visit. +EMELOTEE +fed inmates in G Tier and in 10 South, the high security unit. out +recalled seeing JEFFREY EPSTEIN earlier on August 9 around 9am at the +attorney conference area. EPSTEIN was there with 3 or 4 attorneys who were +in and out of the facility. BEE +recalled there being 2 females and 1 +male. At one point, EPSTEIN had to get an officer's attention to use the +restroom. rama +was not in the SHU when EPSTEIN came back from attorney +conference. Usually EPSTEIN would be cuffed to go back to the SHU from +attorney conference around 7:20pm-8pm. +doesn't remember anyone talking about a phone call that EPSTEIN +made on August 9, 2019. She also is not aware of how either of EPSTEIN's +cellmates were selected. on i +only heard things in passing regarding +EPSTEIN's alleged suicide attempt in July. +SDNY_00008102 + + + +FD-302a (Rev. 5-8-10) +Continuation of FD-302 of (U) Interview of EMPLOYEE 27 +, On +08/20/2019 +_, Page +3 of 3 +EMELOTEE 27 +does not know the particular procedures or guidelines regarding an +inmate who comes off suicide watch. She stated that usually that inmate is +put with a cellmate, but she does not know if this is policy or just general +practice. According +to ENFLOZEE 27 +as an SOS, she wouldn't know if EPSTEIN was +supposed a cellmate. A decision such as an inmate needing a cellmate would +be made at SHU meetings and/or department head meetings. FErVE +doesn't know +if EPSTEIN had a cellmate the day she was acting Lieutenant. +EMPIOYEE 27 +PROTECTED MATY +30 +03 +SDNY_00008103 + diff --git a/vision-fixhub/ds9-parsed-01/1be0146ee51bdf289a12f3b7aa6562ecc49b62edf40124d02799ab945c61a83e.receipt.json b/vision-fixhub/ds9-parsed-01/1be0146ee51bdf289a12f3b7aa6562ecc49b62edf40124d02799ab945c61a83e.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..5bdc9e40ae4c0b4a333e3ab1328c96df1787cacb --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1be0146ee51bdf289a12f3b7aa6562ecc49b62edf40124d02799ab945c61a83e.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -75, + "dataset": "marble-joined", + "doc_id": "1be0146ee51bdf289a12f3b7aa6562ecc49b62edf40124d02799ab945c61a83e", + "engine": "marble-apple-vision", + "event_count": 6, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "3886da0c4a0813045b306406ab5b1c8cde772d0a886015802c5e074bc7afa9b8", + "output_sha256": "f9b4b334f5e67c8c0782cd4ad8f09e3fe7a242f80f2ff2604a9e80e975bd940d", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1bf573b04dff0e34fa6f01f2fcf1bb62d0c91323b5f45ea34dd5b3077c2234ec.md b/vision-fixhub/ds9-parsed-01/1bf573b04dff0e34fa6f01f2fcf1bb62d0c91323b5f45ea34dd5b3077c2234ec.md new file mode 100644 index 0000000000000000000000000000000000000000..bcabc94fe62eb8554a01bdd674caf910a54e5d63 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1bf573b04dff0e34fa6f01f2fcf1bb62d0c91323b5f45ea34dd5b3077c2234ec.md @@ -0,0 +1,66 @@ +U.S. Department of Justice +United States Attorney +Southern District of New York +The Silvio J. Mollo Building +One Saint Andrew's Plaza +New York, New York 10007 +November 4, 2021 +BY ELECTRONIC MAIL +Christian Everdell, Esq. +Cohen & Gresser LLP +800 Third Avenue +New York, NY 10022 +Laura Menninger, Esq. +effrey Pagliuca, Esq +laddon, Morgan and Foreman, P.C +150 East Tenth Avenue +Denver, CO 80203 +Bobbi Sternheim, Esq. +Law Offices of Bobbi C. Sternheim +33 West 19th Street-4th Fl. +New York, NY 10007 +Re: +United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) +Dear Counsel: +Pursuant to the Court's November 1, 2021 order, we write to provide you with categories +and exemplars of statements that are admissible as co-conspirator statements under Federal Rule +of Evidence 801(d)(2)(E). +Because no attorney can predict the verbatim testimony of a witness, please note that the +following statements are simply the Government's understanding of the sum and substance of the +statement. And for that same reason, while we have identified examples of co-conspirator's +statements that we expect to offer for the truth of the matters asserted therein under Rule +801(d)(2)(E), we also list certain examples of statements made by co-conspirators that we expect +will not be offered for the truth of the matters asserted therein. We list these additional examples +in an abundance of caution, in the event that the witness's statement varies from our expectation +in a manner that makes some part of the statement admissible for its truth under Rule 801(d)(2)(E). + + +Page 2 +1. Statements made by Epstein to friends and family of Minor Victims +Epstein had one-on-one conversations with the friends and family of Minor Victims, +generally on the telephone. For example: +• +2. Statements by Epstein to his employees +Epstein made statements to his employees, including statements that relate to their duties, +provide background information or history about the conspiracy, or promote efforts to conceal the +• In or about 2005, Epstein told an employee witness ("CC-1"), who was identified as a coconspirator in the Government's October 11, 2021 letter, that the defendant used to find +• In or about October 2005, Epstein and an employee ("CC-2"), who was identified as a coconspirator in the Government's October 11, 2021 letter, told CC-1 to go to his Palm Beach +house to help someone who was coming to take the computers from Epstein's Palm Beach +House. +• +3. Statements made by CC-2 to the Minor Vietims or their families +CC-2 placed many calls to Minor Victims or their friends and family in order to schedule +massage appointments. The Government expects several witnesses to testify about receiving those +calls. For instance: +• +4. Statements made by Jeffrey Epstein to the Minor Victims or in their presence +The Government expects to offer numerous statements made by Jeffrey Epstein to the + + +Page 3 +by: +Very truly yours, +DAMIAN WILLIAMS +United States Attorney +S/ +Assistant United States Attorneys diff --git a/vision-fixhub/ds9-parsed-01/1bf573b04dff0e34fa6f01f2fcf1bb62d0c91323b5f45ea34dd5b3077c2234ec.receipt.json b/vision-fixhub/ds9-parsed-01/1bf573b04dff0e34fa6f01f2fcf1bb62d0c91323b5f45ea34dd5b3077c2234ec.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..15085b99cded8780fc0df85d500b0594e70df0ef --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1bf573b04dff0e34fa6f01f2fcf1bb62d0c91323b5f45ea34dd5b3077c2234ec.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -40, + "dataset": "marble-joined", + "doc_id": "1bf573b04dff0e34fa6f01f2fcf1bb62d0c91323b5f45ea34dd5b3077c2234ec", + "engine": "marble-apple-vision", + "event_count": 5, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "18a278c3c2db145e5b0fa617ebe5fe7d0903bf6c4d7cec73b8e6a03fd8c0a88f", + "output_sha256": "266afaa028dcb5110eb0b565bd50fe534c023303411f57c0dfbe17b04873bc61", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1c407eee094de82e2fabc91c275d9d4d72c77a2adc8c1e26a30de28eff34a7cf.md b/vision-fixhub/ds9-parsed-01/1c407eee094de82e2fabc91c275d9d4d72c77a2adc8c1e26a30de28eff34a7cf.md new file mode 100644 index 0000000000000000000000000000000000000000..e9a8e10534509b733605b3790b38c4eec25e46a6 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1c407eee094de82e2fabc91c275d9d4d72c77a2adc8c1e26a30de28eff34a7cf.md @@ -0,0 +1,83 @@ +From: " +To: " +D" < +Subject: FW: 2019.8.15 - SDNY Production Index.xIsx +Date: Tue, 20 Aug 2019 18:15:14 +0000 +Up to you guys, but given that there's no rush on moving on financial leads, it seems most efficient to just do this together +on 9/5, when everyone is back from Florida. But I don't have strong views. +From: Moyne, Parvin < +Sent: Tuesday, August 20, 2019 2:03 PM +To: +Cc: Moyer, Thomas < +Subject: RE: 2019.8.15 - SDNY Production Index.x/sx +Initially, we propose that the lawyers (myself, my colleagues at Akin Gump, and someone from | Legal) deliver a +presentation that provides an overview of Epstein's relationship with the bank, the different accounts affiliated with +Epstein and the types of transactions found in the accounts. We would also highlight various transactions that we have +noted in our internal investigation. Our aim is that the attorney proffer would help you in sifting through the records we +have provided so you can more readily identify whatever information you are most interested in. Following the proffer, if +there are particular accounts or transactions of interest, we can identify the person within who can best answer +questions on those areas and that person would then meet with you. +In terms of timing, I estimate 2-3 hours for the attorney proffer. (I think closer to 2 hours but I hate to underestimate.) +Best, +Parvin +From: +Sent: Monday, August 19, 2019 8:14 PM +To: Moyne, Parvin < +Cc: Moyer, Thomas < +Subject: RE: 2019.8.15 - SDNY Production Index.xlsx +Parvin, +Could you please let us know what format we should expect in terms of the proffer? That will help us with figuring out +scheduling. I.e., do you expect to make an attorney proffer in the first instance, or should be expect to be meeting with +personnel, etc? And approximately how long should we be planning to block out? +thanks, + + +From: Moyne, Parvin < +Sent: Monday, August 19, 2019 12:04 +To: +Cc: Moyer, Thomas < +Subject: RE: 2019.8.15 - SDNY Production Index.x/sx +Hi +The proffer may be helpful in guiding you through the production. That said, we can be available whenever makes most +sense on your ends. +We have time this week (Thursday or Friday afternoon) and next week (Monday - Wednesday), and we have time in +September. If you give us a few options in terms of dates/times, we will sort out schedules on our ends. +Best +Parvin +From: +Sent: Saturday, August 17, 2019 1:59 PM +To: Moyne, Parvin < +Cc: Moyer, Thomas < +Subject: RE: 2019.8.15 - SDNY Production Index.xIsx +**EXTERNAL Email** +Parvin, +We received the index, thank you. In terms of a proffer, what generally did you have in mind regarding timing? I think +we'd like to have some time with the subpoena returns to get familiarized, and our team has a combination of travel and +trials in the next couple weeks, but we could do early September if that works on your end. Thoughts? +thanks, +From: Moyne, Parvin +Sent: Thursday, August 15, 2019 09:48 +To: +Cc: Moyer, Thomas < +Subject: 2019.8.15 - SDNY Production Index.xIsx +Please find attached an index to our productions to date. This is a work in progress - we will update it as we gather and +produce additional documents. +Would you like to touch base later today about scheduling a proffer? We are free after 4 p.m. + + +Best, +Parvin +Parvin Daphne Moyne +AKIN GUMP STRAUSS HAUER & FELD LLp +One Bryant Park New York, NY 10036-6745 | USA | Direct: +1 +/akingump.com Bio +Internal: +The information contained in this e-mail message is intended only for the personal and confidential use of the +recipients) named above. If you have received this communication in error, please notify us immediately by e- +mail, and delete the original message. +The information contained in this e-mail message is intended only for the personal and confidential use of the +recipient(s) named above. If you have received this communication in error, please notify us immediately by e- +mail, and delete the original message. +The information contained in this e-mail message is intended only for the personal and confidential use of the +recipients) named above. If you have received this communication in error, please notify us immediately by e- +mail, and delete the original message. diff --git a/vision-fixhub/ds9-parsed-01/1c407eee094de82e2fabc91c275d9d4d72c77a2adc8c1e26a30de28eff34a7cf.receipt.json b/vision-fixhub/ds9-parsed-01/1c407eee094de82e2fabc91c275d9d4d72c77a2adc8c1e26a30de28eff34a7cf.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..d793ab7aeee8800747ced56fad06d799a8981452 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1c407eee094de82e2fabc91c275d9d4d72c77a2adc8c1e26a30de28eff34a7cf.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -36, + "dataset": "marble-joined", + "doc_id": "1c407eee094de82e2fabc91c275d9d4d72c77a2adc8c1e26a30de28eff34a7cf", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "498df018491ec6e65daa2ce4ac2d8ebc53928e354ad3b61a3f902b5edab81f53", + "output_sha256": "ff043d50d5b7de9a316f75342f7f66ab380e564c5924ad7516bc1e4156316a73", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1c4a03260e4f37ef92bc43656a656b313d5bf11af359330e78e5bccb1d92b8ea.md b/vision-fixhub/ds9-parsed-01/1c4a03260e4f37ef92bc43656a656b313d5bf11af359330e78e5bccb1d92b8ea.md new file mode 100644 index 0000000000000000000000000000000000000000..503a6e09fe4ca54fc9a0cc8209e97f1a32bbfa49 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1c4a03260e4f37ef92bc43656a656b313d5bf11af359330e78e5bccb1d92b8ea.md @@ -0,0 +1,38 @@ +Untitled +| RECORD NUMBER: 104 TIME STAMP: 9-AUG-2019 19:19 +| Start Date 8/9/19 | Answer Date 8/9/19| End Date +| Start Time 18:58:03 | Answer Time 18:58:22 | End Time +8/9/19 +19:19:10| +| Caller Station +| Selected Trunk Group 6 +Caller Circuit +02-05-03 | Selected Circuit +01-14-23 +| Caller COS +150 +[Selected COS +| Caller Routing Class 1 +¡Selected Routing Class +| Caller Switch ID 001 +| Selected Route Pattern +23 +| Caller ANI +| Selected Facility. +| Record Audit +2702 +| Call Type LINE TO TRUNK +| Conference Audit +| Call Status IN CONVERSATION +| Access Code +9 +1 Queue Status NULL QUEUE +i Code Validation +1 Queue Time +| Dialed Number + +i Account Code +| Authorization Code +Use CTRL/Z to CANCEL; CTRL/S to PAUSE and CTRI/Q to CONTINUE +23/16/2022 +Page 1 diff --git a/vision-fixhub/ds9-parsed-01/1c4a03260e4f37ef92bc43656a656b313d5bf11af359330e78e5bccb1d92b8ea.receipt.json b/vision-fixhub/ds9-parsed-01/1c4a03260e4f37ef92bc43656a656b313d5bf11af359330e78e5bccb1d92b8ea.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..022925a6c17531f451f3f90395342c09c19a8b60 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1c4a03260e4f37ef92bc43656a656b313d5bf11af359330e78e5bccb1d92b8ea.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -23, + "dataset": "marble-joined", + "doc_id": "1c4a03260e4f37ef92bc43656a656b313d5bf11af359330e78e5bccb1d92b8ea", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "c3bd6110857922e8117f762707f40aa537a67558069dd4c9126e89cf394521e3", + "output_sha256": "57d7f045b53db715124fa2b3efa3eeaa3bdb04b7c53d220dd8f65a44b2db508f", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1c4d4d928b74db6c0e46fa63e578140bba9cd95c19d5d4347fe8bc3bff949858.md b/vision-fixhub/ds9-parsed-01/1c4d4d928b74db6c0e46fa63e578140bba9cd95c19d5d4347fe8bc3bff949858.md new file mode 100644 index 0000000000000000000000000000000000000000..fac2c78d04ce9ed06f11fb938225e45ff741682b --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1c4d4d928b74db6c0e46fa63e578140bba9cd95c19d5d4347fe8bc3bff949858.md @@ -0,0 +1,109 @@ +CHS REPORTING DOCUMENT +HEADER +OFFICIAL RECORD +Source ID: +Date: +Case Agent Name: +Field Office/Division: +Squad: +S-00099701 +10/19/2020 +Los Angeles +I 01 +SOURCE REPORTING +Date of Contact: +10/16/2020 +List all present including yourself (do not include the CHS): +SAI +Type of Contact: +Other Contact Type: +Other +Encrypted Messaging App +Date of Report: +10/19/2020 +Substantive Case File Number +8041-LA-3315657-INTELPRODS +Substantive Case File Number +50D-NY-3027571 +Check here if additional reporting is in Echo +No +Source Reporting: +(U) Captioned Confidential Human Source (CHS) was asked by the handling agent about information he/she may be aware of +(U) +Harvard Law Professor Alan Dershowitz (Dershowitz). CHS learned that +Dershowitz influenced many students from wealthy families. For example, Josh Kushner (Josh) and Jared Kushner (Jared) were +both his students. Dershowitz told CHS that if he were young again, he would be holding a stun gun as an Israeli Intelligence +(Mossad) agent. CHS believed Dershowitz was co-opted by Mossad and subscribed to their mission. CHS still continues to +communicate occasionally for Dershowitz [See previous reporting]. +(U)Jeffrey Epstein (Epstein) was represented by Dershowitz. CHS remembered Dershowitz tell Alex Ocasta (U.S. Attorney of +outhern District of Florida at the time) that Epstein belonged to both U.S. and allied intelligence services. CHS shared phone call +etween Dershowitz and Epstein during which he/she took notes. After these calls, Mossad would then call Dershowitz to debriel +Syria. One of CHS'S + + + +CHS REPORTING DOCUMENT +OFFICIAL RECORD +(U)Masha Drokova (Drokova), telephone number +ne ventures. v +cooked at tHe and said, You knew Epstein, didnt you.She said Epstein was a didnteal mall and at was can she +what had being done to him. CHS concluded Day One Ventures was in Silicon Valley to steal technology. +(U)CHS advised Chabad is doing everything they can to co-opt the Trump presidency. Chabad is basically state-sanctioned +Judaism. It is used by Putin to keep tabs on all the Russo-Jewish oligarchs. On the day Trump was elected President, Ivanka +Trump (ivanka) and Jared were at the gravesite of Rabbi Scheersom, who was the most powerful Rabbi in the Chabad network +Jared didn't disclose his stake in Cadre, because of its ties to the Russian state (NFI). CHS believed this was/is the "real" Russiar +collusion story. Kushner has moved a lot of Russian investment money around. The FBI should investigate Kushner's family +charities to find evidence of corruption and money laundering. Chabad routinely uses charities to launder money. +(U)CHS provided the attached article entitled "Jim McGreevey and His Main Man By Craig Horowitz," published 09/10/2004. While +the article is old and centered on Charles Kushner (Charles), it highlights and documents the deep ties the Kushner family has with +Israel and their history of corrupt business practices and alleged violations of election laws. CHS stated that if the FBI is serious +about investigating the Kushners and their relationships with Middle East, they should look closely at Ken Kurson, who "knows +everything" (NFI). CHS advised Henry Kissinger introduced Charles to Cui Tiankai, the Chinese ambassador to the U.S., a +relationship that could have been helpful; at around the same time of the introduction, Anbang was entering negotiations with the +Kushners over 666 Fifth Avenue. +(U)Hary Tanoesoedinbjo (Hary) has been involved has developed Trump's hotels and is a billionaire. Hary +introduced him/her to the Indonesian CIA. +Harv +speak Indonesian. Hary bought his Beverly Hills home from Trump +at an inflated price (NFI). On +was at Hary's house when Haryl +that Trump told him +that he was going to "fuck Amazon" over their military contracts. CHS advised that this was a real collusion story - Trump has been +compromised by Israel, and Kushner is the real brains behind his organization and his Presidency. +(U)Igor Korbatov (Igor) brokered the sale of a Beverly Hills mansion Trump acquired for $800,000 less than the market value. CHS +ferenced the attached article that summarized the matter - "A small-time scam artist gave Trump a mansion for SO. Why' +ublished April 12 2018 by Lance Williams and Matt Smith in "Reveal from The Center for Investigative Reporting." Ross Delston, +Washington, D.C.-based attorney and consultant on financial crimes to the International Monetary Fund, said the deal included +"many facets that don't add up" and that the deal warrants further scrutiny and investigators should follow up on the "numerous +oddities and red flags that this series of transactions raises." +) The Fisches (NFI) signed the deed transferring the Beverly Hills home. The Fisches are prominent Los Angeles real esta +vestors and political donors. They have given more than $250,000 to GOP candidates and causes, records show. They we +ests at the White House when George W. Bush was president and accompanied him on a trip to Israel, Selma Fisch said in +one interview. Their daughter and wife of the sales broker, Lisa Korbatov (Lisa), is a GOP activist and president of the Beve +Hills Unified school board; Lisa is an active member of the Jewish community in Beverly Hills. After one season on the West Coast +"The Apprentice" moved back to New York. Trump never lived in the Beverly Hills mansion. In the summer of 2009, he sold the +respond to multiple requests for comment. + + + +CHS REPORTING DOCUMENT +OFFICIAL RECORD +(U)CHS stated +Renda Tillerson (Renda), telephone number +Tillerson (Rex), former Secretary of State for Trump. Renda told CHS about smears in the New York Post and how Jared was +running a rival State Department operation. Rex affirmed Renda's claim. Renda was introduced to CHS by Daren Blanton +(Blanton). Renda and Rex both told CHS they had been under intense surveillance. Renda told CHS she can't wait for the FBI to +call her, so that she can tell them everything she knows. +Kushners $184 million (USD) while Kushner was facing his 666 5th Avenue disaster. [see attached screenshots for references] +(U)Elliott Broidy (Broidy) recently plead to charges related to money laundering unregistered lobbying for the UAE. Broidy +(NFI). Royce's wife may be a lobbyist who works with Broidy. +(U)CHS emphasized the importance for the FBI to investigate Gawker for its involvement in pushing Russian propaganda. Matt +Melen told CHS that after Gawker was destroyed, the Russian Intelligence Service started using Zero Hedge to influence U.S. +people. +Synopsis: +Foreign influence on U.S. officials by Israel, Russia, and UAE +SIGNATURE +Submitted By +First Level Approved By +Mon, 19 Oct 2020 15:23:26 - 07:00 +Mon, 19 Oct 2020 15:26:28 -07:00 diff --git a/vision-fixhub/ds9-parsed-01/1c4d4d928b74db6c0e46fa63e578140bba9cd95c19d5d4347fe8bc3bff949858.receipt.json b/vision-fixhub/ds9-parsed-01/1c4d4d928b74db6c0e46fa63e578140bba9cd95c19d5d4347fe8bc3bff949858.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..a0b9b12f76458be5f024db53fec106800e548f26 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1c4d4d928b74db6c0e46fa63e578140bba9cd95c19d5d4347fe8bc3bff949858.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -388, + "dataset": "marble-joined", + "doc_id": "1c4d4d928b74db6c0e46fa63e578140bba9cd95c19d5d4347fe8bc3bff949858", + "engine": "marble-apple-vision", + "event_count": 7, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "d57cb2f96e7940ddfbe0b6f965a13924e1aef02876381eedb4cc4dc477c1e687", + "output_sha256": "b7bf2c06991e712826f861ad139603eff4f66919f096ce533c7a79738ed23e05", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1c640ec4ed25302692e30cc780dbe25875306a6e643660a7930a547fd65b2141.md b/vision-fixhub/ds9-parsed-01/1c640ec4ed25302692e30cc780dbe25875306a6e643660a7930a547fd65b2141.md new file mode 100644 index 0000000000000000000000000000000000000000..846795174720ba42c995093b9ab513ba06971a0d --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1c640ec4ed25302692e30cc780dbe25875306a6e643660a7930a547fd65b2141.md @@ -0,0 +1,71 @@ +Person of Interest Worksheet +Prepared by IA Mollory Rosso, ID-13/C-19 +IT LIGENCE DIVED +Case Number: 90A-NY-3151227 +Case Agent: SA Amanda Moore +Person of Interest +Name: Michael Albert Thomas AKA: +DOB: 02/11/1978 +Height: 5'06" +Weight: 165 Ibs. +Sex: Male +Race: Black +Ethnicity: Not Hispanic +SSN: 143-84-8558 +US Passport #: 478053167 (Exp. 06/21/2021) +New Jersey Driver's License #: T35945446102782 +Michael Thomas +New Jersey DMV Image +Addresses: +- 371 Bowler Court, Piscataway, NJ 08854 +• CLEAR Reported: 05/01/2012 - 04/02/2019 (Credit reporting) +• Accurint Reported +• NJ DMV Reported +- 1409 Sunnyview Oval, Keasbey, NJ 08832 +• CLEAR Reported: 06/25/2019 - 08/02/2019 (Credit reporting) +Criminal History: +- Negative for a criminal history in ejustice +- Negative for a criminal history in NYPD database +• Victim in a domestic incident (#5064637) from 26 December 2014 (NYPD) +• Incident was an argument over custody with a girlfriend, Monique Faare +Telephone Numbers, Email Addresses, and Social Media: +- 973-698-8814 (CLEAR; NYPD) +- +908-279-6215 (CLEAR) +- +908-753-0285 (CLEAR) +- +973-530-4039 (CLEAR) +732-926-1020 (CLEAR) +- mats7896@gmail.com (Cell phone provider) +• Google User ID: 100486930516069814682 +- Negative results for social media +Vehicles: +1 + + +- White 2016 Nissan Maxima +• VIN: 1N4AA6AP3GC443578 +• Plate #: A57LBX +Other Notes: +- Name match for 20+ New Jersey civil court filings (Open source) +• More than half of these filings include either a DOB, phone number, or address +that does not match records for the subject. Other filings do not have identifiers +listed for the defendant, so the results are inconclusive. +- Negative for bankruptcy filings (Pacer) +• One name match returned for a joint Chapter 7 filing from 12 July 2019 with +Ashley M Thomas, but the filing was in Kentucky and the associated SSN does +not match +- Negative for civil filings (Pacer) +Results Checks (enclosed unless otherwise noted) +• CLEAR - positive results +• ejustice - negative results +• TECS - positive results +• Closed - negative results +• Facebook - negative results +• NYPD Reporting - positive results +INY DMV - negative results +~ NJ DMV - positive results +• Accurint - positive results +• Pacer - negative results +2 diff --git a/vision-fixhub/ds9-parsed-01/1c640ec4ed25302692e30cc780dbe25875306a6e643660a7930a547fd65b2141.receipt.json b/vision-fixhub/ds9-parsed-01/1c640ec4ed25302692e30cc780dbe25875306a6e643660a7930a547fd65b2141.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..d5d06915069d0e9163b2a25b601b07e88fa9f19d --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1c640ec4ed25302692e30cc780dbe25875306a6e643660a7930a547fd65b2141.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "1c640ec4ed25302692e30cc780dbe25875306a6e643660a7930a547fd65b2141", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "96cd5bdaa9459801e3a87bd65d37f69cc337ba7c0db469a839dc8a5303207d0a", + "output_sha256": "d2b8df865895554d25bb93a5702db969af9f7d8aff0696a55991b4efc3cbd64b", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1c69c970441114243c58542341d0232dffe87fc107031ba1ffbc1c552885f5be.md b/vision-fixhub/ds9-parsed-01/1c69c970441114243c58542341d0232dffe87fc107031ba1ffbc1c552885f5be.md new file mode 100644 index 0000000000000000000000000000000000000000..071e17a7d5e4db2d968faf56dffb684201657640 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1c69c970441114243c58542341d0232dffe87fc107031ba1ffbc1c552885f5be.md @@ -0,0 +1,12 @@ +Event: Proffer: +Start Date: 2019-09-10 15:30:00 +0000 +End Date: 2019-09-10 18:00:00 +0000 +Organizer: +Location: WPB Hilton +Class: X-PERSONAL +Date Created: 2019-12-18 17:02:18 +0000 +Date Modified: 2019-12-18 17:02:18 +0000 +Priority: 5 +DTSTAMP: 2019-09-05 14:03:57 +0000 +Attendee: +(NY) (FBI) < diff --git a/vision-fixhub/ds9-parsed-01/1c69c970441114243c58542341d0232dffe87fc107031ba1ffbc1c552885f5be.receipt.json b/vision-fixhub/ds9-parsed-01/1c69c970441114243c58542341d0232dffe87fc107031ba1ffbc1c552885f5be.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..262a34e14861268e2ca0bfbd6ffa50aef7a9a0b7 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1c69c970441114243c58542341d0232dffe87fc107031ba1ffbc1c552885f5be.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "1c69c970441114243c58542341d0232dffe87fc107031ba1ffbc1c552885f5be", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "2af5cd1b3466d7e018c07ef085ba89f33cdf5ee82f417992adddfb6f4433d5ed", + "output_sha256": "1fd2e5819108c8dddc6464d4166f57d450a18630f9dfc179e422e9edb6e76e25", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1c89c04a249999d91d4302ab4b1ff455d8e0a9300c4a08a45c1aaf6ce31949a5.md b/vision-fixhub/ds9-parsed-01/1c89c04a249999d91d4302ab4b1ff455d8e0a9300c4a08a45c1aaf6ce31949a5.md new file mode 100644 index 0000000000000000000000000000000000000000..e4baa871dd51421fd84804700a734a2a4b45eaf9 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1c89c04a249999d91d4302ab4b1ff455d8e0a9300c4a08a45c1aaf6ce31949a5.md @@ -0,0 +1,1334 @@ + +ACCOUNT NAME +JEFFREY E EPSTEIN S +ACCOUNT NUMBER +BILL DATE PAGE +FEB 14, 2004 +1.0 +SUMMARY OF MONTHLY CHARGES FOR ACCOUNT +Wireless Number Multi-Line Account +Previous +Balance +3,308.41 +Payments +Received +Late Payment Adjustments +Charge +4, 793.89CR +.00 +94.99 +Your billing cycle began on 01/13 and ended on 02/12. +Balance +Forward +1, 390. 49CR +Current +Charges +1,273.67 +Total Amt Due +116.82CR +Current Monthly Charges +Summary of Individual Number Charges +I G. MAXWELL +Total Current Monthly Charges +TOTAL AMOUNT DUE +357.99 +1,273.67 +116.82CR +116.82CR +Acet Name: JEFFREY E EPSTEIN & CO +Account: +Wireless:| +ACCOUNT NAME +JEFFREY E EPSTEIN & +ACCOUNT NUMBER +AMOUNT DUE: +ATET WIRELESS +P.O. BOX 8220 +AURORA IL 60572-8220 +JEFFREY E EPSTEIN & CO +457 MADISON AVE +NEW YORK NY 10022-6843 +BILL DATE PAGE +FEB 14, 2004 +3.0 +SIGN UP FOR PAPERLESS BILLING TODAY! +Pay your bill online anytime, day or night.* And you can also get instant +account information, view your service plans, +and change or add features. +Sign-up today at www.attwireless.com/ocs +*subject to credit approval +PAYMENTS AND ADJUSTMENTS +DETAIL OF PAYMENTS +AST Proprietary +The infornation contained here is for use by authorized person only +and 1s not for general distribution. +1 + + + +1/16/04 PAYMENT RECEIVED - THANK YOU! +1, 485. 48CR +2/11/04 PAYMENT RECEIVED - THANK YOU! +3,308.41CR +TOTAL OF PAYMENTS RECEIVED THROUGH 2/14/04 +4, 793.89CR +DETAIL OF ADJUSTMENTS +} MONTHLY SERVICE CHARGE - ADJ +94.99 +TOTAL OF ADJUSIMENTS +ACCOUNT NAME +ACCOUNT NUMBER +MOBILE NUMBER +94.99 +BILL DATE PAGE +JEFFREY E EPSTEIN & +10.0 +FEB 14, 2004 +SUMMARY OF CHARGES +IMPORTANT MESSAGES: +You received an adjustment on your account. Please see the Payments and +Adjustments detail on a previous page of this invoice. +Your wireless service is currently in a canceled status. +MONTHLY SERVICE CHARGES +1/13/04 Through 2/12/04 +MONTHLY SE - ATST DIGITAL ONE RATE $14 +149.99 +MONTHLY SE - ATGT DIGITAL ONE RATE $14 +104.99CR +CALL FORWARDING +.00 +THREE WAY CALLING +CALL WAITING +.00 +.00 +CALLER ID +WORLDCONNECT +.00 +2.40 +PCS VOICEMAIL W/NUMERIC +.00 +DETAIL BILLING +.00 +TEXT MESSAGING $9.99 +3.32 +TOTAL MONTHLY SERVICE CHARGES +50.72 +HOME AIRTIME CHARGES +1/12/04 Through 1/22/04 - ATST DIGITAL ONE RATE $149.99 +Category +Minutes +Rate +Charge +INCLUDED IN PLAN +337 +CALL FORWARDING MINS +168 +.000 +.250 +505 +. 00 +42.00 +42.00 +TOTAL HOME AIRTIME CHARGES +HOME LONG DISTANCE CHARGES +ATST WIRELESS +TOTAL HOME LONG DISTANCE CHARGES +ACCOUNT NAME +ACCOUNT NUMBER +JEFFREY E EPSTEIN & +ROAMING CHARGES +ROAMING AIR +ROAMING LONG DISTANCE CHARGES +TOTAL ROAMING CHARGES +TAXES, SURCHARGES & REGULATORY FEES +FEDERAL TAX +SALES TAX +911 SURCHARGE +NY CITY UTILITY G.R. 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PEoprietary +The infornation contained here is for use by authorized person only +and ia not for general distribution. + + + +0206 1/20 12:21P 417/INCOMNG LDSWITZERLAN +0207 1/20 12:35P 417/INCOMNG LDSWITZERLAN +0208 1/20 12:50P 417/INCOMNG LDSWITZERLAN +ACCOUNT NAME +ACCOUNT NUMBER +JEFFREY E EPSTEIN G +NY +NY +NY +.350 +1.050 +19.600 +MOBILE NUMBER BILL DATE PAGE 15.0 +FEB 14, 2004 +REF DATE +TIME NUMBER CALLED +CALL +CALLS TO FROM +MIN +AIR +LONG +DISTANCE +0209 1/20 1:46P 417/INCOMNG LDSWITZERLAN +0210 1/20 1:54P 417/INCOMNG LDSWITZERLAN +0211 1/20 7:20P 417/INCOMNG LDSWITZERLAN +0212 1/21 5:32A 417/INCOMNG LDSWITZERLAN +0213 1/21 6:11A 417/INCOMNG LDSWITZERLAN +0214 1/21 6:18A 417/INCOMNG LDSWITZERLAN +0215 1/21 7:46A 417/INCOMNG LDSWITZERLAN +0216 1/21 7:55A 417/INCOMNG LDSWITZERLAN +0217 1/21 8:00A 417/INCOMNG LDSWITZERLAN +0218 1/21 8:49A 417/INCOMNG LDSWITZERLAN +0219 1/21 10:25A 417/INCOMNG LDSWITZERLAN +0220 1/21 12:02P 417/INCOMNG LDSWITZERLAN +0221 1/21 12:28P 417/INCOMNG LDSWITZERLAN +0222 1/21 1:26P 417/INCOMNG LDSWITZERLAN +0223 1/21 4:39P 417/INCOMNG LDSWITZERLAN +0224 1/22 5:14A 417/INCOMNG LDSWITZERLAN +NY +NY +NY +NY +NY +NY +NY +NY +NY +NY +NY +NY +NY +NX +NX +NY +0225 1/22 5:18A 417/INCOMNG LDSWITZERLAN +0226 1/22 6:08A 417/INCOMNG LDSWITZERLAN +0227 1/22 4:57P 417/INCOMNG LDSWITZERLAN +0228 1/23 6:39A 417/INCOMNG LDSWITZERLAN +NY +NY +NY +0229 1/23 8:51A 417/INCOMNG LDSWITZERLAN +TOTAL HOME AIRTIME AND LONG DISTANCE CHARGES +505 +CALL CHARACTERISTICS: +W = Call Waiting, S = Long Distance Service Billed Separately, +F = Call Forwarding +"CALLS FROM" KEY: +NM = NEW MEXICO, IN = INDIANA, NY = NEW YORK +ROAMING CHARGES +REF DATE TIME NUMBER CALLED CALLS TO +MIN +42.00 +-350 +.350 +.700 +.700 +.350 +.700 +.350 +.350 +350 +.350 +.700 +.350 +1.050 +.350 +.700 +.700 +.700 +.350 +1.750 +1.050 +37.45 +AIR DISTANCE TAXES +Calls Made From: FRANCE, +0001 1/19 1:33P +0002 1/19 1:48P +0003 1/19 3:10₽ +0004 1/19 3:16P +0005 1/19 3:20₽ +0006 1/19 3:20₽ +0007 1/19 3:21P +0008 1/19 6:34P +0009 1/19 6:49P +0010 1/19 6:50P +0011 1/19 7:14P +0012 1/19 7:35P +Subtotal for +Calls Made From: +: FRANCE, +SWITZERLAND, +0013 1/20 12:00A +0014 1/20 2:42P +0015 1/20 2:47P +INTL NIWK +INTL NIWK +INTL NTWK +INTL NIWK +INTL NTWK +INTL NIWK +INTL NTWE +INTL NIWK +INTL NIWK +INTL NINK +INTL NIWE +INTL NTWK +H H +1 +1 +1 +1 +3 +1 +1 +17 +.99 +.99 +.99 +3.96 +.99 +.99 +.99 +• 99 +.99 +2.97 +,99 +.99 +16.83 +.35 +,35 +.35 +1.40 +.35 +.35 +.35 +.35 +.35 +1.05 +.35 +.35 +5.95 +.00 +CALL SVC +INTL NTWK +INTL NIWK +1 +5 +1 +.99 +4.95 +.99 +1.75 +.35 +AFH +AST Proprietary +The infornation contained here is for use by authorized person only + + + +0016 1/20 3:51P +0017 1/20 3:55P +ACCOUNT NAME +JEFFREY E EPSTEIN S +INTL NIWE +INTL NIWE +ACCOUNT NUMBER +1 +2 +MOBILE NUMBER +.99 +.35 +1.98 +.70 +BILL DATE PAGE +FEB 14, 2004 +16.0 +REF DATE +TIME NUMBER CALLED CALLS TO +MIN +AIR DISTANCE TAXES +0018 1/20 3:570 +0019 1/20 3:59P +0020 1/20 4:00P +0021 1/20 4:02₽ +0022 1/20 4:05P +0023 1/20 4:07P +0024 1/20 4:10P +0025 1/20 4:12₽ +0026 1/20 4:14P +0027 1/20 4:19P +0028 1/20 4:20P +0029 1/20 4:20P +0030 1/20 4:21P +0031 1/20 4:25P +0032 1/20 4: 30₽ +0033 1/20 4:41₽ +0034 1/20 4:41P +0035 1/20 5:12P +0036 1/20 5:14P +0037 1/20 6:42₽ +0038 1/20 6:44P +0039 1/20 6:47₽ +0040 1/20 7:50P +0041 1/21 12:04 +0042 1/21 12:04 +Subtotal for +: SWITZERLAND, +Calls Made From: SWITZERLAND, +0043 1/21 11:21A +0044 1/21 11:27A +0045 1/21 12:39E +0046 1/21 1:49P +0047 1/21 1:52P +0048 1/21 2:28P +0049 1/21 2:56P +0050 1/21 2:59P +0051 1/21 3:19P +0052 1/21 3:21P +0053 1/21 4:05P +0054 1/21 4:58P +0055 1/21 5:53P +0056 1/21 6:40P +0057 1/21 6:57₽ +0058 1/21 6:58P +0059 1/21 6:59P +0060 1/21 7:02P +0061 1/21 7:04P +0062 1/21 7:05P +0063 1/21 10:40F +0064 1/21 10:41F +INTL NIWK +INTL. NTWK +INTL NIWK +INTL NIWE +INTL NIWK +INTL NIWK +INTL NIWK +INTL NIWK +INTL NIWK +INTL NTWK +INTL NTWK +INTL NTWK +INTL NIWK +INTL NTWK +INTL NIWK +INTL NTWK +INTL NIWK +INTL NTWK +INTL NTWK +INTL NTWK +INTL NTWK +INTL NTWK +INTL NTWK +INTL NTWK +INTL NTWK +INTL NTWK +INTL NIWK +INTL NTWK +INTL NTWK +INTL NTWE +INTL NIWK +INTL NIWK +INTL NTWK +INTL NTWK +INTL NTWK +INTL NTWK +INTL NTWK +INTL NTWK +INTL NTWK +INTL NTWK +INTL NTWK +INTL NTWK +INTL NTWK +INTL NIWK +INTL NIWK +INTL NIWK +INTL NIWK +APH +2 +1.98 +.70 +-99 +35 +1.98 +1.98 +.70 +.70 +.99 +.35 +2.97 +-99 +1.05 +.35 +2 +1.98 +.70 +2 +1.98 +.70 +HAN +99 +96 +95 +2 +AN N +1 +2 +99 +99 +99 +98 +99 +98 +1. +99 +98 +54 +53 +AN H +1 +NAN +1 +99 +1 +20 +1 +2 +un +un +un +un +un +un +un +un +ino +AT&T Proprietary +The infornation contained here is for use by authorized person only + + + +0065 1/21 10:44F +0066 1/22 12:317 +0067 1/22 1:11A +0068 1/22 3:59P +0069 1/22 4:01P +0070 1/22 4:34₽ +0071 1/22 9:07P +ACCOUNT NAME +JEFFREY E EPSTEIN S +INTL NIWK +INTL. NIWK +INTL NIWK +INTL NTWK +INTL NIWK +INTL NIWK +INTL NIWK +ACCOUNT NUMBER +2 +1 +4 +2 +1 +MOBILE NUMBER +1.98 +.99 +.70 +.35 +3.96 +.99 +1.40 +1.98 +.35 +-99 +.70 +-35 +-99 +.35 +BILL DATE PAGE +FEB 14, 2004 +REF DATE +TIME NUMBER CALLED CALLS TO +MIN +AIR DISTANCE TAXES +0072 1/22 9:11P +0073 1/22 9:12P +0074 1/23 7:22₽ +INTL NIWK +INTL NIWK +INTL NIWK +2 +Subtotal for +: SNITZERLAND, +64 +.99 +.99 +1.98 +63.36 +Calls Made From: FRANCE, +0075 1/19 9:50₽ 1219059000/ +0076 1/20 1:16P +INTL NIWK +INTL NIWK +Subtotal for +: FRANCE, +TOTAL ROAMING CHARGES +.99 +.99 +137 135.63 +1.98 +IF YOU HAVE ANY QUESTIONS CONCERNING YOUR INVOICE OR SERVICE, +PLEASE CALL OUR CUSTOMER CARE DEPARTMENT: +1-800-888-7600 +.35 +.35 +.70 +22.40 +.00 +.35 +.35 +.70 +47.60 +.00 +. 00 +17.0 +APH +AT&T Proprietary +The infornation contained here is for use by authorized person only +- +9 \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/1c89c04a249999d91d4302ab4b1ff455d8e0a9300c4a08a45c1aaf6ce31949a5.receipt.json b/vision-fixhub/ds9-parsed-01/1c89c04a249999d91d4302ab4b1ff455d8e0a9300c4a08a45c1aaf6ce31949a5.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..283aae2a14251d90a20231d6c67319baa2d534d1 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1c89c04a249999d91d4302ab4b1ff455d8e0a9300c4a08a45c1aaf6ce31949a5.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -641, + "dataset": "marble-joined", + "doc_id": "1c89c04a249999d91d4302ab4b1ff455d8e0a9300c4a08a45c1aaf6ce31949a5", + "engine": "marble-apple-vision", + "event_count": 19, + "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "8b0a9b3d68fa37a7f4c1dec72f3de0424c91689f008f53df9910668481e12a19", + "output_sha256": "39f0ba0f81ed5f63c233cc4b313b0de42861e49a33ea7080dbd3443323bc7659", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1c922581ccac53d72b69e011cf7406cdc8b6a967e82085629c5b62ca842a3469.md b/vision-fixhub/ds9-parsed-01/1c922581ccac53d72b69e011cf7406cdc8b6a967e82085629c5b62ca842a3469.md new file mode 100644 index 0000000000000000000000000000000000000000..295badc71048585dee7f7628feb11411f05f80aa --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1c922581ccac53d72b69e011cf7406cdc8b6a967e82085629c5b62ca842a3469.md @@ -0,0 +1,5341 @@ +2 +3 +4 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +DIGITALLY RECORDED +SWORN STATEMENT +OF +OIG CASE #: +2019-010614 +DEPARTMENT OF JUSTICE +OFFICE OF THE INSPECTOR GENERAL +MARCH 21, 2022 +RESOLUTE DOCUMENTATION SERVICES +28632 Roadside Drive, Suite 285 +Agoura Hills, CA 91301 +(818) 431-5800 + + +1 +APPEARANCES: +2 +3 +4 +5 +6 +7 +8 +WITNESS: +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +2 +OFFICE OF THE INSPECTOR GENERAL +BY: +BY: +OTHER APPEARANCES: +NONE + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +3 +: This is Special Agent +The recorder is now on. My name is +• I'm a Special Agent with the +U.S. Department of Justice Office of the +Inspector General New York Field Office and +these are my credentials. I don't know if you +can see it, Mr. +: I could see. +: Okay. This interview with +former Federal Bureau of Prisons employee +is being conducted as part of an +official U.S. Department of Justice Office of +the Inspector General investigation. Today's +date is March 21, 2022. The time is 11:08 a.m. +This interview is being conducted via Zoom +videoconferencing as, Mr. +|, you're +currently in Kentucky; is that accurate? +MR. I +- +_: Also present is DOJ/OIG +Assistant Special Agent in Charge +This interview will be recorded by +me, Special Agent +Could +everyone please identify themselves for the +record and spell your last name? +To start +again, I am DOJ/OIG Special Agent + + +1 +2 +3 +4 +5 +6 +7 +8 +1. That's L +I am Assistant Special +Agent in Charge +DOJ/OIG, +with the +and these are my +credentials. +1: Received. +: Mr. +I can you please +identify yourself and spell your last name for +the record? +4 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +1: Yeah, my name is Jeffrey +I am a Junior on some +documents, and I am a former employee of the +DOJ Federal Bureau of Prisons and particular to +this matter MCC New York. +1: Thank you. This is an +official DOJ/OIG investigation into the events +surrounding the death of Inmate Jeffrey Epstein +and you're being asked to voluntarily provide +answers to our questions. Will you agree to a +voluntary interview with the DOJ/OIG? +: Yes. +: Just for the record I did +email you two forms prior to this interview, +one was OIG Form 3-226-2, that is the Warnings +and Assurances. And the other form is OIG Form + + +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +3-226/10A, which would be the Non-Disclosure +Agreement, and you signed - you read both of +them, signed them, but for the record I'm going +to read them to you and let's start off with +the Warnings and Assurances form. +The United - the form states: The United +States Department of Justice Office of +Inspector General Warnings and Assurances to +Employee Requested to Provide Information on a +Voluntary Basis. You are being asked to +provide information as part of an investigation +being conducted by the Office of the Inspector +General. +This investigation is being conducted +pursuant to the Inspector General Act of 1978 +as amended. This investigation pertains to job +performance failure and security failure. This +is a voluntary interview. Accordingly, you do +not have to answer questions. No disciplinary +action will be taken against you if you choose +not to answer questions. +Any statement you +wish to - you furnish may be used as evidence +in any future criminal proceedings or agency +disciplinary proceeding or both. +The waiver states I understand the +5 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +warnings and assurances stated above and I am +willing to make a statement and answer +questions. No promises or threats have been +made to and no pressure or coercion of any kind +has been used against me. +Mr. +, you've read the form? +: Yes, I have. +: You understand the form and +you agree to move forward with the interview? +1: Yes, I do. +: And you've already signed the +form and you sent it back to me and myself and +- +1: Correct. +1: -- ASAC +will sign +the document after the interview. The second +form states: Department of Justice Office of +Inspector General Non-Disclosure Agreement. I, +1, understand that the Department of +Justice Office of Inspector General OIG will +allow me to review certain documents in +connection with my remote interview with the +OIG on March 21, 2022, in order to facilitate +that remote interview. A copy of the documents +shown to me during my interview with the OIG +6 + + +7 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +labeled OIG Documents will be made part of the +OIG record of that interview. +As a condition of being granted access to +review the OIG interview documents, I agree not +to make an audio or video recording of the +interview, excuse me, and I also agree that +until the OIG's final report or a summary of +the final report is released to the public I +will not copy, photograph, discuss, or disclose +any information from or +about the OIG interview +documents I review to anyone other than the +OIG, my attorney if I have legal counsel who +also executes a non-disclosure agreement with +terms similar to this agreement, or other +specifically authorized by the OIG after any +such person executes a non-disclosure agreement +with terms similar to this agreement. +I further agree that even after the OIG's +final report or a summary of the final report +is released to the public I will not discuss or +disclose any information from or about the OIG +interview documents that are not contained in +or that are redacted from the publicly released +final report or summary of the final report. +These provisions are consistent with and + + +8 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +do not supersede, conflict with, or otherwise +alter the employee obligations, rights, or +liabilities created by existing +statute or +Executive order relating to (1) classified +information, (2) communications to Congress, +(3) the reporting to an Inspector General or +the Office of Special Counsel of a violation of +any law, rule, or regulation, or mismanagement, +a gross waste of funds, an abuse of authority, +or a substantial and specific danger to public +health or safety, or (4) any other +whistleblower protection. The definitions, +requirements, obligations, rights, sanctions, +and liabilities created by controlling +Executive order and statutory provisions are +incorporate into this agreement and are +controlling. +MI. +disclosure order? +I, do you understand that non- +1: I do. +: And you already read the +document, you signed it, and you've dated it. +Thank you for that. +: You're welcome. +Before I start the interview + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +I would like to place you under oath. Mr. +| can you please raise your right hand? +Do you swear to tell the truth and nothing but +the truth during this interview? +1: I do. +: Thank you. You can put your +hand down. Please let me know if you do not - +if you don't understand any questions and I'1l +try to repeat it or rephrase it for you. +: Sure. +: So we'll start with your +background. What is your current home address? +: My current home address is +I and that's in +• +Security Number? +: What is your date of birth? +: And what's your Social +1: Thank you. +What is your +current cellphone number? +- Are code +: Okay. What's your current - +what's your highest level of education? +9 + + +10 +1 +2 +3 +4 +5 +: +Currently in college still +pursuing a bachelor's degree. +: Which college? +: Probably about a semester ago +I was in Champlain College all online out of +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Burlington, Vermont, and I just recently +transferred Gateway Community Technical College +right here in my hometown of Kentucky. +: And what are you pursuing +your bachelor's degree in? +: Liberal arts, yeah. +1: Do you have an associate's +degree? +_: Credit wise, yes, but +formerly, no. +working for the BOP? +: And what did you do prior to +1: Prior to the BOP I was a +truck driver delivering fuel, oil, and stuff +like that. And prior to that I was down in +North Carolina where I was a correctional +officer for the State of North Carolina, which +is what got me my job into the BOP, my +experience. +1: Okay. So from - since high + + +11 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +school - from high school you started working +for the North Carolina BOP or did you do other +jobs before that? +: Oh, from high school I --. +: Various jobs? +1: Man of many - I - man of many +trades. I can't even count how many jobs I've +had, but my main career out of everything was +truck driving. I was pretty much a truck +driver. I drove all kinds of trucks and stuff +like that. Then when I met my current wife +back in '08 we had moved to North Carolina to +be by her family and that's when I acquired a +job with the North Carolina Department of +Corrections, and then I was down there for two +years and did that. +We moved back to New York, which is where +I went back to driving truck again while I was +in the hiring process for the Bureau of +Prisons. And then I ended up getting hired +with the Bureau of Prisons in November of 2011, +and I started at MDC Brooklyn. +: How long were you at MDC +Brooklyn for? +: Right around two years and + + +12 +1 +2 +3 +4 +5 +6 +7 +then I transferred down to FCI Estill in South +Carolina, and I was there for about two years +or 5o, got promoted to General Foreman and +transferred out to +ECC Hazelton, which is a +complex out in West Virginia, Bruceton Mills, +and I did a little over a year there and came +out to MCC New York in December of 2016 is when +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +I got to New York. +1: Was that your first --? +: Basically, worked - what's +that? +time at MCC? +1: Sorry. Was that your first +: Yes. Yep. +1: Okay. Go ahead. +: I worked at all three - the +worst three prisons in the Bureau of Prisons. +1: So with the BOP, once you got +to MCC in 2016 is that where you spent the rest +of your career with BOP at MCC? +: It was. I was there - I got +there in December of 2016, I think it was right +before Christmas and my last day on the job was +Valentine's Day of 2019. +1: Okay• + + +13 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +1: And I was there for that +amount of time as a General Foreman. +1: You --. +: Now was that February 14, +2019? +1: That's correct. +: Okay. Thank you. +: Yeah. +1: Do you recall your EOD date +with the BOP, exact date by any chance? +: Yeah, November 6, 2011. +1: Okay. And when did you +graduate from BOP training? +: I would have to look that up. +: It's okay. If you don't +remember it, don't worry about that. We just - +it's generic question we ask. +1: I was there for Super Bowl, +so if I got hired in November and I was in +Glynco for Super Bowl, I would say it had to +have been February of '20. No, I'm sorry, '12, +2012, yeah. +: So when you started with the +MCC you said you were a general foreman and +that was your position up until when you + + +14 +1 +separated from the MCC in February 14, 2019? +2 +1: Correct. +3 +: Okay. And what is your - +4 +after you left MCC, what is your current title +5 +and what agency do you work for? +6 +: I currently work for the +7 +General Services Administration Public Building +8 +Services, and I am a Building Manager. +9 +1: Okay. While you were at the +10 +MCC as a general foreman, was that your title +11 +in 2018 and 2019? +12 +13 +14 +15 +16 +17 +18 +19 +20 +1: General foreman was the +internal kind of phrase. I think the position +title officially OPM was Maintenance Mechanic +Supervisor. +: Hold on, let me write that. +: And I was WS-4749, Grade 14, +Step Five. +MR. I +: So official title is +Maintenance Mechanic Supervisor? +21 +22 +23 +24 +1: Correct. +: And who did you report to? +1: The facility manager. +1: Who was the facility manager +25 +at that point? + + +15 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: And when did Mr. +- my +understanding is Mr. +retired from MCC. +When did he - according to your recollection, +when did he retire from the MCC? +1: I would probably have to say +- I don't know the exact dates because his exit +was kind of unique. He didn't actually +initially retire; he went out on some kind of +other type of leave and eventually it's to my +understanding he ended up retiring. But when +he had went out all communication stopped with +everybody with him. Nobody - he never kept in +touch with anybody. He never reached out. But +- +1: when was that? +-- I really don't know what - +hey, I don't know his exact date, but I would +probably want to say that I was there for +almost maybe just under or right around of +another year after he had left. I don't think +it was that much because there was several +other people locally that had filled in +including me for his position. +: So you recall that other + + +16 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +people filled in his position while he was gone +while you were still there? +: Correct. +: Okay. So do you believe he +left in 2019 or 2018? +1: I really honestly couldn't +tell you. +I do remember --. +: I think what +is +trying to ask is not his official retirement +date but around when did he leave the MCC and +communication with him stopped. I think you +said -- +1: Yes. +: - it was approximately a +year before you left? +: Yeah. The only thing I can +tell you - I don't really know the dates. The +only thing I know from what I recall is Mr. +had just went to Denver, Colorado, for +some kind of facilities manager conference +training and he had never returned back to the +institution once he went to that training or +conference or whatever it was. It had +something to do with facility managers all +going out there. And all I know is that when + + +17 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +he went out there, he went there for a week or +so, and he never returned to the institution +after that. +1: Okay• +: It was • +: Do you know why he left, +what happened? +: I have no idea. I have no +idea. I couldn't tell you. I mean, there was +a lot of rumors, but I just know that when he +went to that training, it was like he went home +after that. He never came back to the +institution or that conference, whatever. +: Now, do you know if it +was personal reasons, medical, or +administrative? +: I have no idea why he didn't +come back although he did make medical issues +known to us on the job, that he had some +medical issues. +1: Okay. And you said a few +people filled in the position. So his title +you said was Facility Manager, right? And +what, was he your direct supervisor? +_: He was, yep. + + +18 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +1: Okay. And who does the +facility manager report to? +1: The Associate Warden of +Operations. +1: And who was Associate Warden +of Operations in end of 2018 if you recall? +MR. I +1: So we had three in the time +that I was there, and I believe +worked +under all three of them. So there was +, and then the last +one that was there prior to me leaving was +or +• They called him +but I believe his real name was +okay. +: All three of them had +performed - they were the AWO they call it, AW +of Operations, which oversaw the Facilities +Department, and that's who the facility manager +directly reported to. +1: Okay. And when Mr. +left the MCC and that's not when he retired, +let me clarify this, this is when he stepped +away for leave purposes, do you recall who took +over for him initially? +1: Yeah. So the warden at the + + +19 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +time which I can't remember which one it was +because there was so much staff that came and +went throughout this whole thing, that one time +it was the executive assistant who was told to +oversee the department, and then at another +time the AW oversaw the department. +1: When you say "executive +assistant" -- +1: (Indiscernible *00:17:56) . +_ : —- who was that? +: So he oversaw it for a little +bit? +next person? +: He did, yes. +: Okay. And then who was the +He was told to oversee it. And then +there was a little bit of a stint where, you +know, I could just informally absorbed a lot of +his job duties just to get the department +functioning, but I was never actually promoted +or paid or anything like that that actually - I +was never formally designated as acting of +anything like that, I just had to do some of + + +20 +1 +the facility manager functions in order to have +2 +the department operational. +3 +So I would get my go-ahead for - to do +4 +those functions. They would - they oversaw it +5 +or approved by either +or +6 +at the time. +7 +: So they gave you the go-ahead +8 +and you went ahead and completed the functions. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Do you recall when exactly this time period was +when you acted? +: I wasn't really designate - +I wasn't really acting, I was just - if I had +to do - if I had to get something done that a +facility manager would normally have to do, I +would just go to the - whatever time period it +was, if +was over the department or +if +was over the department, I would +have to go to them and say, "Hey, listen, can I +go ahead and do this? Can you give me the +approval, sign off on it?" and then I would +actually do the act. +1: Okay. Bear with me a second. +Let's see. Maybe this might help -- I have a +SigNet contract here, right? And it's multiple +questions will be on the SigNet contract -- + + +21 +1 +2 +3 +4 +5 +1: Yeah. +: - and bear with me. I'm +going to see if I can share my screen here. +This document that I'm showing you, can you see +it? +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +1: No. +: Why is this - how about now? +: I got something coming up. +Yep, I could see it. +1: Okay. So this document that +I'm showing you is - it says, "MCC New York." +It says, "Solicitation Contract Order for +Commercial Items Offered to Complete Blocks 12, +17, 23, 24, and 30." +- +1: Yep. +1: And it says, "Requisition +Number 1064-18." +_: This is just for the record. +I'm just reading it, just the top part, so we +know which document this is. The Contract +Number states GS-07F as in Frank-0322T, and the +Award Effective Date is 09/21/2018. Do you +recall -- +1: Okay. + + +1 +2 +3 +no. +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +22 +: - this document at all? +: I don't see that document, +: See over here. +: But it's not under the +facility manager one. I don't recall ever +putting my eyes on the document. +: This is part - Section 15. +You see over here? +1: Correct. +: And it's - it's says +"Delivered to Federal Bureau of Prisons MCC New +York" and lists you as a point of contact. +: Correct. +: Now, if we scroll down a bit. +1: Uh-huh. +: We're going to scroll down to +Page 6 on this document. +Correct. +: It lists you as the +facilities manager. Does this jog your memory +at all? +: I do. I was always - when +had left, I was pretty much assumed the +facilities manager. Like I said, I was never + + +23 +1 +formally promoted or even temporarily entered +2 +that position, nor was I ever designated as +3 +acting. So the fact that that says facility +4 +manager, I don't know why or who put that there +5 +because I was always a general foreman. I was +6 +never, ever in the role of a facility or with +7 +full title, whether temporary or permanent, was +8 +never a facility manager. +9 +: Okay. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +1: I was never even formally +designated as acting, they just pretty much +said, "There's no facility manager, +is +next in the chain of command," so they just +referred to me as it. That's what I'm assuming +whoever typed this up. +: I know it's been about three, +four years. I know it's kind of tough +remembering some of this stuff, that's why we +trying to pull - we try to pull documents where +we believe it could help you. +: Right. +: I know we have an email. I +don't know if this will help a little bit too. + + +1 +2 +This email right here, it says "Regarding +forward cameras from +to +." Who is that? +: He was, I believe, the +supervisor of the SIS Department at the time. +1: And was --. +: He was like the lead SIS +investigator. +24 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +1: Okay. And then we have +who is that? +: He was a communications +technician that I supervised in the Facilities +Department. +_: And we have +Was +that the executive assistant that you mentioned +before? +1: oh, correct, yep. +: And this is dated January 4, +2019. +: Correct, yep. +: And we'll go through the +email, but it says on the bottom, it says | +Is that - that's your signature, CESCO +General Foreman-Acting Facility Manager? +1: Correct. + + +25 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: So I know this is in January +4th. I know you mentioned you were always under +the title of General Foreman, but you were also +not officially acting, but you were still doing +the job. Does that help at all jog your +memory? +: Right. So an email went out +by the AW telling all the department heads that +when +had left that I would be running +the Facilities Department until a replacement +was found, hence why I would assume the acting +part went into my signature line. +: Got it. And do you know when +this email went out? +1: That looks like a month +before I left according to the date. +: No, no, I meant - you said +there was an email that went out saying - from +the AW saying that you would be acting --. +: oh. Oh, yeah, I don't - I +couldn't - it'd have to have been - it was +shortly after - it might have even been from +the warden if I'm not mistaken, which was +, because I remember whatever happened +with +down in Colorado and why he didn't + + +26 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +come back I remember that the Warden +was very, very upset with whatever was going +on, and I just remember somebody, I can't +recall exactly who - +came down to the +office, to my office, and spoke to me +personally and told me that he would like me to +just hold things down until they figure out +things, what was going to happen with +and see what was going to happen. +And then I remember an email going out +telling all department heads that I would be - +to see me for any facilities-related issues -- +1: okay. +1: -- because +was no +longer there. +: Okay. So according to this +you were acting facility manager, but you were +general foreman, but you were acting at this +point. And so, on record is it possible from +the time that when Warden assigned you the +title to when you left were you the acting +facilities manager - facility manager? +: So I don't - I would - +definitely not up until the time I left because +there was some butting of heads between me and + + +1 +2 +3 +4 +5 +6 +7 +8 +27 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +and D +at times where they +overrode a lot of decisions that I made that +I'm normally supposed to make underneath my +title. So -- +believe +_: Can you give us an example? +: - at the very, very end I +at the time was running the +department for the most part at the time that I +left. So it wasn't the whole entire time, it +was very sporadic. It was just constant change +of roles and responsibilities and - but I was +definitely at one point - like I said, it was +like a - it was just like an informal internal, +"Hey, this is +He's going to be the +facility manager until we figure out what's +going on," and they fill the position, which +they had not since I walked out the door. +: So basically - my +understanding from what you're saying is on --. +1: But I guess what you would +say is during this time period I would be the +guy who would have - if anybody had any +questions or concerns involving this contract, +they would had to have I guess come to me, +yeah. + + +28 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +1: Okay. Now, do you remember - +I know you mentioned that the previously. Tell +me, do you recall if there was an update or +upgrade of the camera system going on in - at +the MCC in 2018 or '19? +: Prior to this right here? +: Well, ignore this document +for a second. Give me - hold on, let me see. +We'll come back to that document. Do you +recall in general was there an upgrade +happening at the MCC for the camera system? +1: There was an upgrade that +started with +: okay. +1: There was - from what I +understand there was camera issues well - going +way back well before I even got there, long +before +even got there. They had +recorder and decoder issues. There was a whole +slew of things and I would assume - I would +imagine it was probably due to the age of the +institution and there was very little +infrastructure upgrades and updating and stuff +like that. But I remember prior to, you know, +me inheriting what +• started, there was + + +29 +1 +all kind of issues with the cameras from what I +2 +heard from internal communications and stuff +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +like that. +So +I started this program, this +project, at the request of higherups. I don't +really know the backdrop on that, that was in +between them. And then I really did not get +involved with it at all until he never came +back to work. He dropped off and then I just +picked up after him. +: I kind of missed a key point +I wanted to ask. So as a - can you +differentiate the job duties between a facility +manager and the general foreman? +1: So basically, the facility +manager they keep track of the budget. They +authorize expenditures. They obviously +supervise me, and then I in turn supervise the +subordinate staff, the wage grade trade guys. +But basically, he handled the approval of +projects, you know, submitted approvals for +projects. +He did, like, the five- and 10-year +plans for the facility, authorized all the +expenditures. He went ahead and sat in on all +the department head meetings to give executive + + +30 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +staff briefings on what's going on in the +department, progress reports, stuff like that. +Listen to any concerns that they would have and +then he brings it back to us. +And in my job, my main job by title is +literally - I was in charge of supervising, +monitoring, and then the wage grade guys that +were below me because I was also wage grade. +The facility manager is a GS employee. I was a +WS employee just like the rest of the trade +guys. And my job was basically to supervise +them guys, assign them work, make sure they +were coming and going in the facility with the +inmates, make sure that they were handling +their tools and all that other stuff. I did +their performance evaluations and all that +other stuff. And the facility manager pretty +much did all that on me. +So he was my supervisor. He would +evaluate me, you know, keep track of my time +and all that other stuff. And that's pretty +much it. +: Who were some of the +employees that reported to you? You said the +wage employees. Who were the employees that + + +31 +1 +2 +3 +4 +5 +6 +7 +8 +reported to you? +: In the Facility Department it +was the trade specific wage guys, so you had +the communications technicians, engineering +technicians, carpenters, plumbers, +electricians, HVAC guys. And then each one of +those tradesmen have a cadre of inmates that +work for them, so I would go ahead - work +orders would come in from all departments, you +know, requests, "Hey, can you change a light +bulb? Can you unclog the toilet here?" I +would give that work order to the appropriate +trade guy and then he would take his group of +inmates and go out into the institution and fix +it and close out the work order, report back to +me. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +1: okay. Agent +any +questions on that before I move forward with +the contracts? +Yes, I'm just writing +down some follow-up questions. So just - can +you just clarify again, when were you actually +the acting facilities manager? +: It was whenever they wanted +me to be basically. It was sporadic and on and + + +32 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +off, so -. +: Yeah. I got it. You +said, like, when Beckham or +departed +they put out an email and then we saw an email +that was from January of 2019 that said that +you were acting facilities manager but then you +said you weren't. +: Well, it was in my signature +line the acting facility manager, so I think it +was just never - I think I rolled with that +since +left. I think that acting part +just stayed in the signature line. But there +was -. +After they made the +notification that you were the acting facility +manager, did they ever tell you that you were +not the acting facility manager? +: Yeah, that's why I was saying +it was - I bumped heads with executive staff +sometimes because I thought a lot of the +decisions that they were making weren't in the +best interest of the facility at the time. And +when I say that I mean, like, infrastructure +stuff, you know. And I kind of like - they +didn't like the way I prioritized certain + + +33 +1 +things within the department. +2 +So there was some conflicts every now and +3 +again and that's why the warden would go ahead +4 +and say, "Okay. Hey, +, you know what, +5 +you're overseeing the Facilities Department +6 +now. Have +I report to you." And then they +7 +also did the same thing with +at one +8 +point where he came in, which was right around +the +thing and where he was told that he +10 +was going to go ahead and - so they were like +11 +dual role. They were pretty much - your +12 +executive assistant and the facility manager +13 +and then your AWO and the facility manager. +14 +: So were you still the +15 +16 +17 +acting facility manager and they were just +overseeing what you were doing to make sure +that in your acting capacity you're doing it +18 +19 +20 +21 +22 +23 +24 +25 +right? Or they --. +: That's up to interpretation. +I didn't have any decision-making power. It +had to all go through them - +But --. +1: — while (Indiscernible +*00:34:33). +But at least in your + + +1 +signature line you maintained the acting +2 +facility manager? +34 +3 +4 +5 +: I guess. I guess I just +never took it out, yeah. But -. +But was there ever +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +anything official that went out, like there was +an official email saying you're the acting +facility manager. Was there ever anything that +said you're no longer the acting facility +manager or - you know what I'm saying, like --? +: Yeah, no, not to my knowledge +there was - because there was talks because +they were dragging on the hiring of a +replacement facility manager because +case, whatever he had going on on his personal +side with the Bureau they couldn't fill the job +until they finalized what was happening with +him. They needed like, I guess, an end date or +something like that. They needed to know when +was falling off the books in order for +them to re-post the job. +So there was never - it went on for so +long. Like I said, it was from the point that +I had walked out the door there in February of +'19 there was still no facility manager there. + + +35 +1 +2 +3 +4 +5 +And I also know at the time that I walked out I +may have not took the word "acting" out of my +signature line, but I know I wasn't acting at +that time that I had left per se. +And I don't recall ever an official email +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +going out saying where I was acting. I +remember an email going out saying to all +department heads that +was no longer +around and if anybody needed anything from the +facilities department to see me. +Now, were you -. +: (Indiscernible *00:36:07). +: Through the whole time +were you a part of these meetings that you said +that the facility manager would be a part of? +: Some of them, yes, I was. +Yep. +: So until the time you +left you still were sitting in the meeting the +facility manager would sit in then? +: I was even in those meetings +when the facility manager was there. We all +sat in together. +: Now, would you have been +sitting in those meetings if you were just the + + +1 +general foreman? +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: At his request if he wanted +me to or even if one of the executive staff +wanted me there. It all depends on what they +would have discussed at that time. +*00:36:44) --? +*00:36:45). +: Did you (Indiscernible +: He could choose. So the -- +(Indiscernible +: —- facility manager could +choose to have me there, or he could say, "I +got this. Don't worry about, you don't got to +come." +: So when you were - at +least, you know, from the time +left +until February, were you automatically assumed +to be in those meetings or you'd have to be +invited to each individual one? +: It's kind of like both. I +expected myself to be there because somebody +had to represent the department in there, but +they also put out a roll call sheet prior to +those meetings and if I saw my name on it, I +went. +36 + + +37 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +And was your name on it? +1: Not always, no. +: Okay. No, I'm just +trying to get behind were you acting and then +you just had someone overseeing you or - yeah, +I'm just trying to figure out how because we're +-. +: I always had somebody +overseeing me, always. +Right. +: Because even the facility +manager had somebody overseeing him, so. +: But if you were going to +write your resume would you say that you were +acting a facility manager for that time? +: No, because it wasn't +official. +So if well --. +: well, I --• +I'd say that was +official. +: I don't know what an official +is really. +Yeah. +: I couldn't be honest with + + +1 +you. +2 +3 +4 +5 +6 +7 +8 +38 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: No, if you're acting, if +they sent out an email, I would say that's +pretty official saying that you're the acting +facility manager and you could put it in your +signature line. I mean, there's not like --. +: I would normally and I +thought so, but I also found out also that if +you're, like, you know, not temporarily +promoted into it and stuff like that and you're +not getting paid to do the job - but like I +said, I do remember emails going out, I just +cannot recall if the word "acting" was put into +it or not and if the word "acting" was in it, +but I don't know if I ever recall that or not. +I mean, there +was several times where it +would go out because +called in sick or +he went on vacation. I just don't recall if it +was ever done when he went off permanently. I +don't know if that was ever --. +: Would it be a fair +statement for us to say that you were acting +facility manager with oversight? Would that be +a fair --? +1: I -. + + +39 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Or just tell --. +: I guess so. +: We just have to document +it in our reports of, like, you know, what this +person's role was from this time to this time. +So in order for us to be clear, I want to make +sure that we're not writing something that's +inaccurate. It's nothing -- +1: Yeah. +: — to do with, like, +you're, you know - you know, this is just for +our report writing purposes we can say, you +know, " +went out, you were the acting +facility manager from this date until, you +know, February 2019, and then, you know, you +clarify that you had oversight from the +executive staff in your position and were +limited with your facility manager decision +making ability." +Would that be fair? +•: Right, because if regardless +of whether I was acting or not and whether I +had oversight or not, the mere fact that +was not there, I still had to do a lot +of his duties to keep the department +functioning whether somebody deemed me + + +1 +officially acting or not. +I was still doing +2 +his functions because he was not there. +3 +: Okay. +4 +: Under oversight from +5 +executive staff. +40 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: Yeah, that sounds like +acting to me, so I just want to make sure that +we are clear there. Like you're just saying +you're not acting because you weren't official +- you know, you weren't temporarily promoted, +but you were performing those duties with +oversight. +1: They would - like I said, he +would call in sick and not come into work for a +couple days or go on vacation, so he would put +out an email to everybody in the institution +saying, +is acting facility manager +for the time that I'm out." +: And +: And would you --? +himself, the +facility manager. +going out in 2018? +: Oh, prior to +: He would - if he wanted to +take a week off and go somewhere, he would put + + +41 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +out an email letting the institution and the +executive staff know that " +will be +acting in my capacity while I'm out." +Happened +all the time. Same thing like me, I would do +the same thing and I would designate one of my +subordinates as acting for me if I went out. +But I do believe that at some point some +kind of email went out by one of the executive +staff after +left that everybody should +come and see me for all facility-related issues +till further notice. And like I said, +came to my office right after we had found out +that +wasn't coming back shortly after +that Denver trip and he told me that I would +have to run the department until they figure +out what was going on with him, which was top +secret and nobody knew anything. They didn't +know nothing, couldn't tell you. +: All right. Go ahead, +: Just to clarify. After you +had that meeting with +is that when he +sent out that email? +1: I don't think - I don't know +if he was the one that sent it out, I can't + + +42 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +recall. I just know some kind of email went +out for the department heads and it was also +brought up in one of the meetings reminding +people that +was no longer there and +that if they had any facility-related issues +I +was the one - I was the POC. +MR. I +: Okay. Now, is it okay - I'm +going to move forward in the topic. Now, +during that time period do you recall during +your tenure after +left and before +left, was there a camera project that +was started at the MCC? +: It was there. It was already +started. I believe when I had gotten there, +they were still doing market research and stuff +like that. +: Is it in 2016? +: What's that? +: You said when you started, +you're talking about 2016? +1: There was talks of - there +was already camera issues I guess had going on +when I had gotten there. +i Okay. +_: And I believe - well, it was + + +43 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +December of 2016, so nothing happened in '16. +I think, you know, because I was - I got there, +like, the week of Christmas. So going into +'17, I know that there was talks about - it +wasn't so much on the cameras, it was on the +recorders. There was always constant internal +chatter between the comm techs and SIS and +everything else on how - I guess they had an +older system that was analog and everybody else +had digital, but their main gripe was, I guess +- and I'm not too familiar with the security +side of stuff, I'll be honest with you, I +always refer to them when I needed a question +answered, but from what I gather, what I +understand, they weren't able to go back in +time on the recorders as far as they +experienced, I guess, with other institutions. +So there was no secret that there was +cameras that were not working throughout the +facility. Like I said, that was a dead horse +from what I understand. They were dealing with +broken cameras long before I had even gotten +back there. And this recorder issue for +whatever reason evolved and turned into camera +issues, you know, and exposed the entire + + +44 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +infrastructure eventually. +: So you mentioned there's two +issues. There is one the - there were actual +cameras that weren't recording, I mean, +cameras +that weren't working. +: Right. +: That means there was no live +feed, there's nothing recording either because +the cameras itself were broken? +: Right. So the - from what I +understand you had a combination of two +problems there. You had some cameras that +legitimately were not working. They just - +there was no communication. There was no +nothing. And then you had other cameras which +were in certain cells up in the Special Housing +Unit where whether they were working or not, it +was to my understanding that there was a lot of +damage being done to them by the inmates that +were in those cells. So they were either +scratching the lenses on the cameras, covering +up with wet toilet paper or whatever the case +may be. +I, myself, I couldn't even tell you if +those cameras were ever working. I only knew + + +45 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +of one camera in the Special Housing Unit that +worked for the cells for the ranges and that +was, like, one suicide cell that they had there +on J-Range. But I don't - it started out with +me, the recorders were the issue, and then they +were like, "Oh, okay, we're going to go ahead +and spend this money and fix these recorders +and get these - this conversion from analog to +digital, let's suck in the cameras too that +don't work." +But I can tell you that I know that SIS +was constantly going to the comm techs all the +time because they were doing investigations and +had no camera footage. It almost seemed like +(Indiscernible *00:45:47). And obviously this +was long before the Jeffrey Epstein thing +because, you know, I had even left the +institution before Jeffrey Epstein got there. +This was just for, like, smaller internal +investigations that they were doing where they +were constantly going to +for the camera +footage issues. +And the determination was made by +and the higherups, I guess, and they said, +well, if we're going to go ahead and change + + +46 +1 +2 +3 +4 +5 +6 +7 +8 +this recorder why don't we just go ahead and +try to upgrade everything, get some new cameras +inside and out. And they even wanted to add +cameras to the existing complement because they +had a lot of blind spots and then obviously the +infrastructure itself, like the wiring and the +conduit was all part of that deal. +: In your knowledge in 2018 and +in '19, how many cameras were there inside the +MCC? +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: I couldn't tell you honestly. +There was a lot, but there was also a lot that +should have been there. +But I do remember +had a map of where every single - preexisting camera was in the institution and I +believe the conm techs also had an inventory +tracking sheet, because each one of those +cameras had an asset number assigned to it -- +- ray. +: -- that was in the MTMMS +Maintenance Management System. +: What was that --? +: So - it's on the Maintenance +Management System, the --. +: MTMS? + + +47 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: TMS, yep, Total Maintenance +System. So, you know, all that equipment was +in there, so you should be able to pull the +report out of there. +That would list all those +cameras including any asset numbers assigned to +the associated components that's maintainable. +If it's something that's maintainable and could +be repaired and it's not like a throwaway. +We +call it run-to-die. If it's maintainable, +reparable, it's worth putting money into it, +it's in that system. +1: Okay. So in the SHU, do you +know how many cameras were in the SHU offhand? +1: No, because it was very +inconsistent because it was to my understanding +certain cameras were added throughout the years +for certain specific reasons. They would +designate certain cells for certain purposes +and then they would cancel that purpose and +convert it back to a regular cell. I mean, it +was just the constant changing of the +operations that changed the cameras, and that +was just obvious without even knowing the +backdrop because you could tell just by the +cameras there were so many different makes and + + +1 +2 +models. They weren't all consistent. They +weren't all consistent. They weren't the same +3 +for the most part depending on what area you +48 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +were in. +1: And so, this is - +1: So SHU --. +1: -- in the SHU you're talking +about? You're not talking about 10-South? +We're talking about between G, I, J, K, I, M, I +that's inside the SHU? +: Yes, those for the SHU, as +far as I know those were all there pre-existing +before me. There was never no camerawork done +up there, whether they were working or not. +1: But you just mentioned they +were adding cameras and taking them out. +: Yeah, but I was talking +institution wide -- +Okay. +: - not just - yeah, not just +SHU, you know. It was institution wide. +: So let's get back on track. +We talked about the fact that +started a +project and the project - what did that project +for the cameras entail? + + +49 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +done was +1: So I really - for the project +the way it was designed, the way we wanted it +had put this package together. +We were going to get - he had the map of the +cameras I was telling you about. So we were +going to upgrade the existing cameras, add new +cameras because • +took this map, brought +it to the executive staff and to SIS and they +said, "Hey, listen, this is what we have now. +We're going to go ahead and try to get this +project. Where do you need cameras?" +So they did a tour around the institution +and they went ahead and they asked to have +other cameras placed, like on certain ranges +that didn't have any coverages. There was, +like, a little mini IV rec room in the housing +units that had no camera coverage in them. +There was a lot of blind spots in certain areas +throughout the institution. So they went ahead +and they added what they wanted to add. +But then also because the recorder was +getting upgraded, the infrastructure that was +in place because it was analog, obviously it +was going to go to digital, they had to run new +wiring, new conduit. All that had to be done. + + +50 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +So under that contract, last I remember +walking out that door, what happened was it +came in over a million dollars originally and +somebody came back and said, "Listen, we need +to get this to 800,000 or lower." Somebody +threw out a number there, I don't remember who +it was. It came through +and somebody +up top said that because of some kind of +procurement avenue or regulation or something, +they would've had to go through a whole +different procurement avenue because of that +amount. They said to make it easier and to try +and increase our chances of getting this money +and getting it done, we had to bring the number +down to like 800,000 or something. I don't +remember the exact number. +So then the decision was made because +originally we did this contract, whoever we +were purchasing the cameras from, they were +also supposed to install those cameras. We +paid for the labor for them to do the entire +project initially. My guys weren't going to +touch anything, they were just going to provide +support. So the initial $1 million number was +to have the contract SigNet, I guess it was in + + +1 +that contract, whoever we were getting those +2 +cameras from, they were going to go ahead and +3 +do the install and we would supervise them, +4 +escort them, and give support when they came. +5 +So when they came back and told us that +51 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +that number needed to get down below 800 or +whatever, that's when the decision was made to +where they said, "Okay. We can do this. We +can just have the contractor install the +cameras and we can use the trade guys, the +electrician and the comm techs to run the cable +and the wiring to save on the labor, to bring +the labor costs down to try and get into that +number." +And that was the last - that's how I left +off. That's how the project was supposed to be +done, because when I was there, my last year +that I was there for the better - for the +second half of '19, well, '18 into "19, the +electrician and the comm techs had already +started running conduit in the housing units +and stuff like that. They had already begun to +hang conduit. But I could tell you from the - +right up till I walked out that door there were +never no cameras or even wiring for that matter + + +52 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +in that institution. +They were never there. +: So we'll come to that. So +that's some of the questions I have. I'm going +to share -- +1: okay. +1: -- back my screen. Do you +recall if this was the contract that was +awarded? It looks like it states on Line 17A. +It's the same document I showed before. +1: Yeah. +: This says SigNet Technologies +and it's to Federal Bureau of Prisons. And if +you scroll down to page - looks like it's Page +4, it lists the schedule of supplies. +1: Yep. +: What was - were these the +items the contract listed and does the contract +through SigNet all the purchase of all the +items for the upgrades inside MIC? +, can you scroll +back up there because I want to make sure it's +the right institution on this? +: So this one - yeah, don't +look at - this - what you see FCI Fort Dix +(Indiscernible *00:54:15). I must clarify. + + +53 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +FCI Fort Dix handles all the payments on the +East Coast. +oh, okay. +1: Yeah. +Sorry about that. +1: They do all - they did all +the contracting for MCC New York and MDC +Brooklyn because they didn't have in-house +contractors at the facility institutions. +1: So --. +And I see below it says, +"Delivery Date September 28, 2018, MCC New York +Camera System." +: Yeah. So that's --. +: Okay. +: I'm going to come back to +that part too. So over here, this is all the - +these are all the technology, well, the pieces. +Let's go through it, just - we'll go through it +quickly. It says for this license, the single +license for Nice Vision Enterprise package +audio channel, it looks like Vision Smart Hub +Recorder. This might be the recording system +that you're talking about, Mr. +? +: I would - I guess so. +I'm + + +54 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +going to guess. +I'm not a comm tech. For now, +I'll say yes. +1: No problem. And there's a +recorder (Indiscernible *00:55:04) licenses and +then it looks like a package major version, +then we got the decoders. +We got the AMS and +Nice Vision supporting 16 cameras, the IP +cameras. Now, you mentioned that this - if +this is the contract that was awarded, was the +plan to replace every camera inside the MCC or +replace only certain cameras? +: I was under the impression it +was every camera we purchased for them, so if +you're looking at that Line Number 9 where it +says SigNet labor for a quarter of a million +dollars -- +•: Uh-huh. +: — they better have installed +every damn camera because that was my +intention. That's what I was - thought I was +paying for was +-- +: So they're replacing - +1: -- every camera - current +camera in the MCC plus adding additional + + +1 +cameras? +2 +: Correct, yep. +3 +: And the total here says +4 +698,108, and what you mentioned a little while +5 +before was initially the contract was over a +55 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +million dollars and your understanding was this +part right here, this SigNet labor was much +higher and the idea, the proposal that came +around was to get rid of the SigNet labor in +terms of the conduit, wiring, the wiring, to be +done by in-house comm techs and electricians so +that this labor -- +: Right. +: — cost of whatever the total +was would come down and would be below the +$800,000 mark in total? +: That was my - I don't know +what the numbers exactly were but that was my +understanding was that in order to drop that +quote down, we had to cut back on - they just +said, you know, "Let's go ahead and cut back on +the labor on the wiring side, " which is why the +guys started running conduit in-house on their +own because it was to my understanding that's +what got cut from the contract. + + +56 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: Okay. And you wouldn't +happen to recall offhand what the initial +SigNet labor proposal was, right? +_: I just remember the original +first estimate that went out came back when +was still here was like over a million +dollars. +: Okay, the total. Okay. +1: The total, yeah, uh-huh. +: And based on this, it 1ooks +like Line 8 it shows IP cameras. It looks like +the quantity is 135. Then it says the Corner +VEN cam. That looks like there's 75 pieces. +So you're looking at over 200 cameras in total +that was ordered. +: Yeah, I would say so. Yeah. +: One thing I don't see in here +- well, maybe you can explain it since I don't +see. +Do you see the order for the conduits in +here, the wiring? +1: No. +1: But if that was part of the - +- +: But if -. +1: Who was supposed to provide + + +57 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +that? +: You have - so I believe - we +had a lot of conduit left over at Building 4. +It was a warehouse that we had in Brooklyn that +belongs to MCC New York. It's like their food +service warehouse and facilities had a storage +and I guess they had a whole bunch of conduit +there from a surplus from another project, so +they started bringing that stuff over to the +institution and using +that. The wiring I +believe was purchased separately through - I +don't remember the company's name. The comm +tech would know because he did the order, but +we purchased that through - what is the website +where you buy stuff from GSA? +: I'm not sure. I'm not +familiar with the purchasing department. But +it was purchased through GSA according to your +memory? +I: Well, it's a website GSA has. +something? +: GSA Advantage or +: That's it. Yeah, so all +these companies sell their stuff on this GSA +website, GSA Advantage, and I know all of the + + +58 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +quotes for that wiring and stuff came from +vendors off that website. That's where were +. - +it was eventually purchased through a separate +procurement I believe, if it wasn't part of +this, I can't even recall. But I do remember +the shopping for the wiring being done on GSA +Advantage through a vendor there. +: Okay. This might sound like +a --. +: I just don't remember. +: Sorry. This might sound like +a dumb question. +: I just don't remember. +: What's the difference between +a conduit and a wiring? +_: So the conduit is the metal +pipe that you see running across or up and down +a wall that runs into little junction boxes and +the wiring just runs into it. +1: So --. +: Runs through it. +: So that's a protection, the +conduit, it's an actual protection over the --. +: Yeah, yeah, it's metal or it +could be PVC, but obviously in the institution + + +59 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +it was metal and you run the conduit and you +run the junction boxes and everything and then +you pull your cable through it and it's +basically a protective housing to protect the +wiring and keep it from being exposed. +1: And according to your memory, +do you recall whose decision it was to have the +in-house staff do the conduits and the wiring? +: It came down from the +executive staff, but that was discussed, jeez, +I can't even remember. That was back when the +numbers started flying in and they were trying +to find out ways to bring the numbers down and +everything, but it was somebody higherup that +made the decision to try and cut there on the - +when they saw how much the labor was, they were +like, "Well, maybe we could cut back on the +labor," because it was my goal that if they +were going to spend this kind of money, you +might as well have the contractor do +everything. +got killed because they saw the number and +wanted to cut some fat and - but --. + + +60 +1 +2 +3 +4 +5 +6 +7 +8 +1: No problem. +See on the +bottom, it says - it was - the document +"Signature Offer Steven +" It looks like +you signed on 09/21/2018 and that's - he works +for SigNet Technologies. And Line 31A that's - +1ooks like U.S. Government, that's Freelon +Peyton (Phonetic Sp. *1:01:38), and that was +signed on 09/21/2018, and he's a Section Chief +FAO. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +1: Yeah. +: And the delivery date on Line +20 up here, it says, "Estimate" - well, I don't +know if it's estimate, but it says, "Delivery +date is on 09/28/2018." It says, "MCC New York +camera system: provide services in accordance +with SFS, SoW, and technical proposal." And it +looks like GSA, GSO7F-0322T. It looks like the +contract number's in here too. It looks like +based - looking at this, the contract, the +estimate was - I mean, the contract states that +the delivery for all that equipment and +everything that was ordered was scheduled to be +delivered at the MCC on September 28, 2018. +According to your recollection, do you +recall if all these items were delivered to the + + +61 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +MCC in September 2018? +1: Can we go back to when this +contract was drafted? Okay. So you see here +where the award was 09/21? +1: Yes. +1: And then the delivery date is +09/28, that's a week. There is no way, no way +- I'm not even going to - I shouldn't have to +go any further, but I'm going to do it anyway. +There's no way you could deliver a product like +that - the install alone if the contractor +would have did it would have taken well over a +year. Just the install alone for that kind of +equipment if they were to do everything soup to +nuts on their own, conduit and everything, +would have took a year. +: But is it --? +1: So -- +: Where is the equipment coming +from? +: -- I'm thinking that that +delivery date is the date they delivered the +contract to the contractor because there's no +way you can award a contract and expect to have +everything that's in that contract in seven + + +62 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +days get done. Delivery date I think is when +they delivered the contract to the contractor. +But to answer your question, as of February 14th +of 2019, my last day there, there was not a +single camera on-site there -- +1: Is it possible - +1: -- because +-- +1: - the cameras -- +I: What's that? +1 : — were delivered without +your knowledge? Is it possible the cameras +would have been delivered without your +knowledge? +: That place, absolutely. But +I could tell you this much, two things wrong +with that. Number one, it was my impression +that the contractor when they received all the +cameras and got all the cameras in stock and +everything was on-site and they had all the +equipment on-site and everything was in stock, +they were bringing it with them. I didn't - I +don't know if they were going to dropship that +or not and have the stuff delivered directly to +the institution and then come afterwards. But +even if that was the case, somebody would have + + +63 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +to had gone to the rear loading dock where that +stuff comes in and there's a logbook back there +and they would've had to sign for that delivery +and it would've had to been somebody in the +facilities department. +1: So you're under the +impression that - when you say "contractor," +you're talking about SigNet? +1: Yes. +: So you're under the +impression that SigNet was supposed to bring +all that equipment with them when they come in +to install? +1: Correct. +1: So you're not sure --. +: We paid them to install it, +so to me contractually wise there would have +been too much liability there to have the stuff +shipped directly to the institution and then +call the contractor up and say, "Hey, come in, +all the stuff is here," because if something +was missing or broken, because the contractor +didn't have chain of custody of that equipment +the whole entire time, they could blame us. We +had a lot of liability on our hands and we + + +64 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +would still have to pay the contractor +regardless. We wouldn't be able to hold them +liable for any damages as far as that goes. +So my impression was when we did this +everything was going to go to SigNet or SigNet +was purchasing it and when everything was inhouse they would come and bring everything with +them and install it. +1: I have an email here. I'm +going to show this to you. This email is from +Justin Houston. He's a program manager for +SigNet Technologies and -- +1: Yeah. +: - this is addressed to me. +It says, "I wanted to send this to you in +regards to the questions you asked." This is +dated October 1st, Friday, 2021, and this is -- +MR. I +- +1: Yeah. +: -- from Justin Houston to +myself. And he states, "Hey, +- I wanted +to send this to you in regards to the question +you asked regarding if they had new gear onsite. Attached is the PO that we received on +09/21/2018. +The gear was delivered around 30 +days after that and on 11/01/2018 I sent over + + +65 +1 +the paperwork for the site to submit for the IP +2 +addresses needed to install the system. I will +3 +forward the email traffic as well." +4 +It looks like based on what he stated - +5 +let me see if I can get this. Actually, this +6 +is the contract itself. It looks like he's +7 +stating that by 09/21/2018 that's - the +8 +contract was signed, and it looks like within +9 +30 days all the gear was delivered. But you're +10 +stating you don't believe the gear was +11 +delivered? +12 +1: Nope, not at all. +13 +: Is it possible that he was - +14 +now you - based on what your statement, you +15 +believe the gear might have been delivered to +16 +them. +17 +18 +19 +20 +: Well, that's my problem is he +doesn't clarify what gear means. I don't know +what gear means. +Does gear mean just the +cameras? Does it mean just the wire? Does it +21 +22 +23 +24 +25 +mean the entire contents? I don't know what he +- does it mean just the recorder. He's not +clarifying what gear means. +1: Okay. +soing back to what I sald, i + + +66 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +could tell you that unless somebody signed for +something without my knowledge and didn't tell +me about it, there was no cameras on that. +There was no gear. They were just hanging +conduit when I leave there and that was conduit +that we owned that we didn't even purchase. It +was already there. +So +--. +: If gear was delivered, where +would it have been delivered to at the MCC if +the items - all these items were delivered? +: So it would've had to gone to +the rear dock. The rear gate they called it. +And then there's a Shipping and Receiving +personnel there, staff, and they have a big +cage that's in that loading area, so all the +deliveries go in there +and then they would +write down who had deliveries, call those +departments and say, "Hey, you need to send +somebody to come pick up your stuff. You got +stuff here." So whoever that person was to go +there to pick up the stuff would have to sign +the logbook saying that they picked up the +stuff. +But you're talking about a truck loading +stuff that wouldn't even have fit in that cage. + + +1 +It would've been like pallets and stuff like - +2 +it would have been huge to store that stuff. +3 +It would've had to have, you know - and then, +4 +you know, it's all electronic stuff. That's +5 +why I don't recall that stuff being delivered +67 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +prior to the - but I was under the impression +the contractor was coming with that stuff. I +was not under the impression that that was +going to get delivered separately, and if did +it wasn't to my knowledge. +I never saw a single new camera while I +was there or recorder or anything like that and +somebody would've had to have signed for that. +And then we would have had to have - there +would have had to have been inventory taken to +put that in storage and somewhere in the +Facilities Department. +So like I said, going back to the +contract, they awarded it on the 21st and wanted +it done by the 28m, that's just totally +unrealistic and irrational. I don't - +: Now -- +-- see that. +- if the things that you +purchased from them, would have that been the + + +68 +1 +material as well that your staff members would +2 +have been using to run the conduit and wiring +3 +and things? Is that part of that purchase +4 +order or is that something you were going to be +5 +receiving yourself and --? +6 +1: So I was under the impression +7 +that SigNet was going to wait until they had +8 +all their equipment, wherever they get it from +9 +or whoever they're buying it from or who their +10 +supply is, when they have everything they need +11 +to do the job that's within the scope of work +12 +13 +14 +15 +16 +17 +of the contract, they were going to come onsite with everything and begin doing the work +themselves. The only that -- +18 +19 +20 +21 +22 +23 +24 +25 +: I thought you --. +: -- my guys --. +: I'm sorry, go ahead. +: The only thing my guys - +yeah. The only thing my guys were going to do +was install the conduit. The wiring if I +remember correctly was purchased separately +through that GSA Advantage website and it was +through - I remember it was through a vendor +that they had purchased from previously in the +past, the comm shop, for regular supplies and + + +69 +1 +2 +3 +4 +5 +6 +7 +8 +stuff. It was just like a regular +cabling/wiring company that had a GSA schedule +on that site. And that would have been +delivered directly to the institution. +: I apologize. I have one more +email. I'm going to share this with you too. +1: Okay. +1: This is Anixter IP-120, 240 +and SigNet Tech. This is from +to +- there's a whole bunch of names: +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +,, the people listed. It's dated on April +1, 2019. Subject is Anixter TP-120, 240, and +SigNet Tech. It says, "Good afternoon, Ms. +• After reviewing my CORS Report for the +Central Office supplies +samples, I went ahead +and asked I. +our comm tech on the status +of these particular PO's and he advised me that +they haven't been able to receive the fiber +cable and without the cable they cannot - they +can't proceed with the camera systems. He +mentioned that the company's requiring some +sort of documentation and he would be - he +should be able to provide you with the details. +Sincerely, +• Financial Program + + +70 +1 +2 +Specialist, U.S. Department of Justice, BOP." +Now, does that help clarify anything? +3 +4 +1: Yeah -- +: I know this is --. +5 +: - it just tells me that - it +6 +verifies what I said, that there was no cameras +7 +8 +or wiring or anything on-site there at the time +that I left. It was just not there. But it +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +also makes sense that if these - the wiring +isn't there, they can't hook up the cameras. +But what got me - where I'm concerned, I guess, +with this is who were they talking to here +because this would have +to be a problem with +SigNet. If SigNet's installing - connecting +the wires to the cameras and everything like +that, I don't know +who they're really +addressing in that email. +: It 100ks like it's more +internal email, right? And they're trying to +figure out what exactly - why the camera +systems have not been installed yet. It 1o0ks +like +told them that the status +of the fiber cable is not in, like the fiber +cable or cables have not been delivered, right? +I'm sorry. And without the cables they can't + + +71 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +proceed with the camera systems. +: Well, yeah, that's cause and +effect. Yeah, so that's accurate as I read it. +The fact that it's three years since I left +there and there's still no wiring there is kind +of intriguing in itself. +: Well, this is 2019. This is +like a couple months after you left, April 1, +2019. +: Oh, I got you. Okay. Yeah. +: So that Anixster, would that +be the company? Would that be one of those +companies that provides wiring? +1: Possibly, yeah. I guess so. +I'm not -. +• I just sent you +an email. Can you just share your - or scroll +down to the second email and just - so that +maybe this will help -- +1: Bear with me. +received and what wasn't. +- clarify what was +1: Okay. Share your screen. Is +this the - you want me to scroll all the way +down? + + +72 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +No. It would be the one +that says - what I sent you was the - did you +receive what I sent you -- +: Sorry. +- the email from +? It was from Nobile - +: oh, it's on the bottom, okay. +-- to +-- +: Yeah, it's on the bottom of +that. +- that -. +: Right here. +: That's it. Not on the +bottom. It's middle. +1: Right here. It's in the +middle. So this is an email documentation from +, that's +dated -- +1: Share your screen. +1: Oh, I apologize. I thought +it was shared. Sorry, go ahead. Can you see +that? +1: Yeah. +1: We're talking about this part +right here. + + +73 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Correct. +1: It says, " +I didn't +want to leave you hanging, so this is what we +know so far. It appears that FedEx might - +must recycle tracking numbers. The order was +placed on 09/27/2018 from SigNet to Qognify. +Nice and Divisional PO shows it was shipped +directly to the site, MCC New York. It shows +that it was scheduled to ship on 09/30/2018 +from lognify. We currently don't have the +tracking that shows when you exactly received +it but best guess is seven to 14 days, which +would put it on your dock +around October 14, +2018, and it was installed the week of August +16, 2019. We will try to continue - we will +continue to try and find the tracking +information for when it actually hit your dock. +Let me know if you need anything else." +: Yeah. So that was going to +be my next question is: Where is any tracking +information on this? And then if FedEx does +recycle tracking numbers, that's definitely +news to me. But also, when this email - what +are they saying they shipped? +: It looks like it was a + + +1 +question about the camera system that was on- +2 +site at MCC. They're talking about +3 +specifically the camera system that was sent +4 +from SigNet -- +5 +: It doesn't say that. It +6 +doesn't say that. It doesn't tell them what +7 +they're - it doesn't even - forget about the +8 +fact they don't have no tracking - it doesn't +even say what they're talking about other than +if we could identify what the - I don't even +know what that lognify stuff is. That doesn't +74 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +even look familiar to me. +: So lognify is the company, +the parent - the company that they deal with +for the Nice video system. +1: Right. +1: So they are the ones who +handle --. +: So that would tell me then +that's only going to be that component that was +delivered, which still if it was delivered, I +had no knowledge of it while I was there. +: And you're saying if it comes +in that pallet - let's just say the MCC +received a truckload of something like that and + + +75 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +it can't be housed inside the MCC at that +location, where else could it be housed? +: Well, I don't think - it +could be housed there, it just wouldn't be in +that warehouse there. It would have to be in +some other secure location within the facility, +like somewhere in the Facilities Department. +Most likely probably, like, in the comm shop or +something like that someplace. +: But if this --. +: I wouldn't necessarily say +that it would be stored offsite. +: Hey, +• just scroll +above to the email that I sent. It's +specifically with regard to Nobile. He said +that it's the camera system that was installed +on the 19th. I mean, and if you don't know, +Nobile was the acting facilities manager from +February through March of - of May of 2019 and +then became the permanent facilities manager or +facility manager. +1: Yeah, I believe he walked in +right as I walked out or right after or +something like that. It was very close. +So he's telling us that + + +76 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +the camera system - you know, everything that +they installed was already on-site and that's +what he had told us. So he's saying it was onsite by the time he got there, so we're just +getting confused when you're saying that it +wasn't there because he said it was already +there when he got there. +: I never laid eyes on it, and +I was never made aware that those cameras were +on-site in my whole entire time that I was +there. +Somebody would have had to sign for +them. There's got to be some kind of tracking +information, and then like I said -- +: So -. +: -- going back -- +: No. +: -- I was under the impression +the contractor was bringing the cameras, not +being delivered separately without the +contractor. +: So according to his +email, you know, they're claiming that +beginning of October 2018 is when they would +have arrived, so is that - were you acting at +that point or was +still there? + + +77 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: Like I don't know, I can't - +I would need to know the date that +acted his last day on the job. And the only +milestone I can give you for that is, like I +said, when he went on that Colorado training +trip, he just never came back from that. +: Well, last time we spoke - +last time - my understanding is when +left is August of 2018 was the last time he +stepped foot inside MCC. Does that help? +: Yeah, it does, but like I +said, I'm just - I never saw anything outside +of conduit regarding this project on-site there +at that institution. I was never made aware of +any of that being there from my - since the day +the contract was awarded up until the time, I +walked out the door there was no cameras in +that building - +_: And -. +: - at least to my knowledge. +I never was made - I was never told, made +aware, never signed for them, never was - +nothing. +I: And if it did come, it says - +according to - it looks like this is the + + +78 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +contract. If it was delivered, it should have +been delivered attention to you according to +the contract, right? +: That's - should have - +exactly that's how that should have been done +if things are done the way they're supposed to +be done, but I never was made aware of any of +that stuff. I mean, like I said, it's been a +long time, but I never - I don't think there +was any - there's no way. +And before - just on a +side note, as far as the conduit that needed to +be run, how long should've that taken your +people to run? +1: It would have taken a very +long time because the department was severely +understaffed, and the institution came first. +The daily operations of the institution came +first. So if you had lights out, you had +phones down, you know, stuff like that the +tradesmen had to go ahead and take care of work +orders and stuff to maintain the institution +first and then they would come back and on +their downtime and stuff and do work pertaining +to this. + + +79 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: Okay. About how many man +hours do you think it takes though, I mean, if +they actually had worked on it? +: It's kind of hard to tell +because I don't know the total picture of the +routing of where all the cameras were going in +addition to the ones that are existing there, +but I can tell you that when this whole thing +was going on every - we were all short-staffed. +There was a constant flip over of staff, and +then you had augmentation going on. +My guys were working housing units more +than they were in the department and working +mandated overtime. So they were covering - +augmentation was like you would act as a CO and +go up in the housing unit for the shift, and +then some of them would get stuck doing +overtime for another shift. And then depending +on how that fell, they went up there all day +working the housing unit, got told they had to +work all night, then they were banging on me in +the morning because they worked a double before +that. +So - but I mean, man hours' wise, I really +couldn't tell you. I know there's a book out + + +80 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +there, electrical code book out there that +tells you the standard amount of feet of +conduit that can be installed within an eighthour period, but I mean, it just - that stuff +doesn't apply to a prison, especially MCC New +York. There are just too much operational +changes and stuff on a daily basis that +prevented these guys from dedicating 100 +percent of their work to something like that. +Especially being that they already had +something in place that was semi-functional. +1: Just to clarify, I know you +mentioned it, said you never received anything, +you never signed for anything. If the +receiving - if the delivery area received it, +right, you said the back - the rear door +received it, would they have some kind of 1og +they kept? +: Yep, uh-huh. +I: Where would I find that? +1: So that log was kept in the +cage where the packages were - be delivered at. +So inside that - they had one officer dedicated +that had one key for that cage back there and +that was their job. +& D it was called, they + + +81 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +were part of that crew, and they would just go +ahead and you get delivery, UPS, Fedex, they +would all come in, put all that stuff in a +cage, and they would write in the book who it +was addressed to, what department, and then +they would call you and let you know you had +something or send you an email, however the +officer chose to do it, and you would go there +and sign for it and pick it up. +1: And no one notified you. +This - the book that they keep, is it labeled +anything specific as you recall? +: If I recall correctly, I saw +two different versions of the book. One was a +binder, a three-ring binder type with a prefilled out form, and then +also there was a - +have you ever seen those little green +government logbooks that are just plain? You +know, there was one of those back there at one +point. +: Okay. And that should tell +us when - if and when it was delivered? +1: Yep. +1: Okay• +: And in addition to the + + +82 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +tracking information, of course, you know, +because I believe the three-ring binder part of +that - because that's the other thing is if +something is getting delivered to me, if I +ordered something out of the department, I +don't care what it was, a case of light bulbs +oI, you know, a truckload of conduit or +whatever, when that stuff ships this way, the +vendor's sending me an email with tracking +information letting me know when to accept it +because they know it's coming to a secure +institution where the truck and the driver are +subject to screening and there's only certain +hours that they can deliver during the day. +So it's not like a wide open 24/7 +warehouse obviously. They can only deliver +during certain hours. So I would make sure and +let everybody know you need to give me the +tracking information and I need to know what +day that this stuff is coming to me because I +need to make sure that I have the arrangements +in place to get this delivery accepted and not +turned away. +1: Were you - back then were you +in constant communication with SigNet or was + + +83 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +there somebody else on your staff that was in +communication with SigNet? +: The comm techs. We had two +comm techs that started with this thing and +initialed. I inherited two comm techs when I +came there, which both were involved with the +project with +when he started it. One +of them had retired and then one of them stayed +behind. He was still there. He was a younger +guy, which is that +guy on the email. +: And who is the one that +retired? +: Samuel Yaegly (Phonetic Sp. +*1:27:11). +1: Yaegly. Do you know when he +retired? +: While I was there. I +couldn't give you an exact date. I really +couldn't tell you. I'm --. +: Was this toward the end of -- +1: What (Indiscernible +*1:27:26). +: - 2018, beginning of 2019, +or was it earlier? +: What's that? + + +84 +1 +2 +3 +4 +5 +6 +7 +8 +: Was it towards the end of +2018, beginning of 2019 or earlier? +1: I honestly really couldn't +tell you. +: Is it possible that SigNet +sent the tracking information to +: Very possible. They did a +lot of communication from what I understand +back and forth that I was not looped in on, but +that was during the pre-contract, pre-planning +phases or pre-ordering phase I should say. But +yeah, very possible that it could have went to +him. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +• Okay. +: And it's also very possible +it could have went to the contracting officer. +Sometimes they do do that. So - and I noticed +if you go back to that contract there was that +guy +(Phonetic Sp. *1:28:18) on there. +: This is up top. +1: Do you see his name +: This is up here, right here, +you're talking about +? +: Yep. So he is what we call - +I think he was in the Budgeting Department, but + + +85 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +he was what we called the "paper pusher" for +Fort Dix. +1: That would be here? +: So basically, he did all the +financial stuff for MCC New York. He was the +guy that was on-site in the budget office and +then all that paperwork, he was technically, +like, an employee of Fort Dix. He was working +with them in the contracting and budgeting +office of Financial Services. +: You're talking about Line TA +where it states L +(Indiscernible *1:29:05)? +1: Yeah. So any time I want to +purchase anything, it doesn't matter what it +is, he would get the paperwork and then the +rest of it's between him and the contracting +staff at Fort Dix, the CO at Fort Dix, whoever +that Co is. +So sometimes with stuff like this, I have +seen in other instances where people will 1o0k +at this contract and they don't - they just see +a name and they just put it on there and send +them stuff. +But I would also like to think +that if +or even +• the + + +86 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +comm tech, or somebody got a tracking number +that they would have had the decency or the +common sense or whatever you want to call it to +to forward it to me, you know, to send it to +me. +left -- +1: Okay. As far as you recall +you left in February 14, 2019, and when you +1: Sure. +1: -- as +far as you recall -- +: (Indiscernible *1:30:06) . +: -- MCC never received the +cameras or anything on this order, which would +be that - everything that's listed on Page 4 of +this contract order, you don't recall them +receiving it. And you believe that --. +: I don't at all. When I left +there, they were still hanging conduit when +they could - +: And the conduit was -- +: —- at times (Indiscernible +*1:30:27). +: - items that was already inhouse that MCC from a previous project? +: I don't - yeah, because I + + +87 +1 +2 +3 +4 +know they had plans to purchase more just in +case. But I remember going over to Building 4 +and there was just racks and racks and racks of +conduit that they had over there. The +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +electrician knew - was there, that was part of +his overstock for his shop - +: Where was Building 4? +: - that he hung. It's just +over the bridge in Brooklyn, an old Navy +shipyard. +1: The Brooklyn Navy Shipping +Yard. +: Yes. +: So MCC kept -- +1: It's right on -- +: MCC had a building inside the +yard? +: Yeah. It's kind of like +separated. It was - used to be part of the +yard, but it's totally fenced in by itself and +there's a big huge warehouse there. And at the +time that I had left there, food service, staff +from food service ran that operation because +they had big giant walk-in freezers and coolers +there, which is where they kept a lot of their + + +88 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +overstock. +But also, every single department in the +institution, didn't matter who you was, human +resources, trust fund, facilities, everybody +had their own separate cages in that warehouse +as well to keep overstock supplies for their +departments as well. And has its own loading +dock, trucks go in and out of there every day, +all day with deliveries and all kinds of stuff, +and if it's something that they can't fit at +the institution, it goes to Building 4. You +can have the driver take it to Building 4. +But in this case, I would have never +allowed that because I - the supervision and +the oversight, there is none out there. At +least there wasn't at the time that I was +there. There was just one guy running the +whole show over there with a handful of +inmates. +: Okay. Agent +any +questions on that? +: No. I'm just looking +through all the emails from +right now. +1: I don't have much more in +terms of questions in terms of follow-up + + +89 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +because we covered a lot of details. Bear with +me one minute. +1: Sure. You guys owe me lunch, +I could tell you that. +: You just threw us for a +total loop because we've been proceeding this +whole time with the knowledge that these have - +were on-site, so that's where we - you've kind +of blown our minds here not knowing about it. +1: Yeah, I just - I told - I - +when Agent +gave me the initial phone +call, I was like, wow, 2018. That was like - I +just had no - we were still waiting on +everything. And even if - I would have +expected the contractor to be with them. But I +know there was delays with the wiring. The +wiring was crazy. They had some crazy delays +with wiring. +And to be honest with you, something like +this just the way that institution was ran, +there was just way too many hands in the pot. +It was just - two wardens, two AW's, two comm +techs, two facility managers it sounds like. +There's just too much stuff going on, too many +people involved. + + +90 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Assistant +1: You mentioned that Executive +and +they possibly - you know, I know you were +acting facility manager, but at the same time, +you know, they instructed you, gave +instructions too. Any chance that they had +communications with SigNet over this? +1: I don't see how or why, but I +wouldn't say no. I would say that if that did +happen, it would have probably been more with +than the AW because he had more +interaction with the warden as far as, you +know, keeping him abreast of things and stuff +like that, so. +last name +1: And just for the record, the +? +other AW's too, | +: Correct. +: And you mentioned there was +? +1: +mentioned there was another +• And then you +- +That's +last name. +oh, I apologize. + + +91 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +1: okay• +: Don't ask me how to spell it, +I don't know. He was an Egyptian. +1: Okay. +.I --. +IM +: You would have saw his name +on the earlier stages of the project back when +was still managing it because he was +the AW with at that time. +1: Okay. And you said the comm +techs would usually fix the issues that came up +in - prior to this camera system being - new +camera system being ordered, the comm techs +would fix the issues that came up with the +recorder and the decoder. What's a decoder? +1: A decoder? +- Yeah. +1: I have no idea. I just heard +it being used all the time. But see, I had a +personal issue. You got to realize in my +tenure with the Bureau, I worked at four +different institutions, three of them high +profile. +All right. MCC New York, me and + + +1 +2 +3 +4 +5 +6 +7 +8 +92 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +used to - I had a problem with that +equipment being in the same office as my comm +tech. You go to any other institution, that +equipment is under SIS control and if they need +a comm tech to look at it, SIS calls for the +comm tech and then SIS stays there and provides +oversight, an escort the whole time that +they're working on that equipment. +Here at MCC New York, and I'm only +assuming because MCC New York's the oldest +building I've ever worked in - I think it was +built in the late '60s early '70s. But I just +was not used to that equipment being in the +office of the comm tech. Everywhere I've ever +been that was always in SIS, but these were all +newer buildings. I think every other +institution I worked in was much newer, but I +just wasn't accustomed to that equipment being +in - it was just unreal to me. I just, you +know --. +1: Can you explain that to me +one more time? So my - our understanding is +there's a SIS office, then there's a video -- +: Yeah. +: —- monitoring room, right, + + +93 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +where they can see - +1: Right. +: — everything on the cameras. +That's where the SIS - an SIS officer sits. +They watch everything on the video monitor. +And isn't the access for the camera system +inside a room that's inside the video +monitoring room? +1: Are you talking where? +: At MCC. +: Yeah, but where, downstairs +in the comm tech's office, or up in someplace +else? +: So - wait, wait. So I'm +talking about on the third floor where the SIS +office is. +monitoring room? +1: Okay. +: Isn't there a video +1: I've never - I don't know. +I +never put eyes on it. I know that there was +equipment in +office and +office, the two comm techs in that same office, +and there was equipment that was in that room +that was part of that system. + + +94 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +1: What equipment was in that +room? +1: I have no idea, I just know +it was, like, in a locked cabinet. +: So you're saying the comm +techs had equipment, the live equipment for the +recorder, everything in their room that they +could access? +: There was some kind - yeah, +there was something related to the camera +system that was in a cabinet in their office +that was related to that and that's why in that +office they also had a secured cabinet for shop +stock and supplies. And if any of that stuff +would have got delivered and I knew about it, +that's exactly where I would have put it was in +that cage. +: The comm techs in their +office, did they have live monitoring, monitors +set up for the cameras? +: What do you mean by that? +1: Like for the video. You know +how the SIS shop has - you can watch the live +videos throughout the institution? They have a +few of them that are up live feed. + + +95 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: That's what I was trying to +say. I don't know what equipment's involved +behind that, but they had the ability to watch +video from the cameras in their office. +1: And --. +1: And like I said, I've never +seen that at any of the other institutions I +was at. It was always the comm tech goes to +SIS, puts their hands on the equipment and +fixes it, does whatever they've got to do. +: When --? +: MCC New York, I don't know if +it's because of the age of the institution or +not, but they did - I don't know what the +equipment is, but they -- +: Excuse me. +: -- have the ability to see +footage from their office. +: Did they have TVs set up on +their wall or was it just on their computer +screen? +1: No, the had IVs on a wall. +: And do you --? +1: I don't know how - they had - +yeah, they had - I don't know how they monitor + + +96 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +it, but they did have IVs on the wall, at least +one that I can remember. +: And you recall being in the +comm techs' office and you could see the live +feeds on their wall? +1: No. I remember seeing a IV. +I never witnessed any live footage, but I know +that it was discussed through just variable +internal things where they had that capability +in there. +: And you believe in that +little - the cabinet that was locked up in +their office they had - those were the actual +DVRs, the recorders, were inside the office? +1: I don't know what the +equipment was, I just know that they had the +ability to monitor cameras in their office. +- +1: okay. +_: Yeah. I don't know what was +in there, but I am assuming that if they had +the ability to monitor the cameras, they have +some sort of equipment in there, unless for +some reason or another somebody ran -- +: Is it possible -- +- wires from it. + + +97 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +1: - for like the night +supervision, like if they had supervision +access, they could log in and view cameras off +their computer system? +: I don't know. If they had +any kind of access like that, I wasn't aware of +it. +: okay. +: I always - I just had a hard +time - I just never seen +• that before. They +shouldn't - you know, the only time a comm tech +is dealing with camera stuff is when there is +there's a repair or maintenance involved. You +know, they shouldn't be able to, at least in my +opinion and from what I've seen at other +institutions, be able to just hit a power +button and turn on a monitor and see footage, +whether live or recorded. +And then the fact that that was in their +office, you know, was just astonishing to me. +It was new to me, and the only thing that kept +me somewhat at bay was that it was - the comm +techs were the only trade in the whole entire +department who didn't have inmates working for +them because of this - the equipment they had + + +98 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +access to. Which is also a reason they can't +get a lot of work done so quick is because they +don't have inmate (Indiscernible *1:42:19). +They're the only people in the entire +Facilities Department who doesn't get any +inmate labor help because of the equipment and +stuff that they have access to. +: Where was the office located, +the comm techs' office? +: It was over - it was +downstairs in the basement and it was between +the Safety Office and Food Service. +: Okay. That's all I have. +Agent +, do you have anything else? +: No, I don't think so. +: Mr. +• I know it's been +- I told you it's going to be a short interview +and it's been almost two hours now. Thank you +for being patient. I know we went back and +forth. As +mentioned, you know, a couple +things threw us for a loop because our idea of +what transpired, how things transpired, +complete changed at this point, but we might +have questions, follow-up questions for you in +the future, and is it okay if we reach back out + + +99 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +to you if we have more questions? +We'll probably do it via +email just so that we're not taking more of +your time and then you can have a moment to +actually review it and then just send us +something back, so we're not going probably +interview you again or anything like that. +: Yeah, that's fine. I just - +like I said, the - you're saying I threw you +guys for a loop. You guys threw me for a loop. +I mean, some of that stuff on that paperwork is +just - I mean, reading it as it is, it just - I +don't know, but yeah, I guess if you need me +again just give me a shout, send me an email, +or whatever the case may be, and I'll send you +the bill for lunch. +: If you think about anything, +if you feel like you thought about something +that popped in, your memory got refreshed while +you're sitting there, you want - send me an +email. +- I got you. +1: Thank you again for taking +the time to talk with us, and this is Special +Agent +The time is 12:50 p.m. + + +LIMITED OFFICIAL +USE +1 +and we +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +100 +are +turning off the recorder. + + +1 +2 +3 +4 +5 +6 +7 +8 +101 +CERTIFICATE +I hereby certify that the foregoing pages +represent an accurate transcript of the +electronic sound recording of the proceedings +before the Department of Justice, Office of the +Inspector General in the matter of: +Interview of +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Lise AFatt +Lisa A. Losleben, Transcriber \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/1c922581ccac53d72b69e011cf7406cdc8b6a967e82085629c5b62ca842a3469.receipt.json b/vision-fixhub/ds9-parsed-01/1c922581ccac53d72b69e011cf7406cdc8b6a967e82085629c5b62ca842a3469.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..e2f95a5599eb33b0db1ecc625a69746bc9776dfb --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1c922581ccac53d72b69e011cf7406cdc8b6a967e82085629c5b62ca842a3469.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -5609, + "dataset": "marble-joined", + "doc_id": "1c922581ccac53d72b69e011cf7406cdc8b6a967e82085629c5b62ca842a3469", + "engine": "marble-apple-vision", + "event_count": 110, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "0df76fb962a033526a99ab7b44e8895864187e67eebf9d4c3da3783d1d3a8a27", + "output_sha256": "838a35b8ea519d1816b95d4bb8f4e4d9b88d3bc6aa91fd97885fd32c6be846ba", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1c9430fc83476751901e322ab02b2f1086237c75cbd8d46fdc20b8a720cbac79.md b/vision-fixhub/ds9-parsed-01/1c9430fc83476751901e322ab02b2f1086237c75cbd8d46fdc20b8a720cbac79.md new file mode 100644 index 0000000000000000000000000000000000000000..129433719f5d1fd9fdf7059cf776d5dc25458ca4 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1c9430fc83476751901e322ab02b2f1086237c75cbd8d46fdc20b8a720cbac79.md @@ -0,0 +1,315 @@ +From: +To: " +Subject: FW: travel approval request (Hotel Options) +Date: Fri, 24 Jan 2020 16:48:06 +0000 +Inline-Images: image001 jPg; image002.jPg; image003.jPg; image004.jPg; image005.jPg; image006.jPg +My day so far... +From: +Sent: Friday, January 24, 2020 11:47 +Subject: RE: travel approval request (Hotel Options) +This email made me actually laugh out loud. The absurdity of DOJ's bureaucratic nonsense never ceases to amaze. I feel like I'm living in a +satiric novel. +From: +Sent: Friday, January 24, 2020 11:41 AM +Subject: RE: travel approval request (Hotel Options) +So, two fun things about the hotels. First, note that basically all of the hotels that I +I sent are well over the per diem, so I'm going to +email about getting approval for that. The other thing is, for reasons that I absolutely cannot fathom, the locations for a bunch of the +hotels in E2 are totally wrong. For example, that horrible WAERDSHUSET place (which, don't look at the photos online, it's terrifying) is +shown in E2 as being right downtown, here: +StocQolm +when in reality it's an hour and 30 minute drive from downtown: + + +*Gammel Tanne +So Stockholm +Conversely, the Diplomat, where the FBI says the Legat may be able to book for us through the Embassy (!), is listed as being hours and hours +outside of town: +Vallentuna +Hotel Diplomat-Worldhotel +Skr3.640 +$342 +• Akersberga- • +StocOolm +Gustavsberg +when in fact it's right downtown: + + +yungsgatin +et by Scandic +$118 +Hotel Riddargatan +( ProfilHotels +Jan 20 - 27 +Hotel Diplomat +$155 +Strandige +ROSENBAD +Kungliga slottet O +• Lydmar Hotel +5243 +Vasamuseet Q +- First Hotel Reisen +skyrkan +Chalkhana 9 +Steppsbron +* Hotel Ske +Grona L +• Hotel Rival +Fotograliska ! +Also notably, the prices in E2 are way higher than if we just booked through, like, Hotels.com (the Diplomat is $155 online or $382 on E2). +I have no fucking clue why we're all being tortured in precisely this fashion, but here we are. +From: +Sent: Friday, January 24, 2020 10:33 +Subject: RE: travel approval request (Hotel Options) +I'm fine with either one. +From: +Sent: Friday, January 24, 2020 10:22 AM +Subject: FW: travel approval request (Hotel Options) +Importance: High +What do you guys think? The Sheraton seems pretty standard, located in city center, and it should be easy to get a conference room there. +Or if you'd rather stay somewhere less standardized, the Hotel Kung Carl is also in the city center, seems well reviewed, and has meeting +rooms. +From: +Sent: Friday, January 24, 2020 9:12 AM +Cc: +Subject: RE: travel approval request (Hotel Options) +Importance: High +Good morning all, +l've searched previously in anticipation of your trip to Stockholm, Sweden between the original dates between 1/27 - 1/31/20, and a few +were within per diem, but those same hotels now are either sold out, or over per diem. I've screen captured a few of the hotels that popped +up in my search this morning. I've hid the sold out hotels within the Stockholm area. + + +Select a hotel +* Airport, city, or address +Stockholm, Sweden +* Check in +02/04/20 +* Check out +02/07/20 +Rooms +1 +© Current location +248 of 283 hotels +Stockholm +Show map > +Property Filters +C Reset Property Fillers +/ Hide sold out +Hide out of policy +Dictanoe from: Stockholm, Sweden +within 25 miles +Hotel name +Name or chain +Amenities +ADA accessitie (26) +Airport shuttle (15) +Breakfast included (126) +Coffee in room (107) +Eco friendly (31) +Executive foors (6) +Fitness room (99) +in room safe (70) +Laundry services (88) +Mini refngerator (56) +Non-smoking property (143) +Non-smoking rooms (207) +Panting offered (170) +Restaurant on sile (139) +Room servioe (09) +Swimming pool (25) +Translation services (5) +• Whoeichair acoessible (99) +• WFI in public spaces (105) +• WFi in room included (122) +WAERD SHUSET GAMMEL TAMMEN +Desterbybruks Hergard Cesterbybruk: 116 46 Sweden +0.3 mles 5 +9 Map +à Amenties +* • required +Search +Sort by Price +Skr800 +$84 +per dien 5r1,000 $101 +SHERATON STOCKHOLM HOTEL +Tegelbacken 6-Bck 195 Stockholm 10123 Sweden +0.4 mles N +9 Map +• Amenties +Skr2,495 +$262 +per den Sert,ase Ste +la Photos +HOTEL GAMLA STAN +Skeppsbron 22 Stockholm 11130 Sweden +@.1 mies NW Map dAmentes +Skr2,561 +$209 +per dien 5xr1,000 $100 +HOTEL HELL STEN +LUNTMAKARGAT 6B Stockhaim Sweden +0.6 mles NW 9Map dAmentes +Skr2,690 +S283 +per den Skr1,306 $ 106 +FIRST HOTEL NORRTULL +SAINT ERISGATAN 119 STOCKHOLM 111 57 Sweden +0.7 mles NW 9Map #Amentes +Skr2,695 +$283 +mr dian Shr1,306 $ 106 +HOTEL KUNG CARL +Begor Jarisgatan 21 Stockholm 11187 Sweden +0.7 mles N +@ Map | d Amenities +Skr2,790 +$293 +SCANDIC KLARA +Siodigatan 7 Stockholm 11157 Sweden +0.0 miles NW 9Map d Amentes +Skr2,890 +5304 +1306 $ 120 +In my opinion, the best hotel option is Sheraton Stockholm Hotel that's about $66 over per diem. Since it's out of our control, we'll need to +book a hotel over per diem. If you agree that I should reserve the Sheraton Stockholm Hotel, I'Il inform O +]of the issue so we could get +approval to reserve a hotel over per diem and fill out the forms to give to him to sign. In the meantime, I'II see if I could reserve your +preferred flights so they don't get sold out either. +Thanks for informing me. + + +U.S. Attorney's Office (SDNY) +From: +Cc: +Sent: Thursday, January 23, 2020 11:37 PM +Subject: RE: travel approval request +,, similar request from me for the same trip, if you could please book the following refundable tickets - +• Monday, 2/3, Delta, 6:40 p.m. departure from JFK, landing at 11:55 a.m. in Stockholm (ARN) on 2/4, with a layover in Paris +• Friday, 2/7, Delta, 12:45 p.m. departure from Stockholm (ARN), landing at 9:55 p.m. at JFK, with a layover in Paris +Note that it appears this set of flights is only available in premium economy but those seats are *cheaper* than any other flights on those +days in regular economy seating. Please let me know if e2 or EOUSA says we have to fly regular economy (and therefore spend more money) +and I can look at other flight times. +Separately, could you also please take a look at hotel options in downtown Sweden that are within the per diem allowance? We generally +need to be in this area, downtown: +OSTERMALM +KUNGSHOLMER +StocRolm +222 +222 +I looked for a long time and literally didn't see anything at $196 or below, so if you could please take a look and let us know three or four +options, we can take a look at those. +thanks very much, +From: +Cc: +Sent: Thursday, January 23, 2020 17:54 +Subject: RE: travel approval request +Hi H +appreciated: +For this trip, could you please help with booking flights? If you could please book the following refundable ticket, that would be very much + + +• Monday, 2/3, 8:15 p.m. departure from JFK, landing at 2:25 p.m. in Stockholm on 2/4, with a layover in London (American Airlines) +• Thursday, 2/6, 11:40 a.m. departure from Stockholm, landing at 7:30 p.m. at JFK, with a layover in London (American Airlines) +Thanks! +From: +Sent: Tuesday, January 21, 2020 2:56 PM +Cc: +Subject: RE: travel approval request +Approved +From: +Cc: +Sent: Tuesday, January 21, 2020 2:49 PM +Subject: RE: travel approval request +Similar to prior requests in connection with the Epstein investigation (2018R01618), but with an added international element, we'd like to +please request permission for the team to travel next week for an interview near Stockholm, Sweden, next week on January 29th and/or +30th. We expect to be traveling, respectively, some combination of the 27th (overnight) to the 31st, depending on when the interview ends +up being scheduled, and we'll put final dates on our formal applications. Also similar to prior trips, we'd like to request approval to get a +conference room for one of those days at a hotel for the interview itself. +Also based on our discussion earlier we'll be mindful of looking for domestic (or domestic-flagged) carrier flights, as well as the costs of any +alternatives, in looking at possible specific bookings. Thanks as always for your help and input on that. +thank you, +From: +Cc: +Sent: Wednesday, December 11, 2019 09:58 +Subject: RE: travel approval request +Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request permission for the team to +travel next week for an interview (or possibly interviews) in Los Angeles on December 16 and/or 17. We expect to be traveling, respectively, +some combination of the 15th to the 18th. Also similar to prior trips, we'd like to request approval to get a conference room for one of those +days. +thank you, +From: +Sent: Tuesday, November 05, 2019 16:53 +Cc: +Subject: RE: travel approval request + + +Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request permission for the team to +travel next week for an interview in Los Angeles on November 14. We expect to be traveling, respectively, some combination of the 13th to +the 15th (and no conference room necessary for this trip). +thanks, +From: I +Sent: Tuesday, October 22, 2019 13:55 +Cc: +P; +Subject: RE: travel approval request +Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request permission to travel next +week for an interview in West Palm Beach on November 4. It will just be me and I +1 and we'll travel some combination of the 3rd to +the 5th. And also same as last time, we'd like to ask permission to reserve a conference room at the hotel on that Monday for the interview, +please. +thanks very much, +From: +Cc: +Sent: Wednesday, June 12, 2019 14:51 +Subject: RE: travel approval request +Again in connection with the Epstein investigation (2018R01618), we'd like to please request permission to travel next week for a victim +interview in Los Angeles. As of now we tentatively expect to fly down Wednesday and return no later than Friday (and will keep the +timeframe as short as scheduling allows). The trip will be some combination of me, . and/or +1, as previously. And also same as +last time, we'd like to ask permission to reserve a conference room at the hotel on Thursday for the interview, please. +thanks very much, +From: +Sent: Friday, May 24, 2019 14:57 +Cc: +Subject: RE: travel approval request +Again in connection with the Epstein investigation, we'd like to please request permission to travel for approximately three days next week for +meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly down Tuesday night and return on Wednesday +or Thursday (and will keep the timeframe as short as scheduling allows). +Unfortunately we're still trying to pin down timing for interviewing the victims, so depending on the timing it will either be me and • +and +I, but we wanted to ask for permission now either way so we weren't doing it super last minute after the holiday on +Tuesday. And also same as last time, we'd like to ask permission to reserve a conference room at the hotel for the interviews, please. +or + + +thanks very much, +From: | +Sent: Wednesday, April 03, 2019 20:57 +Subject: RE: travel approval request +Thank you +From: +To: | +Sent: Wednesday, April 03, 2019 20:46 +Subject: Re: travel approval request +Approved +Sent from my iPad +On Apr 3, 2019, at 8:02 PM, +P wrote: +For the same case as below, United States v. Epstein, 2018R01618, an investigation relating to enticement of minors for sexual activity, +and I would like to please request permission to travel for approximately three days next week for meetings and interviews in West +Palm Beach, Florida. As of now we tentatively expect to fly down Tuesday night and return on Friday, though we will shorten the timeframe +if scheduling allows. +Please let us know if any other information would be helpful, and thanks very much. +From: +Sent: Thursday, March 14, 2019 18:32 +Cc: +Subject: travel approval request +and I would like to please request permission for travel for United States v. Epstein, 2018R01618, an investigation relating to +enticement of minors for sexual activity, for two days of meetings and interviews in West Palm Beach and/or Fort Lauderdale, Florida. As of +now we're hoping to fly down next Wednesday night and return on Saturday. +Please let us know if any other information would be helpful, and thanks as always. +Assistant U.S. Attorney +Southern District of New York \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/1c9430fc83476751901e322ab02b2f1086237c75cbd8d46fdc20b8a720cbac79.receipt.json b/vision-fixhub/ds9-parsed-01/1c9430fc83476751901e322ab02b2f1086237c75cbd8d46fdc20b8a720cbac79.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..42b384a7258beaa06936212ecde42408ec3a390e --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1c9430fc83476751901e322ab02b2f1086237c75cbd8d46fdc20b8a720cbac79.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -161, + "dataset": "marble-joined", + "doc_id": "1c9430fc83476751901e322ab02b2f1086237c75cbd8d46fdc20b8a720cbac79", + "engine": "marble-apple-vision", + "event_count": 9, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "c7eb8647e259b0c7dd9dc16c41cb5abcb473cebb4da80502b0dc69949b396969", + "output_sha256": "f314244669249adea025fbfab84e06f784403b1947704192a6b1dd60ddae15b6", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1c9ab2ada3143454e2bacb6c08483fd1e5abddd7543576a9c1465061634304f1.md b/vision-fixhub/ds9-parsed-01/1c9ab2ada3143454e2bacb6c08483fd1e5abddd7543576a9c1465061634304f1.md new file mode 100644 index 0000000000000000000000000000000000000000..2bf7bf936957a9dcb284926a024dc2f5f0d0c5ff --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1c9ab2ada3143454e2bacb6c08483fd1e5abddd7543576a9c1465061634304f1.md @@ -0,0 +1,49 @@ +From: +10: +Cci +Subject: RE: RE: updated JE will production +Date: Thu, 16 Jan 2020 23:13:28 +0000 +On the timeline, I generally agree though it's also conceivably possible that there were other wills / changes and the +Trustees just either don't have them or aren't aware - probably unlikely, but it is a long period of no change followed by +basically yearly updates so who knows. +On the trusts issue, I have to take some blame - when we requested the wills, the ask from Geoff was specifically for prior +wills, so that was our initial ask (and didn't include trusts). When we got the wills today, I responded that we also wanted +the trusts, and they were like, why didn't you just ask us for everything together, which I should have just done from the +start. So they're going to circle back to their clients, and I don't expect there's likely to be a huge delay, but in addition to +calling me today about it I expect they'll send an email to convey their clients' frustration on that issue in particular. So +we'll follow up on timing but did just ask them today so it may be early next week that we get an update, and they're +certainly aware they need to get them to us. +They also reiterated their continued interest in meeting with someone at DOJ, whether our office or otherwise, to engage +in discussions on forfeiture negotiations, particularly since they view it as an overhang that affects their ability to finalize +payments through a Fund process, which they have a hearing about in USVI on Feb. 4. So they'll likely send a letter on +that as well, which I'll pass up the chain. No real change there but just FYI. +From: +To: +Cc: +Sent: Thursday, January 16, 2020 17:37 +Subject: RE: RE: updated JE will production +These are very interesting, thanks. As best I can tell, there are no changes to the trust agreement between 2001 and +October 2012 - so for the full time period covering the prior investigation and his state prosecution - which is itself +somewhat interesting. It looks like Indyke's name first appears around 2004, while Kahn doesn't show up as an executor +until 2018. +Also interesting to see that Staley appears to be an executor or backup executor from 2012-18. +I did a quick google search to see if I could find any connection between Ruemmler and Epstein and came up empty. It's +an odd choice. Somewhat less odd, although equally notable, is Larry Summers. +Any response yet from the Trustees on when we will get the additional trust agreements (by my count, we need 2001; +October 2012; September 2013; November 2014; June 2017; and May 2018)? We should send these on the Brass no later +than tomorrow, ideally with an update on when we will get the trust agreements. +Thanks, + + +From: +Sent: Thursday, January 16, 2020 1:52 PM +To: +Cc: +Subject: RE: updated JE will production +We received a production from the Trustees today that includes an additional eight prior wills, going back to 2001. In +response, we also followed up by asking for the various Trusts referenced in the wills, but wanted to get you these since +they're what we asked for in the first instance. Saved here: +MUsa.doj.gov\cloud\NYS|StAndrews|Shared\USEpstein-201801618 Investigation\# 2018 SDNY investigation\Subpoena +Returns\ Trustees (Indyke and Kahn)\2020-01-16, supplemental production, wills +Assistant U.S. Attorney +Southern District of New York diff --git a/vision-fixhub/ds9-parsed-01/1c9ab2ada3143454e2bacb6c08483fd1e5abddd7543576a9c1465061634304f1.receipt.json b/vision-fixhub/ds9-parsed-01/1c9ab2ada3143454e2bacb6c08483fd1e5abddd7543576a9c1465061634304f1.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..2c1b87e74a136f5e694be54c0534e2720d82aec0 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1c9ab2ada3143454e2bacb6c08483fd1e5abddd7543576a9c1465061634304f1.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "1c9ab2ada3143454e2bacb6c08483fd1e5abddd7543576a9c1465061634304f1", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "791fa65f20fdec3883ffc0bc305dda7eaebe8107b358bd28516f2de10f19a479", + "output_sha256": "4de42dd137a1e1676c220b1e266b992e3db363a54f37d12e8fd1992d7d376df1", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1cd1bc4b0eb8fcf6f72922c9be324632534ab445a00468e19c65b1eacde9096f.md b/vision-fixhub/ds9-parsed-01/1cd1bc4b0eb8fcf6f72922c9be324632534ab445a00468e19c65b1eacde9096f.md new file mode 100644 index 0000000000000000000000000000000000000000..b4764fb5fde9efd7b8209febf5b46ffd94169f09 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1cd1bc4b0eb8fcf6f72922c9be324632534ab445a00468e19c65b1eacde9096f.md @@ -0,0 +1 @@ +No Images Produced diff --git a/vision-fixhub/ds9-parsed-01/1cd1bc4b0eb8fcf6f72922c9be324632534ab445a00468e19c65b1eacde9096f.receipt.json b/vision-fixhub/ds9-parsed-01/1cd1bc4b0eb8fcf6f72922c9be324632534ab445a00468e19c65b1eacde9096f.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..5d87dcfdee33b0641cb2d196aaecb8afec810b3a --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1cd1bc4b0eb8fcf6f72922c9be324632534ab445a00468e19c65b1eacde9096f.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "1cd1bc4b0eb8fcf6f72922c9be324632534ab445a00468e19c65b1eacde9096f", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "e6ccf8f518addf3b7ef821f5da4c92862845dfd5a9296cce70d5f709e05d87e7", + "output_sha256": "3874328764c818fba06683a6d5ddc2edc2d7850aaf4ba18646f81d3f8420a729", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1cdcd3dc9b951887108bab28447a9b03adea68b7f841603f761853f8d9613ec2.md b/vision-fixhub/ds9-parsed-01/1cdcd3dc9b951887108bab28447a9b03adea68b7f841603f761853f8d9613ec2.md new file mode 100644 index 0000000000000000000000000000000000000000..d7c8221ccc26baa26ce2e63d8affb7e8af2dcd8a --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1cdcd3dc9b951887108bab28447a9b03adea68b7f841603f761853f8d9613ec2.md @@ -0,0 +1,106 @@ +From: "l +To: " +(USANYS)" < +Subject: RE: NTW 5 +Date: Wed, 20 Oct 2021 01:45:20 +0000 +(USANYS) [Contractor]" +Thanks so much for your help on this. +reviewed NTW Production 5 and it is now ready for you to get ready to +produce. Can you please work on stamping the materials and updating the index and let us know when it is ready for +review? +Thanks so much! +From: [ +Sent: Monday, October 18, 2021 10:32 PM +To:1 +| (USANYS) [Contractor] < +Cc: | +| (USANYS) ‹ +Subject: RE: NTW 5 +Thanks! +From: [ +• (USANYS) [Contractor] < +Sent: Monday, October 18, 2021 9:47 PM +To: l +Cc: +(USANYS) < +P: +(USANYS) [Contractor] +Subject: RE: NTW 5 +Hi again! I've finished converting all the emails within SDNY Email Tips, so they're ready for your review. Thanks so much +for your patience! +From: +Sent: Monday, October 18, 20218:40 PM +| (USANYS) [Contractor] ‹ +| (USANYS) < +(USANYS) [Contractor] +Subject: RE: NTW 5 +Sorry about that! FYI, I was able to review the other folder in native format (the "Epstein Emails from VSD"), so no need to +convert that one. +From: +| (USANYS) [Contractor] 4 +Sent: Monday, October 18, 2021 8:22 PM +To:| +Cc:| +(USANYS) < +P: +(USANYS) [Contractor] +Subject: RE: NTW 5 + + +- I'm actually still working on converting the emails within the SDNY Email Tips folder, so what's currently in that +folder isn't complete. The jpg files were attachments to an email 1 was converting. I'Il let you know when everything is set +and you can review. Thanks! +From: +To:l +Cc:| +Sent: Monday, October 18, 2021 8:07 PM +| (USANYS) [Contractor] ‹ +(USANYS) < +Subject: RE: NTW 5 +Hey +(USANYS) [Contractor] +In reviewing this folder, there seem to be a bunch of jpg files that don't open. I moved them to the DNP folder, but do you +know where they came from? Were they generated when the emails were converted to pdf? Thanks. +From: +To: +Cc: +Sent: Monday, October 18, 2021 5:13 PM +(USANYS) [Contractor] < +| (USANYS) +Zio Y +2830 +3:01 +3:30 +420( +4:33 +520) +3231 +4202 +4:34 +5701 +Sul +6i01 +6t0l +6231 +720° +Fior +730 7E +MCC NEW YORK +30 MINUTE CHECK SHEET +ZB +DATE: Z B +7-10.- +19 +TIME FRAME +8:00-8:30 AM +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30-1:00 PM +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +DAY WATCH +OPERATIONS +LIEUTENANT +START +END +80? +806 +838 +910 +913 +948 +944 +1D14 la 10i7 +1049 1851 +1\07 +1104 +1134 1136 +1717 +1719 +1331 +1740 +115 +117 +144 +147 +2°7 +204 +231 +7-33 +319 +327 +336 +331 +TIME FRAME +START +END +4:00-4:30 PM +401 +403 +4:30-5:00 PM +5:00-5:30 PM +43343L +5055г +5:30-6:00 PM +6:00-6:30 PM +6:30-7:00 PM +7:00-7:30 PM + +00300+ +036ES5 + +7:30-8:00 PM +38 140 +8:00-8:30 PM +302804- +8:30-9:00 PM + +9:00-9:30 PM + +9:30-10:00 PM +14442 +1008\011 +104о 1043 +I/15 +11:30-12:00 PM +1142 1144 +VENING WATCH +PERATIONS +IEUTENANT +A star member must ouserve all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (examnle, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice +conducted on an irregular schedule and no more than 40 minutes apart +MOO NEW YORK +SPEGIALHOUSING UNIT + + +MOC NEW YORK +FRAME +START +END +12:00-12:30 AM +12:30-1:00 AM +1:00-1:30 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00-5:30 AM +5:30-8:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +PERATION +LIEUTENANT +MCC NEW YORK +30 MINUTE CHECK SHEET +ZA +TIER-G +DATE: 07/10/2019 +TIME FRAME +8:00-8:30 AM +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30- 1:00 PM +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +DAY WATCH +OPERATIONS +LIEUTENANT +START +841 842 +903 +доч +quo qui +1003(00 +104510%6 +o'y/0 +03 +155 +33 +TIME FRAME +4:00-4:30 PM +4:30-5:00 PM +5:00-6:30 PM +5:30-6:00 PM +6:00-6:30 PM +6:30-7:00 PM +7:00-7:30 PM +7:30-8:00 PM +8:00-8:30 PM +- 8:30-9:00 PM +9:00-9:30 PM +9:30-10:00 PM +10:00-10:30 PM +10:30-11:00 PM +11:00-11:30 PM +11:30-12:00 PM +EVENING WATCH +OPERATIONS +LIEUTENANT +MOC NEW ТОПИ +START +END +402 +1404 +432 +433. +50L 503 +532 533 +60 +6/2 +632 +634 +1706 +707 +1731 +733 +804 806 +832. +833 +910 +9/2 +932. +933 +1009 +110/0 +107, +73 +112 +4L + + +SPECIAL HOUSING UnIT +FRAME +12:00-12:30 AM +12:30-1:00 AM +1:00-1:30 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00-5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MCC NEW YORK +30 MINUTE CHECK SHEET +ZA +TIER-H +START +END +1712 +TIME FRAME +2 +DATE: 07/10/2019 +START +END +100-8:30 AM +gos +gou +30-9:00 AM +00-9:30 AM +30-10:00 AM +0:00-10:30 AM +0:30-11:00 AM +1:00-11:30 AM +1:30-12:00 AM +2:00-12:30 PM +2:30-1:00 PM +848 +005 +1206 +quz +943 +10°10% + +2° +1270 +:00-1:30 PM +:30-2:00 PM +6°% +685 +705 +735 +706 +:00-2:30 PM +:30-3:00 PM +:00-3:30 PM +30-4:00 PM +739 +140 +209 +210 +27 +295 +205 3a4 +235 386 +TIME FRAME +START +4:00-4:30 PM +4:30-5:00 PM +5:00-5:30 PM +5:30-6:00 PM +8:00-6:30 PM +6:30-7:00 PM +7:00-7:30 PM +7:30-8:00 PM +8:00-8:30 PM +8:30-9:00 PM +9:00-9:30 PM +9:30-10:00 PM +10:00-10:30 PM +10:30-11:00 PM +11:00-11:30 PM +11:30-12:00 PM +405 +406 +434 +435 +504 505 +534 536 +613 +614 +635 636 +708 709 +134 735 +807 808 +834 835 +913 +9/4 +934 +935 +101/ +1012 +(Ot) +LIEUTENANT +EVENING WATCH +OPERATIONS +LIEUTENANT +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +MOG nEW YORK +SPECIL HOUSING UNIT + + +SCO NEW YORK +SPECIRL HOURING UNIT +FRAME +12:00-12:30 AM +12:30-1:00 AM +1:00-1:30 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00-5:30 AM +5:30-8:00 AM +6:00-8:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +OPERATIONS +LIEUTENANT +START +05 +END +MCC NEW YORK +30 MINUTE CHECK SHEET +ZA +TIER-J +DATE: 07/10/2019 +TIME FRAME +START +0-8:30 AM +до5 +806 +0- 8:00 AM +0-9:30 AM +0-10:00 AM +00-10:30 AM +30-11:00 AM/ +00-11:30 AM +30-12:00 AM +00-12:30 PM +30-1:00 PM +10-1:30 PM +0-2:00 PM +0-2:30 PM +0-3:00 PM +0-3:30 PM +10-4:00 PM +MOC NEW YORK +SPECIAL HOUSING UNIT - 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5:30 PM +5:30-6:00 PM +6:00-6:30 PM +6:30-7:00 PM +7:00-7:30 PM +7:30-8:00 PM +8:00-8:30 PM +8:30-9:00 PM +9:00-9:30 PM +9:30-10:00 PM +10:00-10:30 PM +10:30-11:00 PM +11:00-11:30 PM +11:30-12:00 PM +DAY WAICH +OPERATIONS +LIEUTENANT +EVENING WATCH +OPERATIONS +LIEUTENANT +MOC NEW YORK +SPECIAL HOUJING UNIT +START +END +408 409 +438 439 +508 509 +539 +J4D +617 6/8 +639|640 +71L +138 +1139 +811 +812 +840 +914 +07) +102 +46 +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +condued on an irregular schedule and no more than 40 minutes apart observatione rouses a + + +МОС ПЕШ ТОЛК +FRAME +12:00-12:30 AM +12:30- 1:00 AM +1:00-1:30 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00 - 5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +OPERATIONS +LIEUTENANT +START +END +MCC NEW YORK +30 MINUTE CHECK SHEET +L-TIER +DATE: _ +07/10/2019 +TIME FRAME +START +8:00-8:30 AM +8:30-9:00 AM +f49 +g'o +85 +9:00-9:30 AM +9:30-10:00 AM +49 +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30-1:00 PM +246 +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +205 +Boa +3Yl 382 +TIME FRAME +START +END +:00-4:30 PM +:30-5:00 PM +:00-5:30 PM +:30-6:00 PM +:00-6:30 PM +:30-7:00 PM +:00-7:30 PM +30-8:00 PM +400 +411 + +5/0 5/1 +$41 542 +620 +611 642 +1713 +1143 +:00-8:30 PM +:30-9:00 PM +:00-9:30 PM +:30-10:00 PM +0,46 +947 +0:00-10:30 PM +0:30-11:00 PM +11:00-11:30 PM +1:30-12:00 PM +DAY WATCH +OPERATIONS +LIEUTENANT +EVENING WATCH +OPERATIONS +LIEUTENANT +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +documented. +MCG NEW YORK +REVIEWED BY MORNING WATCH LIEUTENANT — + + +ПОС ПЕШ ТОПК +FRAME +12:00-12:30 AM +12:30-1:00 AM +1:00-1:30 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00-5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +OPERATIONS +LIEUTENANT +MCC NEW YORK +30 MINUTE CHECK SHEET +M-TIER +DATE: 07/10/2019 +START +END +TIME FRAME +START +TIME FRAME +8:00-8:30 AM +др2 +0-4:30 PM +8:30-9:00 AM +0-5:00 PM +9:00-9:30 AM +13 +9:30-10:00 AM +- +10-5:30 PM +10-6:00 PM +10:00-10:30 AM +10-6:30 PM +10:30-11:00 AM +10-7:00 PM +11:00-11:30 AM +0-7:30 PM +11:30-12:00 AM +0-8:00 PM +START +END +1422 +413 + +5/2 513 +043|544 +621 +622 +643 644 +146 +12:00-12:30 PM +12:30-1:00 PM +12M +200 +0-8:30 PM +822 +0-9:00 PM +850 +1:00-1:30 PM +0-9:30 PM +12% +1:30-2:00 PM +10-10:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +2! +7 +208 +Lupo +us +246 +00-10:30 PM +991 +10" +30-11:00 PM +:00-11:30 PM +D'Y +1035 +20 +3:30-4:00 PM +30-12:00 PM +DAY WATCH +OPERATIONS +LIEUTENANT +EVENING WATCH +OPERATIONS +LIEUTENANT +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +documented. +MCC NEW YORK \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/1d5cc19d0abc0dd86031a03b1b532bbfedb3ceefadf83c56fde519be89d092de.receipt.json b/vision-fixhub/ds9-parsed-01/1d5cc19d0abc0dd86031a03b1b532bbfedb3ceefadf83c56fde519be89d092de.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..5012359f6e42f819dbbec114a64c1312e992ffa1 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1d5cc19d0abc0dd86031a03b1b532bbfedb3ceefadf83c56fde519be89d092de.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -1088, + "dataset": "marble-joined", + "doc_id": "1d5cc19d0abc0dd86031a03b1b532bbfedb3ceefadf83c56fde519be89d092de", + "engine": "marble-apple-vision", + "event_count": 16, + "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "c1f30c372d2e6f33ba102aafa679769bf1a6675dfb3e742ed396506d07a20b84", + "output_sha256": "9b8263f7f62b26a1b3f7714703ac34278dce4868ff9422d7ddc33b362384d116", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1d6f074b25ca6c1368280db8e2a45e3ff8ffb0ade004d071ea60f3b4c8335103.md b/vision-fixhub/ds9-parsed-01/1d6f074b25ca6c1368280db8e2a45e3ff8ffb0ade004d071ea60f3b4c8335103.md new file mode 100644 index 0000000000000000000000000000000000000000..c393869211f1b161236855f0d10ab2a18d21751a --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1d6f074b25ca6c1368280db8e2a45e3ff8ffb0ade004d071ea60f3b4c8335103.md @@ -0,0 +1,8873 @@ +Attachment N4 +METROPOLITAN CORRECTIONAL CENTE:- +NEW YORK, NEW YORK +WATCH CALL +DATE: +89/19 +STAFF NAME +MORNING WATCH +1:00 +1:30 +2:00 +2:30 +3:00 +3:30 +4:00 +4:30 +5:00 +5:30 +6:00 +Thomos +EVENING WATCH +A.M. POST +OPS LT +SANITATION +INTERNAL +OSP #1 +UNIT 2 +UNIT 3 +UNIT 5 NORTH +UNITS SOUTH +UNIT 7 NORTH +UNIT 7 SOUTH +UNIT 9 NORTH +UNIT 9 SOUTH +UNIT I0 SOUTH +UNIT 11 NORTH +UNIT I SOUTH +DUTY P.A. +R & D +FOOD SERVICE +LAUNDRY +LOBBY +OPS LT +ACT LT +INTERNAL +OSP #1 +UNIT 2 +UNIT 3 +UNIT 5 NORTH #I +ThomAs +UNIT 5 SOUTH #1 +UNIT 7 NORTH #1 +12:30 +6 +30 +X +x +x +x +30 +* * +Xx +- WATCH CALLS WILL BE MADE ON THE HALF HOUR. THE OPERATIONS LIEUTENANT SHALL B3 NOTIFIED IF CALLS ARE NOT RECEIVED WITHIN 5 MINUTES OF THE +EDULED TIME. THE LIEUTENANT ANDY OR A DESIGNATED STAFF MEMBER WILL BE DISPATCHED TO ASLESS THE STATUS OFTHE STAFF MEMBER. STAFF WORKING +CIAL ASSIGNMENTS WILL BE WRITTEN IN, FORM WILL BE ROUTED TO THE CAPTAIN'S OFFICE UPON COMPLETION + +SDNY 00013480 +Page 001 + + +CONT. EVENING WATCH +6:30 7:00 +7:30 +8:00 +8:30 +9:00 +9:30 +10:00 +STAFF NAME +P.M. POST +6:00 +UNIT 7 NORTH #2 +UNIT 7 SOUTH #1 +UNIT 7 SOUTH #2 +UNIT 9 NORTH #1 +UNIT 9 NORTH #2 +UNIT 9 SOUTH #1 +Noel. +UNIT 9 SOUTH #2 +UNIT 9 SOUTH 83 +UNIT 9 SOUTH 84 +UNIT IO SOUTH +• UNIT I NORTH •1 +UNIT II NORTH #2 +UNIT 1I SOUTH #1 +UNIT II SOUTH #2 +VISIT #I & #2 +VISIT 43 & 84 +VISIT ESCORT +LOBBY +ATTY CONF 81 & 82 +R&D +COMMUNICATIONS +RECREATION +FOOD SERVICE +DUTY P.A. +UNIT TEAM 2&3 +UNIT TEAM 5 & 7 +UNIT TEAM 9 & 11 +REAR GATE +ESCORT TEAM +CHAPLIN +X +X +X +ALI WATCH CALLS WILL BE MADE ON THE HALF HOUR. THE OPE +SCHEDULED TIME, THE LIEUTENANT AND/ OR A DESIGNATED ST +SPECIAL ASSIGNMENTS WILL BE WRITTEN IN. FORM WILL BE RO +M/W CONTROL CENTER OFFICER SIGNATURE_ +M/W LIEUTENANT'S SIGNATURE +E/W CONTROL CENTER OFFICER SIGNATUR +E/W LIEUTENANT'S SIGNATURE +CAPTAIN'S SIGNATURE +X - WATCH CALL RECEIVED +ATTACHMENT 4 +10:30 11:00 | 11:30 +× *× +xxx +Xxxxx +xxxxxxxx +xxx +xxx +xxx +xx +xxxx +* xx +x×× +*x* +* * × +xxxx* +* x +TIONS LIE TENANT SHALL BE NOTIFIED IF CALLS ARE NOT RECEIVED WITHIN 5 MINUTES OF THE +'MEMBER WILL BE DISPATCHED TO ASSESS THE STATUS OF THE STAFF MEMBER. STAFF WORKING +ID TO THE CAPTAIN'S OFFICE UPON COMPLETION. +Dant +O- WATCH CALL NOT RECEIVED + +SDNY_00013481 +Page 002 + + +DATE: 8/9/19 +BODY ALARM TESTING +ATTACHMENT #S +ASSIGNED UNIT +LOBBY +2*" FL SALLY +UNIT 1 SECRETARY +UNIT 2 (BA) +UNIT 3 (CA) +UNIT SN (EN) +UNIT 5S (ES) +UNIT 7 SECRETARY +UNIT 7N (GN) +UNIT 75 (GS) +UNIT 9N (IN) +UNIT 95 (ZA) +UNIT 95 a2 +UNIT 95 #3 +UNIT 95 #4 +UNIT 9S REC +UNIT 105 (ZB) +UNIT 11 SECRETARY +UNIT IIN (KN) +UNIT 1IS (KS) +S VISITING +7 VISITING +9 VISITING +II VISITING +ATTY CONF ROOM +C.M.S. SECRETARY +EDUCATION +R&D +R&D +BODY ALARM +1024 +1020 +021 +1001 +1002 +1004 +cool +005 +1007 +1008 +009 +L010 +Loll +1094 +1012.1013 +10 14 +1015, lolla +1020 +L02L +022 +RECREATION +SPEC. WATCH23 P.P1 1039 +FOOD SERVICE +DUTY PA. +UNIT TEAM 23 +UNIT TEAM 57 +UNIT TEAM S/I1 +M/W OFFICER +DAW OFFICER +E/W OFFICER +SIGNATURE: D/W +SIGNATURE: E/W +SDNY_00013482 +Page 00: + + +Artachment #4 +NEW YORK, NEW YORK +WATCH CALL +DATE: +8/10/19 +MORNING WATCH +STAFP NAME +A.M. POST +OPS LT +12:30 +1:00 +XX +1:30 +2:00 +2:30 +3:00 +3:30 +4:00 +4:30 +5:00 +5:30 +CX +6:00 +SANITATION +INTERNAL +OSP 21 +UNIT 2 +UNIT3 +UNIT 5 NORTH +UNIT 1 SOUTH +UNIT 7 NORTH +UNIT 7 SOUTH +UNIT 9 NORTH +Thomas, +UNIT 9 SOUTH +UNIT 10 SOUTH +RANIT II NORTH +UNIT II SOUTH +DUTY P.A. +R&D +FOOD SERVICE +LAUNDRY +LOBBY +EVENING WATCH +OPS LT +ACT LT +INTERNAL +OSP #1 +UNIT 2 +UNIT 3 +UNIT 5 NORTH 2I +UNIT 5 SOUTH #1 +UNIT 7 NORTH I +XXxXXX +XXXXXX +X +X +=>> +Xx +X +X +K +X +X +X +ALL WATCH CALLS WILL BE MADE ON THE HALF HOUR. THE OPERATIONS LIEUTENANT SHALL BE NOTIFIED IF CALLS ARE NOT RECEIVED WITHIN 5 MINUTES OF THE +SCHEDULED TIME. THE LIEUTEMANT AND/OR A DESIGNATED STAFF MEMBER WILL BE DISPATCHED TO ASSESS THE STATUS OF THE STAFF MEMBER, STAFF WORKING +SPECIAL ASSIONMENTS WILL BE WRITTEN IN, FORM WILL BE ROUTED TO THE CAPTAIN'S OFFICE UPON COMPLETION. + +SDNY_00013483 +Page 004 + + +CONT. EVENING WATCH +ATTACHMENT 4 +STAFF NAME +P.M. POST +6:00 +6:30 +7:00 +7:30 +8:00 +8:30 +9:00 +9:30 +10:00 +10:30 +11:00 +11:30 +UNIT 7 NORTH 82 +UNIT 7 SOUTH #1 +xxxxx +x+t +UNIT 7 SOUTH 12 +UNIT 9 NORTH •1 +UNIT 9 NORTH 37 +UNIT 9 SOUTH 91 +X +UNIT 9 SOUTH #2 +UNTT 9 SOUTH ag +UNIT 9 SOUTH 14 +1X +X +UNIT IO SOUTH +UNIT II NORTH BI +XX +X +X +xXxxxxxxxxx +UNIT I! NORTH E3 +LINIT II SOUTH #1 +UNIT 11 SOUTH 57 +****→* +VISIT #I & I2 +VISIT 03 & 84 +VISIT ESCORT +LOBBY +ATTY CONF DI & 02 +RAD +COMMUNICATIONS +RECREATION +FOOD SERVICE +DUTY PA. +*xxxxxxx- +UNOT TEAN 1&J +UNIT TEAM 5 & 7 +UNIT TEAM9 & 11 +REAR GATE +ESCORT TEAM +CHAPLIN +SCHEDULE ME TELE TENANT AND OR A EATED STAT MEMBER WE BE SATED ASE TATUS OF THE TAT MEMBER STATE WORKING +SPECIAL ASSIGNMENTS WILL BE WRITTEN IN. FORM WILL BE ROUTED TO THE CAPTAIN'S +S OFFICE UPON COMPLETION. +MW LIEUTENANENSROFFICER SIGNATURE +M/W LIEUTENANT'S SIGNATURE +E/W CONTROL CENTER OFFICER SIGNATURE +E/W LIEUTENANT'S SIGNATURE +CAPTAIN'S SIGNATURE_ +WATCH CALL RECEIVED +O- WATCH CALL NOT RECEIVED + +SDNY_00013484 +Page OFf + + +BP-A0292 +APR 16 +SPECIAL HOUSING UNIT RECORD +Inmate Name: +EPSTEIN, JEFFREY EDWARD +Team/caseworker: +UNASSIGNED ADMISSION +Violation +N/A +or Reason:_ +Admitance +Authorized: NIA +Pertinent information: +N/A +N/A +Separation Information: +Special Housing Unit Ceil Number: Z05-124LAD +NIA +U.S. DEPARTMENT OF JUSTICE +FEDERAL BUREAU OF PRISONS +NEW YORK MCC +(Institution) +Reg. No. 78318-054 +Regular Unit ABON. REID, UNIT MANAGER X 6473 Coll: A80 +Time +Date +-Rec'd: +Date +Rel.: +NIA +N/A +- Rec'd: +Time +NA +NIA +Rel.:. +N/A +N/A +_AD Status +Is Inmate on Medication:_ +Date +Shift +Meals +BT D +SH +Exercise +_Inmate Is in: +Out of cell time +(Total min/hrs). +_DS:_ +N/A +Medical Department Notified: +Comments +Medical +Staff Sign +OIC Signature +Mom +Day +Eve +SHAKIR, SAADIG M +07-08-2019 +Mom +Day +Eve +Morn +Day +Eve +Mom +Day +Eve +07-11-2019 +07-11-2019 +07-11-2019 +Mom +Day +Eve +Y +5eo 2nd page +Ret +07-12-2019 +Mom +67-12-2019 +Day +07-12-2010 +Eve +See 2nd page +07-13-2019 +07-13-2019 +07-13-2019 +Mom +Day +Eve +EXPLANATORYNOTES:Pertinent Info: Le., Epileptic; Diabetic; Suicidal; Assaultive; etc. Meals/SH: Shower - Yes (Y); No (N): Refused (R)Out-of-Cell +Time: (LL) Law Library, (LV) Legal Visit, (U) Unit Team, (P) Psychology, (E) Education, (H) Haircut, (C) Chapel, (R) Recreation, P) Property Issue, V +/isir, (M) Medical, (C) Court, (O) Other - Yes (Y) if applicable / Enter Actual Time Period Start and End (i.e., 0930 - 1030 hrs) in Out of Cell Time Block +Prescribed by P5270 +PDF +This form reptaces BP-292(52) dated AUG 2011. +SDNY_00013485 +Page 006 + + +07-11-2019 +Day shift comments: +Health: Valoes no medical complaints. +07-12-2019 +Day shit. comments: +Heath: Voices no medical complaints. +SDNY_00013486 +Page 007 + + +BP.A0282 +APR 16 +SPECIAL HOUSING UNIT RECORD +U.S. DEPARTMENT OF JUSTICE +FEDERAL BUREAU OF PRISONS +NEW YORK MCC +(Institution) +Inmate Name: +EPSTEIN, JEFFREY EDWARD +Reg. No. 76318-054 +UNASSIGNED ADMISSION +Team/caseworker. +Regular Unit: ABON. REID. UNIT MANAGER X6473 Cell: A80 +Date +Time +Violation +NIA +N/A +-Rec'd: +_ Recd:. +NIA +or Reason: +Date +Time +Admittance +N/A +N/A +Rel.: +N/A +Rel.: +Authorized: +N/A +Pertinent Information: +N/A +Separation Information: +Z05-124LAD +Special Housing Unit Cell Number: +N/A +Is Inmate on Medication: +Date +Shift +B +Meals +D +SH +Exercise +S +07-14-2019 +07-14-2019 +07-14-2019 +Mom +Day +Eve +N +No +No +07-15-2019 +07-15-2019 +07-15-2019 +Mom +Day +Eve +No +No +07-16-2019 +07-16-2019 +07-16-2019 +Mom +Day +Eve +No +07-17-2019 +07-17-2019 +07-17-2019 +Mom +Day +Eve +Ref +No +07-18-2019 +Mom +07-18-2019 +Day +07-18-2019 +Eve +N +Ref +No +07-19-2019 +107-19-2019 +07-19-2019 +Mom +Day +Eve +07-20-2019 +07-20-2019 +07-20-2019 +Mom +Day +Eve +N +No +N/A +NIA +_DS:_ +_AD Status +Inmate Is In: +NIA +_Medical Department Notified: +Out of cell time +Comments +Medical +Staff Sign +OIC Signature +(Total min/hrs) +01:00 +See 2nd pape +See 2nd page +01:00 +See 2nd pape +See 2nd page +00:15 +See 2nd page +EXPLANATORYNOTES:Pertinent Info: ie., Epileptic; Diabetic: Suicidal; Assaultive; etc. Meals/SH: Shower - Yes (Y); No (N): Refused (R)Out-of-Cell +Time: (LL) Law Library, (LV) Legal Visit. (U) Unit Team, (P) Psychology, (E) Education, (H) Haircut, (C) Chapel, (R) Recreation, (X) Property Issue, (V) +Visit, (M) Medical, (C) Court, (O) Other - Yes (Y) if applicable / Enter Actual Time Period Start and End (i.e., 0930 - 1030 hrs) in Out of Cell Time Block. +Medical: Medical providers will sign the segregation log each shift and the record sheet each time the inmate is seen by a medical provider. At a minimum, +the record sheet must be signed at least once each day by the medical provider. Comments: i.e., Conduct, Attitude, etc. Additional comments on reverse +side must include date, signature, and title. OIC Signature: OIC must sign all record sheets each shift. (OIC - Unit Officer) +PDF +Prescribed by P5270 +This form replaces BP-292(52) dated AUG 2011. +SDNY_00013487 +Page 008 + + +07-15-2019 +Day shift comments: +Health: Voices no medical complaints. +07-16-2019 +Day shift comments: +Health: Voices no medical complaints. +07-17-2019 +Day shit comments: +Health: Voices no medical complaints. +07-18-2019 +Day shift comments: +Health: Voices no medical complaints +07-19-2019 +Day shift comments: +Hesith: Voices no medical complaints. +SDNY_00013488 +Page 009 + + +NYMEC 530.03 * +PAGE 001 +BUREAU OF PRISONS COUNT SHEET +NEW YORK MCC +QTRG EQ **** +OCTG EQ +**** +T +R +T +D +COUNT +AREA +CENSUS +B-A +C-A +K-S +R-A +Z-A +2-B +26 +10 +83 +79 +78 +88 +4 +86 +89 +137 +1 +72 +5 +TOTAL +758 +COUNT +VERIFY +E +V +2 +2 +-1---- +OFFICIAL PREPARING COUNT +OFFICIAL TAKING COUNT: +COUNT CLEARED TIME: +08-10-2019 +01:20:48 +VERIFY +COUN +COUNT COUNT AREA +26 B-A +10 +C-A +81 +E-N +79 +E-S +78 +G-N +88 +G-S +4 +H-A +86 +I-N +89 +K-N +135 +K-S +1 +R-A +72 +Z-A +5 +Z-B +754 +324 +SDNY_00013489 +Page 010 + + +NEW YORK, NY +OFFICIAL OUT COUNT +DATE: +FROM: +APPROVED: +REG # +08/10/2019 +(Staff Member Preparing Out Count) +(Operations Lieutenant) +NAME +UNIT +KS +KS +5N +5A8 +COUNT TIME: +LOCATION: +0300Am +Hoof +REG # +NAME +• UNIT +13. +14. +4. +5. +6. +7. +8. +9. +10. +11. +12. +B-A +I-N +C-A +K-N +E-N +K-S +OUT-COUNT BY UNIT +2 +E-S +G-N +7 +R-A += +Z-A +G-S +Z-B +H-A +Total Out-Counted: +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected count. +Prepare this form in ink. Group the inmates according to their respective housing units. This form is to be used only as an +Out-Count. No other form will be accepted in lieu of the Out-Count Form +SDNY_00013490 +Page 01 + + +NYMEC 530*05 * +INMATE ROSTER + +CATEGORY: OCT +ASSIGNMENT: HOSP +OPER CATG ASSIGNMENT +OPER +• CATG ASSIGNMENT +* +08-10-2019 +01:21:34 +GROUP CODE: +FACILITY: NYM +OPER CATG ASSIGNMENT- +NUM ASSIGNMENT REG NO +0001 HOSP +0002 +0003 +0004 +NAME +OCT DATE +OTR +08-10-2019 E05-535L +8-10-2019 K09-028t +18-10-2019 E06-5461 +08-10-2019 K11-053L +WRK +SUICIDE OR +UNASSG +SUICIDE OR +SUICIDE PR +UNASSG +ES WAREHOL +SUICIDE OF +G0000 +TRANSACTION SUCCESSFULLY COMPLETED +SDNY_00013491 +Page 01: + + +Unit: BA +Date: 810:19 +Count: 26 +Time: 3:00Am +Signature: +Signature: +¡ Unit: +/ Count: +Signature: +Signature. +CA +10 +Date. +8/10/12 +Time: +SQNY_00013492 +Page 013 + + +Unit: EN +Count: _ +Print Nan +Signature +Signature +_ Date 08-10-2019 +81 +Time: 3:00A.M +Unit:_ +ES +Print Nam +Signature: +Signature +_ Date _ +8l10li9 +19: +SDNY_00013493 +Page 01- + + +.... +Signature: +Signature: +GN +Date: +8/10/19 +78 +Time: 3:00 fr +Signature: +Signature: +Date: +08/10/19 +88 +• Time: 03w0 +SDNY_00013494 +Page 01: + + +Print Name +Signature: +Print Name +Signature +KN +_ Dare 8/10/19 +89 +Time: 300am +Unit: _ +Print Name +Signature: +Print Names +Signature +KS +_ Date +135 +8/10/2017 +Time: 02 0a1 +SDNY_00013495 +- +Page 016 + + +HOSP +Date: 8:10-19 +Time: 3:00 Am +Signature: +Print Name +Signature: +Print Nan +Signature +Print Nam +Signature: +HA +4 +Date: 8-10-19 +Time: 3:00Am +SDNY_00013496 +Page 017 + + +New York, New York +RA +Date: +8/10/19 +1 +" Time: +3:00 +1. Print Name: +1. Signature: +2. Print Name: +2. +Signature: +IN +Date: +8/10/19 +86 +San +Signature: +Signature: +SDNY_00013497 +Page 018 + + +Signature: +Signature: +metrupuman correctional Center +ZA +Date: +ElIclIg +Time: 3 Am +i ticmas +sael? +2-3 +Date: S-10-2019 +Count:_5 +/limer +30fem +Signature: +Signature: +velo +-- +SDNY_00013498 +Page 019 + + +NYMFC 530.03 * +PAGE 001 +A +T +BUREAU OF PRISONS COUNT SHEET +NEW YORK MCC +OTRG EQ **** +OCTG EQ ** +4 2 5 +OUTCOUNT +F +F +S +S +E +CTION +E +F +KZ +S +& +W +D +V +COUNT +AREA +CENSUS +B-A +C-A +E-N +E-S +G-N +G-S +H-A +I-N +K-N +K-S +R-A +Z-A +Z-B +26 +10 +83 +79 +78 +88 +4 +86 +89 +137 +1 +72 +5 +TOTAL +758 +COUNT +VERIFY +2 +2 +OFFICIAL PREPARING COUNT: +OFFICIAL TAKING COUNT: +COUNT CLEARED TIME: +gr +08-10-2019 +01:20:48 +OC +UO +TU +N +2 +VERIFY +COUNT +COUNT COUNT AREA +HAHAHAHA +26 B-A +10 C-A +81 +E-N +79 +E-S +78 +G-N +88 +G-S +4 +H-A +86 +I-N +89 +K-N +135 +K-S +1 +R-A +72 +Z-A +5 Z-B +754 +3'au +SDNY 00013499 +Page 020 + + +NEW YORK, NY +OFFICIAL OUT COUNT +DATE: +FROM: +APPROVED: +08/10/2017 +COUNT TIME: +LOCATION: +0500 Am. +Hoop +REG # +risparing Out Count) +(Operations Lieutenant) +NAME +UNIT +REG # +NAME +UNIT +4. +5. +6. +7. +8. +9. +10. +12. +B-A +I-N +5N +13. +14. +15. +17. +21. +C-A +K-N +E-N +K-S +OUT-COUNT BY UNIT +2 +E-S +G-N +R-A +Z-A +G-S +Z-B +H-A +Total Out-Counted: +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected count. +Prepare this form in ink. Group the inmates according to their respective housing units. This form is to be used only as an +Out-Count. No other form will be accepted in lieu of the Out-Count Form. +SDNY_00013500 +Page 02 + + +NYMEC 530*05 * +INMATE ROSTER + +CATEGORY: OCT +ASSIGNMENT: HOSP +OPER CATG ASSIGNMENT +OPER +CATG ASSIGNMENT +* +08-10-2019 +01:21:34 +GROUP CODE: +FACILITY: NYM +OPER CATG ASSIGNMENT +NUM ASSIGNMENT REG NO +0001 HOSP +0002 +0003 +0004 +NAME +OCT DATE +OTR +08-10-2019 E05-535L +08-10-2019 K09-028U +08-10-2019 E06-546L +08-10-2019 K11-053L +WRK +SUICIDE OR +UNASSG +UNASSG +ES WAREHOU +SUICIDE OR +TRANSACTION SUCCESSFULLY COMPLETED +SDNY_00013501 +Page 022 + + +Signature: +Signature: +ZA +72 +Date: 8:10. 2019 +Time: 5:00am +CaNN +BA +26 +Signature: +Signature: +Date: 8-10-19 +Time: 5:00Am +SDNY_00013502 +Page 023 + + +CA +_ Date — +8/10/12 +10 +_ Time: Sco +Unit: _ +' Count: +Print Name! +Signature: +Print Name +Signature_ +HOSP +4 +Date: 8/101,9 +Time: 5:00wm +Signature: +Print Name +Signature: +SDNY_00013503 +Page 02- + + +Unit: EN +81. +Prist Na +Signatut +Print Na +Signatu +Metropolitan Correctiona. Center +Date 08-10-2019 +_ Time: 5:00AM) +Unit: _ +ES +79 +Print Nam +Signature: +Print Name +Signature +Date_ +Sliolig +→ T 50C/AM +SDNY_00013504 +Page 02: + + +Signature: +Signature: +SN +Da: 8/10/19 +78 +Time: 5:00AM +| Signature: +Signature: +Dare: 48/18/19 +88 +Time: 050ф +SDNY_00013505 +Page 020 + + +_HA +4 +Signature: +Signature: +Date: 8:10/9 +Time: 5:00AM +Print Nam +Signatures +Print Name +Signature: +IN +Date: +Time: +e/0/19 +SDNY_00013506 +Page 027 + + +Metropolitan Correctional Cente +KN +_ Date 8|10/10 +89 +- Time: 5CCAm +Print Nar +Signature +Print Nan +Signature +Unit: KS. +count: 135 +Print Nan +Signature +Print Nam +Signature +Date. 8/10/2019 +_ Time: 0,500Am +SDNY_00013507 +Page 028 + + +New York, New York +RA +Date: +810/18 +Time: +5,00 Am +1. Print Name: +1. Signature: +!. Print Name: +Signature: +роз. +Pri +Sigr +Signature: +2-0 +Date: 8-10-2019 +Time: 5:00Am +noeL +SDNY_00013508 +Page 029 + + +MGO NEW YORK +SPECIAL HOUSING GRIT +12:00-12:30 AM +12:30-1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00 -5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +IPERATIONS +JEUTENANT +CO BEW TORK +30 MINUTE CHECK SHEET +ZA +TIER-H +IPECIALHOUSING UNIT +DATE: 07/22/2019 +TIME FRAME +TIME FRAME +12:06 12:07 +8:00-8:30 AM +12:3612'37. +8:30-9:00 AM +l'06 1'01 +9:00-9:30 AM +1:36 +11:31 +9:30-10:00 AM +2:06 +2:07 +10:00-10:30 AM +2:36 +2:31 +10:30-11:00 AM +3:06 +3:07 +11:00-11:30 AM +3:36 +3:37 +11:30-12:00 AM +4:06 +4:07 +12:00-12:30 PM +4:36 +4:37 +12:30-1:00 PM +5:06. +5:07 +1:00-1:30 PM +5:36 5:37 +1:30-2:00 PM +6:06 +6:07 +2:00-2:30 PM +66:36 +6:37 +2:30-3:00 PM +3:00-3:30 PM +7:06 +8:07 +7:36 7:7963 +3:30-4:00 PM +8°° +836 +8°9 +837 +9 +4:00-4:30 PM +407 +1739 +KOS +N +5:00 - 5:30 PM +9 +41 +10'S +1015 +// 11 +138 +42 +5:30-6:00 PM +10" +1076 +ak +09 +6:30-7:00 PM +08 +46 +gos +4) +9/3 +914 +942 +943 +10:00-10:30 PM +10/2/073 +1043 +10441 +14/5 +11/6 + +EVENING WATCH +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +documented. +REVIEWED BY MORNING WATCH LIEUTENANT +SDNY_00013509 +Page 030 + + +SCO NEW TOK +SPECiAL HOUSING UNIT +12:00-12:30 AM +12:30- 1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00-5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +PERATIONS +JEUTENANT +1231 +1:01 +1'31 +1:32 +2:01 +2:0263 +2:31 +2: 30 63 +3:01 +302k03 +3: 31 +3'32 +4.01 +4:02 +4: 31 +4:32 667 +5:01 +5:0262 +5:31 +5:32€3 +6.01 +6:0262 +6:31 +2.01 +6.322 +1.02 +7:31 +7:3263 +BOO BEW TORK +30 MINUTE CHECK SHEET +L-TIER +DATE:07/22/2019 +SPECIAL HOUSING Un +TIME FRAME +8:00-8:30 AM +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +8° +8°+ +83' 832 +905 906 a +987 935 ze +10'° +10" aC +10t0 +10*1 +1/15 +//' +TIME FRAME +4:00-4:30 PM +5:00-5:30 PM +5:30-6:00 PM +6:30-7:00 PM +16" +1632 +34 +16 +17°7 +17 +Ge +17% +17'° +18° +18° +18" +1837 +G5 +(12 +11:30-12:00 AM +12:00-12:30 PM +12:30- 1:00 PM +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +Lo +46 +08 +37 +112 +Bingo +10:00-10:30 PM +846 +10 +932 +9Ll +933 +101D +/DI/ +1033 +1034 +1/DJ +1106 +1132 +1133 +lis +Wes +EVENING WATCH +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations müst be +documented. +REVIEWED BY MORNING WATCH LIEUTENANT +SDNY_00013510 +Page 031 + + +ROG SEW YORK +IPECIREHOUHAG UNIT +12:00-12:30 AM +12:30-1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00 -5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +IPERATIONS +IEUTENANT +30 MINUTE CHECK SHEET +M TIER +DATE: 7/22/2019 +Ri02 Los +12132/05 +TIME FRAME +TIME FRAME +4:00-4:30 PM +12:01 +12:31 +l'ol +D:31 +2:0l +2:31 +3:02 +3:32 +4:02 +4:32 +5:02 +5:32 +6:02 +6.32 +1:02 +2:32 +8:00-8:30 AM +8:30-9:00 AM +9:00-9:30 AM +1:3263 +2:0218 +2:3290 +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +6 0+ +8°5 +832 +833 +906 +907 +9 37 +938 +EL +10" 10' x +1041 +10t2 I +110C +(107 +5:00 -5:30 PM +5:30-6:00 PM +106 401 +431 +818 +SAB +6" +- 31 +6:30-7:00 PM +3'33 +4:03 +4:33 +5:0366% +5:36 +6'03/5 +6:35 +7:03 +2:33 +11:30-12:00 AM +12:00-12:30 PM +12:30-1:00 PM +1:00-1:30 PM +1:30-2:00 PM +3 +40 +2:00-2:30 PM +10:00-10:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +8|3 +8/4 +847 +848 +912 +913 +934 +935 +10/2 +1013 +1033 +1036 +1/07 +1108 +1/34 +113/ +EVENING WATCH +05 +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +documented. +REVIEWED BY MORNING WATCH LIEUTENANT — +E +МОС ВЕШ ТОПН +S +SPECINLHOUFING UN +SDNY_00013511 +Page 032 + + +GO NEW TORK +SPECIES HOUSING UNIT +12:00-12:30 AM +12:30-1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00-5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +IEUTENANT +12:03 +12:33 +1:03 +1:33 +1:34 +2:03 +2L04 +2:33 +234 G +303 +3:04 +3:33 +3:34 +4:03 +4:04 +4:33 +4:34 +5:03 5:04 +5:33 +5:34 +6:03 +6:04 +6:33 +6'34 +1:03 +7.04 +7:33 +7:341 +30 MINUTE CHECK SHEET +ZA +TIER-J +SCO NEW TORK +IPECIALHOUNIOG UNI +DATE: +07/22/2019 +TIME FRAME +TIME FRAME +8:00-8:30 AM +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +8°5 +8°6 +8 33 +8 34 +907 +9° +9 +38 +939 +10'2/0'3 +10 * 403 e +1115 +1114 +0a +38 +1159 +4:00-4:30 PM +5:00-5:30 PM +5:30-6:00 PM +406 +400 +438 +4 +39 +5153 +5* 538 +6:30-7:00 PM +54 10 +12:00-12:30 PM +8 +5,76 +83 +12:30-1:00 PM +3T +1:00-1:30 PM +1:30-2:00 PM +12 +2.00-2:30 PM +10:00-10:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +40 +41 +936 +937 +10/4 +10/J +1032 +1/09 +103X +111D +1136 +1137 +EVENING WATCH +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +а.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +documented. +REVIEWED BY MORNING WATCH LIEUTENANT +SDNY_00013512 +Page 033 + + +PEGHSHOUSIOG URIT +12:00-12:30 AM +12:30-1:00 AM +1:30-2:00 AM +2.00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00-5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +MPERATIONS +JEUTENANT +30 MINUTE CHECK SHEET +ZA +TIER-K +DATE:_ +07/22/2019 +TIME FRAME +12:0412:05 +12:34 12:35 +1:04 +1:05 +1:34 +1:35 +2:04 2:05. +2:34 +2:35 +3:04 +3:05 +3:34 +3:35 +4:044:05 +4:34 4:35 +5:04 +5:05 +5:34 +6:04 +5:35 +b'os +6:34 6:35 +1:04 +1:05 +7:34 +2:35 +8:00-8:30 AM +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +8°" +8 34 +908 +939 +10'3 +10+3 +(1146 +8°1 a +835 +909 +940 +10't +1044 +1119 +00 +37 +12:00-12:30 PM +12:30- 1:00 PM +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +70 +10 +• 11 +2:30-3:00 PM +3:00-3:30 PM +3.30-4:00 PM +TIME FRAME +4:00-4:30 PM +• 37 +5:00-5:30 PM +5:30-6:00 PM +6:00-8:30 PM +6:30-7:00 PM +10:00-10:30 PM +908 +938 +10/6 +1039 +1017 +1040 +Ш11 +11/2 +1/38 1139| +EVENING WATCH +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +conducted on an irregular schedule and no more than 40 minutes apart. All observations mundse +REVIEWED BY MORNING WATCH LIEUTENANT +MOC NEW TORK +SPECIAL HOUSING UN +SDNY_00013513 +Page 034 + + +TOO NEW YORK, +IPEGIRL HOUSING UNIT +12:00-12:30 AM +12:30-1:00 AM +1:30-2:00 AM +2.00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00-5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +MPERATIONS +JEUTENANT +1236 12 0 667 +12:35 12:06 +1.05 1:06 +1-35 136 67) +2:052:06 +2:35 +2:36 +3:05 +3:06 +3:35 +3:36 +4:05 +4:06 +4.35 +4:06 +5:05 +5:06 +5:35 +5:36 +6:05 +16:35 +6:06 +1:05 +66:36 +2:06 +7:35 7:36 +30 MINUTE CHECK SHEET +ZA +TIER-G +DATE: 07/22/2019 +TIME FRAME +8:00-8:30 AM +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30-1:00 PM +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +TIME FRAME +807 +8°° +8 85 +836 +909 +910 +9t0 +941 +15 +10 +ID +10+4 +10*5 +1108 +4:00-4:30 PM +5:00 -5:30 PM +5:30-6:00 PM +6:30-7:00 PM +ST +191 +SI +46 +47 +5555 +12 +10:00-10:30 PM +EVENING WATCH +AB +434 +459 +0Y01 +04/ +1041/042 +1113 +1114 +1140 114) +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +etention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12: +m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (exampl +2:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to b +onducted on an irregular schedule and no more than 40 minutes apart. All observations must b +MOC NEW TORR +SPECIM HOURING UNI +и) +4S +REVIEWED BY MORNING WATCH LIEUTENANT +SDNY_00013514 +Page 035 + + +MOO nEW YORK +12:00-12:30 AM +12:30- 1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00 -5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +NAS +ner +Vir +MA +MB +MB +135 +2°0 +2$ +3 +339 +40 +you +poo +2% +275 +n-B +340 +yor +Tur +505 +MB +MB +TB +606 +6 +785 +738 +MB +MB +no +30 MINUTE CHECK SHEET +ZB +DATE: +1/22/11 +TIME FRAME +8:00-8:30 AM +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30-1:00 PM +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +816 +841 +915 +942 +819 +ve +544 ve +911 ve +945 +10/6 +10/3 +1032 +034| +ne +1119 +1171 +1: 34 +1/31 +re +1707 +1765 +173i +1233 +M +109 +11 7 +128 +141 ne +76b +H1 Me +no5 ve +335 ve +TIME FRAME +4:00-4:30 PM +5:00-5:30 PM +5:30-8:00 PM +6:00-8:30 PM +6:30-7:00 PM + +5:0 +5'30 + + +85 +839 +842 +F +T I0 +913 +10:00-10:30 PM +10°1003 +1035 +1038 +11l5 +189 . +EVENING WATCH +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +documented. +MOO NEW YORK +SDNY_00013515 +Page 036 + + +IGO NEW TORE +SPEGIELHOUHAG UNIT +12:00-12:30 AM +12:30-1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00 -5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +1213 +1274 +/244 1245 +119 +120 +is +142 +143 +и12 +213 +241 +242 +309 +370 +341 +342 +4/3 +432 +433 +ws +502 +503 +510 +541 +676 +617 +639 +640 +7/0 +1701 +741 +742 +30 MINUTE CHECK SHEET +ZA +TIER-H +DATE: 07/23/2019 +TIME FRAME +8:00-8:30 AM +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +) 12 +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30-1:00 PM +1:00-1:30 PM +13 +215 +1:30-2:00 PM +37 +12 +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +208 +395 +RICO NEW TORK +SPECIA HOUSING UNIT +TIME FRAME +4:00-4:30 PM +5:00-5:30 PM +5:30-6:00 PM +6:30-7:00 PM +10:00-10:30 PM +404 #05 +433 434 +513 514 us +534 335 +60? 608 +636 637 +112 +113 +134 +135 +812 +813 +834 +835 +907 +908 +936 +937 +16/2/013 +WUS +aUs +1034/035 +1/08 +1109 +//34 1135 +EVENING WATCH +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +documented. +REVIEWED BY MORNING WATCH LIEUTENANT +SDNY_00013516 +Page 037 + + +MOG NEW TORR +SPEGIN HOUNG UNIT +12:00-12:30 AM +12:30- 1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00-5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +1202/203 +1234 1235 +110 +11/ +132 +133 +204 +205 +233 +2.34 +301 +302 +333 +334 +40б +406 +433 +434 +504 +JoS +538 +539 +674 +675 +637 +638 +708 +709 +739 +740 +ПОС ПЕШ TORK +30 MINUTE CHECK SHEET +L-TIER +DATE: +07/23/2019 +SPECIALHOUHING UNIT +TIME FRAME +TIME FRAME +8:00-8:30 AM +4:00-4:30 PM +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +12.00-12:30 PM +12:30-1:00 PM +1:00-1:30 PM +1:30-2:00 PM +gos +840 +913 +946 +10" +1046 +116 +1/40 += +804 +841 +914 +94) +10'2 +107) +714) +зіг +45 +76 +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +46 +341 +5:00 -5:30 PM +5:30-6:00 PM +6:30-7:00 PM +10:00-10:30 PM +KJ +4/06 +407 + +0/5 516 + +609 610 +63×639 +714 715 +736 +737 +8/4 +836 +815 +837 +909 +7/0 +938 +939 +10/41015 +1036 +1637 + +WJ +EVENING WATCH +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +documented. +REVIEWED BY MORNING WATCH LIEUTENANT +20 +SDNY_00013517 +Page 038 + + +ROG NEW TORK +SPECIES HOUSING UNIT +12:00-12:30 AM +12:30-1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00 -5:30 AM +5:30-8:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +1204/205 + +1/1 +112 +134 +13J +206 +207 +235 +236 +363 +304 +331 +1536 + +435 +436 +507 +508 +537 +538 +612 +673 +635 +636 +706 +707 +73> +738 +Ws +30 MINUTE CHECK SHEET +M-TIER +DATE: 07/23/2019 +TIME FRAME +8:00-8:30 AM +8:30-9:00 AM +9:00-9:30 AM +доз +87 +9" +937 +10 +14 +105 +1118 +504 CE +TIME FRAME +4:00-4:30 PM +Siz +5:00-5:30 PM +5:30-6:00 PM +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30-1:00 PM +1:00-1:30 PM +1:30-2:00 PM +17 +6:30-7:00 PM +2:00-2:30 PM +08 +Sb +218 +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +10:00-10:30 PM +0s +47 +378 +408 +409 +437 +438 +509 +509 + +611 +612 +640 +1641 +116 +717 +738 +739 +8/6 +817 +838 +839 +911 +9/2 +940 +941 +10/610/7 + +1/2 1113 +1138|1139 +EVENING WATCH +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +documented. +REVIEWED BY MORNING WATCH LIEUTENANT +SPECIALHOUSIRG URIT +les +SDNY_00013518 +Page 039 + + +ICO NEW TORE +SPECIEL HOURING UNIT +12:00-12:30 AM +12:30 - 1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00-5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +1206 1207 +1238 1239 +113 +114 +136/37 +208 +209 +237 +238 +305 +306 +337 +409 +338 +410 +438 +439 +509 +0/D +535 +536 +610 +611 +633 +634 +704 +705 + +lif +lis +WVS +30 MINUTE CHECK SHEET +ZA +TIER-J +DATE: 07/23/2019 +TIME FRAME +TIME FRAME +70 S +8:00-8:30 AM +4:00-4:30 PM +8:30- 9:00 AM +9:00-9:30 AM +9:30-10:00 AM +1/ +945 +O98 +5:00-5:30 PM +5:30-6:00 PM +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30-1:00 PM +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +/077 +R +70 +Ot5 +113 +41 +6:30-7:00 PM +-SU +40 +41 +10:00-10:30 PM +EVENING WATCH +410 +411 + + + +673 +614 +642 643 +718 +740 +741 +878 +819 +840 +841 +473 +9/4 +942 +943 +16/8 +1019 +1010 +1114 +11401/4/1 +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +documented. +REVIEWED BY MORNING WATCH LIEUTENANT +MCC nEW YORK +SPECIELHOUSING UNIT +is +(US +Nj +SDNY_00013519 +Page 040 + + +SPECIAL HOUNG AIT +12:00-12:30 AM +12:30-1:00 AM +1;30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00-5:30 AM +5:30-6:00 AM +8:00-8:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +1208 1209 +1240/241 +115 116 +138 139 +UD +1211 +V39 +240 +307 +308 +339 +340 +411 +412 +430 +431 +500 +501 +142 +543 +6/8 +6/9 +641/642 +112 +743 +713 +es +Ws +и +cuS +30 MINUTE CHECK SHEET +ZA +TIER-K +DATE: 07/23/2019 +TIME FRAME +TIME FRAME +8:00-8:30 AM +8:30. 9:00 AM +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30. 1:00 PM +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +2.30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +870 +1942 +10" +1060 +13 +1140 +12 +11 +1275 +06 +05 +13 +0$ +38 +діг +Gist +4:00-4:30 PM +yOL +403 +5:00-5:30 PM +5:30-6:00 PM +8:30-7:00 PM +7.00-7:30 PM +10:00-10:30 PM +431 +437 +510 +532 533 +605 606 +654 +635 +110 +74 +132 +810 +233 +832 +905 +833 +934 +906 +935 +10/0 +/0/1 +1032 +1033 + +132 1133 +EVENING WATCH +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +REVIEWED BY MORNING WATCH LIEUTENANT +DOC NEW TORN +SPECT HOURG UNIT +Ws +SDNY_00013520 +Page 041 + + +MOO REW TORE +SPECIRL HOUSING URIT +12:00-12:30 AM +12:30- 1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00 -5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +30 MINUTE CHECK SHEET +ZA +TIER-G +DATE: +07/23/2019 +TIME FRAME +д07 +TIME FRAME +1210 +121/ + +in +117 +140 +141 +U1D +234 +20/ +339 +411 +440 +5/1 +533 +608 +631 +102 +733 +240 +J08 +340 +412. +441 +072 +534 +607 +632 +703 +734 +8:00-8:30 AM +4:00-4:30 PM +8:30-9:00 AM +213 +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +5:00 -5:30 PM +5:30-6:00 PM +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +40 +13 +/4D +6:30-7:00 PM +12:00-12:30 PM +12:30- 1:00 PM +1:00-1:30 PM +07 +1:30-2:00 PM +140 +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +10:00-10:30 PM +318 +350 +EVENING WATCH +BCC NEW TORK +SPEGIEEHOUSIRG URIT +412 +413 +441 442 +512 513 +J4Z 543 +615 +6/6 +1644 +645 +721 +742 +743 +8L0 +821 +342 +9/5 +843 +9/6 +944 +945 +1020/021 +1042/043 +1116 +1/42 1143 +Us +cus +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +documented. +REVIEWED BY MORNING WATCH LIEUTENANT +20 +SDNY_00013521 +Page 042 + + +ПСО ПЕШ YORK +12:00-12:30 AM +12:30-1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00 -5:30 AM +5:30-6:00 AM +6:00-8:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +MB. +13г +1200 +10 +/ +30 +MD +135 +23 +25 +3w +23r +zor +340 +34г +45 +4A5 +MB +MB +MB +MB +sor +MB +тВ +J40 +600 +640 +J45 +605 +678 +MB +MB +•73T +736 +30 MINUTE CHECK SHEET +ZB +DATE:_ +1/23/19 +TIME FRAME +8:00-8:30 AM +8:30-9:00 AM +834 +815 +839 +M +9:00-9:30 AM +9:30-10:00 AM +ve +ne +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +948 +1003 +1634 +11:30-12:00 AM +12:00-12:30 PM +12:30- 1:00 PM +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +141 +1724 +12 37 +106 +151 +770 +731 +2203 +313 +751 +j00L +1035 ve +119 +ne +143 м +1276 +me +1731 1 +re +109 re +5 +4 же +273 M +734 +ne +30b +316 ve +TIME FRAME +4:00-4:30 PM +5:00-5:30 PM +5:30-8:00 PM +6:30-7:00 PM +4i1 404 + +D07506 + + + +1702 +3½ +4 +831 +106 +94. +10:00-10:30 PM +0D8/2I1 +10:30-11:00 PM / 042 2043 +X/13 //18 4 +148/15022 +EVENING WATCH +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +documented. +REVIEWED BY MORNING WATCH LIEUTENANT +BOO NEW TORK +SDNY_00013522 +Page 04: + + +ICO REW TORK +12:00-12:30 AM +12:30-1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00 -5:30 AM +5:30-6:00 AM +8:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +12/3 1214 + +114 /15 +14/2 +143 +211 +212 +232 +233 +304 +305 +334 +331 +410 +411 +432 +433 +510 +511 +533 +534 +610 +611 +633 +634 +200 +10/ + +W5 +WJ +Us +Us +30 MINUTE CHECK SHEET +ZA +TIER-H +DATE: 07/24/2019 +TIME FRAME +8:00-8:30 AM +807 +Jos +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +9 +37 +(0" +176 +11:00-11:30 AM +11:30-12:00 AM +136 +12:00-12:30 PM +12:30- 1:00 PM +40 +1:00-1:30 PM +1:30-2:00 PM +14 +7 +48 +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +TIME FRAME +4:00-4:30 PM +406 +401 +435 +5:00-5:30 PM +5:30-8:00 PM +6 +6:30-7:00 PM +37 +TO +170 +818 +169 +836 +87 +9/6 +917 +939 +940 +10:00-10:30 PM +101/ /0/2 +1640104/ +1110 +1/11 +1140 +1/41 +EVENING WATCH +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +documented. +REVIEWED BY MORNING WATCH LIEUTENANT +WOO NEW YORK +SPECIALHOUJING URIT +SDNY_00013523 +Page 04- + + +MGO ПЕШ ТОПИ +12:00-12:30 AM +12:30- 1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00-5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +1215 +MB +MB +105 +/ +MA +por +230 +зок +30 +348 +MB +you +MB +MB +54: +MB +MB +640 +645 +MB +por +790 +1:35 +MB +30 MINUTE CHECK SHEET +ZB +DATE: +1/214/2019 +TIME FRAME +8:00-8:30 AM +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30- +1:00 PM +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +8:03 +8:06 +8:46 +8149 +9:22 +9:27 +9:30 +19:35 +10:00 +110:05 +10.50 +10:55 +1/03 +1105 +1'39 +1141 +17/4 +171 T +1234 +lio +138 +140 +707 +250 +309 +ve +297 +313 ve +334 ve +TIME FRAME +4:00-4:30 PM +40/ 405 + +5:00-5:30 PM + +5:30-8:00 PM + +606 609 +6:30-7:00 PM + +700 703 + + +839843, +1/I 915 + +10:00-10:30 PM 10/4 / 0|7 +10:30-1:00 PM 045, 040 +1130-1200 PM 48 17 +EVENING WATCH +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +а.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +documented. +REVIEWED BY MORNING WATCH LIEUTENANT +MOO NEW TORK +SPECIALHOUJING UNIT +SDNY_00013524 +Page 045 + + +MOO REW YORK +12:00-12:30 AM +12:30-1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00-5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +30 MINUTE CHECK SHEET +ZA +TIER-J +DATE: 07/24/2019 +TIME FRAME +803 +1206 +1/207 +1235 1236 +110 +136 +205 +243 +306 +348 +414 +436 +5/4 +537 +674 +637 +764 +237 +137 +206 +244 +306 +349 +415 +437 +515 +538 +675 +138 +705 +738 +8:00-8:30 AM +8:30-9:00 AM +9:00-9:30 AM +goy +x16 +/12 +le +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30- 1:00 PM +947 +018 +1052 +N16 +38 +013 +-37 +1:00-1:30 PM +1:30-2:00 PM +46 +2:00-2:30 PM +aus +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +386 +TIME FRAME +4:00-4:30 PM +5:00 -5:30 PM +5:30-6:00 PM +6:30-7:00 PM +10:00-10:30 PM +EVENING WATCH +Sto +530 +6'8 +7127 +734 +1735 +812 +834 +713 +835 +912 +913 +935 +936 +1607 +1036 +100% +103. +1/06 1107 +1136 1/37 +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +documented. +REVIEWED BY MORNING WATCH LIEUTENANT +MOC nEW TORK +SPECIALHOUSING URIT +WUS +SDNY_00013525 +Page 046 + + +BOG BEG TORK +SPEGIN HOUSING UNIT +30 MINUTE CHECK SHEET +ZA +TIER-K +DATE: 07/24/2019 +TIME FRAME +TIME FRAME +12:00-12:30 AM +i208 +1209 +12:30- 1:00 AM +1237 +1238 +11/ +112 +1:30-2:00 AM +134 +135 +2:00-2:30 AM +204 +205 +2:30-3:00 AM +215 +246 +3:00-3:30 AM +30° +308 +3:30-4:00 AM + +4:00-4:30 AM +416 +4:30-5:00 AM +438 +5:00-5:30 AM +576 +5:30-6:00 AM +139 +6:00-6:30 AM +616 +6:30-7:00 AM +7:00-7:30 AM +639 +706 +7:30-8:00 AM +239 +439 +517 +540 +617 +640 +707 +740 +8:00-8:30 AM +4:00-4:30 PM +MORNING WATCH +4S +8:30-9:00 AM +803 +838 +10 +9:00-9:30 AM +5:00 -5:30 PM +9:30-10:00 AM +5:30-6:00 PM +10:00-10:30 AM +TO" +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +37 +12:00-12:30 PM +12:30-1:00 PM +1036 +1:00-1:30 PM +1:30-2:00 PM +052 +14 +38 +3o6 +231 +112 +747 +6:30-7:00 PM +2:00-2:30 PM +41 +Zis +10:00-10:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +13% +315 R +3 Y +811 +832 +833 +410 +9/1 +933 +934 +10/0 1011 +1035 1036 +1/04 /105 + +L/ +EVENING WATCH +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +documented. +REVIEWED BY MORNING WATCH LIEUTENANT +MOC nEW YORK +IVS +Wus +SDNY_00013526 +Page 047 + + +ПОС ПЕш ТОПК +SPECIE HOUSING UNIT +30 MINUTE CHECK SHEET +L-TIER +DATE: +07/24/2019 +TIME FRAME +804 +TIME FRAME +12:00-12:30 AM +1202 +12:30-1:00 AM +1231 +106 +1:30-2:00 AM +140 +2:00-2:30 AM +204 +2:30-3:00 AM +234 +3:00-3:30 AM +306 +3:30-4:00 AM +336 +4:00-4:30 AM +412 +4:30-5:00 AM +434 +5:00-5:30 AM +512 +5:30-6:00 AM +535 +6:00-6:30 AM +612 +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +13K +702 +135 +8:00-8:30 AM +4:00-4:30 PM +4" +441 +4'2 +441 +MORNING WATCH +1203 +1232 +/07 +141 +410 +23j +307 +337 +413 +43) +013 +536 +6/4 +636 +703 +236 +-(r) +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +945 +976 +0" +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +o4 +38 +TOS +1139 +12:00-12:30 PM +12:30-1:00 PM +1:00-1:30 PM +1:30-2:00 PM +236 +18 +$0 +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +41 +214 +241 +U +3:30-4:00 PM +5:00-5:30 PM +5:30-6:00 PM +532 +6'8 +6:30-7:00 PM +10:00-10:30 PM + +888 +919 +838 +839 +9/8 +940 +919 +941 +10/3 1014 +1042-1043 +1112- +1113 +1142|1143 +EVENING WATCH +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +а.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +documented. +REVIEWED BY MORNING WATCH LIEUTENANT +BOO NEW TORN +SPECIRLHOURING URIT +VE +le +из +SDNY_00013527 +Page 048 + + +ROO NEW TORE +SPECIAL HOUSING URIT +12:00-12:30 AM +12:30-1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00-5:30 AM +5:30-6:00 AM +6:00-8:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +1204 120) +1233|1234 +108 +109 +138 +139 +207 +208 +241 +24) +354 +34G +305 +347 +412 +413 +434 +435 +5/2 +5/3 +535 +536 +672 +6/3 +635 +636 +102 +703 +235 +1236 +30 MINUTE CHECK SHEET +M-TIER +DATE: 07/24/2019 +TIME FRAME +TIME FRAME +8:00-8:30 AM +003 +X50 +4:00-4:30 PM +4" +8:30-9:00 AM +12 +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +5:00-5:30 PM +439 +S" +11:30-12:00 AM +12:00-12:30 PM +CAT +D" +1076 +7 17 +54 +-B +5:30-6:00 PM +S +/D12 +6:30-7:00 PM +12:30-1:00 PM +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +146 +зів +238 +10:00-10:30 PM +3:30-4:00 PM +50 +100 + +814 +836 +815 +837 +9/4 +915 +937 +938 +1009/0/0 +1038 +1039 +1/08 +1109 +1/38 +1/39 +EVENING WATCH +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +documented. +REVIEWED BY MORNING WATCH LIEUTENANT +TOO nEW TORK +les +WUS +SDNY_00013528 +Page 049 + + +RIGO REW TORK +SPECIAL HOUSING WINT +12:00-12:30 AM +12:30- 1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00-5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +1210 +/211 + +1/21/3 +/32 +133 +202 +203 +277 +249 +309 +310 +352 +353 +418 +440 +4119 +441 +<78 +519 +841 +542 +618 +6/9 +641 +6417 +708 +709 +141 +742 +-US +30 MINUTE CHECK SHEET +ZA +TIER-G +DATE: +07/24/2019 +TIME FRAME +8:00-8:30 AM +8:30-9:00 AM +9:00-9:30 AM +Eloo +9.30-10:00 AM 946 +10:00-10:30 AM +10:30-11:00 AM +100 +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30-1:00 PM +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +999 +O51 +4/ +14 +235 +10T +1234 +138 +205 +135 +206 +232 +240 +309 +30° +339 +340 +00 +Th +TIME FRAME +4:00-4:30 PM +5:00-5:30 PM +5:30-6:00 PM +6:30-7:00 PM +10:00-10:30 PM +EVENING WATCH +744 +745 +820 +821 + +1970 +921 +942 +943 +10/5 +1016 +1044 +1045 +1114 +11/T +1144 +1|47 +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +documented. +REVIEWED BY MORNING WATCH LIEUTENANT +WOO GEW TORK +SDNY_00013529 +Page 050 + + +RIGOREW TORE +12:00-12:30 AM +12:30-1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00 -5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +1213 1214 +n40 1241 +DI? +10/8 +141 +142 +108 +23 b +307 +336 +412 +432 +513 +536 +609 +635 +112 +140 +237 +308 +337 +4/3 +433 +514 +537 +60 +636 +113 +74г +aS +a5 +30 MINUTE CHECK SHEET +ZA +TIER-G +DATE: +07/25/2019 +TIME FRAME +8:00-8:30 AM +18 +ов +0339 +20 +08!! +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30-1:00 PM +1:00-1:30 PM +66 +00 +10 +13 +10 +Be +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +TIME FRAME +4:00-4:30 PM +5:00 - 5:30 PM +5:30-6:00 PM +6:30-7:00 PM +10:00-10:30 PM +EVENING WATCH +410 +411 +440 +441 +818 519 +540 541 +6/6 +617 +640 +641 +712 +713 +143 +144 +8/8 +8/9 +840 +841 +9/8 +917 +942 +943 +10/8 +1019 +/040 +(D4/ +1/27 +122 +1144 114f +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +documented. +REVIEWED BY MORNING WATCH LIEUTENANT +SCO NEW TORK +SPECIEL HOUSING UNIT +wj +и) +aj +SDNY_00013530 +Page 051 + + +#GO REW YORK +12:00-12:30 AM +12:30-1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00 -5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +1215 1216 + +1119 010 +143 +144 +703 +204 +233 +234 +305 +300 +33K +335 +4/D +411 +430 +431 +510 +512 +534 +535 +603 +033 +110 +634 +71/ +NS +30 MINUTE CHECK SHEET +ZA +TIER-H +DATE: 07/25/2019 +TIME FRAME +8:00-8:30 AM +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +083° +08"! +CA 7 +04"S +10'3 +10°3 +TIME FRAME +4:00-4:30 PM +08 - 6E +5:00 -5:30 PM +5:30-6:00 PM +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30-1:00 PM +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +10'€ +6:30-7:00 PM +10:00-10:30 PM +41г +413 +442 443 +520 521 + +678 619 +642 +643 +1/5 +716 +745 +746 +820 +821 +842 +843 +920 +921 +944 +дит +1020 +/072 +1042/043 +1/23 +1124 +1146 114) +X +EVENING WATCH +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +а.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +documented. +REVIEWED BY MORNING WATCH LIEUTENANT +SCO NEW YORK +af +SDNY_00013531 +Page 052 + + +SOO DEW TORK +SPECIALHOUSING WAIT +12:00-12:30 AM +12:30-1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00 -5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +1208 1209 + +113 +1/4 +137 +138 +2101 +2402 + +3 11 +3/L +340 +341 +416 +417 +431 +437 +512 +518 +540 +541 +113 +614 +640 +641 + + +W) +30 MINUTE CHECK SHEET +ZA +TIER-J +DATE: 07/25/2019 +TIME FRAME +8:00-8:30 AM +032 +28* +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +Ge +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +10° +1087 +• 167 68 +11:30-12:00 AM +12:00-12:30 PM +12:30-1:00 PM +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +TIME FRAME +4:00-4:30 PM +5:00 -5:30 PM +5:30-6:00 PM +6:30-7:00 PM +10:00-10:30 PM +403 +432 +433 +510 +532 +6i0 +533 +611 +632 633 + +735 736 +810 +821 +832 +833 +910 +911 +932 +933 +1010 +/01/ +1b32 +1013 +1115 +11/6 +1134| 1735 +EVENING WATCH +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +documented. +REVIEWED BY MORNING WATCH LIEUTENANT +MOO NEW TORK +SPECIALHOUSEG URIT +W +aj +SDNY_00013532 +Page 053 + + +ПОС-WTORK +SPECIE HOUSING UNIT +12:00-12:30 AM +12:30-1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00-5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +1210 +1121 + +115 +116 +139 +140 +209 210 +238 +239 +309 +310 +338 +339 +4|4 +434 +435 +51б +516 +5381 +539 +671 +612 +637 +634 +214 +715 +742 743 +30 MINUTE CHECK SHEET +ZA +TIER-K +DATE: 07/25/2019 +TIME FRAME +8:00-8:30 AM +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +1в +087 +083 +09 +TIMES +TIME FRAME +4:00-4:30 PM +0835 +0s'5 +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30-1:00 PM +1:00-1:30 PM +10'Oe +39 +0"' GE +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +5:00-5:30 PM +5:30-6:00 PM +6:30-7:00 PM +10:00-10:30 PM +404 +405 +434 +435 +0/2 +513 +534 +535 +672 +673 +634 +635 +706 +107 +737 +738 +812 +813 +834 +835 +9/2 +P13 +434 +931 +10/2/013 +1634 1035 +11/7 /118 +1136|1137 +EVENING WATCH +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +а.m. - 12:30 a.m.) followed by another round in the sceond 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +documented. +REVIEWED BY MORNING WATCH LIEUTENANT +MOG NEW YORK +SPECIRL HOUSING UNIT +uS +(v) +SDNY_00013533 +Page 054 + + +ROO BEW TORK +SPECIM HOURAG URIT +12:00-12:30 AM +1203 +1205 +12:30-1:00 AM + +110 +121 +1:30-2:00 AM +/33 +134 +2:00-2:30 AM +712 +213 +2:30-3:00 AM + +3:00-3:30 AM + +3:30-4:00 AM +344 +345 +4:00-4:30 AM +470 +421 +4:30-5:00 AM +440 +5:00-5:30 AM +521 +522 +5:30-6:00 AM +544 +54(1 +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +617 +618 +644 645 + + +MORNING WATCH +W/S +aS +30 MINUTE CHECK SHEET +L-TIER +DATE: +07/25/2019 +TIME FRAME +8:00-8:30 AM +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +14 +08"5 +09" +08"1 +зе'? +35"! +107 +1037 +TIME FRAME +4:00-4:30 PM +5:00-5:30 PM +5:30-6:00 PM +Ce +10:30-11:00 AM +11:00-11:30 AM +6:30-7:00 PM +11:30-12:00 AM +12:00-12:30 PM +12:30-1:00 PM +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +10:00-10:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +EVENING WATCH +406 +407 +436 +437 +514 T/5 +536 +537 +674 +6/5 +636 +637 + +739 +740 +314 +875 +836 +837 +9/4 +9/5 +1936 +932 +1$14 10/5 +1036/037 + +1140 1141 +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +а.т. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +documented. +REVIEWED BY MORNING WATCH LIEUTENANT +MCG NEW YORK +SPECIAL HOUFING UNIT +uS +SDNY_00013534 +Page 056 + + +MCO NEW TORK +SPECIM HOWHaG WAIT +12:00-12:30 AM +12:30-1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00-5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +1206 1207 + +171 +112 +135 +136 +708 +247 +243 +313 +3/4 +347 +343 +4/ D +419 +438 +437 +619 +520 +542 +543 +615 +642 +643 +71379 + +Us +uS +LeS +30 MINUTE CHECK SHEET +M-TIER +DATE: 07/25/2019 +TIME FRAME +8:00-8:30 AM +10 +12 +33 +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +Sey +10:00-10:30 AM +10:30-11:00 AM +33°3 +053? +03 +10°5 +1003 C +38 +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30-1:00 PM +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +TIME FRAME +4:00-4:30 PM +5:00-5:30 PM +5:30-6:00 PM +6:30-7:00 PM +10:00-10:30 PM +408 +409 +138 +1439 +516 +517 + +614 675 +638 639 +7/0 +741 +742 +8/6 +717 +18:38 +83% +9/6 +917 +940 941 +1016/0/7 +(0381039 +1/21/1122 +11421143| +EVENING WATCH +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +documented. +REVIEWED BY MORNING WATCH LIEUTENANT +NOO NEW TORK +ins +SDNY_00013535 +Page 056 + + +MGO nEW TORH +12:00-12:30 AM +12:30- 1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00 -5:30 AM +5:30-8:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +2:0/12.2 +12131 +12:32 +1:011:02 +1:31 1:32 +2:0l 2:02 +2: 312:32 +3: +0|3:02 +3:31 +3:32 +4101 +4. +4.3L +4326B +- +240L +0.31 +020| +5:3 +6:02 +0:3i +7:01 +6'32 +7.083 +2:312321 +30 MINUTE CHECK SHEET +ZB +DATE: +7-25-19 +TIME FRAME +8:00-8:30 AM +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30-1:00 PM +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +B115 +18:20 +Shall +8:40 8:45 +Small +9:25 +9:30 +small +9148 +4:52 +small +10:00 +10:05 +small +10:35 +10:40 Sall +10:06 +110 +1130 +small +11:35 +Small +12:25 +12:30 +Small +12:55 +1:00 +smar +1:20 +small +1:45 +1.50 +small +2:07 +2:00 +*40 +3:42 +2:42 +3:24 +3:41 +3:43 +83 +TIME FRAME +4:00-4:30 PM +401 +405 + +5:00-5:30 PM + +5:30-6:00 PM +537 538 +608 609 +6:30-7:00 PM +23/ +04705 +13538 +80780 + +9/0 +14/3 +9/1 +146 +10:00-10:30 PM +1013 lOS +046/048 +1/49 1/53 +50 +EVENING WATCH +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +MOO NEW TORK +SPECIRL HOUSING URIT +REVIEWED BY MORNING WATCH LIEUTENANT +SDNY_00013536 +Page 057 + + +GO NEW TORK +SPECIALHOUSING WAIT +12:00-12:30 AM +12:30-1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00-5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +1213 1214 + +DI7 018 +741 +142 +108 +23 b +307 +336 +412 +432 +513 +536 +609 +635 +112 +140 +237 +308 +337 +413 +433 +514 +537 +610 +636 +113 +aS +30 MINUTE CHECK SHEET +ZA +TIER-G +DATE: 07/25/2019 +TIME FRAME +8:00-8:30 AM +, 18 +20 +ов. +8:30-9:00 AM +0839 +08"1 +9:00-9:30 AM +c3-1 +9:30-10:00 AM +00 +10:00-10:30 AM +13 +10 +10 +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30-1:00 PM +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +MOO NEW TORK +TIME FRAME +4:00-4:30 PM +5:00-5:30 PM +5:30-6:00 PM +6:30-7:00 PM +10:00-10:30 PM +410 +411 +440 +441 +818 +519 +540 +541 +616 +6/7 +640 +641 +7/2 +713 +743 +144 +8/8 +84D +819 +841 +9/8 +942 +917 +943 +10/8/019 +/040 +(D4/ +1/27 +1122 +1144 114$ +и) +aj +EVENING WATCH +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +а.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +documented. +REVIEWED BY MORNING WATCH LIEUTENANT +SDNY_00013537 +Page 058 + + +ROC AEW YORK +SPECIEL HOUSING UNIT +12:00-12:30 AM +12:30-1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00 -5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +115 1216 + +1119 Ö10 +143 +144 +203 +204 +233 +234 +305 +334 +4/0 +430 +510 +534 +607 +633 +110 +335 +M11 +431 +512 +035 +608 +634 +711 +uS +AS +WI +30 MINUTE CHECK SHEET +ZA +TIER-H +DATE: 07/25/2019 +TIME FRAME +8:00-8:30 AM +0372 +8:30-9:00 AM +08"! +08 - 6€ +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30-1:00 PM +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +09"S +10'3 +10€ +10" 20 +25 +TIME FRAME +4:00-4:30 PM +5:00 -5:30 PM +5:30-8:00 PM +6:30-7:00 PM +10:00-10:30 PM +412 +413 +yиz v43 +520 521 + +478 619 +642 +643 +1/5 +1716 +145 +746 +820 +821 +842 +843 +920 +921 +944 +945 +1020/071 +1042/043 +1/23 +1124 +1146 114) +X +EVENING WATCH +A staff member must observe all inmates confined in a continuous loeked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +а.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +documented. +REVIEWED BY MORNING WATCH LIEUTENANT +GO NEW TORH +SPECIRL HOUSING UNIT +af +af +af +SDNY_00013538 +Page 059 + + +12:00-12:30 AM +12:30-1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00 - 5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +1208 1209 +1236 1237 +113 +1/4 +137 +138 +201 +2102 +240/241 +3/V +340 +341 +416 +417 +431 +437 +512 +518 +540 +541 +*13 +614 +640 +L41 +716 +717 + +W) +uS +uS +30 MINUTE CHECK SHEET +ZA +TIER-J +DATE: 07/25/2019 +TIME FRAME +8:00-8:30 AM +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +e8? +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30-1:00 PM +10% +1007 +107 6e +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +2.30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +TIME FRAME +4:00-4:30 PM +5:00-5:30 PM +5:30-6:00 PM +6:30-7:00 PM +10:00-10:30 PM +EVENING WATCH +402 +403 +432 +433 +510 +532 +533 +6i0 +611 +632 +633 +7o4 +705 +735 +236 +810 +821 +B2 +833 +910 +911 +932 +933 +1010 +/D7/ +1632 +1013 +1115 +11/6 +113 / 135| +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +documented. +REVIEWED BY MORNING WATCH LIEUTENANT +IGO GEW YORK +SPECIAL HOUSING URIT +SDNY_00013539 +Page 060 + + +ROG-SEW TORK +SPEGIN HOURING UNIT +12:00-12:30 AM +12:30-1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00 -5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +1210 1211 +1238 1239 +115 +116 +139 +140 +209 +1210 +238 +239 +309 +316 +338 +339 +Ч/4 +415 +434 +435 +51Б +516 +538 +539 +611 +612 +637 +637 +314 +715 +742 +743 +и) +и +aS +30 MINUTE CHECK SHEET +ZA +TIER-K +DATE: 07/25/2019 +TIME FRAME +TIME FRAME +8:00-8:30 AM +4:00-4:30 PM +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +2835 +0°3 +0s 5 +10:00-10:30 AM +189 +0821 +10' OR +10:30-11:00 AM +32 +10 +Ge +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30-1:00 PM +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +5:00-5:30 PM +5:30-6:00 PM +6:30-7:00 PM +10:00-10:30 PM +EVENING WATCH +404 +405 +434 435 +5/2 +513 +534 +535 +672 +673 +634 +635 +706 +1707 +737 +738 +812 +813 +834 +835 +9/2 +Ф 13 +934 +935 +10/2 +- /013 +1634 +1035 +11/7 +1118 +1136|1137 +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example +2:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to b +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +documented. +REVIEWED BY MORNING WATCH LIEUTENANT +MOO NEW TORK +uS +W) +(e) +uS +SDNY_00013540 +Page 061 + + +ROO NEW YORK +SPECIAL HOUSING URIT +12:00-12:30 AM +1203 +1205 +12:30-1:00 AM + +110 +121 +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00-5:30 AM +5:30-6:00 AM +/ 33 134 +712 +213 +244 +1245 + +344 +345 +4W0 +421 +Ч40 +441 +521 +522 +544 +54(1 +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +617 +618 +644 +645 +720 +721 + +MORNING WATCH +30 MINUTE CHECK SHEET +L-TIER +DATE: 07/25/2019 +TIME FRAME +8:00-8:30 AM +14 +coff +8:30-9:00 AM +0835 +9:00-9:30 AM +09" +08°1 +3?!? +9:30-10:00 AM +3s"! +10:00-10:30 AM +10°7 +10:30-11:00 AM +107 +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30-1:00 PM +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +TIME FRAME +4:00-4:30 PM +5:00-5:30 PM +5:30-8:00 PM +6:30-7:00 PM +10:00-10:30 PM +406 +407 +436 +437 +514 T15 + +674 +615 +636 +637 +708 709 +739 +740 +314 +815 +836 +837 +9/4 +9/5 +436 +937 +1814 +/D/5 +1036 +1037 +1113 1120 +1140 1/Ч/ +EVENING WATCH +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +documented. +REVIEWED BY MORNING WATCH LIEUTENANT +BOO DEW TORK +uS +uS +SDNY_00013541 +Page 062 + + +EGG NEW TORK +SPECIM HOURING UNIT +12:00-12:30 AM +12:30-1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00-5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +1206 1207 + +212 +155 136 +708/211 +242 +243 +313 +314 +342 +343 +419 +43% +437 +619 +1 500 +542 +543 +615 616 +642/643 +71870 + +30 MINUTE CHECK SHEET +M-TIER +DATE: 07/25/2019 +TIME FRAME +8:00-8:30 AM +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +10 +12 +7/ +33 +02- +09°7 +033 +053? +03 +102 +10°5 +103! +03 C +SC +11:30-12:00 AM +12:00-12:30 PM +12:30- 1:00 PM +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +TIME FRAME +4:00-4:30 PM +5:00-5:30 PM +5:30-6:00 PM +6:30-7:00 PM +10:00-10:30 PM +408 +138 +409 +439 +JIT +039 +674 +675 + +71024 +741 +742 +8/6 +1838 +317 +839 +9/6 +917 +940 +941 +101616/7 + +1/21/1122 + +EVENING WATCH +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +а.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +REVIEWED BY MORNING WATCH LIEUTENANT +MOO NEW TORK +SPECIAL HOUSING UBIT +ins +SDNY_00013542 +Page 063 + + +MOO NEW YORK +SPECINLHOUSING UNIT +12:00-12:30 AM +12:30- 1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00 -5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +MOO NEW YORK +30 MINUTE CHECK SHEET +ZB +DATE: +7-25-19 +TIME FRAME +210/12:2 +12131 +12:32 +1.0l1:02 +1:31 +11:32 +2:012:02 +3: 313:321 +3:02 +3:31 +3:32 +4:01 +4. +4.3L + +5:02 +5.31 +620L +5:32 +6:02 +0:3i +7:01 +6132 +7.028 +7:31232- +8:00-8:30 AM +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30-1:00 PM +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +Bi15 +8:20 +8:40 +8:45 +Small +XmalL +9:25 +9:30 +smal +9:48 +4:52 +small +10:00 +10:05 +ID:35 +small +10140| +Small +18:06 +1130 +small +11:35 +12:25 +12:30 +Small +Small +12:5S +1:00 +1:1S +1:20 +smar +small +11:45 +150 +small +2:07 +2:09 +9"40 +2:42 +3:22 +3:24 +8B +85 +3:41 +3:43 +83 +TIME FRAME +4:00-4:30 PM +401 +405 + +5:00 - 5:30 PM + +5:30-6:00 PM +537 538 +608 609 +6:30-7:00 PM +8078K +838 841 +9/0 +4/3 +941 +446 +10:00-10:30 PM +O1S OS +046/048 +17/114 +149 1/53 +50 +EVENING WATCH +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +documented. +SPECIAL HOUTING UNIT +REVIEWED BY MORNING WATCH LIEUTENANT +SDNY_00013543 +Page 06- + + +ICO BEW YORK +30 MINUTE CHECK SHEET +ZA +TIER-H +DATE: 07/26/2019 +TIME FRAME +1200123011/201 120b Mon +| 8:00-8:30 AM +12:30 - 1:00 AM +12:40 +12241 HM +8:30-9:00 AM +1'2 +9:00-9:30 AM +1:30-2:00 AM +2:00-2:30 AM +1141 +гло +1142 +9:30-10:00 AM +10:00-10:30 AM +80 +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00-5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +9" 912 +2:41 +3209 +3:4р +4110 +4141 +2:42 +ну +10:30-11:00 AM +338 +11:00-11:30 AM +3182 +4:11 +4:42 +11:30-12:00 AM +12:00-12:30 PM +41 +12:30- 1:00 PM +1:00-1:30 PM +5:41 +6!11 +6:40 +110 +42 +6:12 +6:41 +117 +11) +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +56 +TIME FRAME +4:00-4:30 PM +5:00 - 5:30 PM +5:30-6:00 PM +6:30-7:00 PM +10:00-10:30 PM +AORNING WATCH +IPERATIONS +IEUTENANT +EVENING WATCH +43 +4% +20° +21: +77 +22. +22% + +2372335| +G +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +documented. +REVIEWED BY MORNING WATCH LIEUTENANT +MOO NEW YORK +SDNY_00013544 +Page 064 + + +#CO NEW YORK +IPECIALHOUSING UNIT +12:00-12:30 AM +12:30-1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00 -5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +IPERATIONS +JEUTENANT +30 MINUTE CHECK SHEET +ZA +TIER-G +DATE: 07/26/2019 +TIME FRAME +12051208 MAN +8:00-8:30 AM +1439 12139 +8:30-9:00 AM +140 +9:00-9:30 AM +1240 +9:30-10:00 AM +Zioy +2:39 +Sio7 +3119 +4108 +4.19 +2:09 +10:00-10:30 AM +2:40 +10:30-11:00 AM +3:08 +11:00-11:30 AM +3:40 +11:30-12:00 AM +4:09 +4:40 +11) +dly +12:00-12:30 PM +12:30-1:00 PM +1:00-1:30 PM +5i195i40 +6:09 +Z:10 +6:38 6:39 +7228 7:09 +7119 7:69 +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +938 +016 +1058 +15 +16 +39 +MGO NEW YORK +SPECIAL HOUSING USI +TIME FRAME +4:00-4:30 PM +5:00 - 5:30 PM +5:30-6:00 PM +6:30-7:00 PM +10:00-10:30 PM +" +3.f +2,37 +220° +OS +22 +224° +2240 +OG +6e +23- +23°7 +33 +23. +2334 +EVENING WATCH +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +conducte-o: 0 me thus ensuri an inmates base edit les vice per boser is rounds are to be +REVIEWED BY MORNING WATCH LIEUTENANT +SDNY_00013545 +Page 066 + + +BOO BEW FORK +PEGIN HOUSEG USIT +12:00-12:30 AM +12:30-1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00-5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +AORNING WATCH +JEUTENANT +12031209/11AN +12:30 +1101 +121) +1102 +1:3/ +1132 +2.00 +2:31 +2:32 +3000 +J20( +3:31 +3132 +48.00 +42ol +Ф'sl +Sio0 +4:22 +53l +540/ +Sisa +11/ +14 +6J02 +6isl +2:DO +7301 +111 +N3100 +30 MINUTE CHECK SHEET +L-TIER +DATE: +07/26/2019 +TIME FRAME +8:00-8:30 AM +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +И +046 +10B +10:30-11:00 AM +11:00-11:30 AM +17 +11:30-12:00 AM +12:00-12:30 PM +38 +TP +12:30-1:00 PM +1:00-1:30 PM +1:30-2:00 PM +11 +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +18 +- +ICO NEW TORE +SPECIAL HOUSING UN +TIME FRAME +4:00-4:30 PM +5:00-5:30 PM +5:30-6:00 PM +6:30-7:00 PM +300-8:30PM +10:00-10:30 PM +16°3 +16÷60 +16% +3в +16 +17. +1731 +Be +1730 +18ов +189 +GE + +19915* +19%! +11942 +05 +202 +20 +35 +20- +2035 +Ge +21. +214 +G +40 +21"' +6 +6 +12246 +Se +23 +123- +G +2538 +EVENING WATCH +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must b +documented. +REVIEWED BY MORNING WATCH LIEUTENANT +SDNY_00013546 +Page 067 + + +#CO NEW TORK +IPECIRLHOUNOG UNIT +12:00-12:30 AM +12:30-1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00 -5:30 AM +5:30-6:00 AM +6:00-8:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +PERATIONS +IEUTENANT +30 MINUTE CHECK SHEET +M-TIER +DATE: 07/26/2019 +TIME FRAME +12101216 MASON 800-830 AM + +8:30-9:00 AM +103 +1104 +9:00-9:30 AM +1:33 +114 +9:30-10:00 AM +L02 +10:00-10:30 AM +2433 +2:34 +10:30-11:00 AM +3:02 +Bio] +11:00-11:30 AM +3:33 ]17Y +11:30-12:00 AM +4!o2 +4:03 +12:00-12:30 PM +4:JY +12:30- 1:00 PM +102 +50) +11y +1:00-1:30 PM +038 935 +10" +U70 +3) +149 +1:30-2:00 PM +6:23 +7102 +711) +6:04 +4Y +633 +7i0} +73441 +2.00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM ++ Fash +MOG NEW TORK +SPECIAL HOUSING UN +TIME FRAME +4:00-4:30 PM +5:00-5:30 PM +5:30-6:00 PM +6:30-7:00 PM +10:00-10:30 PM +16 °° +16°2 +GE +1625 +60 +17'° 17" +30 +173 17 39| +09 +18% 18€| +18 " 18" +15% +15°1 +1940 +15"! +20% +20=20 +e +6 +e +16 +12 +21- +21 +2,42,42 +22°7 +22°8 +2240 +25" +23€ +GO +23 " 23"9| +EVENING WATCH +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +documented. +REVIEWED BY MORNING WATCH LIEUTENANT +SDNY_00013547 +Page 068 + + +ICO REW YORK +12:00-12:30 AM +12:30-1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00-5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +PERATIONS +IEUTENANT +1204/208 116 +12134 12135 +ну +1205 +1:26 +(17 +/U)5 1:36 +HY +21042:05 +3:04 +3J +Cloy +3105~ +3056 +40 Г +4.16 +5:04 +505 +556 +brot +6:06 +6414 63N + +2335-7:16 +30 MINUTE CHECK SHEET +ZA +TIER-J +DATE: 07/26/2019 +TIME FRAME +8:00-8:30 AM +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +39 +12:00-12:30 PM +12:30-1:00 PM +1:00-1:30 PM +1:30-2:00 PM +) +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +18 +3535 +MCC NEW TORK +SPECIGLHOUSING WAI +TIME FRAME +4:00-4:30 PM +12 +437 +5:00 -5:30 PM +5:30-6:00 PM +6:30-7:00 PM +20° +10:00-10:30 PM +38 +21 +39 +22°22°5 +42 +45 +22- +22 +23°% +23°1 +2335 +23381 +EVENING WATCH +15 +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. AlLobservations must-be +documented. +REVIEWED BY MORNING WATCH LIEUTENANT +SDNY_00013548 +Page 069 + + +PECUR HOUSING UNIT +30 MINUTE CHECK SHEET +ZA +TIER-K +MOO NEW YORK +SPECIAL HOUSING UN +DATE: 07/26/2019 +12:00-12:30 AM + +12:30- 1:00 AM +12136 1237 144/ +1(07 +1:08 41 +1:30-2:00 AM +1837 1:38 217 +2:00-2:30 AM +Zi0G +20711Y +2:30-3:00 AM +2117 2:30 +3:00-3:30 AM +3205 1:06 +3:30-4:00 AM +3237 1:38 +4:00-4:30 AM +4106 +4107 +4:30-5:00 AM +4:17 +4:38 +5:00-5:30 AM +5X07 +5:30-6:00 AM +5.17 +44 +11) +5-38 +6:00-6:30 AM +6:07 6:08 +6:30-7:00 AM +7:00-7:30 AM +6:36 6:37 +117 +1i0 6 +7:30-8:00 AM +7:07 +<<7738 +TIME FRAME +TIME FRAME +8:00-8:30 AM +4:00-4:30 PM +MORNING WATCH +IPERATIONS +IEUTENANT +8:30-9:00 AM +9:00-9:30 AM +5:00-5:30 PM +9:30-10:00 AM +5:30-6:00 PM +10:00-10:30 AM +1014 +10:30-11:00 AM +6:30-7:00 PM +11:00-11:30 AM +11:30-12:00 AM +39 +34 +12:00-12:30 PM +19 +12:30-1:00 PM +20"" +1:00-1:30 PM +e +1:30-2:00 PM +2:00-2:30 PM +738 +16 +35 +10:00-10:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +3" +3 +39 +40 +21 +2205 +2205 +e +2203 +22"4 +2391 +23° +G +G +23 +237 +5 +EVENING WATCH +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart All observations must be +documented. +REVIEWED BY MORNING WATCH LIEUTENANT +SDNY_00013549 +Page 070 + + +MOO NEW TORK. +12:00-12:30 AM +12:30-1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00 -5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +12;42 +1207 +12:31 +12:37 +1:03 +1:40 +1:32 +1:40 +Nel +21° +2:31 +2:38 +3:01 +3:09 +3:32 +3:40 +4:01 +4:08 +4:31 +4:31 +5:01 +5:10 +5:31 +5:38 +6:01 +6:01 +6:31 +6:31 +1:01 +1:05 +1:35 +1:40 +TIME FRAME +30 MINUTE CHECK SHEET +ZB +DATE:. +7-26-19 +8:00-8:30 AM +0806 +0809 +8:30-9:00 AM +0830 +0833 +9:00-9:30 AM +9:30-10:00 AM +0910 +0913k +0934 +087Y +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +10:0/10:04X +103L +1031 g +1215 +1132 +1221.2 +12:30-1:00 PM +12445 +TIME FRAME +4:00-4:30 PM +4.80 +4:40 +402 +·:15- +5:00-5:30 PM +5:30-6:00 PM +5:30 +6:30-7:00 PM +16137 +6.35 +y +17.30 +Silen +8:33. +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +136 +2:01 +2:35 +2:38 +10:00-10:30 PM +19:32 +10:06 +10:31 +125 +7.4p +8'08. +81312 +9113- +9:32 +10.05 +15:3L +ex +920- 9:30- +BW +113 +EVENING WATCH +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +documented. +REVIEWED BY MORNING WATCH LIEUTENANT +MOO NEW TORK +SDNY_00013550 +Page 07* + + +SPECIRLHOUFING UNIT +12:00-12:30 AM +12:30-1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00 -5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +1201am 12030m TN +1231am 1233am TA +0lam 1030m TN +131cm 133am TN +20lam 203cm TN +23lam 238m TN +B0am 303(m TN +38lam 33zm TN +40lam 413am TN +431am 403cm TN +5dlam 503cmTN +531am 53Bam TN +alamkazam IN +031am, 08m TN +7030NTN +30 MINUTE CHECK SHEET +ZB +DATE: 7.27.19 +TIME FRAME +8:00-8:30 AM +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30-1:00 PM +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +870 +82y ne +841 +543 M +918 +920 +936 935 ve +1003/005 ve +1049 1057 re +1100 +1143 +1212 +1237 +1145 MC +1714 me +1740 ne +109 +133 +135 M +707 +736 +3IL +337 +238' +re +319 re +339 k +TIME FRAME +4:00-4:30 PM +5:00 -5:30 PM +5:30-6:00 PM +6:30-7:00 PM + +13243 + +25528 +008 60 +e37639 +42/45 + + +51Z920 + +100-1030 PM /020/024 +052X055 +1/56 /158 +bico +EVENING WATCH +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +MOO NEW TORK +REVIEWED BY MORNING WATCH LIEUTENANT +SDNY_00013551 +Page 072 + + +MGO NEW TONE. +12:00-12:30 AM +12:30-1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00 -5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +205 +235 +338 +yo +115 +145 +2N +240 +3 ur +335 +yor +445 +MB +MB +MB +MB +MB +MB +Jur +535 +60° +608 +MB +TOV +731 +pr +7 +MB +30 MINUTE CHECK SHEET +ZB +DATE: +1/29/19 +TIME FRAME +8:00-8:30 AM +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30- 1:00 PM +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +806 +845 F4F me +4/3 +915 +ve +937 +737 re +1070 +1077 ne +1051 +1053 ne +lol +1o4 Me +1144 me +1711 +1742 +173 +136 +707 +737 +215 +17/9 +1247 +124 +135 +ж +ne +704 +240 +ne +TIME FRAME +4:00-4:30 PM +5:00 -5:30 PM +5:30-6:00 PM +6:30-7:00 PM +10:00-10:30 PM +EVENING WATCH +Ho' +403 + + +→19 _ 22 +8028°5 +837 8 40 +9t3 +10°° 0°3 +1031 +1034 +1113 +1176 +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +REVIEWED BY MORNING WATCH LIEUTENANT +MOO NEW TORK +SPEGIRL HOUSING UNIT +SDNY_00013552 +Page 073 + + +MGO NEW TORE +SPECIAL HOURING UNIT +12:00-12:30 AM +12:30-1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00 -5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +30 MINUTE CHECK SHEET +ZB +DATE: +7-28-19 +TIME FRAME +TIME FRAME +1206/209 1800-30AM +1232 1234 +/ 830-9:00 AM +115 +149 +6 8009304м +j42 +194 +9:30-10:00 AM +225 +255 +328 +358 +40° +439 +10:00-10:30 AM +1 / 10:30-11:00 AM +11:00-11:30 AM +X11:30-12:00 AM +12:00-12:30 PM +12:30-1:00 PM +5'° +549 +512 +551 +1:00-1:30 PM +1:30-2:00 PM +For +834 +91l +917 +1005 +1037 +1116 +1150 +1703 +1732 +2:00-2:30 PM +718 +770 +738 740 +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +142 +212 +241 +301 +333 +803 +5361 +913 +944 +1011 +10 35 +1119 +~ +1153 +10 5 +ve +1731 +re +118 +ne +145 +re +714 +ve +249 +ve +307 re +336| +ve +4:00-4:30 PM +5:00 -5:30 PM +5:30-6:00 PM +6:30-7:00 PM +10:00-10:30 PM +400 +482 +138 +490 +520 +5'42 +1544 +623 +624 + +715 +717 +770 +742 +809 +811 +836 +835 +913 +916 +948 +950 +/021 +1025 +1043 +1044 +418 +1u19 +1133 +134 +EVENING WATCH +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations mus +documented. +REVIEWED BY MORNING WATCH LIEUTENANT +MOO NEW TORK +SPEGIRL HOUSING UNIT +SDNY_00013553 +Page 07- + + +MOO BEW TORK +IPEGIRL HOURING UNIT +12:00-12:30 AM +12:30- 1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00 -5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +PERATIONS +JEUTENANT +120S +1236 +112 +200 +246 +312 +347 +404 +443 +509 +535 +613 +631 +108 +1207 +1237 +113 +140 +201 +242 +313 +348 +465 +444 +510 +536 +6/4 +632 +709 +132 +A +Of +30 MINUTE CHECK SHEET +L-TIER +DATE: 07/28/2019 +TIME FRAME +8:00-8:30 AM +8:30-9:00 AM +9.00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30-1:00 PM +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +806 +808 +183g +9151 +946 +947 8C +10/6/017 1c +1038 +1039 ^ +11/6 +140 +1216 +1247 +119 +15°0 +216 +236 +/141 +12/7 +1248 +126 +15/ +217 +21 H +~ +~ +313 +344 +345 +TIME FRAME +4:00-4:30 PM +5:00-5:30 PM +5:30-6:00 PM +6:30-7:00 PM +10:00-10:30 PM +EVENING WATCH +SCO NEW TORK +SPECIAL HOUSING UN +402 +404 +434 +435 тс +509 +539 540 +613|614 +636 637 +~ +716 +717 +145 +1548 +8a0 +Rail +850 +851 +918 +910 +941 +1942 +1600 +/DOL +1037 +1038 +1105 +1104 +11421143| +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +documented. +REVIEWED BY MORNING WATCH LIEUTENANT +SDNY_00013554 +Page 075 + + +MOO nEW YORK +PEGIRL HOUSING UNIT +12:00-12:30 AM +12:30-1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30AM +4:30-5:00 AM +5:00-5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +JPERATIONS +JEUTENANT +1207 +1209 +1238 +R40 +113 +114 +140 +141 +201 +202 +242 +243 +314 +315 +348 +349 +405 +4060 +444 +445 +511 +5/2 +536 +531 +614 +615 +632 +433 +109 +110 +733 +1,35 +30 MINUTE CHECK SHEET +M-TIER +DATE: 07/28/2019 +TIME FRAME +8:00-8:30 AM +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30- 1:00 PM +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +809 +810 +840 +8VI +9/6 +417 +9V8 94g +1018/019 +1040 +104, C +1118 +1119 +117g +1141 +1218 +1219 +12t8 +1249 +FE +121 +23 +152 +218 +153 +238 +211 +F +239 +315 +31G +346 347 +MOO NEW TORK +SPECIAL HOUSING Un +TIME FRAME +4:00-4:30 PM +5:00-5:30 PM +5:30-6:00 PM +6:30-7:00 PM +10:00-10:30 PM +4/05 +406 +436 +437 +TC. +JIU +S11 +54, +542 +615 +16/6 +638 +639 +7.8 +719 +749 +750 +830 +552- +920 +921 +943 +1002 1003. +1009 +1107 +1108 + +EVENING WATCH +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +documented. +REVIEWED BY MORNING WATCH LIEUTENANT +SDNY_00013555 +Page 07€ + + +IGO BEW TORE +SPEGIALHOUSING UNIT +12:00-12:30 AM +12:30- 1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00 -5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +JPERATIONS +IEUTENANT +1210 +1212 +1241 +1242 +115 +116 +(41 +142 +202 +203 +243 +244 +310 +317 +349 +350 +407 +408 +445 +446 +512 +513 +531 +538 +615 +616 +634 +635 +710 +11/ +736 +738 +30 MINUTE CHECK SHEET +ZA +TIER-J +DATE: 07/28/2019 +TIME FRAME +8:00-8:30 AM +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30-1:00 PM +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +811 +e +842 +8Y3 +918 +919 +950 +N20 +§ 51. +1021 +1042/1043 - +1120 +IDL +1142 +1143 +1220 +1221 +TC +1250 +ILSI +123 +174 +154 +155 +220 +221 +240 +241 +0•7 +318 +TC +348 +349 +ICO NEW YORK +SPECIAL HOUSING URI +TIME FRAME +4:00-4:30 PM +5:00 -5:30 PM +5:30-6:00 PM +438 +429 +511 513 +143 +6+7 +TC +6:30-7:00 PM +8:30- +9:00 PM +10:00-10:30 PM +618 +641 +720 +721 +851 +752 TC +824| 885 + + +948 +1004 +10057 +104l 1047/x +1169 +'1110 + +EVENING WATCH +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +documented. +REVIEWED BY MORNING WATCH LIEUTENANT +SDNY_00013556 +Page 07: + + +MCG NEW TORK +PECIALHOURNG UNIT +12:00-12:30 AM +12:30-1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00 -5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +SPERATIONS +JEUTENANT +1212 +1243 +117 +142 +203 +244 +318 +350 +409 +446 +513 +538 +6/6 +835 +1/1 +739 +1214 +1244 +118 +143 +204 +245 +317 +351 +410 +447 +514 +539 +617 +636 +112 +741 +30 MINUTE CHECK SHEET +ZA +TIER-K +DATE: 07/28/2019 +TIME FRAME +TIME FRAME +8:00-8:30 AM +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30-1:00 PM +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +813 811 +874/845^ +920 921 +952 953 +|2Z |023 +1044 +/122 +1144 +1222 +1121 +1145 +1220 +1252 +12S3 +125 +15 6 157 +212 223 +242 +243 +319 +350 +351 7L +4:00-4:30 PM +5:00-5:30 PM +5:30-6:00 PM +6:30-7:00 PM +10:00-10:30 PM +EVENING WATCH +MOG DEW TORK +SPECIRLHOURNG UN +409 410 +440 441 +JIy SIS +J45 +546 +619 620 + +TC +12723 +753 75k +8016 +FE +890 TC +856857 70 + +94 9480 +1006 1007 +1044 +1007 +7112 +1130h1 +1145|147207 +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +REVIEWED BY MORNING WATCH LIBUTENANT +SDNY_00013557 +Page 078 + + +MGO BEW YORK +12:00-12:30 AM +12:30-1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00 -5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +JPERATIONS +IEUTENANT +1217 +1219 +12 46 1247 +121 +122 +144 +145 +205 +206 +247 +248 +322 +323 +38 +354 +411 +412 +449 +450 +515 +516 +≤41 +542 +619 +620 +638 +639 +113 +114 +745 +747 +30 MINUTE CHECK SHEET +ZA +TIER-H +TIME FRAME +DATE: 07/28/2019 +TIME FRAME +8:00-8:30 AM +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +1817 +811 +848 849 +G2U 925 +G56 +026 +1078 +126 +4:00-4:30 PM +5:00 -5:30 PM +5:30-6:00 PM +11:30-12:00 AM +1077 +1049~ +1127 +1149 +6:30-7:00 PM +12:00-12:30 PM +12:30-1:00 PM +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +1220 +1254 +1257 +129 +30 +147 +148 + + +323 +321 +354 +355 +er +10:00-10:30 PM +EVENING WATCH +SUP +SPECIAL HOUSING URIT +413 444 +444 445 18 +Sit 519 k +S50 551 +623 62V| +~ +674|647 + +S24 825 +8371 + +929 +1930 +PSI +952 +2009 +11048 +1049 +1111 +1118 +1158/1531 +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +а.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +documented. +REVIEWED BY MORNING WATCH LIEUTENANT +SDNY_00013558 +Page 079 + + +MOG nEW TORK +IPECIALHOUJING UNIT +12:00-12:30 AM +12:30-1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00-5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +JPERATIONS +JEUTENANT +1215 +1216 +1244 1245 +119 +120 +143 +144 +204 +205 +245 +246 +320 +321 +351 +352 +410 +41/ +447 +448 +Sly +515 +539 +540 +6/8 +6/9 +636 +637 +712 +713 +742 +744 +30 MINUTE CHECK SHEET +ZA +TIER-G +DATE: 07/28/2019 +TIME FRAME +8:00-8:30 AM +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30- 1:00 PM +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +815 +816 +846 877 +9 22 927 +954 +1956 +1024 +1025 ~ +1016 1047 +1241 +I122 +1146. +122V +1225 +12-54 +1255 +127 +128 +15Y +S +224 +244 +32 + +TIME FRAME +4:00-4:30 PM +412 +4142 +443 +5:00-5:30 PM +516 +5:30-6:00 PM +548 549 +(2) +622 +6:30-7:00 PM +644 +645 +724 +7251 +TODS +7560 +829 +858 +(8591 +921 +1149 +950 +10:00-10:30 PM +1008 +1046 +17047 +414 +1150 +LIST +EVENING WATCH +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must bé +documented. +REVIEWED BY MORNING WATCH LIEUTENANT +ICO NEW YORK +SPECIAL HOUSING VENT +1 +SDNY_00013559 +Page 080 + + +12:00-12:30 AM +12:30- 1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00-5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +PERATIONS +JEUTENANT +120702- +1234 1234 +104 +65 +132 +204 +2°6 +25 +234 +503 +30€ +833 +334 +TL +43г +505 +53L +661 +634 +BY +437 +506 +532 +GUS +634 +208 +732 +TL +R +30 MINUTE CHECK SHEET +ZA +TIER-G +DATE: 07/29/2019 +TIME FRAME +8:00-8:30 AM +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30- 1:00 PM +1:00-1:30 PM +8°2 +803 + +916 +817 +947 +945 +4 +1025 +1047 +1108 +1'39 +12°5 +1101 +111% +12 +1330 +127 +120 +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +TIME FRAME +4:00-4:30 PM +4"' +4" +S'3 +43 +5:00-5:30 PM +5:30-6:00 PM +6:30-7:00 PM +123 +924 +934 934 +10:00-10:30 PM +6010 +104 +LUSE +167% +«12 +1131 +PERATION +EVENING WATCH +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +1.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, 12:3l +am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be conducte +on an irregular schedule and no more than 40 minutes apart. All observations must be documented. +REVIEWED BY MORNING WATCH LIEUTENANT +MOO NEW YORK +SPECIAL HOUSING UnIT +SDNY_00013560 +Page 081 + + +ROG BEW TORK +12:00-12:30 AM +12:30-1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00 -5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +MOO NEW TORK +30 MINUTE CHECK SHEET +ZA +TIER-H +SPECIALHOUSING UBIT +DATE: 07/29/2019 +1211 1217 +TC +133Y1234 +102 163 +R +134 +134 +202 +26u +233 +234 +303 +303- +9 < +332 +333 +ez. +404 +434 BL +505 +R +538 +531 +606 +607 +T +638 +638 +202 +746 +731 +7307- +TIME FRAME +TIME FRAME +8:00-8:30 AM +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30-1:00 PM +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM + +10 +836 +837 +Y 13 +149 +G,4 +950 +10|6 +1a7 +104T +1049 +1110 +111 +l1YI +1142 NO +1207 +1208 +1229 +1230 +129 +30 +144 +145 +218 +230 +3" +338 +BR +38° +4:00-4:30 PM +5:00 -5:30 PM +5:30-6:00 PM +6:30-7:00 PM +yiz +yur +5" +545 +546 +17 +643 +4(4 +773 +744 +8'° +845 +10:00-10:30 PM +6011 +1631 +102 +10327L +134 0348 +EVENING WATCH +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, 12:30 +am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be conducted +on an irregular schedule and no more than 40 minutes apart. All observations must be documented. +REVIEWED BY MORNING WATCH LIEUTENANT +SDNY_00013561 +Page 082 + + +DOG NEW TORK +IPECHN HOOFLOG WAIT +12:00-12:30 AM +12:30-1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00-5:30 AM +5:30-6:00 AM +6:00-8:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +MERATIONS +IEUTENANT +1201 +6202 +1234 +1234 + +138 +204 +13€ +206 +233 +2351 + +334 +40L +334 +402 +436 +432 +505: +504 +D30 D +ç02 +20% +632 +703 +734 +787 +MD +Brt +Th +Th +MD +MD +M1 +30 MINUTE CHECK SHEET +ZA +TIER-L +DATE: 07/29/2019 +TIME FRAME +8:00-8:30 AM +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +812 813 +540 841 +Te +908: 906 +939. 940 +e +1003 1004|- +1037 +10 38 ~ +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30-1:00 PM +1:00-1:30 PM +1220 +125 +119 +1.2 +25 2 +120 +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +244 +đ0 +DOO DEW TORK +SPECIA HOURAG UN +TIME FRAME +4:00-4:30 PM +5:00-5:30 PM +5:30-6:00 PM +6:30-7:00 PM +8°1 +835- +934 +gat +10:00-10:30 PM +1000 +936 +1009 + +107 110302 +134134 92 +EVENING WATCH +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +etention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:0 +.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, 12:3 +am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be conducted +on an irregular schedule and no more than 40 minutes apart. All observations must be documented. +REVIEWED BY MORNING WATCH LIEUTENANT +10 +SDNY_00013562 +Page 083 + + +MCO BEW YORK +IPEGIRL HOUSING UNIT +12:00-12:30 AM +12:30-1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00-5:30 AM +5:30-6:00 AM +6:00-6:30 AM 7 +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +IPERATIONS +JEUTENANT +12021204 07 + +101 +102 +134 13L + + +OT. +303 +304 +OT +334 +336 +OT +404 +406 +136 +432 +505 +504 +536 +532 +6T +601 +602 +634 +63€ +702 +703 +734 +736 +30 MINUTE CHECK SHEET +ZA +TIER-M +DATE: 07/29/2019 +TIME FRAME +8:00-8:30 AM +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +810 81 +842 843 +91° +9 1L +441 942 Ic +1°05 +1006 +1041 +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30- +1:00 PM +1:00-1:30 PM +1:30-2:00 PM +1040 +11S +1133 +1134 +| 223 +1224 +1248 +12451C7 +121 +122 +153 +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +-3:30-4:00 PM +19 +MOO NEW TORK +IPECINLHOUSING Un +TIME FRAME +4:00-4:30 PM +5:00 -5:30 PM +yus +433 +5'' +531 +6°1 +6 +35 +you +434 +5:30-8:00 PM +S3r +6'° +6:30-7:00 PM +6" +704 +235 +8°' +836 +236 +802 +837 +2'8 +932 +10:00-10:30 PM +905 +4834 +180L +(D3b +8V +134 И 32 +in +EVENING WATCH +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, 12:30 +am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be conducted +on an irregular schedule and no more than 40 minutes apart. All observations must be documented. +REVIEWED BY MORNING WATCH LIEUTENANT +10 +SDNY_00013563 +Page 084 + + +ROC NEW TORN +SPECIM HOUSING UNIT +12:00-12:30 AM +12:30- 1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00 -5:30 AM +5:30-6:00 AM +6:00-8:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +JEUTENANT +605 +AB4 +102 +703 +134 +13€ +202 203 +234 +23C +304 +go€ +334 +394 +402 +403 +434 +488 +508 +534 +604 +63l +202 +73ł +Coz +633 +263 +234 +Ta +30 MINUTE CHECK SHEET +ZA +TIER-J +DATE: 07/29/2019 +TIME FRAME +_ 8:00-8:30 AM +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30-1:00 PM +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +866 +834 +835 +912 +913 +943 +10/0 +944 +LiDI +1042 +1043 +10V/10s +1/35 +1136 +1201 +1202 +12RS +1226 +1247 +ver +1246 +123 +151 +338 +TIME FRAME +4:00-4:30 PM +5:00 -5:30 PM +5:30-6:00 PM +6:30-7:00 PM +10:00-10:30 PM +932 + +1034 1084) +4102 +EVENING WATCH +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +MOO BEW YORK +SPECIAL HOUSING URI +SIGNATUR +REVIEWED BY MORNING WATCH LIEUTENANT +SDNY_00013564 +Page 08: + + +ПОС ПЕШ TORK +PECIHOURDGUNIT +12:00-12:30 AM +12:30-1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00 -5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +DPERATIONS +JEUTENANT +DATE: 07/29/2019 + +Th + +162/02 +TL +132 +204 +206 +23l +23Y +12 +302 +304 +2 +33L +ЧиЧ +234 +404 +K +734 +! 731 +50г +504 +531 +533 +60C +602 + +262 +243 +236 +BE +T +30 MINUTE CHECK SHEET +ZA +TIER-K +IGO NEW TORK +SPECIEL HOUSING UG +TIME FRAME +TIME FRAME +8:00-8:30 AM +4:00-4:30 PM +835 +yor +438 +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30-1:00 PM +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +Pus +1012 +1044 +1006 +1/37 +1203 +1227 +125 +149 +203 +233 +1897 +831 +915 +946 +1013 +L045 +L/D2 +1138 +1204 +1820 +126 +36 +5:00-5:30 PM +5:30-6:00 PM +6:30-7:00 PM +10:00-10:30 PM +'S" +54L +" 13 +Г +331 19 +107 +231 +8005 +770 +7o5 +770 +g°c +84 +82 +82 +721 +934 +101L +934 +00 +1012 +1034 +(03> +UIS +434 +434 +DAY WATCI +PERATION: +EVENING WATCH +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, 12:30 +am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be conducter +on an irregular schedule and no more than 40 minutes apart. All observations must be doey +REVIEWED BY MORNING WATCH LIEUTENANT +SDNY_00013565 +Page 086 + + +MOO BEW TORE. +SPECINLHOUSING WAIT +12:00-12:30 AM +12:30-1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00 -5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7:00-7:30 AM +7:30-8:00 AM +MORNING WATCH +12'° +129: +160 +121" +1L4 +MB +210 +240 +300 +335 +You +440 +Jou +535 +62 +640 +700 +733 +178 +218 +248 +30r +340 +yor +44r +MB +MB +MB +MB +MB +MB +MB +540 +69 +645 +Jur +MS +pro +30 MINUTE CHECK SHEET +ZB +DATE: +1/30/12 +TIME FRAME +8:00-8:30 AM +808 +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +903 +94 L +10:00-10:30 AM +10:30-11:00 AM +1057 +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30-1:00 PM +1:00-1:30 PM +1:30-2:00 PM +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +i140 +1216 +1739 +103 +144 +217 +751 +7o 1 +331 +810 +не +846 +ne +705 +948 +10/3 +1054 +1116 +ve +ve. +1142 +1719 +1742 +10L +re +141 +719 +254 +pe +ne +703 +ne +TIME FRAME +4:00-4:30 PM +5:00-5:30 PM +5:30-8:00 PM +6:30-7:00 PM +410 +440 +51) +539 +614 +641 +71/ +737 +114 +9, 2 +942 +10:00-10:30 PM +014 +1034 +1/42 +413 +444 +S/S +543 +617 +643 +715 +739 +917 +PY1 +915 +944 +1017 +104L +1115 +1/45 +EVENING WATCH +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart. All observations must be +documented. +REVIEWED BY MORNING WATCH LIEUTENANT +MOO NEW TORK +SDNY_00013566 +Page 087 + + +SPECIRL HOUSING UNIT +12:00-12:30 AM +12:30-1:00 AM +1:30-2:00 AM +2:00-2:30 AM +2:30-3:00 AM +3:00-3:30 AM +3:30-4:00 AM +4:00-4:30 AM +4:30-5:00 AM +5:00 -5:30 AM +5:30-6:00 AM +6:00-6:30 AM +6:30-7:00 AM +7.00-7:30 AM +7:30-8:00 AM +MORNING WATCH +12:0212:04 +12:32 12:34 +11:38 +133 +203 +1:31 +2:01 +23 +S05 +3202 +40} +432 +502 +533 +602 +310 +33f +407 +438 +507 +B3 +70] +739 +30 MINUTE CHECK SHEET +ZA +TIER-G +DATE: 07/30/2019 +TIME FRAME +8:00-8:30 AM +8:30-9:00 AM +9:00-9:30 AM +9:30-10:00 AM +10:00-10:30 AM +10:30-11:00 AM +11:00-11:30 AM +11:30-12:00 AM +12:00-12:30 PM +12:30- 1:00 PM + + +98 919 +951 +952 +10il +1017 +1043 +13 +37 +114 +38 +to +1:00-1:30 PM +1:30-2:00 PM +34 +2:00-2:30 PM +2:30-3:00 PM +3:00-3:30 PM +3:30-4:00 PM +209 +102 +317 +TIME FRAME +4:00-4:30 PM +5:00-5:30 PM +5:30-6:00 PM +6:30-7:00 PM +10:00-10:30 PM +10.30-11:00 PM +EVENING WATCH +413 +414 +44044) +516 512 + +670 +611 +148 +190 +74) +140 +741 +8/0 +81 +842 +843 +9/5 +943 +944 +1018 +1019 + +113 +1114 +1/42|1/43 +A staff member must observe all inmates confined in a continuous locked down status, such as administrative +detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 +а.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour example, +12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be +conducted on an irregular schedule and no more than 40 minutes apart +documented. +REVIEWED BY MORNING WATCH LIEUTENANT +INGC REW TORN +SPECINLHOURING UNIT +SDNY_00013567 +Page 088 \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/1d6f074b25ca6c1368280db8e2a45e3ff8ffb0ade004d071ea60f3b4c8335103.receipt.json b/vision-fixhub/ds9-parsed-01/1d6f074b25ca6c1368280db8e2a45e3ff8ffb0ade004d071ea60f3b4c8335103.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..843150ef5f307b4d6d97b9087ef63df9b11fc68f --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1d6f074b25ca6c1368280db8e2a45e3ff8ffb0ade004d071ea60f3b4c8335103.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -26727, + "dataset": "marble-joined", + "doc_id": "1d6f074b25ca6c1368280db8e2a45e3ff8ffb0ade004d071ea60f3b4c8335103", + "engine": "marble-apple-vision", + "event_count": 208, + "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "2ecf289465fc6f48c65bd3aea10d639ce3addd0ab1d350e289d5c83cf3b13612", + "output_sha256": "b8bfe4a773f3726caf82d848ae7c34c3234650570baa2863c75d44eefccc5de0", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1d7fd7a2b315587b21a5925006c973e6800963a860a25aed6425d31b38872682.md b/vision-fixhub/ds9-parsed-01/1d7fd7a2b315587b21a5925006c973e6800963a860a25aed6425d31b38872682.md new file mode 100644 index 0000000000000000000000000000000000000000..b0d12905b19946fed46de65cd4554910615cb6f0 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1d7fd7a2b315587b21a5925006c973e6800963a860a25aed6425d31b38872682.md @@ -0,0 +1,186 @@ +U.S. Department of Justice +United States Attorney +Southern District of New York +The Silvio J. Mollo Building +One Saint Andrew's Plaza +New York, New York 10007 +June 24, 2019 +BY MAIL +Amazon.com, Inc. +Corporation Service Company +300 Deschutes Way SW, Suite 304 +Tumwater, WA 98501 +Attn: Legal Department - Subpoena +To whom it may concern: +Please be advised that the accompanying grand jury subpoena has been issued in +connection with an official criminal investigation of a suspected felony being conducted by a +federal grand jury. Pursuant to the accompanying non-disclosure order issued under 18 +U.S.C. § 2705(b), you are prohibited from notifying any subscriber or other third-party of +the existence of this subpoena for a period of 365 days from the date of the order. If you +ever plan to notify the relevant subscriber(s) of the existence of this subpoena, even after +the 365-day period, please advise me before you do so, in case the investigation remains +ongoing and the order needs to be renewed. +You are hereby directed to preserve, under the provisions of 18 U.S.C. § 2703(f)(1) +any and all information, including, if applicable, all emails/attachments or other content +information, as well as any backup copies of such data or data designated for deletion, +pertaining to the domain(s) and account(s) referenced in the accompanying subpoena, for a +period of 90 days. This letter applies only retrospectively; it does not obligate you to capture +and preserve new information that arises after the date of this letter. +Thank you for your cooperation in this matter. +Sincerely, +GEOFFREY S. BERMAN +United States Attorney +By: +Assistant United States Attorney +Telephone: + + +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +19 MAG +5896 +Grand +Subpoena +Amazon.com, Inc. dated June 20, 2019, +USAO Reference No. 2018R01618 +§ 2705(b) +Non-Disclosure Order +to Service Provider +SEALED +Upon the application of the United States pursuant to 18 U.S.C. § 2705(b): +1. The Court hereby determines that there is reason to believe that notification of +the existence of the attached subpoena will result in one or more of the following consequences, +namely, endangering the life or physical safety of an individual; flight from prosecution; +destruction of or tampering with evidence; intimidation of potential witnesses; or otherwise +seriously jeopardizing an investigation or unduly delaying a trial. +Accordingly, it is hereby ORDERED: +2. Amazon.com, Inc. (the "Service Provider") shall not, for a period of 365 days +from the date of this Order (and any extensions thereof), disclose the existence of this Order or +the attached subpoena, to the listed subscriber of the accounts referenced in the subpoena, or to +any other person, except that the Service Provider may disclose the attached subpoena to an +attorney for the Service Provider for the purpose of receiving legal advice. +3. This Order and the Application upon which it was granted are to be filed under +seal until otherwise ordered by the Court, except that the Government may without further order +provide copies of the Application and Order as need be to personnel assisting the Government in +the investigation and prosecution of this matter, and disclose these materials as necessary to +comply with discovery and disclosure obligations in any prosecutions related to this matter. +Dated: +New York, New York +JUN 2 1 2019) +S/Sarah Netburn +UNITED STATES MAGISTRATE JUDGE +SARAH NETBURN +Inited States Magistrate Judg +outhern Pistriet of New Yor + + +Grand Jury Subpoena +United States District Court +SOUTHERN DISTRICT OF NEW YORK +TO: +Amazon.com, Inc. +Corporation Service Company +300 Deschutes Way SW, Suite 304 +Tumwater, WA 98501 +Attn: Legal Department - Subpoena +GREETINGS: +WE COMMAND YOU that all and singular business and exeuses being laid aside, you appear and attend +before the GRAND JURY of the people of the United States for the Southern District of New York, at the +United States Courthouse, 40 Foley Square, Room 220, in the Borough of Manhattan, City of New York +New York, in the Southern District of New York, at the following date, time and place: +Appearance Date: +July 5, 2019 +Appearance Time: 10:00 a.m. +to testify and give evidence in regard to an alleged violation of : +18 U.S.C. §§ 371, 1591, 1594(c), 2422(b) +and not to depart the Grand Jury without leave thereof, or of the United States Attorney, and that you bring +with you and produce at the above time and place the following: +See Attached Rider +Personal appearance is not required if the requested records are (1) produced by on or before the return +date to Special Agent +, Child Exploitation and Human Trafficking Task Force, telephone: +, or via email at +; and (2) accompanied by an executed copy of the +attached Declaration of Custodian of Records. PLEASE PROVIDE IN ELECTRONIC FORMAT IF +POSSIBLE. +Failure to attend and produce any items hereby demanded will constitute contempt of court and will +subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law. +DATED: New York, New York +June 20, 2019 +United States Attorney for the +Southern District of New York +Assistant United States Attorney +Telephone: + + +RIDER +(Grand Jury Subpoena to Amazon.com, Inc., dated June 20, 2019) +A. Please provide records for all accounts associated with the following email addresses: +• jeeitunes@gmail.com +• jeffreyepsteinorg@gmail.com +• jeevacation@gmail.com +• littlestjeff@yahoo.com +• columbiadentall@yahoo.com +• jeffreyepsteinorg@yahoo.com +• jeeproject@yahoo.com +jeevacation@me.com +• jeevacation1@me.com +Records should include, but are not limited to, the following: +All subscriber identifying information, including, but not limited to: +: +: +name, username or other subscriber identity or number +address +primary and alternate telephone numbers and email addresses +date of birth +social security number +length of service +2. +Records of any IP addresses used by the subscriber during session times; +3. +Order history, including records of items purchased, billing/shipping information, and +methods of payment; +Means and source of payment for services (including any credit card or bank account +number); and +Account notes and logs, including any customer-service communications or other +correspondence with the subscriber. +B. +Please provide any and all records relating to order number 103-1737820-4508648, +including but not limited to: items purchased, shipping and billing addresses, method of +payment, and subscriber information for the purchasing account. +C. +Please provide records of all orders with the following shipping or billing addresses: +• 358 El Brillo Way, Palm Beach, Florida 33480 +• 9 East 71" Street, New York, NY 10021 +• 49 Zorro Ranch Road, Stanley, New Mexico, 87056 + + +Declaration of Custodian of Records +Pursuant to 28 U.S.C. § 1746, I, the undersigned, hereby declare: +My name is +(name of declarant) +I am a United States citizen and I am over eighteen years of age. I am the custodian of +records of the business named below, or I am otherwise qualified as a result of my position with +the business named below to make this declaration. +I am in receipt of a Grand Jury Subpoena, dated June 20, 2019, and signed by Assistant +United States Attorney +I, requesting specified records of the business named below. +Pursuant to Rules 902(11) and 803(6) of the Federal Rules of Evidence, I hereby certify that the +records provided herewith and in response to the Subpoena: +(1) were made at or near the time of the occurrence of the matters set forth in the records, +by, or from information transmitted by, a person with knowledge of those matters; +(2) were kept in the course of regularly conducted business activity; and +(3) were made by the regularly conducted business activity as a regular practice. +I declare under penalty of perjury that the foregoing is true and correct. +Executed on +(date) +(signature of declarant) +(name and title of declarant) +(name of business) +(business address) +Definitions of terms used above: +As defined in Fed. R. Evid. 803(6), "record" includes a memorandum, report, record, or data +compilation, in any form, of acts, events, conditions, opinions, or diagnoses. The term, +"business" as used in Fed. R. Evid. 803(6) and the above declaration includes business, +institution, association, profession, occupation, and calling of every kind, whether or not +conducted for profit. diff --git a/vision-fixhub/ds9-parsed-01/1d7fd7a2b315587b21a5925006c973e6800963a860a25aed6425d31b38872682.receipt.json b/vision-fixhub/ds9-parsed-01/1d7fd7a2b315587b21a5925006c973e6800963a860a25aed6425d31b38872682.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..18fef8e5a90d19363d062392185c1408fb917d3a --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1d7fd7a2b315587b21a5925006c973e6800963a860a25aed6425d31b38872682.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -60, + "dataset": "marble-joined", + "doc_id": "1d7fd7a2b315587b21a5925006c973e6800963a860a25aed6425d31b38872682", + "engine": "marble-apple-vision", + "event_count": 5, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "a5e5ab0fb6d5145ec756fb19fbf4b7000a30fd020e3f74efe1d3b6489970f5bd", + "output_sha256": "197ce8655444cef5cfc87dfe959cd29c2a722faad943f59fe4d0d2c99e677f23", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1d80079d094e1374367e641555100e0daee820e9e4c3d1ef0f77fa9458ee3be1.md b/vision-fixhub/ds9-parsed-01/1d80079d094e1374367e641555100e0daee820e9e4c3d1ef0f77fa9458ee3be1.md new file mode 100644 index 0000000000000000000000000000000000000000..fa41f4f5c66731ff9b3dbf40c8fc5ec94ec90121 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1d80079d094e1374367e641555100e0daee820e9e4c3d1ef0f77fa9458ee3be1.md @@ -0,0 +1,23 @@ +From: +To: " +(USANYS) [Contractor]" < +(USANYS)" +Subject: FW: Responsive chats +Date: Tue, 22 Sep 2020 14:20:36 +0000 +Attachments: 1B37_Chatslof2 +_Translated_-_Formatted.xIsx +(USANYS)" +(USANYS)" < +FYI - I received these yesterday. FBI marked some chats responsive; however, none of them fall within our responsive date +range. +From: +Sent: Monday, September 21, 2020 3:42 PM +To: | +(USANYS) [Contractor] ‹ +Cc: +(NY) (FBI) < +Subject: Responsive chats +Hi +Here are more chats from the translators. The following chats were responsive: +Let me know if you have any questions! +Thanks, diff --git a/vision-fixhub/ds9-parsed-01/1d80079d094e1374367e641555100e0daee820e9e4c3d1ef0f77fa9458ee3be1.receipt.json b/vision-fixhub/ds9-parsed-01/1d80079d094e1374367e641555100e0daee820e9e4c3d1ef0f77fa9458ee3be1.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..6b55407358c721d723038f0f6f1f47b035ff3252 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1d80079d094e1374367e641555100e0daee820e9e4c3d1ef0f77fa9458ee3be1.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "1d80079d094e1374367e641555100e0daee820e9e4c3d1ef0f77fa9458ee3be1", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "04ad0aaa512fc1a3d72c7547609555b715218896864e67eccf6f2597e47b2b5a", + "output_sha256": "59306915dd845fbd59731d3fa9ed60a036b34b64a6894ba8e9260471ce539faf", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1da979aea030e6169eb29adcf9c31f4dabc7b46bba8d66ab723c382396ace679.md b/vision-fixhub/ds9-parsed-01/1da979aea030e6169eb29adcf9c31f4dabc7b46bba8d66ab723c382396ace679.md new file mode 100644 index 0000000000000000000000000000000000000000..2721f9794f9714bad273a3948f0ee7f05490ea81 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1da979aea030e6169eb29adcf9c31f4dabc7b46bba8d66ab723c382396ace679.md @@ -0,0 +1,141 @@ +FD-302 (Rev. 5-8-10) +- 1 of 3- +FEDERAL BUREAU OF INVESTIGATION +OFFICIAL RECORD +Date of entry +08/29/2019 +EMPLOYEE I7 +• was interviewed at 26 Federal +Plaza, +New York, NY 10278. Also present during the interview was DEPARTMENT OF +JUSTICE OFFICE OF THE INSPECTOR GENERAL (DOJ-OIG) Special Agent +• After being advised of the identities of the interviewing Agents, +that the interview was voluntary, and that lying to a federal agent is a +crime, lot +provided the following information: +EMPLOYEE 17 +has worked for the BUREAU OF PRISONS (BOP) since 1994 with one +break in service. +EMPLOYEE +plans on retiring in approximately 7 months. +EMPLOYEE 17 +by him. +account. +confirmed that the email sent from to @bop. gov was composed +EMPLOYEE TO +was +not aware of anyone else having access to his email +EMPLOZEE TA +obtained the name of DOJ-OIG employee +from another BOP +employee, +works in the Community Corrections +Department at the METROPOLITAN DETENTION CENTER (MDC) in Brooklyn, New York. +EMPLOYEE 17 +sent +an email asking for the name of a DOJ-OIG employee he +could contact to make the complaint. Prowe +" met +while working at +the FEDERAL CORRECTIONAL INSTITUTE, DANBURY in Danbury, Connecticut around +2000. +EMPLOYEE 1' +current post at the METROPOLITAN CORRECTIONAL CENTER (MCC) is at +the rear gate. +BELAYED 17 +has worked there for several months. Some of PLoYeE t +primary responsibilities at the rear gate are to check vehicles making +deliveries for any contraband, scan in packages, and to check the gate +passes of inmates who have them. +PLOYEE! has an office at his post but +spends most of his time moving around. +BOP inmate STEVEN LOPEZ has a gate pass, meaning LOPEZ can enter and exit +Investigation on +08/28/2019 +at New York, New York, United States (In Person) +File # +Date drafted 08/29/2019 +by +This distinent outains noite recommendations nor conclusions of the FBI. I is the property of the FBl and is loaned to your agency; it and is contents are not +to be distributed outside your agency- + + + +FD-302a (Rev. 5-8-10) +Continuation of FD-302 of (U) Interview of EMPLOYEE IT +, On +08/28/2019 +_, Page +2 of 3 +MCC to complete whatever task LOPEZ is assigned. LOPEZ also helps other +inmates with their jobs. Typically LOPEZ leaves through the lobby to the +Warden's complex and performs janitorial duties there. LOPEZ started this +job approximately three weeks ago. DIET has frequent interactions with +LOPEZ because floret 1] has to check LOPEZ's gate pass every time LOPEZ enters +or exits the gate. BEVE +would usually make small talk with LOPEZ during +these interactions. +On or about August 15, 2019, at approximately 10:30am, LOPEZ approached +EMPLOYEE 17 +post at the rear gate with approximately three large bags of +shredded +paper. LOPEZ told BELOW I +that "They are shredding everything back +there." LOPEZ said there was a white man with a Southern accent who was +involved in the document shredding. +was unfamiliar with anyone at +MCC that fit that description. Move +surmised that since he did not know +who the white man with the Southern accent was, he must have been part of +the BOP After Action team related to the JEFFREY EPSTEIN suicide. LOPEZ told +EMFLOYEE T7 +he heard someone say, "Make sure you get that box over there too." +MAPLOYEE +thought he remembered LOPEZ telling him that someone asked LOPEZ to +help shred documents as well. +EMPLOYEE I7 +did not know for certain where the +shredded documents originated +from. Shredded documents are thrown out on a +fairly regular basis through +EMPLOYEE IT +post at the rear gate, but we! +thought that there were more shredded documents than usual during this +incident. LOPEZ also told PArDon +* that LOPEZ thought this was more than the +usual amount. +ENPLOYEE 17 +saw LOPEZ a few days later with additional shredded +paper to throw out. +EMPLOD +never witnessed anyone physically shredding documents. BROTH +never looked through the shredded documents that LOPEZ threw out. No one +told +EMPLOYEE 17 +that the shredded documents were related to EPSTEIN. No one +told +BELOVELY +that the BOP After Action Team looking into the EPSTEIN suicide +was shredding documents. +EMPLOYEE T +is still posted at the rear gate as his primary job. +ERFLOTEE 17 +called someone at the FBI on or about August 23, 2019 to file a +report about this incident. He spoke with a female, but could not remember +what +office or number he called. +EMPLOYEE 11 +heard third-hand that an "Officer +" told former MCC Warden +SONY _00007761 + + + +FD-302a (Rev. 5-8-10) +Continuation of FD-302 of (U) Interview of EMPLOYEE IT +08/28/2019 +LAMINE N'DIAYE that EPSTEIN should be confined in the 10 South wing of MCC. +RIA +PROTECTED MATEI +SDNY_00007762 + diff --git a/vision-fixhub/ds9-parsed-01/1da979aea030e6169eb29adcf9c31f4dabc7b46bba8d66ab723c382396ace679.receipt.json b/vision-fixhub/ds9-parsed-01/1da979aea030e6169eb29adcf9c31f4dabc7b46bba8d66ab723c382396ace679.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..b3b227456a84282d4177659b2f6c69d06589f11b --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1da979aea030e6169eb29adcf9c31f4dabc7b46bba8d66ab723c382396ace679.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -75, + "dataset": "marble-joined", + "doc_id": "1da979aea030e6169eb29adcf9c31f4dabc7b46bba8d66ab723c382396ace679", + "engine": "marble-apple-vision", + "event_count": 6, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "da47bdae56ea96fbfce0ce507a2047d5a843397192309fbc1536fc3b94871234", + "output_sha256": "49d68bb9bab8721229a1dab6a94acd913331433dc50d4691862c6682a0ed9945", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1dbe44e90afd6f3e46cec1dfd702b4a74e2eb61efdae0c5ba73e69bb56054db0.md b/vision-fixhub/ds9-parsed-01/1dbe44e90afd6f3e46cec1dfd702b4a74e2eb61efdae0c5ba73e69bb56054db0.md new file mode 100644 index 0000000000000000000000000000000000000000..c72bcc4f1b56bc4489709490bb5dfed18b4cdcaa --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1dbe44e90afd6f3e46cec1dfd702b4a74e2eb61efdae0c5ba73e69bb56054db0.md @@ -0,0 +1,19 @@ +To: +NYM/Lieutenants[NYM/Lieutenants@bop.gov]; NYM/Psychology Svcs[NYM/PsychologvSvcs@bop.gov]: +NYM/Psychology Svcs~ NYM/Psychology Svcs~[NYM/PsvchologySvcs~@bop.gov] +From: +Sent: +Subject: +Mon 7/8/2019 10:00:02 AM +Lieutenant's log and daily activities report for July 7, 2019. +TEXT.htm +LIEUTENANT'S LOG 07-07-2019.docm +Daily Activities Report 7-07-2019.docx +Lieutenant's log and daily activities report for July 7, 2019. +L. +Lieutenant +Federal Bureau of Prisons +Metropolitan Correctional Center +New Vark, N.Y. 10007 + +SDNY_00011306 \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/1dbe44e90afd6f3e46cec1dfd702b4a74e2eb61efdae0c5ba73e69bb56054db0.receipt.json b/vision-fixhub/ds9-parsed-01/1dbe44e90afd6f3e46cec1dfd702b4a74e2eb61efdae0c5ba73e69bb56054db0.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..edd84c5d000e08beb04e0f5b75b551ee5d05b122 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1dbe44e90afd6f3e46cec1dfd702b4a74e2eb61efdae0c5ba73e69bb56054db0.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "1dbe44e90afd6f3e46cec1dfd702b4a74e2eb61efdae0c5ba73e69bb56054db0", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.stamp-stripping.confidential\"]", + "idempotent": true, + "input_sha256": "8eac96f5b7d20448adf4ff80086e52c5ee332b05cc0912a264a6cccdb2ca2d83", + "output_sha256": "7b9ef97635038822c26febc8b2828cad09acc3f74b7eac52b9673cf4bb22e14c", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1dc24e7328569dedf2a21744aea6a6c6088f8055fa67a74d48219ad2ccac418f.md b/vision-fixhub/ds9-parsed-01/1dc24e7328569dedf2a21744aea6a6c6088f8055fa67a74d48219ad2ccac418f.md new file mode 100644 index 0000000000000000000000000000000000000000..212fcde1f05dfa3c1184624f8adefcd3085ed838 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1dc24e7328569dedf2a21744aea6a6c6088f8055fa67a74d48219ad2ccac418f.md @@ -0,0 +1,37 @@ +1AMDOJSA/CardholdersApplicationsSearch/CardholdersApplications/cardhclderld=74971&accountAppld=0 +• 8c +Search.... +nternal White Pages DO/Net E DOJ Portal Enterprise Apps a For Employees +* Forms IPTV a Learn DOJ @ WebTA & certla CSAM +d) remedy +@ Travel +19 +Search Reports lamDOJ +Current PIV Card +ioners/Federal Prison System +rican +Issuance ID: 3 +Serial: 4820502B122426118006 +CHUID Expires: 7/10/2024 12:00:00 AM +CHUID Status: Activated +FASC-N: 15000005208490111003061367115001 +UPN: +PIV Auth Certificate Expires: 7/17/2022 2:33:47 PM +Digital Signature Certificate Expires: 7/17/2022 2:33:47 PM +Certs Expire: 7/17/2022 2:33:47 PM +First Issued: 3/11/2015 12:56:29 PM +Card Certs: 15 +PIVAuth Cert UPN: +2 +Sponsorship +SDNY_MT_00000211 +Status: Sponsored +Last Update: 7/10/2019 11:08:35 AM +Person ID: 1003061367 +Sponsor Organizational Identifier: Bureau of Prisoners/Federal Prison System +Current Sponsor: MERCEDES IDETTA BECKETTSIMMONS (1000488186) +Credential Option: PIV credential to be issued +Shipping Address Code: 10517 +Shipping Address Name: DOJ - 150 PARK ROW +UPN: +Original Sponsorship Date: 9/4/2014 12:00:00 AM diff --git a/vision-fixhub/ds9-parsed-01/1dc24e7328569dedf2a21744aea6a6c6088f8055fa67a74d48219ad2ccac418f.receipt.json b/vision-fixhub/ds9-parsed-01/1dc24e7328569dedf2a21744aea6a6c6088f8055fa67a74d48219ad2ccac418f.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..344874b710bf7188aacf2a5bb330d7ef0f1ca355 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1dc24e7328569dedf2a21744aea6a6c6088f8055fa67a74d48219ad2ccac418f.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "1dc24e7328569dedf2a21744aea6a6c6088f8055fa67a74d48219ad2ccac418f", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "1626dd1d3c14bf4ba1184ffd9433ae8f8083b31dece8a705c8f4c154a6bb077f", + "output_sha256": "b93571b9c1284613f1424dc179d04d5c068309e6cf90088a8f83915716c53cf7", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1de607168eaa62d02a8ddc9ed6c4712d074681b7440a2a8d3f0b0ea08e6728d9.md b/vision-fixhub/ds9-parsed-01/1de607168eaa62d02a8ddc9ed6c4712d074681b7440a2a8d3f0b0ea08e6728d9.md new file mode 100644 index 0000000000000000000000000000000000000000..ebd27cc30e3380733704a1c17fe32cfa81cebce4 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1de607168eaa62d02a8ddc9ed6c4712d074681b7440a2a8d3f0b0ea08e6728d9.md @@ -0,0 +1,143 @@ +From: ' +To: +(CRM)". +USANYS)" +Ce: +(London)'i +Subject: RE: Independent: Prince Andrew: Refusal to talk to Epstein investigators 'straining relations +between UK and America' +Date: Tue, 24 Aug 2021 16:34:32 +0000 +Inline-Images: image001 png +Great. I will send it on. +Best, +U.S. Department of Justice Attaché - London +United States Embassy +3 Nine Elms Lane +condon SWU zUS +From: | +| (USANYS) [ +Sent: Tuesday, August 24, 2021 4:06 PM +To: +(CRM) F +Cc: +(cRM)| +Subject: RE: Independent: Prince Andrew: Refusal to talk to Epstein investigators 'straining relations between UK and +America' +Please see attached written consent from +Best, +attorney. +From: 1 +(CRM) +Sent: Thursday, August 12, 2021 5:49 AM +(USANYS) + + +Co +|(CRM) - +Subject: RE: Independent: Prince Andrew: Refusal to talk to Epstein investigators 'straining relations between UK and +America' +We also just got the following questions on the new MLA request. I have given preliminary responses +(as noted), but want to confirm with you. +1. +Has the witness consented to the release of the information requested? If so, please a copy of the written +consent. +The witness has not been asked for written consent. However, counsel for the witness has encouraged the prosecutors to seek +this information. In can be inferred from the statements of counsel that the witness has consented. +2. +did the witness apply to and what was the year of her application/attendance? +The team was uncertain of which college (I had asked this). Is there a central office at +which can be queried for all +colleges? +3. How, if at all does this request relate to/impact the material witness MLA request? +This request relates to the charged Maxwell case going to trial. The material witness MLA requests relates to a broader +investigation. +4. What were the sentences which applied at the date of the offences (1994 - 2004), as the penalties provided +with the request apply to conduct that occurred after 27 July 2006? +I will check with the case team to confirm specific periods. The sentences will be greater than one year and less than life (with +no death penalty involved), so is there a need to be more precise? +U.S. Department oj Justice Attaché - London +United States Embassy +33 Nine Elms Lane +London SW11 7US +From: +(CRM) +Sent: Thursday, August 12, 2021 9:03 AM +To: +(USANYS) +Cc +America' +(CRM) +(CRM) + +Subject: FW: Independent: Prince Andrew: Refusal to talk to Epstein investigators 'straining relations between UK and +You guys have a moment for a brief call this morning? The Ambassador is concerned about the +attached story, and I wanted to see if you have any sense of where this is coming from. Is this coming +from victims' counsel? Anyone in your shop decided to push this? + + +The quote from the State Department yesterday in the NY Times was unhelpful (and I let them know +it - I think it came from someone spouting off on the European Desk). +I also had the following email from the UKCA yesterday: +We are aware that a civil case has been filed in New York concerning the Epstein investigation with +the material witness as the defendant. Please can you let us know what impact this has on the +material witness's current status, as a witness, in the criminal investigation and in relation to the MLA +request. +I think they are asking whether, in light of the recent allegations, +s now a suspect instead +of a witness (in British parlance). I was going to respond with one word "none" but thought I should +check first. +I am around today whenever you can chat. The earlier the better because the Amb is keen to sort this +out. +Thanks, +U.S. Department of Justice Attaché - London +United States Embassy +33 Nine Elms Lane +London SW11 7US +From this morning's Independent +Fears issue over Duke of York could affect wider efforts to collaborate on high-profile legal cases. +US authorities are growing increasingly frustrated with Prince Andrew's failure to cooperate into their probe +into the network surrounding convicted sex offender Jeffrey Epstein, exacerbating tensions between +Washington and London, The Independent understands. +People familiar with authorities' investigations into Mr Epstein's business affairs told The Independent that the +lack of information-sharing had caused diplomatic strain, with US law enforcement and diplomats raising the +matter with their British counterparts. +They said a new civil case brought by 1 +, alleging the Duke of York had sexually abused her, will add +further strain over the issue, along with the prosecution of Esptein's former girlfriend Ghislaine Maxwell, who is +set to go on trial for sex trafficking charges later this year. + + +There are fears that the issue could sour broader efforts to collaborate on high profile legal cases. +The prince has consistently denied the allegations, while Ms Maxwell denies the charges against her. +The lack of cooperation now spans three years of reported attempts by the US authorities to gather facts from +the royal who, in a statement from 2019, said he would be willing to help US law-enforcement with +investigations. However, in January last year, Manhattan US attorney Geoffrey Berman said the country's +authorities had received "zero cooperation" from the prince, who no longer carries out royal duties. +In June 2020, The Wall Street Journal reported that an application had been made by the Department of Justice +(Do) under a US-UK mutual legal assistance treaty in order to win cooperation from the Duke of York. +This avenue has not been effective, according to sources. They contend that Prince Andrew has failed to share +details of the extent of his ties to Mr Epstein, whose death in a Manhattan prison in 2019 was ruled a suicide. +The extent and nature of Mr Epstein's financial network is still being explored in several jurisdictions, including +the US. +Of particular interest to the US authorities is how money transfers may be linked to the movement of young +women and girls. The various interested bodies, including the FBI, believe these may offer insights into ongoing +organised criminal operations. +These probes are significant not only for legal proceedings related to Epstein, but also to ongoing investigations +surrounding Ms Maxwell, who is currently in prison awaiting trial on sex-trafficking charges. +It is also alleged that multiple authorities are seeking details of flights that the Duke of York used to visit Epstein +in a range of locations, so that they can better understand how people may have travelled into and out of the +disgraced financier's orbit. The authorities' interests are understood to include multiple trips by the royal to +Epstein's Caribbean island, Little St James, as well as Florida and New York. +Last year, prosecutors in the US Virgin Islands, which includes Little St James, alleged Mr Epstein abused +hundreds of young women and girls up until 2018. +The frustration over the Duke of York's lack of cooperation is said to be amplified by the fact that it appears +unlikely that the royal would be extradited. His cooperation would therefore be a matter of bolstering +diplomatic relations and sharing any information which could help avoid future trafficking of young women and +girls. +The lawyer representing Ms +has accused the prince, who is facing the Queen after arriving at Balmoral +on Tuesday, of "stonewalling" appeals for information after the 15-page lawsuit was filed in New York. The +prince is the only defendant in the suit, which alleges she was "lent out for sexual purposes" by Epstein. +Boies said his client ultimately wanted "vindication" from the legal action. +In 2019, Prince Andrew told the BBC that he had not had sex with +said that he had no recollection of having met her. +"It didn't happen," he said. He also diff --git a/vision-fixhub/ds9-parsed-01/1de607168eaa62d02a8ddc9ed6c4712d074681b7440a2a8d3f0b0ea08e6728d9.receipt.json b/vision-fixhub/ds9-parsed-01/1de607168eaa62d02a8ddc9ed6c4712d074681b7440a2a8d3f0b0ea08e6728d9.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..8eccb723e5b8f77f5aead6ca17a1ff844520f5cb --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1de607168eaa62d02a8ddc9ed6c4712d074681b7440a2a8d3f0b0ea08e6728d9.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -48, + "dataset": "marble-joined", + "doc_id": "1de607168eaa62d02a8ddc9ed6c4712d074681b7440a2a8d3f0b0ea08e6728d9", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "86a946688fbacad8ca1d8735731d99dcf49206a1b4bb320dc01a46b352762a0b", + "output_sha256": "82d59a817c922d89eac29774e62ba701e90784dacd5f32392203760ce76f906a", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1e0ac4f1de22dff336dc15808a82e0c7ffd5c772bb0373df69d8fe2c56a2d4d3.md b/vision-fixhub/ds9-parsed-01/1e0ac4f1de22dff336dc15808a82e0c7ffd5c772bb0373df69d8fe2c56a2d4d3.md new file mode 100644 index 0000000000000000000000000000000000000000..39d29bb0c3942b019cd50ffa98911dadf8315d7d --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1e0ac4f1de22dff336dc15808a82e0c7ffd5c772bb0373df69d8fe2c56a2d4d3.md @@ -0,0 +1,75 @@ + + + +1" December 2020 +The Honorable Alison J. Nathan +United States District Court +Southern District of New York +United States Courthouse +40 Folev Sauare +New York, NY 10007 +PRIVATE AND CONFIDENTIAL +Your Honor +Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) +I am sending this letter of support knowing it is to be presented to the Court in connection willi Gilsiame +Maxwell's renewed bail application. The content of this letter is true and within my knowieuge. +I first met Ghislaine Maxwell in 1988 when she employed me to work for her at Maxwell's Corporate Gifts +in London. I left in 1989, but we remained in touch and became close friends and have been in regular +contact ever since. I staved with her in her apartment in New York for some weeks immediatelv after her +father's death in 1991 and have visited with her on numerous occasions and see her whenever she travels +to the UK. She has also staved with me and mv familv at our home in Wiltshire. +I have always found Ghislaine to be open, honest and trustworthy in all her dealings and therefore had no +hesitation when she asked me to be a Director of The TerraMar Charity in the UK and allowed my UK home +address to be used as the Charitv's registered address. Ghislaine is transparent in evervthing she does +including in her financial dealings that I personally witnessed as a Trustee of TerraMar which, following +unwarranted press speculation last year, was investigated by the Charity Commission. No wrongdoing was +found whatsoever but the Charity was subsequently dissolved as the connection with Ghislaine allied to +relentless media pressure made it an untenable enterprise. +Ghislaine knows my family well, I had no hesitation in allowing my daughter (when she was 16 and again at +18) to stay with her in the US and UK, when we both visited. All three of my children (boy twins aged 27 +and a girl, 21) have known her all their lives, love and adore her and she has always been a great support +to them. +Speaking for myself and my family I can confirm that we stand absolutely behind her in her fight to clear +her name. I have never known Ghislaine to be involved in anything unlawful and she has always been a +loyal, genuine and generous friend. Nor have I ever witnessed any inappropriate behaviour on her part. +- 1- + + +Page 2-Re: United States v. Ghislaine Maxwell. 20 Cr. 330 (AJN) +In 2017 | lived with Ghislaine and her familv for a few weeks. helping move them into their house. Her +Spouse. Steochildren and Mother-in-Law subseauentlv came to stav with mv familv in the ÜK in August +2018. When my husband, 1 and our daughter were all staying with them in August 2017, her Spouse's exwife came and had dinner at the house with us. It was a wonderful example of divorced parents making +sure that the children's welfare is put before everything else. Ghislaine is a fun, considerate and loving +Stepmother, making sure that the children feel safe and secure. It is very obvious that they love her +deeply. They are an incredibly strong and close family unit. +Ghislaine has lived in the United States since the beginning of the 1990s and has had to deal with +fluctuating amounts of press interest in her life. This was notwithstanding her huge and understandable +mistrust of the media which started with the fall-out from the sudden death of her Father and has +continued to this day. Despite the tremendous ramping of press interest in her following the death of +Jeffrey Epstein in August 2019 Ghislaine remained living in the States. This was primarily so that she could +be with her family but also to ensure she was available to deal with any civil or even criminal allegations +arising from her past connection to Epstein should these arise. When the press intrusion became too +intense, she removed herself from the family home to protect her Spouse and his children. Any reports to +the effect Ghislaine took that decision to evade law enforcement are as far from the truth as they are +offensive. +My husband and I experienced first-hand what it felt like to be on the receiving end of such relentless press +intrusion in our own lives in the UK. We had to leave our home for a week because the press presence was +so aggressive and so constant: we had phone calls, emails, letters, visits - and everyone in our village was +spoken to. Even my parents and children were harassed. I look after the running of Ghislaine's house in +London and today still there are journalists knocking on the door and filming the house. Ghislaine was +terrified of being found by the press, or by deranged individuals and conspiracy theorists who threatened +to harm her. A UK newspaper (The Sun) put up a bounty for information leading to her discovery. She had +to isolate herself to protect her family and friends as much as herself. I spent a couple of days and nights +with her in October 2019 - we went for a walk and 1 directly experienced for myself the pressure and fear +she was living under. Any car or person that went by the house, or any unusual sounds she heard when we +were in the house, she thought the press or bounty hunters might have found her. She was genuinely +terrified for her safety and this ended up making me feel terrified too. +Ghislaine has always met problems head on and has never been afraid of the truth. I have personally +witnessed this at many points in her life when she has had to pick herself up and rise to the challenge in +front of her. Ghislaine has been a constant and very important part of my life for 32 years and I have no +doubt - particularly if she is permitted properly to prepare her defence in a non-custodial environment +conducive to that end (the primary rationale for her renewed bail application) - that she will attend her +trial to fight these heinous charges and to clear her name. +Respectfullv +Katie Vaughan-Edwards +- 2- diff --git a/vision-fixhub/ds9-parsed-01/1e0ac4f1de22dff336dc15808a82e0c7ffd5c772bb0373df69d8fe2c56a2d4d3.receipt.json b/vision-fixhub/ds9-parsed-01/1e0ac4f1de22dff336dc15808a82e0c7ffd5c772bb0373df69d8fe2c56a2d4d3.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..ff157605bd93e32d64b03e2f88a06f136dc42827 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1e0ac4f1de22dff336dc15808a82e0c7ffd5c772bb0373df69d8fe2c56a2d4d3.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -47, + "dataset": "marble-joined", + "doc_id": "1e0ac4f1de22dff336dc15808a82e0c7ffd5c772bb0373df69d8fe2c56a2d4d3", + "engine": "marble-apple-vision", + "event_count": 5, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "58d4ea43bd8d08a077f1b9af7b270342a4ad4d088830c40c703c2c770692171a", + "output_sha256": "8ac3a2ad1acd54f631412ee6e2b013a632074ad77a6a652f2d53c0ad7e93930e", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1e0c81b243db370481f9a3b80c8acbf4b76490a8ce4a58ed9ed26349775be9ed.md b/vision-fixhub/ds9-parsed-01/1e0c81b243db370481f9a3b80c8acbf4b76490a8ce4a58ed9ed26349775be9ed.md new file mode 100644 index 0000000000000000000000000000000000000000..9de38c58174af35e91bdf7600dee72177043c9c5 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1e0c81b243db370481f9a3b80c8acbf4b76490a8ce4a58ed9ed26349775be9ed.md @@ -0,0 +1,110 @@ +From: +To: +USANYS)" • +(OIG)" • +Cc: +Subject: FW: MCC Visit Thursday +Date: Thu, 15 Aug 2019 13:05:53 +0000 +(NY) (FBI)" +Can you guys assist with this? +From: +To: +Sent: Thursday, August 15, 2019 8:54 AM +pbop.gov»; +(USANYS) < +Subject: Re: MCC Visit Thursday +Sorry about the abrupt prior email. I was hoping to get the names so we could ensure we have enough vests for everyone. +>>> +USANYS)" < +• > 8/14/2019 10:56 PM >>> +I just found out that additional law enforcement agents will be joining but I don't know how many and who. I asked. I'm +sorry! +On Aug 14, 2019, at 12:49 PM, +(USANYS) < +wrote: + +Resending, I got an error last time. +From: +| (USANYS) +Sent: Wednesday, August 14, 2019 12:41 PM +To: +Cc: +USANYS) < +Subject: RE: MCC Visit Thursday +- Principal Deputy Attorney General +Advisor at AG's office +- US Attorney +Deputy US Attorney +Chief of the Criminal Division, SDNY +• Counsel to the US Attorney +Chief, Public Corruption Unit, SDNY +- Chief, Public Corruption Unit, SDNY +AUSA +AUSA +• +From: +Sent: Wednesday, August 14, 2019 12:26 PM +To: +(USANYS) ‹ +Cc: +Subject: RE: MCC Visit Thursday +Hi +Not a problem. I will add them to the list. Do you have everyone's titles? +I will advise the Warden of the request that he accompany us on the tour. +Thank you, + + +Supervisory Statt Attorney +CLC New York +Metropolitan Correctional Center +150 Park Row +New York, New York 10007 +>>> +(USANYS)" < +Two additional people from DOJ will join the visit: +> 8/14/2019 12:17 PM > > > +In addition, +has asked that the new acting warden join the tour. Let me know if you have any questions, thanks. +From: +Sent: Tuesday, August 13, 2019 4:03 PM +To! +(USANYS) < +Cc: / +(USANYS) < +Subject: RE: MCC Visit Thursday +If it is not too much of an imposition, we ask that all visitors come to our front lobby for screening before admission. +Thanks! +>>> +[USANYS)" < +Yes, thank you. Where should we go? +From +Sent: Tuesday, August 13, 2019 3:38 PM +To: +Cc:I +(USANYS) < +Subject: Re: MCC Visit Thursday +Hi L +It should not be a problem. Does 10 am work for Mr. +Thank you, +> 8/13/2019 3:58 PM > > > +(USANYS) < +and the rest of his staff? +Supervisory Staff Attorney +CLC New York +Metropolitan Correctional Center +150 Park Row +New York, New York 10007 +>>> +(USANYS)" < +The list of visitors from our office is below: +> 8/13/2019 2:05 PM >>> + + +As discussed, we would like to see the 2nd floor pscyh observation and suicide watch area; the gth floor SHU, and +Epstein's cell, which we understand to still be cordoned off. As discussed, we would appreciate if only MCC legal would +escort us, and we will not speak to any of the guards present given the ongoing investigations. Please give me a call with +any questions, and let us know what time and where we should go, and if it would be easier for us to enter via the 3rd +floor bridge. +Assistant United States Attorney +Southern District of New York +Tel: diff --git a/vision-fixhub/ds9-parsed-01/1e0c81b243db370481f9a3b80c8acbf4b76490a8ce4a58ed9ed26349775be9ed.receipt.json b/vision-fixhub/ds9-parsed-01/1e0c81b243db370481f9a3b80c8acbf4b76490a8ce4a58ed9ed26349775be9ed.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..ca5dd004600ac9616164ee6a63ee4df57e7b00aa --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1e0c81b243db370481f9a3b80c8acbf4b76490a8ce4a58ed9ed26349775be9ed.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -36, + "dataset": "marble-joined", + "doc_id": "1e0c81b243db370481f9a3b80c8acbf4b76490a8ce4a58ed9ed26349775be9ed", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "bcd11cc76555f04346555d0401e20eca9a267c4d703d7ca3bea9a4c4506b6cae", + "output_sha256": "bf45165168786e3e8cbbca486b0338f78220bcf23517518ddb6c86c098b9c117", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1e156c8f089ea1db2b56aece40b017f543d38110b227db3b1c22486e05a94ef5.md b/vision-fixhub/ds9-parsed-01/1e156c8f089ea1db2b56aece40b017f543d38110b227db3b1c22486e05a94ef5.md new file mode 100644 index 0000000000000000000000000000000000000000..3a77eaa1d2b6274adeeda28dfd3640b78e0f7191 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1e156c8f089ea1db2b56aece40b017f543d38110b227db3b1c22486e05a94ef5.md @@ -0,0 +1,655 @@ +MCU +MUNICIPAL CREDIT LINION +PO. BOX 3205, NEW YORK. NY 10007-3205 +212) 693 4900 OR (800) 323-6713 9H15 ++ 0310263 000454573 OMCU13 0630103 +BROOKLYN NY 11207-1012 +Your Account Summary +Deposits +Primary Share +Checking +TOTAL DEPOSITS +Loans +Personal +TOTAL LOANS +$ +$ +$ +Balance +1.00 +876.08 +877.08 +Balance +684.58 +684.58 +PRIMARY SHARE +Transaction +May 01 +Previous Balance +May 31 +New Balance +Date Transaction +May 01 Previous Balance +May 01 Withdrawal - Transfer +Account Number: +Statement Period: +05/01/19 - 05/31/19 + +MCU News & Promotions +true +0000 3358 1895 2453 +3: 03/17 +8. A. MEMBER +E0122 +Life can truly +VISA +BE REWARDING. +— MCU TRUE Rewards VISA® Card +MCU hear.rg/truerewards +M +Go paperless +With NYMCU® Online +Banking and eStatements +Manage your accounts, reduce clutter +and protect your identity. +Visit nymcu.org today! +Withdrawals +Deposits +Withdrawals +-12.00 +Deposits +S 01 +Balance +1.00 +1.00 +S 02 +Balance +1,138.63 +1,126.63 +www.nymcu.org + + +Transaction +To WASHINGTON, CATIA XXXXXXXXX Share 02 +Mobile Transfer. +May 01 +Withdrawal - VISA - Visa Purchase +04/30 SHELL SERVICE STATION BROOKLYN NY +May 01 +Withdrawal - VISA - Visa Purchase +04/30 RITE AID STORE - 4202 NEW YORK NY +May 02 +Withdrawal - VISA - Visa Purchase +05/01 POPEYE'S #4499 BROOKLYN NY +May 02 +Withdrawal - POS #521693 +MCDONALD'S F27377 1380 BROADWAY BROOKLYN +May 02 +Withdrawal - ACH - Credit One Bank +TYPE: Payment ID: 912240213 +CO: Credit One Bank +May 03 +Withdrawal - VISA - Visa Purchase +05/02 RITE AID STORE - 4202 NEW YORK NY +May 03 +Withdrawal - ATM - #276029 +EFT 1293 Bushwick Ave Brooklyn NY +May 03 +Withdrawal - ATM Fee +EFT 1293 Bushwick Ave Brooklyn NY +May 03 +Deposit - ACH - AGRI TREAS 310 +TYPE: FED SAL ID: 9101036009 +CO: AGRI TREAS 310 +May 03 +Withdrawal - ACH - MACYS +TYPE: ONLINE PMT ID: CITICTP CO: MACYS +May 03 +Withdrawal - ACH - STATE FARM +TYPE: LOAN PYMT ID: 1071174431 +CO: STATE FARM +May 03 +Withdrawal - VISA - Visa Purchase +05/03 BP#2566966SUNRISE GAS S BROOKLYN NY +May 04 +Withdrawal - ATM - #008952 +PAI ISO 139 CHRYSTIE ST NEW YORK NY +May 04 +Withdrawal - VISA - Visa Purchase +05/03 SQC*CASH APP TANIA 8774174551 CA +May 04 +Withdrawal - VISA - Visa Purchase +05/03 SQC*CASH APP TATIAN 8774174551 CA +May 04 +Withdrawal - VISA - Visa Purchase +05/03 SQC CASH APP TATIAN 8774174551 CA +May 04 +Withdrawal - VISA - Visa Purchase +05/03 SOC*CASH APP TANIA 8774174551 CA +May 04 +Withdrawal - ATM - #382054 +EFT 1293 Bushwick Ave Brooklyn NY +May 04 +Withdrawal - ATM Fee +EFT 1293 Bushwick Ave Brocklyn NY +May 06 +Withdrawal - VISA - Visa Purchase +05/06 GRUBHUBSANREMOPIZZERI GRUBHUB.COM NY +May 06 +Deposit - VISA - +SQC Cash App Clyde Wash Visa Direct CA +Date 05/06/19 +May 06 +Deposit - VISA - +SQC Cash App Clyde Wash Visa Direct CA +Date 05/06/19 +May 06 +Withdrawal - POS #065245 +WM SUPERCENTER # Wal-Mart Super Center +BRUNSWICK GA +May 06 +Withdrawal - ACH - COMENITY PAY VI +TYPE: WEB PYMT ID: 1133163498 +CO: COMENITY PAY VI +Withdrawals +-20.00 +-12.46 +-10.33 +-6.85 +-130.00 +-14.31 +-21.50 +-3.00 +-100.00 +-201.47 +-40.02 +-122.95 +-300.00 +-300.00 +-60.00 +-210.00 +-201.50 +-3.00 +-38.00 +-57.73 +-123.98 +0310263 000454573 0MCU13 063010} + +(continued) +Deposits +S 02 +Balance +2,329.40 +258.07 +98.50 +1,106.63 +1,094.17 +1,083.84 +1,076.99 +946.99 +932.68 +911.18 +908.18 +3,237.58 +3,137.58 +2,936.11 +2,896.09 +2,773.14 +2,473.14 +2,173.14 +2,113.14 +1,903.14 +1,701.64 +1,698.64 +1,660.64 +1,918.71 +2,017.21 +1,959.48 +1,835.50 + + +May 07 +May 08 +May 09 +May 09 +May 09 +May 10 +May 10 +May 11 +May 11 +May 12 +May 12 +May 14 +May 15 +May 16 +May 17 +May 17 +May 17 +May 17 +May 17 +May 17 +May 17 +May 17 +May 18 +May 18 +May 18 +Transaction +Withdrawal - 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POS #587431 +NNT NNN PACKAGE SHO062948 6090 ALTAMA AVE +STE 100 BRUNSWICK GA +Withdrawal - ACH - CAPITAL ONE +TYPE: MOBILE PMT ID: 9279744980 +CO: CAPITAL ONE +Withdrawal - ACH - GenesisFS Card +TYPE: 8884987796 ID: 1222528268 +CO: GenesisFS Card +Withdrawal - ACH - LEXINGTON LAW +TYPE: 8003418441 ID: 0009189527 +CO: LEXINGTON LAW +Withdrawal - ACH - BEST BUY +TYPE: PAYMENT ID: CITICTP CO: BEST BUY +Withdrawal - ACH - STATE FARM +TYPE: LOAN PYMT ID: 1071174431 +CO: STATE FARM +Withdrawal - POS #527915 +WAL Wal-Mart Super 241490 0639 WAL-SAMS +BRUNSWICK GA +Withdrawal - VISA - Visa Purchase +05/18 WOK N ROLL BRUNSWICK GA +Withdrawal - VISA - Visa Purchase +05/17 SQC CASH APP TANIA 8774174551 CA +Withdrawal - POS #060419 +CRACKER BARREL # 211 WARREN MASON BLVD +0310263 000454573 0MCU13 0630103 + +(continued) S 02 +Withdrawals +-30.00 +-160.00 +-128.35 +-17.00 +Deposits +Balance +1,805.50 +1,645.50 +1,517.15 +1,500.15 +-41.47 +-91.00 +-62.00 +-3.00 +-22.00 +-41.68 +-8.54 +-10.70 +-7.80 +-64.17 +-100.00 +-101.00 +-129.95 +-130.00 +-201.47 +-3.55 +-11.60 +-290.00 +-26.66 +1,682.09 +1,458.68 +1,367.68 +1,305.68 +1,302.68 +1,280.68 +1,239.00 +1,230.46 +1,219.76 +1,211.96 +2,894.05 +2,829.88 +2,729.88 +2,628.88 +2,498.93 +2,368.93 +2,167.46 +2,163.91 +2,152.31 +1,862.31 +1,835.65 + + +Transaction +BRUNSWICK GA +May 18 +Withdrawal - ATM - #008297 +PAL ISO 200 PIER ALY ST SIMONS ISL GA +May 18 +Withdrawal - ATM Fee +PAI ISO 200 PIER ALY ST SIMONS ISL GA +May 20 +Withdrawal - VISA - Visa Purchase +05/18 THE JUICY CRAB JACKSONVILLE FL +May 20 +Withdrawal - VISA - Visa Purchase +05/19 SOUTHERN SOUL BBQ ST SIMONS IS GA +May 20 +Withdrawal - ATM - #867570 +FLETC EXPRES-257262 1131 CHAPEL CROSSING +RO GLYNCO GA +May 20 Withdrawal - ATM Fee +FLETC EXPRES-257262 1131 CHAPEL CROSSING +RO GLYNCO GA +May 22 +Withdrawal - VISA - Visa Purchase +05/20 SALLYS COP SHOP BRUNSWICK GA +May 23 +Withdrawal - VISA - Visa Purchase +05/22 SHANE'S RIB SHACK BRUNSWICK GA +May 24 +Withdrawal - VISA - Visa Purchase +05/23 TIO TACO BRUNSWICK GA +May 25 +Withdrawal - VISA - Visa Purchase +05/24 DOLLAR RENT A CAR JACKSONVILLE FL +May 25 +Withdrawal - VISA - Visa Purchase +05/24 POPEYE'S #4499 BROOKLYN NY +May 25 +Withdrawal - ATM - #712178 +EFT 1293 Bushwick Ave Brooklyn NY +May 25 +Withdrawal - ATM Fee +EFT 1293 Bushwick Ave Brooklyn NY +May 25 +Withdrawal - VISA - Visa Purchase +05/25 RITE AID STORE - 1947 BROOKLYN NY +May 25 +Withdrawal - VISA - Visa Purchase +05/24 JETBLUE 27926090045 SALT LAKE CTY UT +May 25 +Withdrawal - VISA - Visa Purchase +05/24 FIREHOUSE SUBS FCT JAX JACKSONVILLE FL +May 26 +Withdrawal - VISA - Visa Purchase +05/25 RITE AID STORE - 4202 NEW YORK NY +May 26 +Withdrawal - VISA - Visa Purchase +05/25 SQC*CASH APP TATIAN 8774174551 CA +May 27 +Withdrawal - VISA - Visa Purchase +05/25 MCDONALD'S F27377 BROOKLYN NY +May 27 +Withdrawal - VISA - Visa Purchase +05/26 RITE AID STORE - 4202 NEW YORK NY +May 28 +Withdrawal - VISA - Visa Purchase +05/26 MCDONALD'S F27377 BROOKLYN NY +May 28 +Withdrawal - VISA - Visa Purchase +05/27 RITE AID STORE - 4202 NEW YORK NY +May 28 +Withdrawal - VISA - Visa Purchase +05/27 POPEYE'S #4499 BROOKLYN NY +May 29 +Withdrawal - VISA - Visa Purchase +05/27 MCDONALD'S F27377 BROOKLYN NY +May 29 +Withdrawal - VISA - Visa Purchase +05/28 RITE AID STORE - 4202 NEW YORK NY +May 30 +Withdrawal - VISA - Visa Purchase +05/28 MCDONALD'S F27377 BROOKLYN NY +May 30 +Withdrawal - VISA - Visa Purchase +05/30 RITE AID STORE - 1947 BROOKLYN NY +Withdrawals +-63.00 +-3.00 +-37.82 +-22.84 +-62.00 +-3.00 +-86.08 +-20.10 +-20.22 +-785.26 +-10.33 +-41.50 +-3.00 +-13.04 +-30.00 +-10.93 +-9.28 +-23.00 +-6.85 +-18.65 +-7.50 +-21.84 +-10.33 +-9.22 +-16.44 +-6.85 +-30.88 +0310263 000454573 0MCU13 063010} + +(continued) +Deposits +S 02 +Balance +1,772.65 +1,769.65 +1,731.83 +1,708.99 +1,646.99 +1,643.99 +1,557.91 +1,537.81 +1,517.59 +732.33 +722.00 +680.50 +677.50 +664.46 +634.46 +623.53 +614.25 +591.25 +584.40 +565.75 +558.25 +536.41 +526.08 +516.86 +500.42 +493.57 +462.69 + + +Transaction +May 30 +Withdrawal - ATM - #016636 +EFT 1293 Bushwick Ave Brooklyn NY +May 30 +Withdrawal - ATM Fee +EFT 1293 Bushwick Ave Brooklyn NY +May 31 +Withdrawal - VISA - Visa Purchase +05/30 MICROSOFT*XBOX MSBILL.INFO WA +May 31 +Withdrawal - VISA - Visa Purchase +05/30 SOC*CASH APP TATIAN 8774174551 CA +May 31 +Deposit - ACH - AGRI TREAS 310 +TYPE: FED SAL ID: 9101036009 +CO: AGRI TREAS 310 +May 31 +Withdrawal - ACH - CAPITAL ONE +TYPE: MOBILE PMT ID: 9279744980 +CO: CAPITAL ONE +May 31 +May 31 +Withdrawal - ACH - PAYPAL +TYPE: ECHECK ID: PAYPALEC8B CO: PAYPAL +Withdrawal - ACH - CAPITAL ONE +TYPE: MOBILE PMT ID: 9279744980 +CO: CAPITAL ONE +May 31 +Withdrawal - ACH - CITI CARD ONLINE +YPE: PAYMENT ID: CITICTI +O: CITI CARD ONLINI +May 31 +Withdrawal - ACH - DISCOVER +TYPE: E-PAYMENT ID: 2510020270 +CO: DISCOVER +May 31 +Withdrawal - ACH - STATE FARM +TYPE: LOAN PYMT ID: 1071174431 +CO: STATE FARM +May 31 +New Balance +Totals For This Period: +SIGNATURE +Date Transaction +May 01 Previous Balance +May 10 Payment - Phone Transfer From +Share 02 +May 31 +Advance - Insurance Single Life +May 31 +Advance - Insurance Disability +May 31 +New Balance +Amount +-91.00 +0.27 +1.24 +Totals For This Period +Annual Percentage Rate: 12.500% +Periodic Rate (Daily): 034246% +A Payment of 91.00 is due on 06/11/19 +Interest Due through 05/31/19: 5.14 +-89.49 +YEAR TO DATE TOTALS +Total Dividends YTD +0310263 000454573 0MCU13 0630103 + +(continued) S 02 +Withdrawals +-21.50 +-3.00 +-21.76 +-40.00 +Deposits +Balance +441.19 +438.19 +416.43 +376.43 +1,086.12 +1,462.55 +-25.00 +1,437.55 +-60.00 +-100.00 +1,377.55 +1,277.55 +-100.00 +1,177.55 +-100.00 +1,077.55 +-201.47 +876.08 +876.08 +-5,716.73 +5,454.18 +L 21 +Late +Charge +Interest +Charged +Principal +Amount +12.75 +-78.25 +0.27 +1.24 +Balance +761.32 +683.07 +683.34 +684.58 +684.58 +0.00 +12.75 +-76.74 +2019 Totals Year-to-Date +Total Fees Charged in 2019 +Total Interest Charged in 2019 +8.74 +37.63 +0.00 + + +0310263 000454573 00013 bb0]03 + +IN CASE OF ERRORS OR QUESTIONS ABOUT YOUR ELECTRONIC TRANSFERS +Write to us at P.O. Box 3205, New York, NY 10007 or telephone us at (212)693-4900 (or (800)323-6713 if outside the five boroughs) if you think +you must hear form you arror than i days adre set you the same reer or rear ser i +Your name and MCU account number (if any); +The amount of the suspected error or questioned transfer (and transaction date if known); +USE THE FOLLOWING FORM TO ASSIST YOU IN BALANCING YOUR CHECKING ACCOUNT +LIST CHECKS OUTSTANDING +(NOT CHARGED TO YOUR CHECKING ACCOUNT YET) +PERIOD ENDING +CHECK NUMBER CHECK DATE +$ AMOUNT +1. SUBTRACT FROM YOUR REGISTER ANY CHARGES LISTED ON THIS +STATEMENT BUT NOT DEDUCTED FROM YOUR BALANCE. +2. ENTER CHECKING BALANCE SHOWN $ +ON THIS STATEMENT. ++ +3. ENTER DEPOSITS MADE +AFTER THE ENDING DATE OF +THIS STATEMENT. +TOTAL: ++ +$ +4. TOTAL (2 PLUS 3): +$ +S. TOTAL. VER OUTSTANDING CHECK S +6. REGISTER BALANCE (4 MINUS 5): +$ +SHARES ARE TRANSFERABLE ONLY TO QUALIFIED MEMBERS +and backed by tail tated andy redit of the united fates Government. +NCUA +National Credit Union Administration, a U.S. Government Agency \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/1e156c8f089ea1db2b56aece40b017f543d38110b227db3b1c22486e05a94ef5.receipt.json b/vision-fixhub/ds9-parsed-01/1e156c8f089ea1db2b56aece40b017f543d38110b227db3b1c22486e05a94ef5.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..962a5a8068a51e30ee2010326e7d6b4abe137761 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1e156c8f089ea1db2b56aece40b017f543d38110b227db3b1c22486e05a94ef5.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -514, + "dataset": "marble-joined", + "doc_id": "1e156c8f089ea1db2b56aece40b017f543d38110b227db3b1c22486e05a94ef5", + "engine": "marble-apple-vision", + "event_count": 13, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "c22dbbe680c97c2b35d1a33fba1399c7e5ee5915a3a51d447a459df04509f6ea", + "output_sha256": "7c15af0b9f477e647bcef13ceaf05e41d09a9203e2b0c8a4747fa614e69bf21a", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1e495a3a0f12efd017b15249d12e21f8daf072a47fecb409a37bb1a1f79c8ee5.md b/vision-fixhub/ds9-parsed-01/1e495a3a0f12efd017b15249d12e21f8daf072a47fecb409a37bb1a1f79c8ee5.md new file mode 100644 index 0000000000000000000000000000000000000000..677ba230be4e4eb8e1a6423a38ad1da782958ddd --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1e495a3a0f12efd017b15249d12e21f8daf072a47fecb409a37bb1a1f79c8ee5.md @@ -0,0 +1,19 @@ +From: " +To: " +(USANYS)" 4 +Cc: " +(USANYS)" { +Subject: GM Talking Points +Date: Tue, 23 Jun 2020 14:56:32 +0000 +Attachments: Jeffrey_Epstein_Co-Conspirators_Talking_Points.docx +Hey Guys - With apologies, we still don't have guidance from +on timing. I think, based on our preliminary +conversation with her yesterday, it is extremely unlikely Audrey is going to feel ready to move forward on Thursday, so ! +would not spend a lot of time worrying about being ready to go in 48 hours. We raised with her some of the concerns +voiced on the call yesterday, and asked whether July 6 or 13 might still be an option, and she was going to raise those with +Audrey and get back to us. We will let you know as soon as we know more. +Unrelated, Audrey will be briefing the AG on Thursday about a number of our higher profile upcoming cases, and she has +asked us to put together some bullet/talking points for that call, including ones on Maxwell. Would you mind taking a +look at the attached, and letting me know if you have any comments/edits as soon as possible? We need to get this to +her later today. +Thanks very much, diff --git a/vision-fixhub/ds9-parsed-01/1e495a3a0f12efd017b15249d12e21f8daf072a47fecb409a37bb1a1f79c8ee5.receipt.json b/vision-fixhub/ds9-parsed-01/1e495a3a0f12efd017b15249d12e21f8daf072a47fecb409a37bb1a1f79c8ee5.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..25f6f0a5a7c35f01c8595ebeeeba33b75f83e749 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1e495a3a0f12efd017b15249d12e21f8daf072a47fecb409a37bb1a1f79c8ee5.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "1e495a3a0f12efd017b15249d12e21f8daf072a47fecb409a37bb1a1f79c8ee5", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "db62be3f72ffebc72bb339a26e9a88db06721ab5660507d648d7f307de3fb350", + "output_sha256": "28538b48562ef27a50ddb62a12f86889456cc504209ef2ac993547d517ffe4f0", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1e92733576f288639684eb1d7d00ae954d5bfa2742dd21fa2363e2f52031f99c.md b/vision-fixhub/ds9-parsed-01/1e92733576f288639684eb1d7d00ae954d5bfa2742dd21fa2363e2f52031f99c.md new file mode 100644 index 0000000000000000000000000000000000000000..93f79ec624719465836c312f025811de7cc1b8b7 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1e92733576f288639684eb1d7d00ae954d5bfa2742dd21fa2363e2f52031f99c.md @@ -0,0 +1,18 @@ +U.S. Department of Justice +United States Attorney +Southern District of New York +The Silvio I. Mollo Building +One Saint Andrew's Plaza +New York, New York 10007 +September 29, 2020 +BY FEDERAL EXPRESS +MDC-Metropolitan Detention Center +Legal Department +Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) +Enclosed is discovery pertinent to the following inmate: +• Ghislaine Maxwell: 02879-509 +Please allow her access to the materials enclosed. +Very truly yours, +Acting United States Attorney +by: +Enclosure diff --git a/vision-fixhub/ds9-parsed-01/1e92733576f288639684eb1d7d00ae954d5bfa2742dd21fa2363e2f52031f99c.receipt.json b/vision-fixhub/ds9-parsed-01/1e92733576f288639684eb1d7d00ae954d5bfa2742dd21fa2363e2f52031f99c.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..ede527bb08e47e36430bbb5a502a1bb44e9c21fd --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1e92733576f288639684eb1d7d00ae954d5bfa2742dd21fa2363e2f52031f99c.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "1e92733576f288639684eb1d7d00ae954d5bfa2742dd21fa2363e2f52031f99c", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "3e6a5e2546cb9d44d30216342cc42d79d428ef0deb5c9b8473bc8694618e1e07", + "output_sha256": "edc0493c67daf7e4f0774305e300b04bf9e322268c92fd0535695444a9b8fe19", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1e987e5a8387553e2285e4f2c264a81c1a3fdca5285e6a74b28eaa71cf5bf7de.md b/vision-fixhub/ds9-parsed-01/1e987e5a8387553e2285e4f2c264a81c1a3fdca5285e6a74b28eaa71cf5bf7de.md new file mode 100644 index 0000000000000000000000000000000000000000..11e7dd2300155c404067773ce7cab3b6a04aa07f --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1e987e5a8387553e2285e4f2c264a81c1a3fdca5285e6a74b28eaa71cf5bf7de.md @@ -0,0 +1,12 @@ +From: " +To: " +I (USANYS)" ≤ +Cc: " +(USANYS)" < +Subject: Epstein catch up +Date: Sun, 17 Nov 2019 02:18:48 +0000 +Can we find a time in the near future to catch up on a few things, including hearing more about your interview +last week? Unfortunately both +Land I have to be out portions of Monday/Tuesday. Would Monday at 530 +work for you guys? If not, can we aim for Wednesday morning. Thanks +Sent from my iPhone diff --git a/vision-fixhub/ds9-parsed-01/1e987e5a8387553e2285e4f2c264a81c1a3fdca5285e6a74b28eaa71cf5bf7de.receipt.json b/vision-fixhub/ds9-parsed-01/1e987e5a8387553e2285e4f2c264a81c1a3fdca5285e6a74b28eaa71cf5bf7de.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..a48bca669d7f878cbe9096f73d3c5cdfc8b0dd7a --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1e987e5a8387553e2285e4f2c264a81c1a3fdca5285e6a74b28eaa71cf5bf7de.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "1e987e5a8387553e2285e4f2c264a81c1a3fdca5285e6a74b28eaa71cf5bf7de", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "efa38bd920c8544306fc178c39330aa58ef193375be278a9a3e89c82fa7f2d12", + "output_sha256": "deca53ef6fd77d6eb749f9d9037e23e04882c65fcc358782dc7ed592d3963a7d", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1f3b2614c7ad78ea78e5668152593ee63d271d21513fe333d6389a1ac0580df5.md b/vision-fixhub/ds9-parsed-01/1f3b2614c7ad78ea78e5668152593ee63d271d21513fe333d6389a1ac0580df5.md new file mode 100644 index 0000000000000000000000000000000000000000..604db5ee598be3011472392483fbf2477c282574 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1f3b2614c7ad78ea78e5668152593ee63d271d21513fe333d6389a1ac0580df5.md @@ -0,0 +1,32 @@ +netgovern. archive +Browse +Archive-07 +Mailbox +Sent Items +Calendar +Checklist +Contacts +signet +Advanced Se +MCC New York 200 Budgetary Redundant Nice pdf +SigNet +Technologies +12-2-16 +MCC New York +150 Park Row +New York, NY 10007 +Reference: MCC New York Nice 200 Channel Upgrade Budgetary Proposal +wio AMS, Decoder +Dear Mr. +Signet Technologies is pleased to submit our budgetary proposal submitted on the referenced +solicitation. +We offer MCC New York demonstrated technical and management expertise, successful past +performance on numerous projects of similar size, scope and complexity, exceptional cleared +resource depth and a wealth of directly relevant corporate experience. +This Proposal shall be used and disclosed for evaluation purposes only, and a copy of this data shall +be applied to any reproduction or abstract thereof. Any authorized restrictive notices which +the submitter places on this proposal shall also be strictly complied with. Disclosure of this proposal +outside the Goverment for evaluation purposes shall be made only to the extent authorized by, and +in accordance with FAR Part 3.1 Source Selection Information and FAR Part 15.606. +Search Automatically +Search diff --git a/vision-fixhub/ds9-parsed-01/1f3b2614c7ad78ea78e5668152593ee63d271d21513fe333d6389a1ac0580df5.receipt.json b/vision-fixhub/ds9-parsed-01/1f3b2614c7ad78ea78e5668152593ee63d271d21513fe333d6389a1ac0580df5.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..20395dab94f06fa4ee1f1800a2f14e901fc2db60 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1f3b2614c7ad78ea78e5668152593ee63d271d21513fe333d6389a1ac0580df5.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "1f3b2614c7ad78ea78e5668152593ee63d271d21513fe333d6389a1ac0580df5", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "679e89c99a4b11824cbc970cfe211b7e0253a85d039407ec75aef42e3550de8a", + "output_sha256": "938f2f0b5b40599dd63023723a975f4d85f42f968c9d54d50d89ed3419a5b23b", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1f51d7b709659ca160d0bc4c3ae1d2a8aa6470ff0fa52978cb64f6d498867a09.md b/vision-fixhub/ds9-parsed-01/1f51d7b709659ca160d0bc4c3ae1d2a8aa6470ff0fa52978cb64f6d498867a09.md new file mode 100644 index 0000000000000000000000000000000000000000..1f211be13dbd24c959509338b819ef8058ff02df --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1f51d7b709659ca160d0bc4c3ae1d2a8aa6470ff0fa52978cb64f6d498867a09.md @@ -0,0 +1,117 @@ + + + +CONFIDENTIAL/PRIVILEGED/SEALED +November 19, 2020 +Dr. Scott Borgerson +Dear Judge Nathan, +I respectfully submit this letter in support of Ghislaine Maxwell's bail application. +History +1. I met Ghislaine Maxwell in 2013 at the introduction of a mutual friend. +2. Ghislaine and I developed a friendship through a shared passion for ocean conservation +which over time grew into a close personal relationship. As the years passed, we travelled +extensively together, initially to ocean conferences, and then for leisure and she accompanied +me on business travel. Her trips to Japan, the UK, and other countries over the last few years +were for my legitimate business meetings. We also took the children on a vacation to France +several summers ago which included a visit to Omaha Beach and a study of D-Day. +As our relationship grew, we rented a home together in Manchester in 2015, culminating in a +more permanent arrangement when purchasing a home in 2016 where we lived peacefully +and quietly in until Epstein's arrest last year. I have been a Massachusetts resident since +2009. +Home +3. I am the father off +My ex-wife and I share custody. We co-parent in +grace, love and harmony. We are 1,000% committed to protecting our kids from the media. +4. The person described in the criminal charges is not the person we know. I have never +witnessed anything close to inappropriate with Ghislaine; quite to the contrary, the Ghislaine +I know is a wonderful and loving person. Over the previous years she established an +cellent relationship with my children and others in my life. She was extraordinary lovir +, my kids, attending soccer games and orchestra concerts. hosting birthday parties, cookin +meals, and otherwise she was lovingly active in their daily lives. My children miss her and +they trust her completely. +year, but our existence was quiet and lovely. +Privacy +1 | Page + + +6. The press" behaviour led us early on to determine that we would live our lives privately. +We would not add any oxygen to the press-feeding frenzy by providing details about our +domestic arrangements or any information about our daily existence. +7. I was, of course, aware of Ghislaine's previous relationship with Epstein, a person I have +never met nor had any communication. The media coverage of Epstein is very different +today than it was seven years ago when Ghislaine and I first met. To be clear, I met +Ghislaine nearly two decades after the alleged crimes. +8. The "reporting" of Ghislaine over the past year has exploded exponentially. From the +time of Epstein's arrest and death in custody in the summer of 2019 until Ghislaine's own +arrest in July of this year, huge and increasingly frightening levels of media interest meant +that our previous quiet existence became unbearable. There are many examples of violence +whose seeds were born in conspiracy theories, and the experiences of QAnon, Pizzagate, and +the recent Judge Salas attack are terrifying. +Some of the outlandish conspiracy allegations on the internet have insinuated that I am +somehow involved in trafficking, in cahoots with Ghislaine for nefarious activities, or +shielding her criminal activity. These ridiculous comments on the internet could not be +further from the truth. I (we) lived a law abiding and innocent life. Twitter comments have +been particularly galling, with one speculating that I am a spy (not true) and another "you +think a guy like Scott could disseminate Epstein's hundreds of pedo videos at will?" I have +zero knowledge of any videos or other outlandish conspiracy theories. There are many other +gross and disgusting posts like this on the web that a simple search will bring up. I have also +received threatening messages through social media, which I have reported and blocked. +It is hard to communicate in words the feeling of being stalked, spied upon and trapped by +constant, 24/7 media intrusion from helicopters and drones hovering overhead, to long range +photographers stationed in boats, cars and on foot; with journalists leaping out from behind +trees, hiding behind bins and cars seeking any which way to ambush you. The local police +department has nobly tried to protect my family, at one point parking a marked car in my +driveway. I have filed multiple harassment reports with the police, including against +"journalists" trying to physically enter my house. +Separation +9. It was this aggressive media posture which led to the decision that the only sure-fire +means of ensuring the children's and my protection was for her to leave Massachusetts. +10. The media frenzy has included the publication of an article in the Boston Globe about the +kids' school, ABC continuing to harass school leadership, and tabloid reporters pointing +cameras at my children. This harassment is unacceptable and dangerous. +11. This led to the difficult decision that for the safety and well-being of my family, +Ghislaine having to leave and live on her own, shielding herself as best she could from the +media hunting her. At one point, The Sun even put a "bounty" on her head. +I assisted in the purchase of the New Hampshire property not for the purposes of evading law +enforcement - there was never a warrant out for her arrest and her lawyers reported being in +regular contact with the prosecution offering Ghislaine's assistance - but for the sole reason +of protecting her and my family from the media. +2| Page + + +Despite our best efforts, there have still been life altering consequences as a result of the +media's harassment. This summer I resigned as the CEO of the company I founded and built +over the past decade because my presence was becoming a distraction to an otherwise +fantastic business. It wasn't fair to my colleagues that they be affected by the media attention +that was occurring around me due to my association with Ghislaine, regardless of the facts as +previously mentioned that I met her many years after the alleged misconduct, I do not know +Jeffery Epstein, and otherwise have nothing to do with the situation. +There are other examples of painful and real loss like this due to the media's aggressive +treatment of those who simply know Ghislaine; the entire experience has been most +regrettable. +My support for her bail application +12. I believe that Ghislaine had nothing to do with Epstein's crimes. She has pleaded not +guilty and denied the criminal allegations against her, and I fully believe that it is her intent +and desire to remain in the U.S. to face the ensuing process and to clear her name. +Over the past few years she has had dozens of alternative places she could have gone, but she +did not want to be perceived as running or as having done something wrong. +She was +adamant to not only stay in the United States to fight the smears against her, but to be within +driving distance of New York. This is why she chose to live in New Hampshire - to be +close to New York and close to her family. She was not hiding from the SDNY, but she left +Massachusetts to protect my family from the media and the consequences it was bringing +upon our lives. Her arrest came as a shock. +13. I did not initially come forward as a co-signer of her first bail application for the reasons +stated above, trying to protect my children from ferocious media aggression. The tabloids of +The Daily Mail, The Sun, The New York Post, and The New York Times have particularly +been pernicious, willingly printing disinformation and outright lies for a click. Ghislaine and +I had discussed we would do everything in our power to protect my children from the evil of +the media's intrusion into our lives. Protecting these innocent kids and their mother remains +our utmost priority. +13. As a military veteran and a patriot of deep conviction and character, I believe +wholeheartedly in Ghislaine's commitment to stand trial and not to seek to leave the +urisdiction should her bail application be successful +I pray for Ghislaine's safety. I am praying for justice. And I pray for her constitutionally +afforded due process. +With humility and deep compassion, I am also praying for Epstein's victims. +3 | Page diff --git a/vision-fixhub/ds9-parsed-01/1f51d7b709659ca160d0bc4c3ae1d2a8aa6470ff0fa52978cb64f6d498867a09.receipt.json b/vision-fixhub/ds9-parsed-01/1f51d7b709659ca160d0bc4c3ae1d2a8aa6470ff0fa52978cb64f6d498867a09.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..601fe1702eb704254932741c254587d690458e4f --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1f51d7b709659ca160d0bc4c3ae1d2a8aa6470ff0fa52978cb64f6d498867a09.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -57, + "dataset": "marble-joined", + "doc_id": "1f51d7b709659ca160d0bc4c3ae1d2a8aa6470ff0fa52978cb64f6d498867a09", + "engine": "marble-apple-vision", + "event_count": 5, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "8cbce9f77311698e08f93b57aaf56c00177a259f2595b6be6fc0f6db2bc492e3", + "output_sha256": "b7be72c8fce4f331952fba840180d929f134bd041e8f69e375c610b785e0ab10", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1f60f15ceb581ebe042a47a98eb7e75d0c6685a7a815f51e3018d587190c9e39.md b/vision-fixhub/ds9-parsed-01/1f60f15ceb581ebe042a47a98eb7e75d0c6685a7a815f51e3018d587190c9e39.md new file mode 100644 index 0000000000000000000000000000000000000000..297c1333f666200816354219d037999c36de0c6d --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1f60f15ceb581ebe042a47a98eb7e75d0c6685a7a815f51e3018d587190c9e39.md @@ -0,0 +1,57 @@ +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +USDC SDNY +DOCUMENT +ELECTRONICALLY FILED +DOC#:_ +DATE FILED: _12/28/20 +United States of America, +-v- +Ghislaine Maxwell, +20-CR-330 (AJN) +ORDER +Defendant. +ALISON J. NATHAN, District Judge: +On December 8, 2020, Defendant Ghislaine Maxwell filed a renewed motion for release +on bail. Dkt No. 97. In an Opinion and Order concurrently filed under temporary seal, the Court +DENIES the Defendant's motion. +In light of the fact that the Opinion includes potentially confidential information that +should not be filed on the public docket, the Court will permit the parties 48 hours to propose +any redactions to the Court's Opinion and Order and to justify those redactions by reference to +the Second Circuit's decision in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110(2d Cir. +2006). After determining which, if any, portions of the Opinion and Order should be redacted, +the Court will file the Opinion and Order on the public docket. +This Order provides the bottom line of the Court's resolution. On July 14, 2020, this +Court conducted an extensive bail hearing and determined that pre-trial detention was warranted +because the no conditions or set of conditions could reasonably assure the Defendant's +appearance at future proceedings. Under 18 U.S.C. § 3142(f), a bail hearing may be reopened if +the Court finds "that information exists that was not known to the movant at the time of the +hearing and that has a material bearing on the issue whether there are conditions of release that +will reasonably assure the appearance of such person as required." The Court concludes that +1 + + +none of the new information that the Defendant presented in support of her application has a +material bearing on the Court's determination that she poses a flight risk. +Furthermore, for substantially the same reasons as the Court determined that detention +was warranted in the initial bail hearing, the Court again concludes that no conditions of release +can reasonably assure the Defendant's appearance at future proceedings. In reaching that +conclusion, the Court considers the nature and circumstances of the offenses charged, the weight +of the evidence against the Defendant, the history and characteristics of the Defendant, and the +nature and seriousness of the danger that the Defendant's release would pose. See 18 U.S.C. § +3142(g). The Government does not contend that the Defendant poses a danger to the +community. Nonetheless the Court determines that the other three factors warrant detention +under 18 U.S.C. § 3142(e). The Court also finds that the Defendant's proposed bail conditions +would not reasonably assure her appearance at future proceedings. +As a result, the Court concludes that the Government has met its burden of persuasion +that the Defendant poses a flight risk and that pre-trial detention continues to be warranted. +On or before December 30, 2020, the parties are ORDERED to submit a joint letter +indicating whether they propose any redactions and the justification for any such proposal. +This resolves Dkt No. 97. +SO ORDERED. +Dated: December 28, 2020 +New York, New York +Alia Q. Notor +ALISON J. NATHAN +United States District Judge +2 diff --git a/vision-fixhub/ds9-parsed-01/1f60f15ceb581ebe042a47a98eb7e75d0c6685a7a815f51e3018d587190c9e39.receipt.json b/vision-fixhub/ds9-parsed-01/1f60f15ceb581ebe042a47a98eb7e75d0c6685a7a815f51e3018d587190c9e39.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..5fa9eca2543f0eb7849d022d65eb06167f0f85f8 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1f60f15ceb581ebe042a47a98eb7e75d0c6685a7a815f51e3018d587190c9e39.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "1f60f15ceb581ebe042a47a98eb7e75d0c6685a7a815f51e3018d587190c9e39", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "bcfd16cfee43ef8d49940279edee5e8de3503c081a216b828681233a9b4a70db", + "output_sha256": "8fae2ccee1c3dd23bb95631ac0d01b3abc797887b042551995946b33fde837a1", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1f6538f944a21d72e260c9865c91391e879379d6e767bd29e2a3b5d254826d4b.md b/vision-fixhub/ds9-parsed-01/1f6538f944a21d72e260c9865c91391e879379d6e767bd29e2a3b5d254826d4b.md new file mode 100644 index 0000000000000000000000000000000000000000..9dbdcc61859fd1bd9784c7e19fca8ad94e04378b --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1f6538f944a21d72e260c9865c91391e879379d6e767bd29e2a3b5d254826d4b.md @@ -0,0 +1,2964 @@ +liti +at&t + +AT&T Global Legal Demand Center +VERIFICATION OF AUTHENTICITY OF AT&T RECORDS +STATE OF FLORIDA +COUNTY OF PALM BEACH +BEFORE ME, the undersigned authority, personally appeared Daniel Reller, who being duly sworn, deposes and +says: +My name is Daniel Reller. I am over the age of 18 and qualified to make this affidavit. I am employed by AT&T as a +Compliance Security Analyst and also serve as the Custodian of Records for AT&T. I have been employed by AT&T +since 05/10/1999. Attached to this Affidavit are copies of AT&T subscriber and call detail records for: +Number: +The attached copies of billing records were originally provided without certification by an analyst at the AT&T +GLDC. The records have been purged and are unable to be created in the same format as originally provided. +E-mailed them to the Global Legal Demand Center on 09/30/2021. The attached copies of usage +records appear to be in the same format as records that were maintained and produced by AT&T. These +documents are in the same format and contain call data consistent with AT&T records and do not appear to have +been modified or altered in any way. I routinely rely on these types of documents in the course of my duties as +Custodian of Records and Compliance Security Analyst for AT&T. +Based on the regular practices of AT&T in 2006, the records were: +a. Made at or near the time of each act, event, condition, opinion, or diagnosis set forth in the records. +b. Made by or from information transmitted by AT&T systems. +c. Would have been kept in the course of regularly conducted business activity. +It was the regular practice of the business activity to make these records. +Date: 10/12/2021 +Signature: +The foregoing affidavit was sworn to and subscribed before me by Daniel Reller who is personally known to me. +sharan Dar +Notary Public, State of Florida +Printed Name +Serial Number (if any) +SHARON DALY +Notary Public - State of Fiorida +Commission # HM 030728 +My Comm. Expires Aug 17, 2024 +Bonded through National Notary Assr. +National Court Order Compliance + + +at&t + +AT&T Global Legal Demand Center +VERIFICATION OF AUTHENTICITY OF AT&T RECORDS +STATE OF FLORIDA +COUNTY OF PALM BEACH +BEFORE ME, the undersigned authority, personally appeared Daniel Reller, who being duly sworn, deposes and +says: +My name is Daniel Reller. I am over the age of 18 and qualified to make this affidavit. I am employed by AT&T as a +Compliance Security Analyst and also serve as the Custodian of Records for AT&T. I have been employed by AT&T +since 05/10/1999. Attached to this Affidavit are copies of AT&T subscriber and call detail records for: +Number: +The attached copies of billing records were originally provided without certification by an analyst at the AT&T +GLDC. The records have been purged and are unable to be created in the same format as originally provided. +E-mailed them to the Global Legal Demand Center on 09/30/2021. The attached copies of usage +records appear to be in the same format as records that were maintained and produced by AT&T. These +documents are in the same format and contain call data consistent with AT&T records and do not appear to have +been modified or altered in any way. I routinely rely on these types of documents in the course of my duties as +Custodian of Records and Compliance Security Analyst for AT&T. +Based on the regular practices of AT&T in 2006, the records were: +a. Made at or near the time of each act, event, condition, opinion, or diagnosis set forth in the records. +b. Made by or from information transmitted by AT&T systems. +c. Would have been kept in the course of regularly conducted business activity. +It was the regular practice of the business activity to make these records. +Date: 10/12/2021 +Signature +The foregoing affidavit was sworn to and subscribed before me by Daniel Reller who is personally known to me. +Notary Public, State of Florida +Printed Name +Serial Number (if any) +National Court Order Compliance + + +*cingular® +National Compliance Center +RESPONSE COVER SHEET +PO BOX 24679 +WEST PALM BEACH, FL 33416-4679 +Phone 1 +Facsimile +To: +File Code: 227815 +From: YAB +Number of Pages: +Date: 8/24/2006 +Reces Do: 22006 +you are not already doing i plas begin a drea allen inside is airies. +- The requested information is enclosed. +- Cell site location information is provided upon receipt of a Search Warrant, a Court Order pursuant +to "Specific & Articulabie Facts" or Federal Statute 18 USC $2703 (d). +- There are four (4) folders in the CD that represent the four target numbers. All available information +for the time frame of January 1, 2004 to present has been provided. +This cover sheet, and any document which may accompany it, contains information from the National Compliance Center which is intended for use +only by the individual to whom it is addressed, and which may contain information that is privileged, confidential and/or otherwise exempt from +disclosure under applicable law. If the reader of this message is not the intended recipient or the person responsible for delivering this message to th +intended recipient, any review, disclosure, dissemination, distribution, copying or other use of this message or its substance is strictly prohibited. If +you have received this communication in error, please notify us immediately by telephone to arrange for the return of this communication to us at our +expense. Thank you. +NCC Official Use Only +U +R +0 + + + +- +Questions or Changes? +attwireless.com +Toll Free 1 +: +611 from your wireless phone +TTY users - 1 866 4-AWS-TT +SUMMARY OF MONTHLY CHARGES FOR ACCOUNT +reviou +Account +alanc +Adjustments +0.00 +0.00 +0.00 +Your billing cycle ended on May 02, 2004 +Current Monthly Charges +ubscriber Adjustment +lonthly Servic +Monthly Usage +Charges +Credits +Taxes, Surcharges & Regulatory Fees +Total Current Monthly Charges DUE UPON RECEIPT +TOTAL AMOUNT DUE +Balance +Forward +0.00 +Date of Invoice: May 05, 2004 +Current Monthly +Charges +403.56 +Total +Amount Due +403.56 +0.00 +186.68 +168.91 +0.00 +-12.99 +60.96 +403.56 +403.56 +NO DOMESTIC US DATA ROAMING CHARGES: +AS OF APRIL 18, WE HAVE ELIMINATED ALL DOMESTIC US DATA +ROAMING CHARGES ON ANY MMODE, MOBILE INTERNET DATA PLAN +OR BLACKBERRY ACCESS PLAN. THIS MEANS YOU CAN STAY +CONNECTED ON ANY COMPATIBLE DATA CAPABLE DEVICE +INCLUDING PHONES, PDAS, AND WIRELESS PC CARDS IN THE US +WITHOUT A ROAMING CHARGE. NOTE: CANADA AND +INTERNATIONAL ROAMING CHARGES STILL APPLY. +AT&T WIRELESS APPRECIATES YOUR BUSINESS +Please Return This Portion With Your Payment. +Use seen al arms and Contions or ires in +EE AT&T Wireless +Account Name: JEFFREY E EPSTEIN +Note: +=> +le Print i +ont and Ba +Service # +Account # +#BWNHNGB +#0000000438118630# w +2000247 03 AT 0.701 AUTO T200502 10022 5.22.01.1234.0000 +JEFFREY F EPSTEIN +Date Due +UPON RECEIPT +AT&T WIRELESS +PO BOX 8229 +AURORA IL 60572-8229 +Total +Amount Due +403.56 +Amount +Paid + + +*17480701F00* +REFT (Recurring Electronic Fund Transfer): To enroll: sign below, check the REFT box on the reverse side and +remit with this month's payment. Keep paying your bill until your statement indicates "Do Not Pay." +REFT Agreement: I authorize my financial institution to deduct the amount of my monthly wireless phone bill from +the account associated with the enclosed check and remit payment to AT&T Wireless. This authority will be +effective until | notify AT&T Wireless to terminate it. I agree that I may be assessed a service charge (up to $20) or +late fee or both if a payment is returned by my bank. For more information visit attwireless.com or call 1 +Questions? We can help: AT&T Wireless appreciates your business and welcomes the opportunity to assist you. +or dial 611 from your +wireless phone. ¿Sabias que también ofrecemos servicio al cliente en tu idioma? Marca 611 desde tu teléfono +inalámbrico, o 1 +desde cualquier teléfono y oprime el ". +Driving Wireless Safety: Your wireless phone gives you the freedom and flexibility to stay in touch when you +travel, but don't let a phone call distract you from driving safely. Use hands-free device if allowed or required by +law. Call Carefully, Arrive Safely. +AT&T Wireless Processing Fees: Accounts suspended for non-payment will be subject to a $25 reactivation fee +per line and may be assessed a security deposit prior to reinstatement. Checks returned for non-sufficient funds will +be charged up to a $20 fee. +Local Tax: Local taxes are based on local government boundaries, the address information you provide for your +account and/or your wireless telephone number. Please review the local tax charges on your bill. If you believe +there is an error in the local tax charge, please contact us immediately at 1 l +cal or state laws may require you to follow special procedures when notifying us about a local tax dispute. Yo +nay also use the form below to notify us of any change to your taxing address. Thank you for your cooperatio +Please Send Correspondence To: +AT&T Wireless Next Generation Correspondence +P.O. Box 68056 +Anaheim Hills, CA 92817-8056 +2000247.000001746.7 +Change of Address Only. Please print address clearly and check the box on the reverse side. Please contact Customer Care to change the +Account Name and transfer Financial Responsibility +New Billing Address - +City +State +Zip +Home Phone (. +Work Phone (. +.) +If your billing address is NOT your Tax Address", please enter the Tax Address below. (Multi-line accounts should attach a list of each wireless number and +the respective Tax Address.) +New Tax Address* +Wireless Number ( +City +State +Zip +Inder Federal laws, your Tax Address must be: your primary place of use, your residential or business address, and located within AT&T Wireless +ensed service area. Non-business customers on AT&T Digital One Rate, Regional Advantage or Shared Advantage plans must use their resident +address as their tax address. +Recurring Electronic Fund Transfer (REFT) Enrollment. Please read the agreement on the top portion of this page, sign below and check the +"REFT Registration" box on the reverse side. +- 3G +Financial Account Holder Signature +Email Address* +*I do not wish to receive email notification of special offers available to AT&T Wireless customers. + + + +IMPORTANT ACCOUNT INFORMATION: +IF YOU CANCEL SERVICE BEFORE YOUR CONTRACT END DATE +(INCLUDING IF YOU SWITCH YOUR WIRELESS NUMBER TO +ANOTHER CARRIER), YOU WILL BE CHARGED AN EARLY +TERMINATION FEE OF UP TO $200. +THE $1.75 REGULATORY PROGRAMS FEE HELPS TO FUND AT&T +WIRELESS COMPLIANCE WITH GOVERNMENT-MANDATED PROGRAMS +SUCH AS E911, NUMBER POOLING & LOCAL NUMBER PORTABILITY +WHICH MAY NOT YET BE AVAILABLE TO SUBSCRIBERS. IT IS AN +ADDITIONAL MONTHLY CHARGE CREATED, ASSESSED & COLLECTED +BY AT&T WIRELESS. FOR MORE INFORMATION & A DESCRIPTION +OF THESE GOVERNMENT PROGRAMS PLEASE VISIT OUR WEBSITE +AT WWW.ATTWIRELESS.COM/RPF +ACCOUNT DETAILS +Current Subscriber Monthly Charges and Credits +Subscriber Number +Subscriber Name +Total Current Subscriber Monthly Charges and Credits +Total Current Monthly Charges +SUMMARY OF CURRENT ACTIVITY +Monthly Service Charges +Item Description +1 CALL WAITING +2 AT&T TEXT MESSAGING +I CALLER ID +2 EARLY EVENING +I ENH DISCOUNT INT. DIAL. +7 MULTIMEDIA MESSAGING $2.99 +8 AT&T VOICEMAIL +9 MMODE/DATA SERVICE (4MB) +10 NATIONAL PLAN $149,99 +11 THREE WAY CALLING +12 REGULATORY PROGRAMS FEE +13 VOICEDIAL SERVICE +Service Dates +04/03/04 - 05/02/04 +04/03/04 - 05/02/04 +04/03/04 - 05/02/04 +04/03/04 - 05/02/04 +04/03/04 - 04/15/04 +04/16/04 - 05/02/04 +04/03/04 - 05/02/04 +04/03/04 - 05/02/04 +04/03/04 - 05/02/04 +04/03/04 - 05/02/04 +04/03/04 - 05/02/04 +04/03/04 - 05/02/04 +04/03/04 - 05/02/04 +403.56 +403.56 +403.56 +0.00 +4.99 +0.00 +0.00 +1.73 +2.26 +2.99 +0.00 +12.99 +149.99 +0.00 +Page |of 14 +SUMMARY OF CURRENT ACTIVITY - CONTINUED +Monthly Service Charges - Continued +Item Description +14 DETAIL BILLING +Service Dates +04/03/04 - 05/02/04 +04/03/04 - 05/02/04 +Monthly Usage Charges +Item Description +4 MESSAGE RETRIEVAL +I CALL COMPLETION +7 UNLIM MOBL TO MOBL +8 400 ADD'L ANYTME MIN +9 EARLY EVENING N/WKND +10 ROAMING VOICE +11 ROAMING LD +12 ROAM MSG RETRIEVAL +13 ROAM ENH DISC INT DL +14 LONG DISTANCE +15 ENH DISC INT DL +16 INTL TEXT MSG +17 CALL WAITING +18 DROP CALL CREDIT +19 INCLUDED MINUTES +20 411 INFO PROMO +Total Monthly Usage Charges +| 1.024 Kilobytes (KB) = 1 Megabyte (MB) +Other Subscriber Credits +Item Description +1 MMODE INTRODUCTORY 1 MONTH PROMOTION +Total Other Subscriber Credits +Taxes, Surcharges and Regulatory Fees +Item Description +1 LOCAL WIRELESS SURCHARGE +2 MCTD SURCHARGE +I FEDERAL TAX +A TELECOM EXCISE TAX +/ UNIVERSAL CONNECTIVITY CHARGE +8 NY CITY UTILITY G.R. 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"1f6538f944a21d72e260c9865c91391e879379d6e767bd29e2a3b5d254826d4b", + "engine": "marble-apple-vision", + "event_count": 51, + "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "a8266fe2d0820b7b4e54c91f4005d7d3ae9b28d442635eb63a5e654752e7f89a", + "output_sha256": "219cdbb316503fb0598a3940539acb639bb544df02e5f227eb08e830955e950a", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1f6df0496ff66958e39ebd7b3806daeca6a29bba6e3355cad93906207320d6a3.md b/vision-fixhub/ds9-parsed-01/1f6df0496ff66958e39ebd7b3806daeca6a29bba6e3355cad93906207320d6a3.md new file mode 100644 index 0000000000000000000000000000000000000000..932f8fb1491447a613318bd0b646470c035be376 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1f6df0496ff66958e39ebd7b3806daeca6a29bba6e3355cad93906207320d6a3.md @@ -0,0 +1,219 @@ +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +------- X +UNITED STATES OF AMERICA +V. +GHISLAINE MAXWELL, +S2 20 Cr. 330 (AJN) +Defendant. +-- x +MS. MAXWELL'S MOTION FOR AN ORDER AUTHORIZING A SUBPOENA +PURSUANT TO FED. R. CRIM. P 17(c)(3) +Jeffrey S. Pagliuca +Laura A. Menninger +HADDON, MORGAN & FOREMAN P.C. +150 East 10th Avenue +Denver, CO 80203 +Phone: +Christian R. Everdell +COHEN & GRESSER LLP +800 Third Avenue +Non York, NY 10022 +Bobbi C. Sternheim +Law Offices of Bobbi C. Sternheim +225 Broadway, Suite 715 +New York, NY 10007 +Phone: +Attorneys for Ghislaine Marwell + + +Defendant Ghislaine Maxwell requests that the Court enter an Order authorizing her +counsel to issue a subpoena under Federal Rule of Criminal Procedure 17(c) to +, Epstein Victim's Compensation Program, for certain items identified in +Attachment A to the proposed Subpoena, together attached as Exhibit 1 to this Motion, for the +following reasons: +I. Background +On October 11, 2021, the government began producing 3500 material to the defense. +These rolling productions confirmed that the four Accusers referenced in the indictment applied +for and received millions of dollars from the Epstein Victim Compensation Fund. Ms. Maxwell +requests the Court's assistance in subpoenaing documents submitted by the Accusers and the +witnesses for use at trial. The documents should be returned to this Court for an in camera +review and, subject to the Court's review, disclosed to the defense to be used for impeachment of +the witnesses at trial. +II. Legal Standard +Rule 17(c) permits subpoenas compelling the production of "books, papers, documents, +data, or other objects" prior to trial. Fed. R. Crim. P. 17(c)(1). Most district courts in the Second +Circuit, including this Court, apply the analysis set forth in United States v. Nixon, 418 U.S. 683, +699-700 (1974). See United States v. Pena, No. 15-CR-551 (AJN), 2016 WL 8735699, at *1-2 +(S.D.N.Y. Feb. 12, 2016). The party requesting the information "must make a preponderance +showing that the materials requested are relevant, specifically identified, admissible, and not +otherwise procurable by the exercise of due diligence." Id. (quotations and citations omitted). +1 + + +I. Factual and Procedural History +A. The Allegations in the Superseding Indictment +Counts One and Three of the S2 Indictment allege that Ms. Maxwell conspired to violate +two separate provisions of the Mann Act, 18 U.S.C. §§ 2422, 2423(a). Count One alleges that +Ms. Maxwell conspired to entice "one and more individuals" to travel in interstate and foreign +commerce to engage in "sexual activity for which a person can be charged with a criminal +offense" in violation of 18 U.S.C. § 2422. (S2 Indictment 1911-13). Count Three alleges that Ms. +Maxwell conspired to transport "an individual" in interstate and foreign commerce to engage in +"sexual activity for which a person can be charged with a criminal offense" in violation of 18 +U.S.C. § 2423(a). (Id. IN 16-19). Counts One and Three allege overt acts purportedly involving +Accusers 1, 2, and 4 and Witness-3.' +Count Two of the S2 Indictment alleges enticement to engage in illegal sex acts in +violation of the Mann Act, 18 U.S.C. § 2422. Count Four alleges transportation of a minor to +engage in illegal sexual activity in violation of 18 U.S.C. § 2423. Counts Two and Four concern +Accuser-1. +Counts Five and Six of the S2 Indictment allege that Ms. Maxwell violated and conspired +to violate the federal sex trafficking statute, 18 U.S.C. § 1591. Count Five alleges that Ms. +Maxwell conspired with Epstein and others to recruit "a person" knowing that the person "had +not attained the age of 18 years and would be caused to engage in a commercial sex act" in +violation of 18 U.S.C. § 1591(a). (Id. $ 23-24). Count Six charges Ms. Maxwell with a +substantive violation of § 1591(a), claiming she "did recruit, entice, harbor, transport, provide, +' Pursuant to the Court's ruling at the November 10, 2021 conference, we will refer to Accuser-3 as +"Witness-3." However, for ease of reference, we will refer to these four women collectively as the +"Accusers." +2 + + +and obtain by any means" individuals who were under the age of 18, including Accuser-4, "who +were then caused to engage in at least one commercial sex act with Jeffrey Epstein." (Id. I 27). +Both counts are based on the allegations of Accuser-4 and allege conduct that purportedly +occurred "[f]rom at least in or about 2001, up to and including in or about 2004." (Id. WIl 23, 27). +B. The Accusers and The Epstein Victim Compensation Fund +Accusers 1 and 2 sued the Epstein Estate and simultaneously applied to the Epstein +Victim Compensation Fund. Accuser-4 previously sued Epstein and +and reached a +settlement for those claims. Ms. Maxwell was not mentioned in that lawsuit. Accuser-4 and +Witness-3 applied to the Epstein Victim Compensation Fund. All four women chose to accept +compensation from the Epstein Victim Fund. In its 3500 disclosures, the government has +provided statements from the Accusers indicating that Accuser-1 resolved her claims for +$5,000,000; Accuser-2 for $1,500,000; Witness-3 for $3,250,000 and Aceuser-4 for $3,500,000. +The Protocol for receiving compensation is attached as 1 to Attachment A. The Protocol +requires a written submission. The claims are evaluated per the Protocol which credits +"[w]hether there exists any information and/or pertinent findings offered by the appropriate +Office of the District Attorney, United States Attorney's Office, or other law enforcement +agency." Accordingly, the Protocol credits claimants who have had charges filed against Epstein +or any employee of Epstein. The June 2019 indictment against Epstein did not include the +allegations of the four Accusers that are contained in the S2 Indictment charging Ms. Maxwell. +Under the terms of the Protocol, the Accusers here, and their civil lawyers, stood to benefit if the +prosecution against Ms. Maxwell went forward. The Protocol also rewards Accusers who have +filed a lawsuit, legal action or claim of sexual abuse against Epstein, or the Estate, which +includes any employees or former employees of Epstein. Lawyers for Accuser-2 and Witness-3 +3 + + +were instrumental in creating and structuring the terms of the Protocol. See Co-Executors" +Corrections to Attorney General's Status Report on Voluntary Compensation Program and +Renewed Request for Ruling, +v. Indyke, No. 19-cv-10475-LGS-DCF, Dkt. 73-1. +1. Specificity +The Protocol establishes a process that all claimants must follow. The "Claimant" must +submit a "Claim Form" with documentation. These claims are then evaluated based on the +criteria established in the Protocol. Any deficiencies in the claim are communicated to the +Claimant. If a claim is approved, the Administrator sends the Claimant an offer letter and a +release. Ms. Maxwell is requesting specific documents identified in the Protocol, including the +Claim Form with any supporting documentation, correspondence between the Claimant (or her +attorney) and the Administrator, a copy of the check issued to the Claimant, and a copy of the +release signed by the Claimant. +2. Admissibility +There are no evidentiary impediments to admissibility. The documents are relevant, +authentic, and an appropriate evidentiary foundation can be established under many rules of +evidence. The Claim Form is a prior statement of the Accusers about the events alleged in the S2 +Indictment. The Claim Forms and subsequent communications are admissible impeachment +evidence at trial. +3. Relevance +As previously stated, Accusers 1 and 2 sued the Epstein Estate and simultaneously +applied to the Epstein Victim Compensation Fund. Accuser-4 previously sued Epstein and | +and reached a settlement for those claims. Ms. Maxwell was not mentioned in that +lawsuit. Accuser-4 and Witness-3 applied to the Epstein Victim Compensation Fund. All four +women here chose to accept compensation from the Epstein Victim Fund. In its 3500 disclosures +4 + + +the government has provided statements form the Accusers indicating that Accuser-1 resolved +her claims for $5,000,000; Accuser-2 for $1,500,000; Witness-3 for $3,250,000 and Accuser-4 +for $3,500,000. +The Protocol for receiving compensation is attached as Exhibit 1 to Attachment A. The +Protocol requires a written submission. The claims are evaluated per the Protocol which credits +"[w]hether there exists any information and/or pertinent findings offered by the appropriate +Office of the District Attorney, United States Attorney's Office, or other law enforcement +agency." Accordingly, the Protocol credits claimants who have had charges filed against Epstein +or any employee of Epstein. The June 2019 indictment against Epstein did not include the +allegations of the four Accusers that are contained in the S2 Indictment charging Ms. Maxwell. +Under the terms of the Protocol the Accusers here, and their civil lawyers, stood to benefit if the +prosecution against Ms. Maxwell went forward. The Protocol also rewards Accusers who have +filed a lawsuit, legal action or claim of sexual abuse against Epstein, or the Estate, which +includes any employees or former employees of Epstein. Lawyers for Accuser-2 and Witness-3 +were instrumental in creating and structuring the terms of the Protocol. See Co-Executors" +Corrections to Attorney General's Status Report on Voluntary Compensation Program and +Renewed Request for Ruling, I +v. Indyke, No. 19-cv-10475-LGS-DCF, Dkt. 73-1. +The documents sought are obviously relevant -- statements of the Accusers about what +they claim happened for purposes of securing a settlement. Similarly, the amount of +compensation is also relevant. "Relevant evidence means evidence having any tendency to make +the existence of any fact that is of consequence to the determination of the action more probable +or less probable than it would be without the evidence." United States v. Malpeso, 115 F.3d 155, +162-63 (2d Cir. 1997) (quoting Fed. R. Evid. 410). +5 + + +This trial will turn on the credibility of the individuals accusing Ms. Maxwell of these +crimes. The Court should allow broad cross-examination during the trial on general issues of bias +and motive for fabrication to protect Ms. Maxwell's rights under the Confrontation Clause of the +United States Constitution. A criminal defendant "states a violation of the Confrontation Clause +by showing that [s]he was prohibited from engaging in otherwise appropriate cross-examination +designed to show a prototypical form of bias on the part of the witness, and thereby 'to expose to +the jury the facts from which jurors could appropriately draw inferences relating to the reliability +of the witness."" Delaware v. Van Arsdall, 475 U.S. 673 (1986) (quoting Davis v. Alaska, 415 +U.S. 308, 318, (1974)). "IT]he exposure of a witness' motivation in testifying is a proper and +important function of the constitutionally protected right of cross-examination."" Olden v. +Kentucky, 488 U.S. 227, 231 (1988) (quoting Davis, 415 U.S. at 316-17). The possibility of an +economic reward is classic impeachment material. United States v. Bagley, 473 U.S. 667, 684, +(1985). +Full and complete cross-examination of the Accusers is impossible without understanding +the complete terms of the agreement with the Epstein Fund, including the claims concerning Ms. +Maxwell, as well as others. Cf. Moore v. Marr, 254 F.3d 1235, 1244 (10th Cir. 2001) (noting that +witnesses' "application for victim compensation payments and application for and receipt of +emergency victim compensation payments may well have been 'favorable' within the meaning +of Brady," requiring government disclosure of exculpatory evidence to criminal defendants); +payments and promises made to cooperating witnesses. See also, United States v. DeLeon, 428 F. +Supp. 3d 675, 697 (D.N.M. 2019); and United States v. Sedaghaty, 728 F.3d 885, 898 (9th Cir. +2013), "Impeachment evidence is especially likely to be material when it impugns the testimony" +of witnesses "critical to the prosecution's case." +6 + + +Dated: November 14, 2021 +Respectfully submitted, +s/ Jeffrey S. Pagliuca +Jeffrey S. Pagliuca (pro hac vice) +Laura A. Menninger +HADDON, MORGAN & FOREMAN P.C. +50 East 10th Avenu +enver. CO 8020 +Phone: +Christian R. Everdell +COHEN & GRESSER LLP +800 Third Avenue +New York, NY 10022 +Phone: +Bobbi C. Sternheim +Law Offices of Bobbi C. Sternheim +225 Broadway, Suite 715 +New York, NY 10007 +Phone: +Attorneys for Ghislaine Maxwell +7 + + +Certificate of Service +I hereby certify that on November 14, 2021, I electronically filed the foregoing Ms. +the following: +U.S. Attorney's Office, SDNY +One Saint Andrew's Plaza +New York, NY 10007 +s/ Nicole Simmons +8 diff --git a/vision-fixhub/ds9-parsed-01/1f6df0496ff66958e39ebd7b3806daeca6a29bba6e3355cad93906207320d6a3.receipt.json b/vision-fixhub/ds9-parsed-01/1f6df0496ff66958e39ebd7b3806daeca6a29bba6e3355cad93906207320d6a3.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..64536f93f9cd1525227346adb628f1e294c17587 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1f6df0496ff66958e39ebd7b3806daeca6a29bba6e3355cad93906207320d6a3.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -108, + "dataset": "marble-joined", + "doc_id": "1f6df0496ff66958e39ebd7b3806daeca6a29bba6e3355cad93906207320d6a3", + "engine": "marble-apple-vision", + "event_count": 9, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "83a1de6bd195ee96f8e3a6c81f9c2086c55366507eb2343166cf0287ac907bdd", + "output_sha256": "30cda0984719bf46533737c8c4be5fdb62bb47d9207d6903c4cbe91796a69604", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1f71c982756e0735949571e11e00cd707fd5ead36e58dc7d9b8357f979f072ec.md b/vision-fixhub/ds9-parsed-01/1f71c982756e0735949571e11e00cd707fd5ead36e58dc7d9b8357f979f072ec.md new file mode 100644 index 0000000000000000000000000000000000000000..d1a41a7314572009fe4609b112cf8817ad917963 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1f71c982756e0735949571e11e00cd707fd5ead36e58dc7d9b8357f979f072ec.md @@ -0,0 +1,31 @@ +From: "l +To: "l +Ce: "l +(USANYS)" < +(USANYS)" ‹ +(USANYS)" - +Subject: RE: +Date: Wed, 28 Aug 2019 22:07:56 +0000 +Sure, I'm at my desk, +From: +| (USANYS) 4 +Sent: Wednesday, August 28, 2019 6:07 PM +| (USANYS) < +|(USANYS) < +Cc:| +Subject: Re: | +Yes, that would be | +One for the ages. Are you around now? I can tear myself away from my +Stephen King book to give you the low down on | +Best, +Sent from my iPhone +On Aug 28, 2019, at 6:04 PM, +Hi +(USANYS) < +P wrote: +I said you had a cooperator who was the +give either of us a call when convenient, thanks! +with "urgent" information about Epstein. Feel free to +Assistant United States Attorney +Southern District of New York +Tel: diff --git a/vision-fixhub/ds9-parsed-01/1f71c982756e0735949571e11e00cd707fd5ead36e58dc7d9b8357f979f072ec.receipt.json b/vision-fixhub/ds9-parsed-01/1f71c982756e0735949571e11e00cd707fd5ead36e58dc7d9b8357f979f072ec.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..7b305ff8e34cd99c426276da49f06d1232060dd9 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1f71c982756e0735949571e11e00cd707fd5ead36e58dc7d9b8357f979f072ec.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "1f71c982756e0735949571e11e00cd707fd5ead36e58dc7d9b8357f979f072ec", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "649db37c7efd3161d27ddc5882ce8b85996cfb20befe74ed3884eaf4a5d6c9e2", + "output_sha256": "df1b6d8cf6079b21fa131dab929b1a1068f158e44c4c3d71eae79a0f3c2998c2", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1f81226a49e4c91ffdd906e2d5a83cc9113d66bd2f187d583b5e4f29b846558b.md b/vision-fixhub/ds9-parsed-01/1f81226a49e4c91ffdd906e2d5a83cc9113d66bd2f187d583b5e4f29b846558b.md new file mode 100644 index 0000000000000000000000000000000000000000..c95ceb15d262f989e87e214b5878ad8a595d662c --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1f81226a49e4c91ffdd906e2d5a83cc9113d66bd2f187d583b5e4f29b846558b.md @@ -0,0 +1,4611 @@ +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +1 +J8RSEPS1 +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +UNITED STATES OF AMERICA, +V. +JEFFREY EPSTEIN, +-x +19 CR 490 (RMB) +Defendant. +- X +New York, N.Y. +August 27, 2019 +10:30 a.m. +Before: +HON. RICHARD M. BERMAN, +District Judge +APPEARANCES +GEOFFREY S. BERMAN +United States Attorney for the +Southern District of New York +BY: +Assistant United States Attorneys +MARTIN G. WEINBERG, PC +Attorney for Defendant +BY: MARTIN G. WEINBERG +STEPTOE & JOHNSON, LLP +Attorneys for Defendant +BY: REID WEINGARTEN +MICHAEL MILLER + + +1 +2 +3 +4 +5 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +2 +J8RSEPS1 +(Case called) +THE COURT: Good morning, everybody. Please be +seated. +So just some housekeeping. We have a podium here for +both attorneys and others who may be speaking, and so we would +like you, attorneys and others who are speaking, to come up to +the podium. This room is a little cavernous. We thought the +podium over there would be more comfortable. +For starters, and for this you don't have to go up to +the podium, if you could just indicate your names. This table +in front to my left, your right, are defense counsel, and that +table to my right, your left, are government attorneys. +If we could just ask the attorneys to introduce +themselves. +MS. +and +: Good morning, your Honor. +for the government. Joining us at counsel table +are Special Agent +of the FBI and Detective +of the NYPD. +MR. WEINGARTEN: Good morning, your Honor. +Reid Weingarten. +MR. WEINBERG: Martin Weinberg. +Good morning, your Honor. +THE COURT: Good morning. +MR. MILLER: Good morning, your Honor. +Michael Miller from Steptoe & Johnson on behalf of the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +3 +defendant. +THE COURT: Great. +Again, good morning to all of you. This hearing that +we're having today considers the government's motion to dismiss +the indictment in this case. +I must add that it also serves as the opportunity for +me to thank all of you, the attorneys and the victims who are +here today, among others, for your very hard work and +dedication in this case. +We also have here today the U.S. Attorney for the +Southern District of New York, Geoffrey Berman, who has also +been very helpful and indispensable in this matter. +The news on August 10, 2019, that Jeffrey Epstein had +been found dead in his cell at the Metropolitan Correctional +Center, at the MCC, was certainly shocking. Most of you, and +myself for that matter, were anticipating that the next steps +in this case would be defense motion practice, including a +motion to dismiss, +followed by a trial on the merits before a +jury, if the motions were not successful, and through which the +accusers and the accused would come face to face, allowing +everyone to get their day in court. Mr. Epstein's death +obviously means that a trial in which he is a defendant cannot +take place. It is a rather stunning turn of events. +The government's motion to dismiss the indictment +because of Jeffrey Epstein's death on August 10, 2019, is + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +4 +relatively straightforward. In my view, a public hearing +clearly is nevertheless the preferred vehicle for its +resolution. +Incidentally, while I'm on this subject, I got some +help today from the New York Law Journal from two professors +who write that a hearing is -- let me tell you exactly what +they said. They say, in part, that this is an odd moment for +transparency in a criminal case. I think that is an odd +sentence to hear about, transparency in a criminal case. +They go on to say that normally, if a prosecutor seeks +to dismiss an indictment for such an obviously worthy reason, +the court would simply grant the request. As to that +statement, I respectfully say it is incorrect as a matter of +law. +They go on to say the judge would not schedule a +hearing and he definitely would not allow the victims to speak. +If he did hold a hearing, whatever informational interests the +victims may have would be served by affording them a chance to +attend the hearing, not by giving them a speaking role. +I read it. It was incredulous. I'm still +incredulous. I don't quite understand at all. There is a +suggestion in the article that the reason they are making these +suggestions has to do with minimization of drama in this case. +In the Jeffrey Epstein case, there has not been much a +minimization of drama, and what little drama might happen + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +5 +today, I don't think it would be very significant. +On a somewhat more serious note, don't quote me on +this, but it is my understanding that one of the authors of +that article is himself counsel in one of the Epstein-related +cases. I was surprised to learn that very recently. I'm +certain it is true. I was also surprised that that aspect was +not disclosed in the Law Journal. +But in any event, I think you know where I'm heading. +I respectfully disagree with the Law Journal piece. I was +saying that the government's motion is relatively +straightforward, and in my view, a public hearing is clearly, +nevertheless, the preferred vehicle for its resolution. I'm +still convinced of that. +A few may differ on this, but public hearings are +exactly what judges do. Hearings promote transparency and they +provide the court with insights and information which the court +may not otherwise be aware of. +The victims have been included in the proceeding today +both because of their relevant experiences and because they +should always be involved before rather than after the fact. +Indictment 19 CR 490 charges Jeffrey Epstein with sex +trafficking and with conspiracy to commit sex trafficking. The +U.S. Attorney, on August 19, 2019, requested that the court +approve the government's proposed order of nolle prosequi. +I +think that's a rough justice. That means nolle prosequi, + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +6 +discontinuance by the prosecutor of all or of a part of the +case that he or she has commenced. +The government in its motion concludes that Epstein's +death abates these proceedings. In accordance with Federal +Rule of Criminal Procedure 57(b), I determined to hold a public +hearing and I notified the victims that they would be given the +opportunity to be heard before any final action on the motion. +That is the purpose also of today's proceeding. I would do +that every time. +Also, recognized that Epstein, Mr. Epstein died before +any judgment of conviction against him had been obtained, and +that the government's proposed order appears, in form and +substance, to be appropriate. +Federal Rule of Criminal Procedure 48(a) codifies the +nolle prosequi process. It is entitled dismissal, and it +states in relevant part that the government may, with leave of +the court, dismiss an indictment, information, or complaint, +and that leave of the court proviso, you should know, was added +as an amendment to the original draft of Rule 48, which had +originally provided for automatic dismissal upon the motion of +the government. +This proviso, in my judgment, is clearly directed +toward an independent judicial assessment of the public +interest in dismissing the indictment. Thus, even whereas, in +this case, the standard of court review is deferential, the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +7 +court must still make its own independent determination. A +conclusory statement from the government that dismissal is +appropriate does not satisfy the court's obligations. +It is also, in my view, required that the court +consider the views of the victims in the case at the hearing +and before deciding whether to grant the motion. This is being +done here both as a matter of law and as a measure of respect +that we have for the victims' difficult decisions to come +forward in this matter. +In a case called United States v. Heaton, +H-e-a-t-o-n-, the government filed a Rule 48 motion for leave +to dismiss a charge against a defendant who allegedly committed +a sexual offense against a young victim. Although I should +point out, very importantly, that that defendant was still +alive, which distinguishes it from our case. +Nevertheless, I think it is irrelevant because in +evaluating the Rule 48 motion, then district Judge Paul G. +Cassell -- who is now a law professor at the University of Utah +and is regarded to be a noted expert in victims' rights -- +concluded that under the Crime Victims' Rights Act, victims +have broad rights that extend to a court's decision whether to +grant a government motion to dismiss under Rule 48. +I completely share that viewpoint in these +circumstances, even though the facts of our case, as I said, +are somewhat different from those in Heaton. I believe it is + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +8 +the court's responsibility, and manifestly within its purview, +to ensure that the victims in this case are treated fairly and +with dignity. +The fundamental substantive principle which applies in +considering the government's motion is termed the rule of +abatement. This principle originated in the English common +law. It was adopted by most U.S. federal courts, but more +recently, it has faced some appropriate criticism. The rule of +abatement is best explained in the Second Circuit case of +U.S. v. Wright. +In that Wright case, two defendants had pled guilty to +embezzlement and tax evasion. Both defendants appealed, but +one of the defendants died while his appeal was pending in the +Second Circuit. The Court of Appeals rule that under the rule +of abatement, the judgment of conviction against the deceased +defendant was required to be vacated and the indictment was to +be dismissed. The Wright court held that when a convicted +defendant dies while his direct appeal as of right is pending, +his death abates not only the appeal, but also proceedings had +during the course of the prosecution. +The Second Circuit incidentally has also held that +when a criminal conviction abates upon the death of a +defendant, any restitution ordered as a result of that +conviction must also abate, and it is also ruled the same with +respect to associated forfeiture orders. + + +9 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +This latter application of the rule of abatement +regarding forfeiture has not been universally accepted among +federal courts, but it certainly is the law in this circuit. +Some of you may be interested to know that some United States +courts, state courts, have criticized the rule of abatement, +particularly in the face of growing recognition of victims' +rights in the criminal justice system, including the Crime +Victims' Rights Act. +It has been written and contended in the Brooklyn Law +Review -- I can give you the cite later -- that when courts +abate criminal convictions, they reimpose a burden on victims +that legislatures intended to alleviate through these victim +rights statutes. The state Supreme Court has even concluded +that the expansion and codification of victims' rights provides +the changed conditions needed for overruling the rule of +abatement. It has also been stated that Alaska's statute and +its constitution now require the criminal justice system to +accommodate the rights of crime victims. Further, that the +abatement of criminal convictions has important implications +for these rights. +But coming back to our case, which is what you are +concerned about and I am as well, it is appropriate to conclude +that if the rule of abatement applies to a convicted defendant +as in the Wright case, it should also apply a fortiori in the +Epstein case, which was still in the pretrial phase when + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +10 +Mr. Epstein died, when there had been no conviction. +So that's just some background I wanted to share with +you. At this point in time, I would like to turn to the +government prosecutors to hear from them in support of their +Rule 48 application to dismiss the Epstein indictment. +MS. I +I: Thank you, your Honor. +Would you like me to address the court from the +podium? +THE COURT: If you wouldn't mind. +MS. +: Thank you, your Honor. +I believe your Honor has accurately summarized the +state of the law, as set forth in our papers, in light of the +clear Second Circuit law, that upon the death of a defendant +before a final entry of a judgment of conviction, all +proceedings must be abated. +In light of that clear law, the government is legally +obligated to seek dismissal of the pending indictment against +Jeffrey Epstein, and we respectfully submit, likewise, that the +entry of the proposed order is similarly required by law. +A few notes to make about that, though, your Honor. +Io be very clear, dismissal of this indictment as to Jeffrey +Epstein in no way prohibits or inhibits the government's +ongoing investigation into other potential coconspirators, nor +does it prevent the bringing of a new case in the future or the +prosecution of new defendants. + + +11 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +It also does nothing to prevent the government from +continuing to explore the possibility of seeking civil +forfeiture of any assets that +were used to facilitate the +crimes charged in this indictment. Indeed, as has been stated +publicly, investigations into those matters have been ongoing, +remain ongoing, and will continue following dismissal of the +indictment here. +I would also like to note that, as the government has +previously mentioned, this dismissal in no way lessens the +government's resolve to stand up for the victims in this case, +both those who have come forward and those who have yet to do +so. We agree with your Honor's sentiment that those victims +should be respected, and we appreciate your Honor's recognition +of that. +One housekeeping matter that I did want to reference +for your Honor. The protective order in this case requires +destruction or return of any and all discovery material upon +conclusion of the case. We have been in communication with +defense counsel, who have confirmed that they have returned all +physical copies that they have of discovery that the government +has produced to date, and they are in the process of deleting +any copies that they may have made. So the parties are in +compliance with the protective order. +Finally, I just wanted to say a word about the victims +in this case, and particularly those who are here in court + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +12 +today. I'll note that in light of the court's order indicating +that the victims and their +counsel would be permitted to be +heard in court here today, the government has endeavored to +provide notice to all known victims of today's proceeding. We +did so either directly where a victim was not represented by +counsel or through counsel +where a victim is represented by an +attorney. +The government does not know exactly how many victims +or their attorneys are here today and we do not know how many +of them or their counsel would like to speak. Io the extent +any individuals do wish to speak, we do not know the substance +of what they would like to say. We have left that entirely up +to the individual decisions of the victims and their attorneys. +I will note, though, that throughout this case, the +government has endeavored and done our utmost to fulfill our +obligations under the Crimes Victims' Rights Act. We have done +so by trying to keep as many victims as we are aware of up to +date about the ongoing case and about any developments in the +case. +We will continue to provide services and offer +services to any of the victims in this case, even after the +indictment is dismissed. Both the U.S. Attorney's office and +the FBI have been in touch with all known victims or have +attempted to be in touch with all known victims, either again +directly where victims are not represented by counsel or + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +13 +J8RSEPS1 +through counsel where they have attorneys. We have expressed +to them that services are available for those who wish to take +advantage of them. +Unless the court has any questions for me, the +government will otherwise rest on its papers. +THE COURT: I just have one question. +The protective order, is that self-executing or do I +need to do something? +MS. +1: It is self-executing, your Honor. +THE COURT: Thanks very much, Ms. +MS. +|: Thank you, your Honor. +THE COURT: Yes. +I'll turn to counsel for the defense at this time. +Mr. Weingarten, I'm happy to hear from you. +MR. WEINGARTEN: Thank you. +Your Honor, I think it is an understatement of the +year to say the world looks and feels differently today than it +did the last time I was before you. For us, the elephant in +the room is what happened to our client. I would like to tell +you how we see the world and where we are on that subject. +We start with the Attorney General's statements, +public statements, that there were very serious improprieties +in the jail. We obviously read the press. +We see that the +warden has been taken out. We see that the guards on duty at +the time have been put on leave. We understand guards are + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +14 +refusing to cooperate with the investigation. We have heard +allegations that people at the time who had responsibility for +protecting our client falsified information. We understand +that there were orders out there that Jeffrey Epstein was never +to be left alone and that the orders were ignored by many of +the employees of the prison. +In a word, yikes. +In addition, obviously we followed +the medical examiner's report, or we haven't followed the +report, we haven't seen it, but heard conclusions, initially +not enough evidence to come to a conclusion, wanted to see +more. We assumed she was talking about the videotapes, but +then came to the conclusion that it was suicide. +We report to the court that -- +THE COURT: Suicide by hanging -- +MR. WEINGARTEN: Yes. +THE COURT: -- was her conclusion? +MR. WEINGARTEN: Yes. +And we report to the court that we had a doctor there +at the time, and we also have been in receipt of a tremendous +amount of medical and scientific evidence volunteered to us +opining that the injuries suffered, as reported, were far more +consistent with assault than with suicide, and we are happy to +supply the court with all the information that we have. +Now, in addition, as the court noted, we were underway +with our pretrial motions, and as the court obviously + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +15 +understands, the NPA and the role of the NPA was going to be +critically important. And I would simply like to report that +we went pretty far along. +We interviewed all of the relevant lawyers on the +defense side who participated in the NPA, and we were satisfied +that we had a very strong argument that every one of those +lawyers believed with an objective basis that the deal was +global. That is, at the time -- +THE COURT: I'm sorry, that? +MR. WEINGARTEN: The deal of the NPA was global. That +is, more specifically, at the time, the Florida prosecutors and +agents knew of conduct in New York, and that no competent +defense counsel negotiating in good faith with the prosecutors +would have ever agreed to a deal back then that allowed New +York prosecutors to indict for precisely the same conduct in +the future, which, of course, is what happened. +In addition, we have come up with very powerful +evidence, we believe, that Florida prosecutors, who +participated in the deal, steered the victims and the alleged +victims to New York on more than one occasion because they did +not want to suffer the sleights of attacks against them. So we +have advanced the ball on this very subject and we are prepared +to completely report to the court as to where we are and what +we've done. +Another point. We obviously had contact with our + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +16 +client at or around the time of his death, and obviously the +attorney-client privilege survives death and we are not going +to forfeit the privilege, but we will report to the court, with +as much specificity as the court may want, that at or around +the time of his death, we did not see a despairing, despondent +suicidal person. Details to follow, if the court wishes. +The 800-pound gorilla, for us, of course, are the +video surveillance tapes. Obviously we assume there is a tape +that leads directly to the door where Jeffrey Epstein was +housed. If that tape reports for 12 hours before his death +that no one went in and out of that room, then the suggestion +that there was something other than a suicide seems +preposterous. +But there is no such evidence that has surfaced to +date. Just the opposite. +We have heard, and we actually read +in the press, that the tapes were either corrupted or not +functioning. Talk about a yikes. If, in fact, the system was +broken for six months before Jeffrey Epstein was housed, I +mean, that would be stunning incompetence. If it was allowed +to continue to be inoperative when Jeffrey Epstein was housed, +it would be incompetence times ten. But what if the tapes only +broke down or were inoperative or were corrupted on the day he +was killed or the day he died? Then we're in a completely +different situation. +So where does this lead? I think where it leads, + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +17 +Judge, is there are incredibly important questions that remain +open. The public interest in this matter is obvious from this +courtroom. There are conspiracy theories galore. We are all +for finding the truth. We believe this court has an +indispensable role to play. +Whether or not this indictment is dismissed, I think +this court has the inherent authority to find out what happened +on its watch. Obviously, when the court detained Jeffrey +Epstein, the court did not anticipate that weeks later he would +be dead in his cell. I think given the inherent authority of +the court, the court should make inquiry. +This could come in many forms. Obviously the court +made inquiry as to what happened in the first incident. When +there was an allegation of an attempted suicide, the court made +inquiry. The court obviously was interested. +I recall your language. You talked about that being +one of the several open questions indicating an interest on the +court for the others as well. Obviously, the ultimate question +is what happened to the client. +THE COURT: You're talking about the July 23, 2019 +incident? +MR. WEINGARTEN: Yes. +The court obviously could hold hearings. The court +could assign a lawyer to help the court. I think this is an +area where there is intense public interest. We have complete + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +18 +confidence in the prosecutors in the Southern District and the +FBI to do a competent investigation. But these are allegations +against serious components of the United States Department of +Justice. Sometimes the appearance of justice is just as +important as justice itself. +I think the court supervising, or at least keeping an +interest in this proceeding, is incredibly important for the +public to have confidence in the ultimate findings, and +certainly for us to have confidence in the ultimate findings. +One more issue, Judge. The conditions of the jail, in +a word, they were dreadful. +Not just for Jeffrey Epstein, but +for many of the prisoners over there. This is a prison within +the shadows of this courthouse. The situation is rife with +vermin. +The abuse and the conditions in that prison, in a +word, are a disgrace and everybody knows it. +A person with authority told us, someone with +knowledge, that the prisoners in Guantanamo -- and he spoke +with personal knowledge -- are treated better than the +prisoners right across the way. The feds certainly know how to +run a disciplined, clean prison. I've been in 20 of them. +They know how to do it just fine. And the question is, why in +the world does it not happen down the road? I think that is a +perfectly legitimate subject for the court to make inquiry. +In a word, we want the court to help us find out what +happened. The court has a role to play. It is the institution + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +19 +J8RSEPS1 +that most people have confidence in in these very troubled +times. +So whether or not you dismiss the indictment, to us, +is beside the point. We want you to stay on the case, we want +you to conduct an investigation, and we want to know what +happened here. +Thank you, your Honor. +THE COURT: Just so it is clear, so your view on the +motion directly on its merits of the nolle prosequi order and +application by the U.S. Attorney, do you have a view on that? +MR. WEINGARTEN: I think if the court felt that the +case had to stay alive for the court to continue, we would +oppose it. I think -- +THE COURT: I'm sorry, if what? +MR. WEINGARTEN: If the issue, if you took the +position for you to conduct the investigation or lead the +investigation or participate in the investigation, then we +want, the role we want you to play, if the indictment has to be +alive, we would oppose the motion. +I don't think you need to do that. I think you can +dismiss the indictment. +THE COURT: So you're suggesting that you support the +government's motion, just viewed in the context of -- +MR. WEINGARTEN: Yes, of course. +THE COURT: Great. + + +20 +J8RSEPS1 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +MR. WEINBERG: Judge, if I can just supplement? +THE COURT: Absolutely. +MR. WEINBERG: Thank you, sir. +Thank you, as an out-of-town lawyer for the privilege +to appear in front of you, your Honor. +THE COURT: It's my pleasure. +MR. WEINBERG: First, as to the conditions, we think +your Honor trusted the government, the Bureau of Prisons, to +keep our client safe and keep him in civilized conditions. The +government will again ask, as to other defendants, that they be +detained at the MCC, some +subset of them will end up in the SHU +unit. +It is a horrific. I've called it medieval. There's +vermin on the floor. There is wet from the plumbing. There is +no sunlight. There is limited exercise. It is simply +conditions that no pretrial detainee -- and I would go farther +as a criminal defense lawyer -- no United States defendant +should be subjected to. +Certain judges have taken views of the conditions. We +would urge your Honor, the government talks about and we talk +about transparency, to see what kind of conditions there exist +within 50 or 100 yards of one of the great United States +district courts. +Second, in terms, we have a profound problem with the +conclusions of the medical examiner. There are for three + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +21 +reasons, your Honor. +One is the timing of Mr. Epstein's demise. It was on +August 10. On August 12, a bail pending appeal motion was +being filed in the Second Circuit. On August 12 or 13, the +United States Attorneys were going to respond to our request +for the preservation and production of documents that would +have facilitated and furthered our efforts to demonstrate +communications between the Southern District of Florida, the +Northern District of Georgia, which was standing in the shoes +of the Southern District of Florida main justice and the +Southern District. +In other words, we were beginning the process +discharging our responsibilities. There had been no new +evidence that Mr. Epstein had committed any offense against a +minor after 2005. The subject matter of the New York +prosecution was squarely within the heartland of the Florida +NPA. +We had a significant motion to dismiss. This was not a +futile, you know, defeatist attitude. +Third, we had all the discovery motions that your +Honor had scheduled. So the timing for a pretrial detainee to +commit suicide on August 10, when his bail pending appeal +motion is being filed on August 12, strikes us as implausible. +Second, we had an independent doctor who was present +at the autopsy which occurred on August 11. On August 11, the +city medical examiner's findings were inconclusive. We are + + +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +22 +told by a very experienced forensic pathologist that the broken +bones in Mr. Epstein's neck, in his larynx, are more consistent +with external pressure, with strangulation, with homicide, if +you will, than with suicide. It doesn't exclude suicide, but +the pure medical forensic evidence creates profound issues +about what happened to him. +Also the time of death. Our medical examiner's +opinion is it occurred at least 45 minutes and probably hours +before 6:30 a.m. on August 10, when he was first found, if you +will, according to the reports. +Yet he was moved, something +that is not ordinary in these circumstances. +I would also -- +THE COURT: Excuse me. He was moved? +MR. WEINBERG: Instead of having the cell in the +condition it was found, if he had been dead for 45 minutes or +two hours or four hours, there were efforts to move him and, +therefore, make it more difficult to reconstruct whether or not +he died of suicide or some other cause. +I spoke to Stacey Richmond, who is a responsible +member of this court who represents the family of Mr. Epstein. +She spoke to the medical examiner on the Friday after +Mr. Epstein's death and asked why, if the conclusion was made +late in the afternoon on Friday that week. She specifically +asked about what extrinsic nonmedical evidence caused the +medical examiner to go from uncertain to suicide, and she was + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +23 +told that the medical examiner had seen nine minutes of one +video which was on a stairwell between floors at the MCC. She +was told that the principal video that would have showed the +whole hall was corrupted. It was in DC with the FBI to see if +they can reconstruct it. +And I asked the same questions that my co-counsel did, +you know, was the dysfunction of the critical pivotal video, in +the most secure prison east of Florence, out in Colorado known +to the MCC before August 10, or was this corruption occurring +on August 10, which would again cause us to be skeptical of the +servitude of the medical examiner's conclusions that this was +suicide rather than some other cause. +So with my co-counsel, we ask your Honor, it is not a +question of trust or not trust. They ask you to detain people +and you trust the Bureau of Prisons. And it is within your +inherit authority, your Honor, to find out what happened to our +client. +We are angry about the conditions he was held in. And +we're also angry, quite frankly, your Honor, that the only +source of information that we get as to what happened to him is +through the media rather than through the United States +Attorney's office. We've made requests informal. We have +made Touhy requests. +We've been told there is a pending +investigation. +But we trust your Honor and the judiciary, and with + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +24 +all due respect, we believe there is an inherent and central +role, a pivotal role in your Honor to find out what happened to +a defendant in a case before the court, whether or not the +court grants the nolle pros today or whether it holds it +pending an investigation into Mr. Epstein's death. +We're not here without significant doubts regarding +the conclusion of suicide. +We are not here to say what +happened. We don't know what happened. But we deeply want to +know what happened to our client. +Thank you, sir. +THE COURT: And you, as Mr. Weingarten, have the same +view of the nolle prosequi motion? +MR. WEINBERG: Yes, your Honor. +THE COURT: OK. +MS. +Your Honor, may I respond to some of those +points? +THE COURT: Sure. +MS. +1: Thank you, your Honor. +Just briefly. With the exception of the noting that +the defense does not have an objection to the government's +motion, virtually everything else that defense counsel just +argued, respectfully is completely irrelevant to the purposes +of today's proceeding and to the motion that is pending before +your Honor. +As an initial matter, the question -- + + +25 +J8RSEPS1 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +THE COURT: Well, it may be. Well, I don't know. You +say irrelevant. +It is a public hearing, and I think it is fair game +for defense counsel to raise its concerns. +MS. +: Certainly, your Honor. But it is +irrelevant to whether or not the motion should be granted. +THE COURT: Right. +I get that. +MS. +I: I would also note that the question of +Mr. Epstein's death is the subject of an ongoing and active +investigation, as has been publicly noted, by a separate team +of Assistant United States Attorneys from the Southern District +of New York, separate from the team who is handling this +prosecution, as well as a separate team of FBI agents. +There is an ongoing and active grand jury +investigation into the circumstances +surrounding Mr. Epstein's +death. It is the function of a grand jury and of the Federal +Bureau of Investigation to investigate crimes in the federal +court system. It is not the purview, respectfully, of the +court to conduct an investigation into uncharged matters. +So respectfully, we disagree with defense counsel's +suggestion that the court has some authority to conduct an +independent investigation. To the extent any other defendants +who are detained in the MCC have concerns about the conditions +or believe that the conditions are relevant to a future or +current bail determination, it is for those defendants and + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +26 +their counsel to raise those arguments and for the judges +hearing those arguments to evaluate those claims. It is not +relevant to today's proceedings. +Thank you, your Honor. +THE COURT: In those other cases, Ms. +, judges do +have authority to investigate, but don't here? +MS. +: Not to investigate, your Honor, but to +hear arguments about the conditions of confinement in the MCC +as they may relate to any bail determination. I believe that +was the argument that was made. +The bigger picture here, your Honor, is that the focus +of today's proceeding, as we understand it, is to allow the +victims who have gathered here today to be heard and to comment +upon the case and to comment upon the motion that is pending, +and to bring this case to a close. +THE COURT: Got it. +MR. WEINGARTEN: May I? +THE COURT: Sure. +MR. WEINGARTEN: We obviously saw this as, perhaps, +the last opportunity to be before you, and we wanted to take +advantage of the opportunity to say our peace and thank you for +allowing us. +There is precedent here. Ied Stevens, the Senator +from Alaska case in Washington, DC, Judge Emmet Sullivan +ordered an independent investigation by a private lawyer when + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +27 +he was deeply troubled by the alleged Brady violations. I +represented the prosecutors in that case, so I'm very, very +familiar with it. +It is analogous. It is a situation where there was +tremendous controversy over what happened in the case and +whether or not the prosecutors went off the reservation. Judge +Sullivan -- and there were three or four independent -- not +independent, DOJ inquiries into the very same matter. But +Judge Sullivan wanted his own opportunity to make a judgment +with his own independent investigation. +THE COURT: OK. +MR. WEINBERG: If I could just add one precedent, your +Honor. +The Chief judge in the District of Massachusetts or +the Chief Judge at the time, Judge Wolf, in a case called +U.S. V. Fleming, when the conditions at Walpole, which is a +state prison where federal prisoners were being held -- we +don't have a federal MCC in Boston -- went to the prison, +stayed in the prison to determine whether or not the complaints +about the conditions were authentic. +I think your Honor has the inherent authority to go to +the ninth floor and see how the MCC houses pretrial detainees. +Thank you. +THE COURT: Are you saying that whether or not the +motion is granted that is pending before us? + + +28 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +MR. WEINBERG: Yes, your Honor. +I think, like when appeals are taken, bail issues +remain before the district court. Jurisdiction is not +completely divested. Your Honor issued a pretrial detention +order and your Honor has the power, the inherent authority, +they are not going to refuse to allow you to go look at the +ninth floor. They are going to count on you to make decisions +in the future. +I just trust that the executive branch is not going to +prevent the judicial branch from looking into the death of +Jeffrey Epstein or the conditions in the SHU unit at the MCC, +sir. +THE COURT: Great. Thank you. +MS. +: May I, your Honor? +Just very briefly, your Honor. I would note that upon +the dismissal of the indictment, which I believe the parties +agree is appropriate in this case, there would be no case. +There would be no jurisdiction for the court to conduct any +sort of inquiry, even if the court had such authority. +THE COURT: Right. +OK. I think we've heard enough. +It is at this point in the hearing that I would like +to call upon victims' counsel, plural, for any remarks they may +have and they may wish to make. Also, to introduce their +clients, those of them who wish to be heard. + + +29 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +It would be helpful if, in doing that, if counsel -- +Mr. Edwards and I see and I see Mr. Boise as well -- I know +they are counsel to several, at least several of the victims. +It would be helpful if whoever is speaking, both Mr. Edwards +and Mr. Boise, would indicate to the court whether or not they +have discussed the pending motion with their clients, that is +to say and the rule of abatement, etc., etc. with them prior to +today's hearing. +Are we going to hear from Mr. Edwards first, is that +right? +MR. EDWARDS: Thank you, your Honor. +THE COURT: You bet. +It would be helpful, Mr. Edwards, if you would state +and spell your name for the court reporter. +If you are going to introduce someone else, which I +trust that you are, if you could state and spell their name as +well. +MR. EDWARDS: Yes, your Honor. +May it please the court. Brad Edwards, B-r-a-l +•-d-w-a-r-d-s, with the law firm of Edwards Pottinger. +I have in the courtroom today 15 victims that I +represent and have represented over the years. There are at +least 20 more who didn't make this hearing today for a +multitude of reasons, some out of fear of public exposure, +others because the way in which this case ended will never + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +30 +bring full justice, and they decided it was best for them not +to talk today. +Some of my clients are going to address the court that +are here today. Others are not. Some are going to use their +names, and have in the past, and others wish to remain +anonymous. And I have instructed each of them to inform the +court reporter that they will be proceeding as Jane Doe so that +the court reporter can take them down. +THE COURT: For those who wish to remain anonymous? +MR. EDWARDS: Exactly, your Honor. +THE COURT: And that is satisfactory, as far as I am +concerned. +MR. EDWARDS: Before we do that, I would like to +address a couple of the things that have occurred this morning. +First of all, whether relevant or not, I personally, +and on behalf of my clients, do appreciate the presentation +that Mr. Weingarten made and Mr. Marty Weinberg made. +I have tremendous respect for Mr. Weinberg. I've +worked with him through this and related cases for years, and I +understand the reason why they made the presentation that they +made. +There is two things of interest to our clients in that +respect. One is, because of the tragic ending, that none of my +clients wanted, nor did I, nor did anyone else, if there is +some civil rights violation and there is some civil remedy for + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +31 +Mr. Epstein that goes to the estate, certainly the victims are +interested in that as they might help to repair the damage +done. +Second, Mr. Epstein's untimely death, the timing is +curious to us. But more so, it makes it absolutely impossible +for the victims to ever get the day in court that they wanted +in court and to get full justice. That now can never happen. +I know that Mr. Epstein's attorneys say he wanted it, and they +know, we did too. And there are a lot of people here today +that are very sad by the way that this ended for both +Mr. Epstein and the fact that full justice was robbed from +them, once again. +The second issue I wanted to address was the Law +Review or the Law Journal article that your Honor referenced, +which is troubling because the opinion seems to say that +transparency is not appropriate in the criminal system and is +not appropriate at this point in time. +That's tough to swallow, especially in this case, +given the long history of this case. Personally, it is tough +to swallow, and on behalf of my clients, I can say that is very +concerning. Transparency is the only way that the justice +system works. We know this because there was a similar +investigation of Mr. Epstein many years ago, from 2005 to 2008. +My personal involvement in this case was because a +young female came into my office named +and she + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +32 +came to me not asking to file a lawsuit against Jeffrey +Epstein, but simply asking for the government to talk to her. +She was cooperating in an FBI investigation and wanted the +government to speak with her, and I thought that was going to +be an easy task. +It was only a few months later that we learned that +this investigation that was represented to my client in written +form, that it would be a long investigation, and to be patient. +Basically, to hang tight. It was resolved by way of a secret +deal that never allowed any of the more than 30 victims who had +been identified of Mr. Epstein's abuse in Florida to ever +participate in a single hearing. There was a hearing. They +were never notified. +I then went on to represent many of them in civil +cases and also in extensive pro bono work. And I can tell your +Honor that while Jeffrey Epstein's abuse of them hurt them and +harmed them for many years, the feelings they had was +aggravated exponentially by the facts that they had no rights +in the criminal justice system, by the fact that they were +treated as if they didn't matter. They were not allowed their +rights under the Crime Victims' Rights Act to meaningfully +confer with prosecutors, to be treated with fairness, to be +treated with dignity. That is what this is supposed to be +about, and to have notice of hearings. +So I do want to thank your Honor, and especially the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +33 +prosecutors who have worked this investigation and this case, +which is very different in experience for all of my clients and +the other Epstein victims in this case, because they were +allowed to be a part of the process. While some of them +elected not to be here today, that opportunity should always be +allowed for them. +In 2008, we filed that case under the Crime Victims' +Rights Act because our clients' rights were violated, and as +your Honor knows, a federal judge has ruled in our clients' +favor that their rights were violated. So this hearing today +means a lot to them. The fact that they may never get their +chance to speak in court, they may never get complete closure, +and all of us have to wonder, if their rights had been afforded +them the first time, would any of us be here right now. Or +wouldn't it more likely be the case that everyone, including +Jeffrey Epstein, would have turned out better for it? +Today, I have not only represented, but met and become +very close with many of these victims. Many of these +survivors. They are very strong people. They are people who +have persevered through a lot of adversity. It's been a roller +coaster of emotions that has led us to where we are today. And +while they have all been cast over the years because of the +secrecy of the first investigation, in the shadow as victims, +you can't put them all in one bucket and say one size fits all. +They are each individual people who were harmed differently and + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +34 +distinctly through not only the abuse, but the system. +And on behalf of all of them, I would like to thank +your Honor for the fairness with which they've been treated, +and the United States Attorney's office for the way in which +you have handled this investigation, and especially how you +have treated the victims in this case. +Like I said, I have many who want to speak. Some that +can't. This is a very difficult day for them. But we +appreciate the opportunity and the invitation. +The first client that I have that is going to address +your Honor is the one who walked into my office in 2008 asking +just to be heard, +THE COURT: Hold on one second. Did you all want to +be seated? +You don't need to be standing. Whatever is more +comfortable until you're ready to give some comments. It's up +to you. +Ms. +reporters, please. +MS. -: +if you could spell your name for the court +last name +(Continued on next page) + + +35 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +MS. I +•: My name is +and I'm a victim +of Jeffrey Epstein. Jeffrey Epstein sexually abused me for +years, robbing me of my innocence and mental health. Jeffrey +Epstein has done nothing but manipulate our justice system, +where he has never been held accountable for his actions, even +to this day. +Jeffrey Epstein robbed myself and all the other +victims of our day in court to confront him one by one, and for +that he is a coward. +I want to thank the U.S. Attorney's for seeking +justice that has been long over due, and most importantly, +given us, the victims, our day in court to speak our peace and +find some sort of closure. I feel very angry and sad that +justice has never been served in this case. Thank you. +THE COURT: Thanks +very much. +MR. EDWARDS: I believe my next client who is going to +speak is probably going to speak as Jane Doe. +JANE DOE NO. 1: Yes, Jane Doe. +THE COURT: We'll say Jane Doe No. 1, just for the +record. +JANE DOE NO. 1: Okay. Thank you for allowing us to +speak today. I've shifted what I want to say in hearing +what's already been said, and just about the question of +Jeffrey's death. I don't know what the relevance is to this +hearing, but I do know that it is profoundly relevant to my + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +36 +life, as a victim. I don't like that word, but I still feel +like I am learning the ways that he's impacted me as a complex +situation, but he was also a major part of my life. As +destructive as that relationship was and as much of a villain +as we have created him to be -- based on facts we've created +him to be a villain -- he's a complex villain and actually all +of that is irrelevant. Anybody deserves -- an investigation is +the right thing to do. Like, we do need to know how he died. +It felt like a whole new trauma all over again, and I +don't know why, you know, because I -- I'm trying to defend +myself against him at this point in my life, but it still does +not feel good. It didn't feel good to wake up that morning and +find out that he had allegedly committed suicide. Okay. But I +also wanted to say to the press, I'm reading -- I read my story +in the paper. I read so many other girls' stories that are so +similar to my own, and everything that's been focused on is not +the most important part of it. +There was -- the problem with focusing on these, the +facts of the situation, that were out of the ordinary and like +because he was such a grand person, and it was just a unique +situation. I know that that's the more interesting side of the +story, but I don't want to be used as entertainment. And the +problem, the fundamental problem of the whole situation is the +element of exploitation and coercion, and these are things that +so many girls can relate to. + + +37 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +And even though this Jeffrey Epstein brought it to a +grand scale, on some level, a lot of girls could relate to the +trauma that we are talking about, and even though this whole +situation sucks, I would like to think that it may be possibly +a catalyst for change because, obviously, as we're seeing with +the "Me Too" movement, change needs to happen and it's -- what +I'm seeing in the papers is not a common story, but it's so +much more common than you realize. That's all. Thank you. +THE COURT: Thank you very much. +MR. EDWARDS: I believe that the next client is going +to also be a Jane Doe; so I think for the purposes of the +record it will be Jane Doe 2. +THE COURT: Yes. +JANE DOE NO. 2: Good morning, your Honor. +THE COURT: Good morning. How are you? +JANE DOE NO. 2: Doing okay. I hadn't prepared any +words to speak today, but there is something that was on my +mind this morning when I got here. It's been on my mind in +reading through the press and through the people that I've +spoken to about it, friends, family. It's something that's +bothered me because I think it has a lot of blame in it, as +well, a little bit of what my friend, who was up here, was +speaking about. +I think that a lot of people asked why we spent so +much time, why we stayed. It's an experience that's really + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +38 +hard to explain to people who haven't gone through it. I think +there's a writer, Thomas Nagel, who wrote an essay called "What +is it like to be a bat?" And I think that he touches on it +pretty strongly and if you haven't experienced something, it's +very hard to fully understand why someone makes the decisions +they do and what the circumstances were. +I don't want to speak for all of the victims. I think +each of us has a different story and different circumstances +for why we stayed in it, but for me, I think he was really +strategic in how he approached each of us. Things happened +slowly over time. We didn't -- it almost was like, putting it +like that analogy of a frog being in a pan of water and slowly +turning the flame up. You didn't realize it was happening, and +it just -- I don't think anyone can fully understand the +experience, but I just - the blame feels very strong. +There's a lot of support as well, but I just want +people to try and understand that we aren't bad people. we +weren't trying to -- it wasn't a situation where we were trying +to extort money from someone. A lot of us were in very +vulnerable situations and in extreme poverty, circumstances +where we didn't have anyone on our side, to speak on our +behalf, and that's really scary. +You start to blame yourself because, at first, you +don't tell anyone what's happening, and it becomes your deep, +dark secret that you tried to keep from everyone. And I didn't + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +39 +even know I was a victim until I spoke with my lawyers. I had +no idea. I had so much self-hatred and doubt and just guilt +for everything. I still do. I still don't feel like I deserve +to say I'm a victim, and I think that's a big problem with our +society right now, that people are still blaming victims, and I +think that does need to change. +I hope that today people understand that each of us +has a story, has a past, has a family and just give us a chance +to - you know, that's basically all I just wanted to say. +THE COURT: Thank you so much. +JANE DOE NO. 2: Thank you so much. +THE COURT: okay. +MR. EDWARDS: Okay. I think that the next person who +is going to speak is also going to be speaking as Jane Doe; so +for the purpose of the record, Jane Doe No. 3. +JANE DOE NO. 3: Thank you for allowing us to speak +today. I came to New York City 15 years ago to pursue modeling +from a small town. I signed on with an agency and was excited +to pursue my passion and my dream. Several months later, I met +a female who told me about Mr. Epstein. She portrayed him as +an amazing man who genuinely cared for people and that he was +going to be able to help me in a modeling career. +I was excited to meet him, after hearing her talk +about him. He sounded like an amazing person. An introduction +was made at his New York home, and it is there that I was + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +40 +sexually assaulted. I left his home, after he threw me, +basically put money on the table, and I was ashamed. I was +embarrassed. This was not the way I was brought up, and I +couldn't believe this had happened to me. +I left and my world kind of spiraled after that. I +stopped going on modeling castings. I gained weight. I became +depressed. I stopped going out with my friends, and only five +months after I had been in New York City to pursue my dream, I +left. I left the modeling industry, and I left New York City, +and I totally switched my career paths. +I buried this deep within me, and all of the new +occurrences that have come up in the media is what brought it +back up for me. And I feel sickened and saddened that it took +so many years, and God knows +how many victims, for this to +finally come out, but I'm thankful it did. And I'm just angry +that he's not alive anymore to have to pay the price for his +actions. So I thank you for your time. +THE COURT: You're very welcome. +MR. EDWARDS: Your Honor, Jane Doe No. 4, I believe, +is going to speak now. +JANE DOE NO. 4: Good morning, your Honor. +THE COURT: Good morning. +JANE DOE NO. 4: I just have something very short to +say. I met Jeffrey Epstein at a very vulnerable place in my +life, and whatever the outcome is with everything, I just + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +41 +wanted to express that we, the victims, we will always carry +irreparable damage and pain throughout our lives after this. +It's something that's never going to go away. +You know, whoever we marry in our life, whatever +future we have in our life, it's always going to be something +that's always there for us. +And I'm very nervous right now. +And Jeffrey Epstein, he took away the chance I had at having +the future I had envisioned for myself as a young girl, and I +think many of us here today will never fully heal from that +pain and the heartache that we'll continue carrying with us. +So I just wanted to say that. It's something that +it's irreparable. I can't even really use a better word to +describe that. So thank you for hearing us today. +THE COURT: You're very welcome. +MR. EDWARDS: Your Honor, Jane Doe No. 5 would like to +speak. +JANE DOE NO. 5: This is a letter that I wrote; so +it's going to be: Dear Jeffrey, I think you are a mentally +disturbed human being. You used your power to make me believe +at a young age that I could have my dreams of being a model. +You paid for your freedom. You violated my rights. You should +have to pay for them, just as anyone else. You got a plea deal +that no one else would have been able to get. You used your +money to get out of paying the price for your actions. +Also, as a victim, I never got to see what the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +42 +agreement was or why the special treatment got approved. I +think you should have been in jail for several years in +population and live like everyone else that is mentally +disturbed like you. You paid for yourself to get special +treatment while you were in jail. I don't even think you spent +a day in a jail as a normal human being. +You had investigators come to my house and also went +to my friend's house to question them. I will never be able to +over -- I will never be able to get over the overwhelming +emotions and embarrassment I experienced from that trauma. +needed therapy several times a week and had high stress and +anxiety levels. +You paid your way to make the public think that the +girls had nothing in life going on for them. You wanted to try +and blame that we were lower class and that was the problem +with the girls. I was from a middle class family and did well +in school. I lived the American girl dream -- or the American +girl life. I went on family vacations around the world, grew +up in a good city, and my parents are still married to this +day. Basically, everything you said that we didn't have in our +life, I did. +It all came down to I was told I was making $200 in an +hour. Being young, that was a lot of money, and I didn't know +any better. Sadly, you were the one with an illness that you +should have to go and see a doctor and also have a mentor group + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +43 +for the sickness you have. I will continue with writing my +book about that secret life, with all the newspaper articles of +the case, my high school agenda book of official dates. I'm +basing that proof that I deposited cash after leaving +Jeffrey's. I still have all of the information, articles that +I collected over the years. +You mentally and physically traumatized me. I went to +therapy, and it was the best thing I did for myself. If anyone +only learns one thing from this case, I hope is that money +should not let you buy your way free. A crime is a crime and a +victim is a victim. Thank you. +THE COURT: Thank you. Thank you very much. +MR. EDWARDS: Your Honor, my next client is +MS. +: I met Jeffrey Epstein through my first +massage teacher, a man who took me in as his apprentice to +teach me a practice I wanted to learn while in desperate search +to find a cure for a debilitating neurological disorder that I +have, which manifests into violent vomiting attacks, largely +triggered by stress. It's called Cyclic Vomiting Syndrome. +I was recruited by Ghislaine Maxwell. Upon my first +meeting of her, I wouldn't know +I had been recruited until many +years later, when I would read it in a headline. Ghislaine and +Jeffrey took me in. They sent me to school. They gave me a +job. They flew me around the world, introduced me to a world I + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +44 +had only dreamt of and made me feel as though I had become a +part of their family, another thing I was desperately searching +for. +But on my third or fourth time meeting them, they +brought me to Jeffrey's island for the first time, and on the +first night there, +came tapping on my door late at +night to inform me Jeffrey was ready for another massage. My +instincts told me this didn't feel right, but I got up and +followed her to a villa I hadn't yet seen. Jeffrey and +Ghislaine's villa. +I began my massage, trying not to let him smell my +fear and obvious discomfort, but before I knew what was +happening, he grabbed onto my wrist and tugged me towards the +bed. I tried to pull away, but he was +than I +could think. I was searching for words but all I could say was +meek, "No, please stop," but that just seemed to excite him +more. +He continued +and when he was finished, he +hopped off and went to the shower. I pulled my shorts up, and +I ran as fast as I could back to my own villa, my feet bloodied +from the rocks. I cried myself to sleep that night. +I spent two weeks vomiting, almost to death, in a +Los Angeles hospital after that first encounter. Jeffrey's +abuse would continue for the next three years, and I allowed it + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +45 +to continue because I had been taken advantage of my entire +life and had been conditioned to just accept it. +It took me a long time to come forward, too long +maybe, and all it took to bring - and all that it took to +bring this man to justice has been robbed by his death. Every +day, every week I've spent in the hospital since, I've suffered +and he has won. Every job offer that's been offered to me and +then retracted because of my connection to this case, I have +suffered and he has won. Every public humiliation I have +endured, I have suffered and he has won. Every relationship +that I've had to end because of the abuse that I have endured +by the hands of this man, I have suffered and he has won. +Every woman sitting in this room today, and all of the +women who have yet come forward and who have not yet to come +forward and whose lives have been affected by Jeffrey Epstein's +sick abuse of young girls, we have all suffered, and he is +still winning in death. +I refuse to let this man win in death. I couldn't +fight back when Jeffrey Epstein sexually abused me because I +hadn't yet found my voice. Well, I have found my voice now, +and while Jeffrey may no longer be here to hear it, I will not +stop fighting, and I will not be silenced anymore. I needed +him to hear the pain he's caused, what I've gone through +because of him. I wrote a 350-page book of all the pain that I +have endured at the hands of this man that I really needed him + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +46 +to hear. His death has robbed me of that justice. +Please don't rob us of justice again. Thank you. +THE COURT: Thank you. +MR. EDWARDS: Your Honor, I think I have one more +client that is going to speak today, +THE COURT: Would you spell that? +MS. R +1: Good morning, your Honor. +THE COURT: Good morning. +MS. M +•: My name is spelled +,, space, +Thank you, your Honor, for giving us the opportunity +to be heard this morning. +THE COURT: Sure. +MS. R +1: When I was introduced to Jeffrey +Epstein, I was young and full of hope and the foolishness of a +teenager. I was idealistic, and I saw the good in people. +Jeffrey Epstein manipulated me, coerced me and sexually abused +me. +Something I think is very important to communicate is +that loss of innocence, trust and joy is not recoverable. The +abuse, spanning several years, was devaluing beyond measure and +affected my ability to form and maintain healthy relationships, +both in my work and my personal life. He could not begin to +fathom what he took from us, and I say "us" because I am every +girl he did this to, and they're all me. And today we stand + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +47 +together, those that are present and those that aren't. +I was a victim, and it has taken me many, many years +to stand here and say, yes, it was me. I was a victim, but I +will not remain a victim and be silent for one more day. +Although I think it's tragic when anybody dies before their +time, I'm extremely relieved that Jeffrey Epstein will not be +in a position to hurt anymore children or anymore women, and +I'm glad to be part of a group of women who are now bonded +forever in the trauma that we endured at the hands of this man. +Thank you. +THE COURT: Thank you. +MR. EDWARDS: Your Honor, we had one client who was +not able to be here but sent a message through a letter. Her +name is +last name, +And Brittany Henderson, of my office, is going to +read her letter as instructed. +THE COURT: Sure. +MS. HENDERSON: Thank you, your Honor. +THE COURT: Yup. +MS. HENDERSON: What happened to me occurred many +years ago when I was in high school, but it still effects my +life. I was told then that Jeffrey Epstein was going to be +held accountable, but he was not. In fact, the government +worked out a secret deal and didn't tell me about it. The case +ended without me knowing what was going on, without him being + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +48 +held responsible, without any explanation and without a chance +for my voice to be heard. I was treated like I did not matter. +Many years later, he +was arrested again. These +investigators and attorneys representing the United States have +been completely different. I am still mad, concerned and +confused about how he committed suicide and escaped +responsibility again, but I know it is not the fault of the +judge or the government attorneys. +I was allowed to be a part of the process this time. +My attorney was able to tell me what was going on at every +stage because they kept him informed. Thank you for inviting +me. It means more to me than you can ever know. I was not +able to be here this time, but I know that I was allowed to be +and I had the chance to attend this hearing, which is helping +me in my healing process. The fact that I mattered this time +and the other victims mattered is what counts. For that, I am +grateful. +THE COURT: Thank you. +MR. EDWARDS: Your Honor, finally, in 2008 when I +filed the case under the Crime Victims Rights Act, it wasn't me +alone. I did it with Paul Cassell and Jay Howell. +Paul Cassell is here today, and I think your Honor +even cited to a piece of -- an opinion of his from when he was +on the bench, and he has some remarks to make. +Once again, your Honor, I really do believe that this + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +49 +is a model for how victims should be treated in a criminal +process, and we really do appreciate it. Thank you. +THE COURT: Thank you. +MR. CASSELL: I'll be very brief because I know there +are others that want to speak here. I'm Paul Cassell, +C-a-s-s-e-1-1, previously served as a federal judge at the +District of Utah, currently a law professor, where I teach +crime victims rights at the University of Utah, College of Law. +I just wanted to take one minute to address some +suggestion that there would be no need for a hearing this +morning. I think, having heard already from these powerful +victims and recognizing how important giving those statements +will be in the trajectory of their lives, makes clear that your +Honor has followed exactly the right path. Legally, there is +one precedent, which is U.S. V. Heaton, +a case that you cited +that I wrote about a decade ago, and as explained in that +opinion, victims have important interests in the criminal +justice system that can only be recognized if they're given +their day in court. +With all due respect to other law professors that have +recently written an article, I think transparency is one of the +overriding objectives in our criminal justice system, and the +one substantive action that I would urge your Honor to take +today is to publish your remarks as a published opinion. The +Heaton case is, to my knowledge, the only reported decision on + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +50 +this particular issue, even though it's more than a decade old +and, yet, we can see today that these problems recur in many +other cases. Your remarks today, I think, should be published +so that they can serve as a guide for other judges around the +country. +I would encourage you to add into your remarks a +reference to the Crime Victims Rights Act. The Crime Victims +Right Act promises victims the right to be treated with +fairness, dignity and respect, and the process that we see +unfolding this morning is a clear example of how victims can be +treated with fairness, dignity and respect. +So I know that your Honor is wondering what is the +appropriate action here. Unfortunately, it seems like there +are no other legal options, but there was a legal option for +you to decide to exercise, which was to allow these victims to +come forward. And if there's been one positive thing that has +come out of the tragedies, the abuse, the other events of this +case, it's been your decision to allow these victims to be +heard this morning, and I encourage you to publish your +decision and to encourage other judges to follow what is +clearly a model for crime victims rights and is clearly an +example that should be followed in other cases down the road. +THE COURT: Thank you very much. I appreciate your +being here. I had no idea that you would be here when I wrote +the remarks, but it was clear from the literature that you are + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +51 +the leading expert formerly of the District Court of Utah, I +believe, and it's a pleasure to +• have you here today. +MR. CASSELL: Thank you, your Honor. +THE COURT: Thanks. +Mr. Boies? +MR. BOIES: Thank you, your Honor. David Boies of +Boies Schiller Flexner. We have with us today five of the +victims that we represent. There are a number of additional +victims who either were unable to attend or are still unwilling +to come forward publicly. This has been an enormously +traumatic aspect of their lives, something that, as you've +already heard and will hear more today, is something that they +can never entirely escape from. +I want to, as prior counsel have, commend both the +Court and counsel for the Department of Justice for the +consideration and respect and attention that they have paid to +the victims. We believe that that is not only right, as a +matter of human dignity, but we think that is exactly what the +law requires and intends. +I will be more blunt than the Court has been, or +Professor Cassell has been about Professor Green's article. +That is an article that cites no authority, and I believe there +is no authority for his proposition. I entirely respect his +right to advocate on behalf of his client Alan Dershowitz, who +has retained him in connection with litigation that we've + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +52 +brought against Mr. Dershowitz, but I would have expected that +the Law Journal or Professor Green himself would have disclosed +that connection, which I think is a conflict. +But regardless of the appropriateness of his +disclosure, or lack of disclosure, I think that his article +opposing allowing the victims to have a voice in this +proceeding is inconsistent not only with the policy that +underlies the Crime Victim Rights Act and the very statute that +Mr. Epstein is being prosecuted under, but it ignores the +actual language of those statutes, and many other statutes, in +which Congress has made clear that the purpose of the criminal +law is no longer simply to punish the individual defendant, but +it is to find some way of trying to mitigate the damage that +has been done to the victims through restitution and economic +mitigation, but also through the ability to confront and to +have the court system and the justice system and the +prosecutors treat these victims as they are victims, as they +are human beings, and they are entitled to the respect that our +society needs to give every human being. So I think that this +is not only commendable, but I think it is what the law +requires. +In response to the question the Court asked, I have +discussed this hearing with my clients. I have told them that, +under the applicable law, the government has no alternative but +to move to dismiss this case, and I believe under the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +53 +applicable law in this circuit, the Court has no alternative +but to grant that motion. +I think the current law is outdated, as the Court +suggested in some of its remarks. I think there will come a +time when either an Appellate court or the Congress will make +clear that, just as it's possible to continue civil cases +against someone after they have deceased, it is possible, at +least for purposes of things like restitution, to continue +criminal cases, but we are not there now. And, fortunately, in +this case, there are other ways and perhaps even more efficient +ways to vindicate the interests of the victims here. +We greatly appreciate the remarks of the +representative of the Department of Justice today, and we, too, +on behalf of the victims, are not going to stop when we walk +out of this courtroom. We are going to continue to seek +vindication against Mr. Epstein's estate and, in some senses, +perhaps even more important, against the people who worked with +him and enabled him. +As you have already heard, and will hear more, +Mr. Epstein did not act alone. He could not have done what he +did, on the scope and the scale of what he did, for as many +years as he did it without the activities and support and the +co-conspirator activity of a number of other key individuals, +and those individuals also need to bear their share of +responsibility, and those people need to have a reckoning as + + +54 +well. +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +My partner Sig MoCawley, who's been working with me +for more than five years on this case, is going to, with the +Court's permission, introduce five of our clients who will +speak briefly to your Court. +Thank you very much. +THE COURT: Thank you very much, Mr. Boies. Pleasure +to have you here. +MS. MCCAWLEY: Thank you, your Honor, the first victim +that would like to speak today is +THE COURT: Can we have the spelling of your name? +MS. MCCAWLEY: Sure. Sigrid, S-i-g-r-i-d, and the +last name is M-c-C-a-w-l-e-y, and I'm a partner at Boies +Schiller Flexner. +THE COURT: Thank you. +MS. +: Good morning. +THE COURT: Good morning. +MS. I +Court. My name is +Thank you, prosecutors and Judge, and the +I note today I do feel +respected and listened to; so I appreciate that, and I have to +say that I commend the boldness of the New York prosecutors for +pursuing a man that has, you know -- and others, that have +clearly taken a lot from a lot of people. +17 years ago I knew him only as "Jeffrey." I was +recruited and brought from California to New York, and that + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +55 +experience for the last 17 years has been a dark corner in my +story, in my life, in my life story and that has been +definitely made worse by my own self-shame and that -- and +anger for normalizing all of the red flags. I feel like we are +conditioned to do that, and that's something that needs to +change. +So I'm here today, you know, I'm coming forward +because it is time to bring light to that darkness, and it's +time to replace that darkness with light. And I am a survivor +of this, and I do aim to progress further from being a +survivor, you know. I feel I've worked hard, quite hard, to +get to where I'm at now, and I'm definitely at a place in my +life where I will no longer cover up. I'll no longer cover up +what needs to be brought to light. +Jeffrey is no longer here, and the women that helped +him are, Ghislaine Maxwell. My experience is with Ghislaine +Maxwell and +•. and they definitely need to be held +accountable for helping him, helping themselves, helping one +another carry on this huge, almost like a system. So they need +to be held accountable, all of them, and I would like to see +that, certainly on behalf of myself and for everyone here. +Thank you. +THE COURT: Thanks so much. +MS. MCCAWLEY: Our next client, who is going to speak +this morning, is + + +56 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +MS. +: Good morning, your Honor. +THE COURT: Good morning. How are you? +MS. +: Okay. Thank you. My name is +|, that's • +I am a victim of Jeffrey Epstein and Ghislaine Maxwell +in the dark and cruel and criminal acts they committed against +me and hundreds of other girls and young women for years and +years and years, unstopped. +Thank you for allowing me to address the Court and +speak the truth. I commend the prosecutors from the Southern +District of New York for the ongoing investigation and its +pursuit of justice for us victims. It has given me hope, and I +will not let go of that hope. +When I was recruited by Ghislaine Maxwell at +Mar-a-Lago, just before I was 17, I thought I was given a big +break, and I'd be able to reset my life and become an actual +real massage therapist. My hopes were quickly dashed, and my +dreams were stolen. Jeffrey Epstein is no longer alive, but +this is not about how he died. This is about how he lived. +He will not have his day in court, but the reckoning +of accountability has begun, supported by the voices of these +brave and beautiful women in this courtroom today. The +reckoning must not end. It must continue. He did not act +alone and we, the victims, know that. We trust the government + + +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +57 +is listening and that the others will be brought to justice. +Thank you, your Honor. +THE COURT: Thank you very much. +MS. MCCAWLEY: The next client of ours that will be +speaking this morning is +MS. +: Thank you, your Honor. My name is I +. I'm a victim of Jeffrey Epstein and +Ghislaine Maxwell's international sex trafficking ring. +I would like to thank the Court for the dignity and +the respect you are showing me here today, as well as the other +victims. I would also like to acknowledge and extend my +gratitude to the prosecutors from the Southern District of +New York for pursuing justice on behalf of the victims. +Please, please finish what you have started. I struggled to +find the words to adequately say how important your work is to +us . +For a very long time Jeffrey Epstein gamed the system +at every level, and when he realized he couldn't do that any +longer, he showed the world what a depraved and cowardly human +being he is by taking his own life. But we, the victims, are +still here, prepared to tell the truth, and we all know he did +not act alone. We are survivors, and the pursuit of justice +should not abate. Thank you, your Honor. +THE COURT: You're very welcome. +MS. MCCAWLEY: Our next client who is going to be + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +58 +speaking this morning is I +MS. +Good morning, your Honor. +THE COURT: Good morning. +MS. +I had the opportunity to speak at Jeffrey Epstein's +bail hearing, and I really appreciate that you heard me and +listened to me that day. +I am so sorry that others will not +have the opportunity to stand before him the way that I did. +But I'm here today to speak on behalf of +who could not be here. +Jeffrey Epstein, Ghislaine Maxwell not only assaulted +her, but as we're hearing from so many of these brave women +here today, they stole her dreams and her livelihood. She +risked her safety in 1996, so many years ago, to report them, +to no avail, and it is heartbreaking to her and to me that all +this destruction has been wrought since that time. +We were deeply disappointed and disturbed by Epstein's +death and the fact that that was allowed to happen while he was +in the government's custody, and I'm encouraged to hear that +there will be a full investigation as to how that was allowed +to happen. +But it is extremely important, as others are saying, +that he did not act alone and that the other people that were a +part of what he did are held accountable and that that +investigation continues. + + +59 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +I believe that we have a real problem in this country +with perpetrators of sexual +abuse and sexual assault being held +accountable. There are so many roadblocks to victims being +heard, to cases being investigated thoroughly, and then to +those cases being prosecuted. And so I think this is a really +important signal to send a message to victims out there that +people will take you seriously, people will follow through, and +that even those in power, as we have unfortunately seen, that +has not been often are able to escape that, that even those in +power will be held accountable. Thank you. +THE COURT: Thanks so much. +MS. MCCAWLEY: Our next client, who's going to address +the Court is +She says it much more +beautifully than I do; so +I'll let her say it. +MS. +I: My first name is spelled, +My name is +and I am a victim of +Jeffrey Epstein and the sophisticated sex trafficking operation +he ran, where he allegedly was to be a financier. +I was 20 and previously modeled and was living in the +West Village. I met a young woman named +hrough a mutual +friend. We were friends for a few months. She was an amazing +artist and liked to party. One day she called me and asked if +I was interested in meeting a friend of hers. She told me he +wanted to meet me and really liked blonds, and I thought he was + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +60 +our age and liked to do the same things we did at that age; so +I agreed. +On a sunny, crisp day, we took the train together to +the Upper East Side. She then began to talk a little bit about +him on our way to his house. +I was at his house. I was +sexually assaulted by both +and Jeffrey Epstein in his +mansion. It left me feeling both disgusted and betrayed. +As we walked home to the subway afterwards, she +continued to tell me about the man who had just abused me with +her participation. She seemed exhilarated from the horrific +experience. I was shocked and in a daze. This is a few things +that she had told me. She told me he went to Cooper Union. He +was a mathematical genius. That he had favorite girls that he +would take to Chanel for 15-minute, all-you-can-buy shopping +trips. She told me his right-hand person had connection to the +arts and the fashion world, and she could help me. +This is not my complete story. I'll stop here. I'm +in a good, stable place in my life, and I had decided to come +forward to be a voice to the victims who may not be able to +tell their story, or at least not yet. I feel like I am a +survivor. +Thank you, Judge Berman, for inviting victims to speak +today before you. We hope the government is listening very +closely to the words we are saying. +THE COURT: Thank you very much. + + +61 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +MR. BOIES: Your Honor, just very briefly. +THE COURT: Sure. +MR. BOIES: I would like to express to the Court how +proud I am of all of these women who have come forward. It's +taken an enormous amount of strength and courage for them to do +so. Thank you. +THE COURT: Thanks, Mr. Boies. Hold on one second. +(Pause) +MS. LERNER: Thank you, your Honor. My name is +Kimberly Lerner, of Lerner and Lerner, and your Honor, with +your permission, I would like my client, +• to +stand next to me. +THE COURT: Sure. +MS. LERNER: Would that be okay? +THE COURT: Absolutely. +MS. LERNER: Your Honor, I would like to begin by +saying that I am in awe of all of these beautiful women. I +just want to let you know, +on behalf of +and myself, we +admire you, we respect you, and we applaud you, and you are +brave survivors. And +heart is with all of you, and +we thank you so much for coming forward. +I, when she went public, she thought she was +one of the only ones, and to see all of these faces is, I know, +amazing for her. +Jeffrey Epstein was a predator, a pedophile and a sick + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +62 +individual. However, he was also a thief. He stole +childhood dreams, her innocence and her self-confidence. She +was 14 years old. What he could not buy, he forcibly took. +Why? Because he surrounded himself with a network of powerful +people who not only looked the other way, but also actively +facilitated and participated in his sexual abuse of children. +Jeffrey Epstein thought he was above the law, and +essentially he was until now. The system let +and the +other victims down, but it does not have to end here. We ask +the U.S. Attorney's Office and the FBI to bring all of +Epstein's enablers and co-conspirators to justice. +It has taken +18 years to find her voice, and +again, Jeffrey Epstein has tried to silence her. While she +will never have her chance to face him in court, he no longer +has any power over her. Today, this brave survivor will be +heard. +MS. +: Thank you for allowing me to be able to +have my chance in court today, to be able to tell you what this +horrific man did to my life. You can't even imagine how much +it affected my childhood, all the way through my adult life. +He robbed me of my dreams. He robbed me of my chance to pursue +a career I always adored. He stole my chance at really feeling +love because I was so scared to trust anyone for so many years +that I had such severe anxiety. I didn't want to leave my +house let alone my bed. + + +63 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +The fact that he felt entitled to take away my +innocence, the fact that he felt that he could do whatever he +wanted, regardless of the laws, hurts me so very much. It took +me years to tell anyone what Epstein did to me because I was so +ashamed and embarrassed at what people would say or think of me +until I found out there were other victims, girls just like me. +I knew I could no longer keep my silence no matter how ruthless +and powerful Epstein was, and still is even after his death. +The fact I will never have a chance to face my +predator in court eats away at my soul. Even in death, Epstein +is trying to hurt me. I had hoped to at last get an apology, +but this evil man had no remorse or caring for what he did to +anyone. I felt let down by the people who were supposed to +watch him in prison. They let this man kill himself and kill +the chance of justice for so many others in the process, taking +away our ability to speak. +Out of all the damages and side effects that Epstein +caused by his heartless and selfish acts, it's very hard to put +my feelings and emotions into words, trying to let his +horrendous actions go and attempting to forgive him, has been +so difficult for me. Yet, as hard as it's been to come so +publicly forward, I refuse to let Epstein take me as a victim +anymore. +I am a survivor. The many that stand before me here +today that have shared the horrific experiences with this + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +64 +deplorable human being, because even though this weak, evil +coward tried to steal all of our childhoods, tried to steal all +of our innocence and tried to steal all of our means of +justice, he will never steal our inner strength, and he will +never, ever, ever steal our voice. Thank you so much. +THE COURT: You're welcome. +MS. GIBBS: Good morning, your Honor. Teri Gibbs, +I-e-I-i, G-i-b-b-s. For the record, I am a California +attorney. I'm not admitted to the New York State bar. I am +here to make a statement on behalf of New York attorney, Lisa +Bloom. I work for her firm, The Bloom Firm. +Lisa Bloom represents four of Jeffrey Epstein's +victims, Jane Doe 6, for the record, Jane Doe 7 and Jane Doe 8. +I am so proud of all of you victims who are here today and are +able to voice yourselves today. I will not and cannot comment +on the criminal case, or Ms. Bloom's communications with her +Clients. +Ms. Bloom would like to share three of her client's +statements for the record. Here are the statements. Statement +of Jane Doe 6. +To the Honorable Richard M. Berman. Jeffrey Epstein +stole my innocence. He gave me a life sentence of guilt and +shame. I do not consider myself a victim. I see myself a +survivor. The abuse that I endured cannot continue. Let's +stop this before it happens to other young women. Jane Doe. + + +65 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Statement of Jane Doe T. To the Honorable Richard M. +Berman. I used to be relatively carefree, inquisitive, hopeful +and excited about life, but my life changed because of Jeffrey +Epstein. My perspective on life became very dark when I was +unknowingly recruited by one of his agents. Jeffrey Epstein +ruined me. His recruiter ruined me. The far-reaching +consequences of that day ruined my family's lives. +I've chosen to remain anonymous in order to protect my +family from unwanted media attention. +I was just trying to figure out my path in life when I +encountered Jeffrey Epstein in his New York City mansion. I +cannot even begin to summarize the many detriments this +experience of sexual assault has had on my life. Immediately +following the incident, I was unable to function and be around +other people. My parents had to rescue me and bring me home, +where I became a recluse for years. +I was changed forever and buried my assault deep down, +where the darkness couldn't hurt me anymore, but of course, it +has always been here, lingering and affecting me unconsciously. +At the time, I was mired in shame, guilt and humiliation. I +had somehow tricked myself into thinking that I had allowed the +assault to happen, that I did it to myself, that I don't +deserve to be alive or to be loved. I believed that I was a +disgusting, shameful person who does not deserve to ever be +happy. These are the thoughts I've lived with on a daily + + +66 +basis. +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Furthermore, because I couldn't tell anyone, out of +fear of judgment, blame or retaliation, keeping this secret +completely hindered my ability to uncover why these issues +existed for me, which could have led to a path of healing over +the years. +It is time for those of power to do the right thing. +It is time for compassion toward our fellow human beings to +reign over money, power and greed. We need to protect our most +vulnerable to allow them a chance at a normal life, and nothing +should come in the way of that. I believe that for future +generations, +this case will set a +precedent that victims must no longer suffer in silence on our +own or be shamed for coming +forward to seek protection. +This case should demonstrate to those who want to harm +others that there will be a reckoning, and they will pay dearly +for the harm they inflict on innocent people. Judge Berman, I +thank you for from the bottom of my heart for this forum and +opportunity. +To all of those survivors who came before me, I +commend your bravery. There is no way I could have done this +without you. +Thank you to the public following this story, for your +outrage and desire for answers, which will hopefully move this +case forward so that victims can stop having to relive their + + +67 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +experiences every day and move on to begin to heal. +God bless the victims, their families, the +investigators and public servants working so diligently to find +those answers and to right all these wrongs. Jane Doe 7. +(Continued on next page) + + +68 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +THE COURT: Thanks very much. +MS. GIBBS: One more. Statement of Jane Doe 8. +In the past few weeks, I have had to reflect on my +interaction with Jeffrey Epstein and realized that, though I +have yet to put it all behind me, I am still a victim. I say +this because I have to come to terms with it in an effort to +truly get past the abuse I suffered at the hands of Epstein. +Pursuing criminal penalties against him and having an +opportunity to address the egregious crimes he committed +against me and other young woman would have helped my recovery +process. This all came to an abrupt halt when he took his own +life. This point of disclosure is lost. +I cannot say that I am pleased he committed suicide, +but I am at peace knowing +he will not be able to hurt anyone +else. However, a sad truth remains. I, along with other +people, will never have an answer as to why. I will never have +an apology for the wrongdoing. And most importantly, Epstein +will not be justly sentenced for his crimes. Now I sit in my +home questioning the well-being of those girls like myself. In +choosing death, Epstein denied everyone justice. +Any efforts made to protect Epstein's name and legacy +send a message to the victims that he wins and that he is +untouchable. I understand his case may be dismissed or closed, +but this makes me feel as though I, and anyone else who fell +pry to his hands, simply do not matter. + + +69 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +I ask that you very seriously consider the final +decision, because it will undoubtedly affect all other facets +of this case, including any future charges brought against the +recruiters or third parties to his crimes. I do not want the +narrative to be, Those poor girls. I want to send a message to +anyone who would consider engaging in similar acts to think +twice beforehand. I want some sort of closure for those of us +who relive those horrible moments where we were assaulted, +abused, and taken advantage of by Epstein. +You have the opportunity to help us seek that closure. +I appreciate your time and consideration and ask for your +continued support in dealing with this case to illustrate that +we, Epstein's victims, do matter. +Sincerely, Jane Doe 8. +On behalf of Lisa Bloom and The Bloom Firm, thank you, +your Honor. +THE COURT: Thank you, Ms. Gibbs. +Did we have any other victim's counsel or victims? +Ms. Allred. +MS. ALLRED: Good morning, your Honor. +THE COURT: Good morning. How are you? +MS. ALLRED: Fine. Thank you. +Allred, Maroko & Goldberg by Gloria Allred, +G-1-o-r-i-a A-1-1-r-e-d. +Your Honor, thank you so much for this opportunity to + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +70 +afford the victims their voice, because many of them have never +spoken before. They never spoke in Florida. They never spoke +anywhere. +They never told their mother. They never told their +father. +They never told their family members. This is an +opportunity for them to be heard. We thank you for that. +Your Honor, for 43 +years my firm has been the leading +women's rights private law firm in the United States. We have +helped thousands of victims. And I, as an officer of the +court, and as a believer in the system, have tried to encourage +the victims to have confidence in the system that should +provide them access to justice that should help them to assert +and vindicate their rights in a court of law. It has been +increasingly difficult in this case for me to say to my clients +that they should have confidence in the system of justice given +what has occurred in this case, People v. Jeffrey Epstein. +Having said that, I am encouraged by the fact that +this court, essentially, in an unprecedented situation where +the defendant is deceased, is still affording these victims an +opportunity to be heard. So we thank you for that. It is some +encouragement. +Your Honor, you also asked do our clients wish to be +heard in reference to some of the issues that have been raised +this morning, including what should happen into this case. +Your Honor, there has been a suggestion that the court should +investigate the circumstances of the death of Mr. Epstein. I'm + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +71 +not going to repeat the arguments made by counsel, but I would +say that if there is jurisdiction, and I know that is a legal +issue which has been previously argued, that certainly it would +increase the confidence of my clients. Not just my clients, +but victims all over, and some are, by the way, located in +other parts of the world, to have the court oversee the +investigation. +We are encouraged by the sensitivity of the attorneys +for the United States Attorney's office for the Southern +District of New York and the investigation that is going on +with the separate team. However, and, of course, the defense +is also conducting its own investigation. But I do think the +greatest confidence would be if the court in some way would be +able to oversee an investigation because the court is a neutral +party. And although the court certainly has a stake in finding +out what happened to defendants who are in the custody of the +federal system and who should be there to face the prosecutors +and the charges against them, but now are not because clearly +the system has failed. +And the United States Attorney has admitted that, and +even before he admitted that, everybody knows the system +failed. Failed the victims, failed the court, failed everyone. +In any event, your Honor, having seen so many +thousands of victims of gender violence, sex harassment, sexual +assault, I've dealt with child sex trafficking, child + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +72 +molesters, I mean, this is a unique case because there are so +many victims and so many failures of the system. At this +point, what we would really ask for is not just words, but +words have been helpful, but deeds, and that is very important. +In addition, I would like to say, throughout this case +is the running theme of the betrayal of trust. +Betrayal of +trust by Jeffrey Epstein. Betrayal of trust by the system. +And betrayal of trust to the victims who had a right to +justice. And the Crime Victims' Act should not just be words, +it should have meaning and it should be enforced. +In essence, we are asking, although you may need to, +of course, grant this motion to dismiss, I think because the +court has shown sensitivity to victims and victims' needs, if +there is a way to at least keep the record open so that victims +who have not been able to be physically present in the +courtroom today and who have not been able to submit to the +court any letters, victim impact, and who have not been able to +secure attorneys or speak to attorneys yet -- so, for example, +I'll still hearing from victims who I have not been able to +meet with yet because they just recently are now contacting +me -- so if they could submit, at least for the record, their +victim impact statements, that, I think, would be a very +important assistance to them. So that would be, at least they +would know that what they are sharing is on the record. +So, in summary, I would say that they are looking + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +73 +forward to the very serious investigation by the United States +Attorney of who may have conspired in this case, and that is +very hopeful, and we're hoping that everyone who may have a +role to this criminal prosecution will submit that evidence. +This is about power. This is about many victims +having lived in fear -- fear of the rich, the powerful, the +famous, fear that the system will not afford them justice. +So +fear of not coming forward. And fear, of course, is a weapon +that the rich, powerful, famous, and sexual predators used to +silence the victims. But that is gone for a lot of victims +because they refuse to suffer in silence. +Finally, it does take courage to speak truth to power. +We thank this honorable court for giving these victims a voice. +We thank them, even after the death of the defendant, for +showing respect for the victims, allowing them dignity, +allowing them a voice. We do want truth, we do want justice, +we do want accountability, and we do want those conspirators to +face the justice system. +Your Honor, right now we have two of our clients who +would like to address the court. +THE COURT: Sure. +MS. ALLRED: Then I have a couple of statements on +victims who do not wish to address the court. +As they come up, we'll give them the opportunity to +say either their name or Jane Doe. + + +74 +J8RSEPS3 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +By the way, thank you, your Honor, for allowing some +of these victims to be called Jane Doe. What number the court +affords to them, we'll accept whatever that is. +Thank you. +THE COURT: We're up to nine. +MS. ALLRED: Thank you. +MS. +Hello. My name is +That is +I was going to start this statement by saying that I +was a victim of Jeffrey Epstein. But that's not the case. I'm +still a victim of Jeffrey Epstein. I'm still a victim because +the fear of not being heard stopped me from telling my story +for so many years. This lingering fear almost stopped me from +attending this monumental movement of strength and power. +I'm still a victim because I am fearful for my +daughters and everyone's daughters. I'm fearful for their +future in this world, where there are predators in power, a +world where people can avoid justice if their pockets run deep +enough. +I'm still a victim because the 17-year-old | +was +manipulated into thinking she had found someone who cared, +someone who wanted to help. Jeffrey knew I had nowhere to go. +He knew I was vulnerable, and he took advantage of that poor +girl, who will never be the same. +I cannot eat at the thought that Jeffrey Epstein -- I + + +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +75 +cannot eat at the thought of Jeffrey Epstein not serving the +time he needed to realize the pain and suffering he caused so +many vulnerable young girls. +He thought he was untouchable, +and honestly, so did I. I thought he was the most powerful +person I would ever meet. +But the end is here and here I stand becoming more +powerful than he will ever be. +Thank you. +THE COURT: Thank you. +JANE DOE: Jane Doe. +Um, in 2004, when I was 15 years old, I flew on +Jeffrey Epstein's plane to Zorro Ranch, where I was sexual +molested by him for many hours. What I remember most vividly +was him explaining to me how beneficial the experience was for +me and how much he was helping me to grow. Yikes. +I remember feeling +so small and powerless, especially +after he positioned me by laying me on his floor so that I was +confronted by all the framed photographs on his dresser of him +smiling with wealthy celebrities and politicians. +After he finished with me, he told me to describe in +detail how good my first sexual experience felt. That was the +first of many lies I was forced to carry for him, the weight of +which proliferated my trauma. +I felt powerless not merely +because one man wanted to strip me of my innocence, but because +I was the victim of a system that just enfranchises human +beings, making them vulnerable to pedophilic exploitation. + + +76 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +As unjust as what happened to me was, I believe that +experience to be a symptom of +insidious and pathological +violence that extreme wealth yields, a violence which +ultimately stays hidden through channels of extreme power that +serve it. +I first identified with this feeling the night after I +was molested by Epstein, when another girl and I took out two +of his ATVs and raised them across the mesa. I crashed mine +and expressed my concern to the other girl of getting in +trouble, which she replied to me, Don't worry, no one gets in +trouble for anything here. +Even as a child, I understood, in a sad and precocious +way, what I hoped we have the ability of changing now. Even +though Epstein is dead, there +is still justice to be brought +for the crimes we felt powerless against concealing for him and +the system that supported him for all these years. +Thank you. +THE COURT: You're very welcome. +MS. ALLRED: Thank you. +Your Honor, may it please the court. I would like to +read a statement for Jane Doe, my client, who is present in +court, but requested that I read it. +We only have one opportunity at childhood. One +opportunity to develop. One opportunity to find direction for +our lives. Jeffrey Epstein robbed and denied me at each + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +77 +opportunity he had. +I came from a small Texas town, not far from the New +Mexico border. My mother died when I was 11, after suffering +from cancer for many years. My father was devastated, as were +my siblings and I. My father was saddled with debt. My only +hope for college was to get a scholarship. +When I was 15, I was a blossoming freshman in high +school and was trying to carry on my mother's dream. She +wanted me to master the violin. After school, I would often go +to a mall in a nearby city. A lady approached me and saw I had +a violin case with me and asked if I was any good. We talked +about the violin, my family, and why I had clothes that looked +like hand-me-downs. +The lady told me she works for a very rich man who had +a home close by and that he would pay to hear me play. I was +told that if I could get away, she could arrange for +transportation to and from his place and have me back before +anyone knew I was gone. After some hesitation, I agreed. This +decision was the beginning of the end of my childhood. +The man who only identified himself as J or Jeff had +asked if I would give him a massage, and over four visits, +eventually progressed to l +. The money he +gave me further placed my young soul into a perverse sense of +hell. +I was so utterly disgusted with myself and what he did + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +78 +to me that I stopped going to see him. I had documented the +events with a Texas rape crisis center about the man I know now +as Jeffrey Epstein. +Epstein targeted and took advantage of me, a young +girl, whose mother had recently died a horrific death and whose +family structure had deteriorated. His actions placed me, a +young girl, into a downward spiral to the point where I +purchased a gun and drove myself to an isolated place to end my +suffering. +A voice that could only have been from my mother told +me, quote, I am not the victim, I am the victor, and I dare not +pull the trigger." I returned the gun days later. +Epstein is a coward. He lived his life leaching off +the souls of inspiring, young girls due to the fact that he +could never know how it feels inspired to live. Like a leach, +once Epstein had his fill, he would unlatch and seek out +another victim. +The only sense of justice I had hoped to see was +Epstein being sentenced. However, Epstein died as he lived, +taking the easy way out without any responsibility. +Your Honor, the next statement is also a statement of +a Jane Doe. May it please the court. +I was a 16-year-old virgin when Jeffrey Epstein first +raped me. I was naive and gullable. He was a pillar of +finance and a giant in the world that I was an insignificant + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +79 +part of. I was so impressed that this great man would even +talk to me and impart any of his wisdom on me. I gladly jumped +at the chance to meet him again, when he told me how impressed +he was with my personal story and maturity for my age. +When I was in his presence, he made an effort to call +celebrities and influential people on speakerphone, like +Academy Award-winning actresses and super models, who always +answered his calls. Sadly, I was impressed. +He was friends with former and future heads of states +and every other fixture in the New York social scene and +beyond. He knew important people in my own world that I looked +up to and revered, but he spoke about them like they were sweet +distractions far beneath his stature. He could easily reach +down from his position and influence the people directly +involved with my daily life and future prosperity. I was the +perfect victim. +My whole life was extremely turbulent. But one of my +mother's greatest wishes was that all her children would +graduate from respectable universities. He promised me that he +would write me a letter of recommendation for Harvard if I got +the grades and scores needed for admission. His word was worth +a lot, he assured me, as he was in the midst of funding and +leading Harvard's studies on the human brain, and the president +was his friend. +The fact that all of you already know these next + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +80 +details, which I'll share, should ignite fire instead of induce +the complacency they did in the past, when heard repeatedly +over the years, but yes, an innocent massage turned sexual +almost immediately. +"Here, come. +Come help me with a kink in my shoulder +while we finish our discussion." A large vibrator and a couple +of hundred dollars, disgust +and dirty secret, more praise and +imparted wisdom from a godlike figure, a deliberate diabolical +depression of grooming and submission for his pleasure and +release. +Even if I resisted, I was no match for him. I felt +powerless, ashamed, and embarrassed. I wanted to vomit +remembering these moments. +What I learned in those depraved sessions, staring up +at the dome ceiling in his private massage room, tore a violent +hole through any normal sexual awakening. I'm haunted forever, +having learned everything there is to know about sex through a +vile criminal. Every time a new molestation would bring a new +lesson, the progressive and constant unwinding. I was nothing +more than a teenage prostitute. I was his slave. +I had never even kissed a boy before I met him, and +never throughout the horrific abuse did Jeffrey Epstein kiss me +even once. When he stole my virginity, +and then told me, "If you're +not a virgin, I will kill you." And then I wasn't a virgin +anymore. + + +81 +J8RSEPS3 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +• That was my first time. +I got a few hundred dollars, as usual, as he led me +out of his mansion with assurances that I was on the right path +guided by him. I lied to myself and tried to believe him. I +became a hollow shell. If I missed an appointment, he +threatened me and let me know who was in charge. "Do you know +how important my time is? I'll bury you. I owe this -- I +won't say the word -- F'ing town." He would hang up. +I would stand there frozen in the street, terrified +that his assistant would call to reschedule. I made sure to +stay in line and not disobey him. I was in complete denial. +Being paid after every scheduled meeting felt routine and +disgusting. He was the master of the universe and the world +bent to his will. +He would eventually brag to his assistants about my +ability to please him sexually right in front of me, leaving me +feeling grotesque and worthless. Everything in my outside life +was falling apart. I distanced myself from friends and grew +further away from my family. I felt less human after each +ordeal. My psyche broke down completely and wouldn't let me +continue. + + +82 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +One day I walked out of his residence and passed a +girl similar to myself. When I turned around, she was entering +Jeffrey's residence. +He no longer even tried to schedule his +appointments with other girls in secrecy from me. Maybe he +never did. I was too stupid to see. +My world shattered. I had been so naive. I had an +epiphany in a calvary of desperation. +I realized I was just +one of many young girls he had in rotation come to perform for +him for money. I went into a deep depression and never lifted +completely. I wanted to inflict pain on myself. I was +humiliated, angry, and suicidal. I locked myself away from +everything. I cut myself off forever from the world I had +known. +I endured the daily agony of knowing my life would +never be the same. I could never go back to New York City and +the wonderful life I had taken for granted before I met this +demon named Jeffrey Epstein. +This creature had manipulated and outwitted the whole +system, including some of the most intelligent scientists, +political people, prosecutors, and power players. How easy was +it to manipulate a 16-year-old virgin who never had a boyfriend +and came from a background of hardship with no parental +guidance or support. +I went to therapy and was given antidepressants for +severe anxiety and depression. My only solace, years later, + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +83 +was my desire to succeed on my own terms. I emersed myself +into my studies and was accepted to every college I applied to, +graduating from a top university. To this day, there is still +an ache in my being that I did not apply to Harvard in fear of +his influence there. +They say you never forget your first. I'm in a +never-ending nightmare trying to do just that. I'm forever +suffering because everything reminds me of that horror. This +new wave of worldwide publicity only worsens my despair. +It was only many years later that I was finally +intimate with a man again, and those moments were marred by my +actions as a child with Jeffrey Epstein. Even now is +impossible to separate his treachery from any care of a good +man. +For one brief moment there was elation when he was +recently arrested. I would finally get my chance to see him +again face to face and show him what I had become, that I had +succeeded on my own, that I +was worth something in spite of his +abuse, and that I had surmounted the monumental obstacles he +laid before me throughout my entire life since falling prey to +him. +I had hoped humanity would prevail, but it seems to me +that he outsmarted everyone so far, and his ghost is still +laughing at us. I appeal to all of those just and true that +his evil legacy and his death not stand in the way of + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +84 +resolution and justice for all of his underaged victims. +Thank you, your Honor. +And then just one last one, and this is much shorter. +Statement of Jane Doe, also my client. +I was a model in another country when I came to the +United States. I was told by a booker that I needed to meet +with a man named Jeffrey Epstein, who was the owner of +Victoria's Secret. The booker told me that Mr. Epstein could +help me get into Victoria Secret's world. +It was my childhood dream to be a Victoria's Secret +model. So I went one day +in the afternoon and I met +Mr. Epstein in his office in his mansion in New York. A woman +introduced herself and suggested to me that I should be +extremely nice to Mr. Epstein, because if he liked me, he would +probably have photographers +shooting photos of me right away. +The told me to go upstairs and directed me to Jeffrey +Epstein's office. Mr. Epstein had a white robe on and we +chatted very briefly. I had my portfolio of photos, but he +didn't even look at it. Suddenly, he took his robe off and got +close to me. I got up to leave, but the door was locked. +I didn't know what was going on. It was my first +official meeting to be cast in the United States. I was a +young girl and confused. +skirt on. +He got very close to me, and I had a + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +85 +I took it and threw it at him. +At that point, I ran to the door again and figured out +how to get out of there. A girl outside asked me where I was +going and she said to be careful. She said that Mr. Epstein +knew a lot of powerful people, including Bill Clinton, and that +if I didn't do what Mr. Epstein wanted, I would not be able to +have any job in the industry. +I was so scared. I couldn't wait to get out of there, +and I left. I took the train home. I had spent all of my +savings getting Victoria's Secret lingerie to prepare for what +I thought would be my audition. But instead, it seemed like a +casting call for prostitution. I felt like I was in hell. +Thank you, your Honor. +Thank you. +THE COURT: Thank you, Ms. Allred. +Was there anybody else, any victim's counsel or any of +the other victims who have not been heard and wish to be heard? +Well, OK then. All I have to say, really, is thank +you, all of you, for your participation in today's remarkable +hearing. I think everybody has benefited greatly from your +input, and especially from the testimony of victims here today +and who have had the courage to come forward. +We have also benefited throughout these proceedings, +however brief altogether, +from the attorneys' legal advocacy +and their written and oral submissions. I'm grateful to them + + +86 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +as well, both for the government and the defense and those +representing the victims. +Finally, we're also grateful to the press for their +very diligent coverage of seemingly every detail of this case. +That concludes our work for today and we stand +adjourned. +Thanks. +(Adjourned) \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/1f81226a49e4c91ffdd906e2d5a83cc9113d66bd2f187d583b5e4f29b846558b.receipt.json b/vision-fixhub/ds9-parsed-01/1f81226a49e4c91ffdd906e2d5a83cc9113d66bd2f187d583b5e4f29b846558b.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..04e028c3e76f67f60c8353035d01ed91f6743c33 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1f81226a49e4c91ffdd906e2d5a83cc9113d66bd2f187d583b5e4f29b846558b.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -4659, + "dataset": "marble-joined", + "doc_id": "1f81226a49e4c91ffdd906e2d5a83cc9113d66bd2f187d583b5e4f29b846558b", + "engine": "marble-apple-vision", + "event_count": 87, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "3cdba0f81b33fed29bccc5d71abb194b6b7652367f949ff6b41a99cb9f0386cb", + "output_sha256": "84e098d045e28e678eb5b29c9d7ca1f701b741c01844a1efec9bb48a16203148", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1f8ec923756c620767351798516a7dafd06bd2993902d9c980c7612022851299.md b/vision-fixhub/ds9-parsed-01/1f8ec923756c620767351798516a7dafd06bd2993902d9c980c7612022851299.md new file mode 100644 index 0000000000000000000000000000000000000000..c8787fa8a8f49034606d0fa742cdd783c1ef58a1 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1f8ec923756c620767351798516a7dafd06bd2993902d9c980c7612022851299.md @@ -0,0 +1,1216 @@ +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 1 of 14 +U.S. Department of Justice +United States Attorney +Southern District of New York +The Silvio J. Mollo Building +One Saint Andrew's Plaza +New York, New York 10007 +July 12, 2019 +VIA ECE +The Honorable Richard M. Berman +United States District Court +Southern District of New York +United States Courthouse +500 Pearl Street +New York, New York 10007 +Re: +United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) +Dear Judge Berman: +The Government respectfully submits this letter in response to the defendant's Motion for +Pretrial Release (the "Release Motion"), dated July 11, 2019 (Dkt. 6), and in further support of its +Memorandum in Support of Detention (the "Detention Memo"), submitted to Magistrate Judge +Pitman on July 8, 2019, which is attached hereto and incorporated herein (Ex. A). +PRELIMINARY STATEMENT +The defendant is a serial sexual predator who is charged with abusing underage girls for +years. A grand jury has returned an indictment alleging that he sexually exploited dozens of +minors, including girls as young as 14 years old, in New York and Florida. To this day, he is a +registered sex offender designated by New York State in the highest category of risk to reoffend, +despite unsuccessfully attempting to have that classification lowered. And any doubt that the +defendant is unrepentant and unreformed was eliminated when law enforcement agents discovered +hundreds or thousands of nude and seminude photographs of young females in his Manhattan +mansion on the night of his arrest, more than a decade after he was first convicted of a sex crime +involving a juvenile. +The defendant also faces substantial evidence of his guilt, founded on the corroborated +testimony of numerous victims, and this case presents the very real possibility that he will go to +prison for the rest of his life. The defendant has at his disposal a vast fortune, the details of which +remain largely concealed from the Court. He also has a history of obstruction and manipulation +of witnesses, including, as detailed herein, as recently as within the past year, when media reports +about his conduct reemerged. And he continues to show a shocking lack of understanding of the +gravity of the harm he has perpetrated, including through the minimization of his conduct and +casual disparagement of victims in his arguments. +Against this backdrop of significant-and rapidly-expanding evidence, serious charges, +and the prospect of a lengthy prison sentence, the defendant proposes to be released on conditions +that are woefully inadequate. The Release Motion misconstrues and misunderstands the relevant + + +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 2 of 14 +July 12, 2019 +Page 2 +law, seeks to diminish and demean the harm caused to the many victims of the defendant's +appalling sexual abuse, and utterly fails to meet its burden of rebutting the presumption that no +condition or combination of conditions will reasonably assure the appearance of the defendant as +required and the safety of the community. Rather than even attempting to address the grave risks +of releasing a defendant with extraordinary financial resources and a history of abusing minors, +the defendant instead proposes a bail package that amounts to little more than a barely-secured +bond masquerading as a 14-point plan. The Court should reject the defendant's application and +order him detained pending trial. +Among other things, the proposed bail package contemplates the defendant pledging as the +principal security a property that has already been identified by the Government as subject to +forfeiture upon the defendant's conviction, and which therefore is of no value as collateral. His +proposed global waiver of extradition is unenforceable, and even if enforceable would be little +comfort to victims forced to wait additional years while the defendant is located and returned to +this country. The promise to "deregister or otherwise ground" his private jet is meaningless given +his wealth and ability to easily secure other means of travel. The two co-signers he proposes only +further highlight his minimal community ties, including his lack of any family in or near the +District. Electronic monitoring would merely give the defendant less of a head start in fleeing +and does not guard against the risk of him endangering victims in the very home where he has +continued to hoard nude images of young women and girls. And the private security force he +proposes to guard his gilded cage, a proposal already rejected by this Court in similar +circumstances, simply reinforces the obvious fact that the defendant should be housed where he +can be secured at all times: a federal correctional center. +The defendant faces a presumption of detention, Pretrial Services has recommended +detention, and victims of the defendant seek his detention. Because there are no set of conditions +short of incarceration that can reasonably assure the appearance of the defendant or reasonably +protect the community from the dangers he poses if released, the Court should order him detained. +BACKGROUND +As previously set forth, a federal grand jury in this District returned an indictment (the +"Indictment") charging the defendant with violating Title 18, United States Code Section 1519, +and conspiracy to commit the same. +As charged by the grand jury, the facts giving rise to those counts involve a years-long +scheme to sexually abuse underage girls. Specifically, the defendant enticed and recruited dozens +of minor girls to engage in sex acts with him, for which he paid the vietims hundreds of dollars in +cash, in at least two different states. Victims were initially recruited to provide "massages" to the +defendant, which would be performed nude or partially nude, would become increasingly sexual +in nature, and would typically include one or more sex acts, including groping and direct or indirect +contact with victims' genitals. To perpetuate this exploitation of underage girls, the defendant +actively encouraged certain victims to recruit additional girls to be similarly sexually abused. He +paid these victim-recruiters hundreds of dollars for each additional girl they brought to him, +creating a network of underage victims for him to exploit in New York and Palm Beach. + + +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 3 of 14 +July 12, 2019 +Page 3 +The defendant, through counsel, continues to evidence a complete lack of appreciation for +the gravity of the offenses with which he is charged.' As an initial matter, there can be no plausible +suggestion that the allegations against the defendant involve isolated or aberrational conduct; they +involve repeated, regular acts of sexual abuse committed over a period of many years. And +following the defendant's prior conviction, as described previously by the Government, the +defendant continued to maintain at least hundreds and possibly thousands of nude photos of young +subjects. The defendant's victims in this case, often particularly vulnerable girls, were as young +as 14 years old when he abused them. The defendant knew he was abusing minors, including +because victims told him directly they were underage. And he preyed on his victims habitually +and repeatedly—day after day, month after month, year after year. +The defense calls these disturbing alleged acts "simple prostitution." Mag. Tr. 12:12; see +also D. Tr. at 6:15-19 ("This is basically the Feds today ... redoing the same conduct that was +investigated 10 years ago and calling it, instead of prostitution, calling it sex trafficking"). That +characterization is not only offensive but also utterly irrelevant given that federal law does not +recognize the concept of a child prostitute-there are only trafficking victims because a child +cannot legally consent to being exploited. Defense counsel's repeated assertion that the +Government's case is infirm because no threats or coercion are alleged e.g., Mag. Tr. at 12 +("There was no coercion. There were no threats. There was no violence."), 17 ("there was no +coercion. There was no intimidation. There is no deception."); Release Motion at 2 ("There are +no allegations ... that he forced, coerced, defrauded, or enslaved anybody ....")—is equally +irrelevant because the offense with which the defendant has been charged requires no such proof. +See, e.g., United States v. Afyare, 632 F. App'x 272, 278 (6th Cir. 2016) ("We hold that § 1591(a) +criminalizes the sex trafficking of children (less than 18 years old) with or without any force, fraud, +or coercion, and it also criminalizes the sex trafficking of adults (18 or older), but only if done by +force, fraud, or coercion."). +Far more important, the defense has already effectively conceded that the Government will +be able to present evidence of the actual primary elements of the charged offense i.e., that the +defendant engaged in sex acts for money with girls he knew were underage. See Release Motion +at 2. On this record, the Government agrees with Pretrial Services that the defendant should be +detained pending trial. He poses a tremendous risk of flight and a danger to the community, and +he cannot overcome the statutory presumption in favor of detention in this case. +' Such arguments are unsurprising from a defendant who previously compared himself to a "person +who steals a bagel" or a tragic mythical figure. See, e.g., Amber Southerland, Billionaire Jeffrey +Epstein: I'm a sex offender, not a predator, N.Y. Post (2011) (**I'm not a sexual predator, I'm an +"offender," the financier told The Post yesterday. 'It's the difference between a murderer and a +person who steals a bagel."); Philip Weiss, The Fantasist, NY Magazine (2007) (**It's the Icarus +story, someone who flies too close to the sun, ' I said. 'Did Icarus like massages?' Epstein asked."). +2 "Mag. Tr." refers to the transcript of the hearing before Magistrate Judge Pitman on July 8, 2019; +"D. Tr." refers to the transcript of the hearing before this Court on July 8, 2019. + + +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 4 of 14 +July 12, 2019 +Page 4 +ARGUMENT +The Government respectfully submits that the defendant cannot overcome the statutory +presumption in favor of detention in this case for the following reasons, among others: +1. +Victims Seek Detention +Pursuant to the Crime Victims' Rights Act ("CVRA"), a crime victim has the right to be +reasonably heard at certain public proceedings in the district court, including proceedings +involving release. 18 U.S.C. § 3771(a)(4). Consistent with that requirement, the Government has +been in contact with victims and counsel identified through this investigation in connection with +the argument regarding bail. +Multiple victims and/or their counsel have asked the Government to seek detention (and to +inform the Court of their views in that respect) for multiple reasons. First, they believe that the +defendant's continued detention is necessary under the CVRA's right to be reasonably protected +from the accused. 18 U.S.C. § 3771(a)(1). They have specifically conveyed to the Government +that they would be fearful for their safety if the defendant were released. For the reasons articulated +herein, the Government believes those concerns to be well-founded. +Additionally, certain victims have asked the Government to advise the Court that they are +specifically concerned about the defendant's proposal to be released even if under conditions that +included home detention and full-time private guards. They believe it would be unfair to victims +of a wealthy defendant, like Epstein, if he were to be given greater freedoms than others would be +in similar circumstances, and that such an arrangement would be inconsistent with their rights. +They specifically asked the Government to advise the Court that they believed such an arrangement +could result in harassment and abuse by the defendant. 3 +II. The Defendant's Proposal Does Nothing to Mitigate His Flight Risk +Each of the relevant factors to be considered as to flight risk—the nature and circumstances +of the offense, the strength of the evidence, and the history and characteristics of the defendantcounsel strongly in favor of detention, and the defendant's proposed package would do nothing +whatsoever to mitigate those risks. +A. Defendant Proposes No Infringement Upon His Ability to Use his Vast Wealth to Flee +It might not be immediately apparent to a reader of the Release Motion that the defendant +is extravagantly wealthy and worth, according to records relating to the defendant recently +obtained by the Government from a financial institution ("Institution-1"), more than $500 million. +3 The Government is aware of at least one additional attorney for a victim who has publicly stated +that her client supports the pretrial detention of the defendant. The Government is unaware of any +victim who has expressed support for the defendant being granted pretrial release on bail. + + +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 5 of 14 +July 12, 2019 +Page 5 +Indeed, while the defendant has still not filled out a financial affidavit, under penalty of +perjury, in connection with his application for bail, his token effort to account for his finances +makes painfully clear the need for detention. The defendant reports having an extraordinary +amount of money in both total assets and cash or cash-equivalent holdings. And while the +defendant repeatedly represents in his Release Motion that his assets are "in the United States," +there is absolutely nothing in the defendant's minimal financial submission to verify that. +Indeed, and as discussed further below, even assuming the defendant's assets are presently +in the United States, nothing in the proposed package would prevent the defendant from +transferring liquid assets out of the country quickly and in anticipation of flight or relocation. The +defendant is an incredibly sophisticated financial actor with decades of experience in the industry +and significant ties to financial institutions and actors around the world. He could easily transfer +funds and holdings on a moment's to places where the Government would never find them so as +to ensure he could live comfortably while a fugitive. +But perhaps most important, even were the defendant to sacrifice literally all of his current +assets, there is every indication that he would immediately be able to resume making millions or +tens of millions of dollars per year outside of the United States. He already earns at least +$10,000,000 per year, according to records from Institution-1, while living in the U.S. Virgin +Islands, traveling extensively abroad, and residing in part in Paris, France; there would be little to +stop the defendant from fleeing, transferring his unknown assets abroad, and then continuing to do +whatever it is he does to earn his vast wealth from a computer terminal beyond the reach of +extradition.* +That the defendant faces up to 45 years of incarceration on the current counts with which +he is charged provides the motive for him do so and is another significant factor in assessing the +risk of flight. See United States v. Jackson, 823 F.2d 4, 7 (2d Cir. 1987). So too is the strength of' +the evidence, detailed above and in the Government's Detention Memo. Indeed, that evidence, +already robust less than a week ago when the Indictment was unsealed, is growing stronger by the +day. Just since the Indictment was unsealed, several additional women, in multiple jurisdictions, +have identified themselves to the Government as having been victimized by the defendant when +they were minors. Moreover, pursuant to judicially-authorized search warrants, the Government +has discovered and seized a significant volume of photographs of nude and seminude young +women and girls in the defendant's Manhattan residence, and is in the process of reviewing dozens +of electronic discs that contain still more such photos. And dozens of individuals have called the +Government in recent days to convey information regarding the defendant and the allegations +* As noted in the Government's Detention Memo, the defendant is a frequent traveler and regularly +travels to and from the United States, including approximately more than 20 flights in which he +traveled to or from a foreign country since 2018 alone. Extensive international travel of this nature +further demonstrates a significant risk of flight. See, e.g., United States v. Anderson, 384 F. Supp. +2d 32, 36 (D.D.C. 2005). +5 The Government's review of these materials, seized earlier this week, remains ongoing. + + +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 6 of 14 +July 12, 2019 +Page 6 +contained in the Indictment. All this in less than a week, and all in addition to an Indictment that +already alleges the existence of dozens of victims in New York and dozens of victims in Florida. +B. The Proposed Bond is Inadequate to Overcome the Presumption of Detention +The defendant's "slate of highly restrictive" measures which purportedly "amply suffice to +secure his release" are neither highly restrictive nor amply sufficient. Rather, they are effectively +standard conditions of home confinement, monitoring, and bond unsecured by the defendant's +assets broken out into 14 pieces. The Government will address the most concerning and salient +elements of the defendant's proposal below. +1. Lack of Meaningful Bond Security +The defendant proposes that the Court accept his Manhattan mansion as the primary +security for a personal recognizance bond of an indeterminate amount, to be co-signed by the +defendant's brother and a friend. Release Motion at 4. This is plainly insufficient. +As an initial matter, and as noted above, the defendant's Manhattan mansion has been +identified in the Indictment as subject to forfeiture because it is alleged to have been used to +commit or facilitate the commission of the sex trafficking offenses charged there. See 18 U.S.C. +§ 1594(c)(1). Because the defendant would thus be likely to lose that property following a +conviction, it provides no value whatsoever as collateral. See 18 U.S.C. § 3142(g)(4) ('In +considering the conditions of release described ... the judicial officer ... shall decline to accept +the designation, or the use as collateral, of property that, because of its source, will not reasonably +assure the appearance of the person as required."). And while the defendant offers to also pledge +his private jet as additional collateral, there is absolutely no reason to assume that the defendant +would not readily trade his private plane for his freedom. Indeed, the defendant, who has a net +worth of more than $500 million, by his own admission recently sold a second plane and thus +presumably has cash on hand to replace the posted aircraft without difficulty if need be. +Nor does the proposed security of properties owned by two identified co-signers +meaningfully change the calculus. As further described below, the defendant provides no +information about the value or equity of the property of his brother, Mark (the "Palm Beach +Property"), or the significance of that property in the context of his brother's own net worth.® +Similarly, the defendant provides no details regarding the "investment interests" of his friend Mr. +Mitchell, nor any reason to believe the loss of those "interests" would be meaningful to Mr. +Mitchell, let alone the defendant. More generally, given the defendant's proffered net worth, the +defendant could easily make his co-signers whole - and even reward them - were he to flee. +The proposed security, in sum, should give the Court little comfort the defendant would +appear in Court if released on bail. +" In fact, the defendant's own submission makes clear that the Palm Beach Property is not his +brother's exclusive residence and that his brother lives elsewhere for half of the year. + + +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 7 of 14 +July 12, 2019 +Page 7 +2. Co-Signers, Moral Suasion, and Ties to the Community +The dearth of detailed financial information about the defendant himself, much less his +brother or friend, further shows the hollowness of the proposal. The Court cannot possibly +evaluate whether there would be any incentive whatsoever for those the two proposed co-signers +to exercise moral suasion over the defendant—or whether, as noted above, the defendant could +easily compensate them, perhaps many times over, for any loss they incurred through the +defendant's flight from justice. The defendant provides no information about his brother other +many nime pove +than that he lives half the year in the home he purportedly would pledge, and even less information +about Mr. Mitchell, other than that he is "Mr. Epstein's friend," his "close personal friend of +decades," and his "close personal friend." Release Motion at 4, 9. Their willingness to "guarantee" +his appearance, Release Motion at 9, is meaningless in the absence of such information. +Moreover, the notion that any individual co-signer could meaningfully secure a bond for +this defendant strains credulity. Given the defendant's wealth and his extraordinary risk of flight, +any bond for this defendant would assuredly have to be in the hundreds of millions of dollars to +even be claimed to be sufficient to guard against the risks posed by the defendant's release. The +defendant offers no reason to believe any co-signers could meaningfully sign such a bond, much +less these two particular individuals, which is yet another reason the proposed package is patently +insufficient. +3. The Defendant's "Consent" to Extradition is Unenforceable and Impractical +The defendant's offer to sign a so-called "consent" to extradition provides no additional +reassurance whatsoever. As an initial matter, the Government would need to find and re-arrest the +defendant before such a waiver would even come into play. Moreover, even assuming the +Government could locate and apprehend the defendant, numerous courts have recognized that such +purported waivers are unenforceable and effectively meaningless because any defendant who signs +such a purported waiver and then flees will assuredly contest the validity and/or voluntariness of +the waiver, and will get to do so in the jurisdiction of his choosing (i.e., the one to which he chose +to flee). See, e.g., United States v. Morrison, No. 16-MR-118, 2016 WL 7421924, at *4 (W.D.N.Y. +Dec. 23, 2016); United States v. Kazeem, No. 15 Cr. 172, 2015 WL 4645357, at *3 (D. Or. Aug. +3, 2015); United States v. Young, Nos. 12 Cr. 502, 12 Cr. 645, 2013 WL 12131300, at *7 (D. Utah +Aug. 27, 2013); United States v. Cohen, No. C 10-00547, 2010 WL 5387757, at *9 n.11 (N.D. +Cal. Dec. 20, 2010); United States v. Bohn, 330 F. Supp. 2d 960, 961 (W.D. Tenn. 2004); United +States v. Stroh, No. 396 Cr. 139, 2000 WL 1832956, at *5 (D. Conn. Nov. 3, 2000); United States +v. Botero, 604 F. Supp. 1028, 1035 (S.D. Fla. 1985). . The Department of Justice's Office of +International Affairs is unaware of any country anywhere in the world that would consider an +anticipatory extradition waiver binding. And, of course, the defendant could choose to flee to a +jurisdiction with which the United States does not have an extradition treaty. +Beyond being impossible to guarantee, extradition is typically a lengthy, complicated and +expensive process, and the possibility that it would be successful neither provides any real +deterrent to the defendant's incentive to flee nor any measure of justice to the victims who would +be required to wait years for his return. + + +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 8 of 14 +July 12, 2019 +Page 8 +4. Home Confinement and Electronic Monitoring Provide No Assurance +The defendant's proposal of ankle-bracelet monitoring should be of no comfort to the +Court. In particular, the defendant's endorsement of a GPS monitoring bracelet rather than a radio +frequency bracelet is farcical because neither one is useful or effective after it has been removed. +At best, home confinement and electronic monitoring would reduce his head start should he decide +to cut the bracelet and flee. See United States v. Zarger, No. 00 Cr. 773, 2000 WL 1134364, at *1 +(E.D.N.Y. Aug. 4, 2000) (rejecting defendant's application for bail in part because home detention +Cr. 099, 2002 WL 31410262, at *3 (E.D.N.Y. Oct. 10, 2002) (same). +5. Private Security is Inadequate, Unfair, and Impractical Here +The defendant also proposes the use of a private security force to march him to and from +court under the threat of deadly force. This proposal should be rejected. +At the outset, it is far from clear that private jail, which seeks to replicate the conditions of +a government-run detention facility in the defendant's home, is a condition of "release" that +implicates the Bail Reform Act. "[T]here is a debate within the judiciary over whether a defendant, +if she is able to perfectly replicate a private jail in her own home at her own cost, has a right to do +so under the Bail Reform Act and the United States Constitution." United States v. Valerio, 9 F. +Supp. 3d 283, 292 (E.D.N.Y. 2014) (Bianco, J.) (collecting cases). The Second Circuit has never +directly addressed this issue. See United States v. Sabhnani, 493 F.3d 63, 78 n.18 (2d Cir. 2007) +("The government has not argued and, therefore, we have no occasion to consider whether it would +be "contrary to the principles of detention and release on bail' to allow wealthy defendants 'to buy +their way out by constructing a private jail." (citations omitted)). Indeed, a decision by this Court +reasoned that "the very severe restrictions" in the private jail proposal presented to him did "not +appear to contemplate 'release' so much as it describes a very expensive form of private jail or +detention." United States v. Zarrab, 2016 WL 3681423, at *10 (S.D.N.Y. June 16, 2016). +Courts have long been troubled by private jail proposals like the defendant's which, "at +best 'elaborately replicate a detention facility without the confidence of security such a facility +instills."" United States v. Orena, 986 F.2d 628, 632 (2d Cir. 1993) (quoting United States v. Gotti, +776 F. Supp. 666, 672 (E.D.N.Y. 1991) (rejecting private jail proposal)); see also Valerio, 9 F. +Supp. 3d at 295 ("The questions about the legal authorization for the private security firm to use +force against defendant should he violate the terms of his release, and the questions over whether +the guards can or should be armed, underscore the legal and practical uncertainties indeed, the +imperfections of the private jail-like concept envisioned by defendant, as compared to the more +secure option of an actual jail."). A private security firm simply cannot replicate the controlled +environment of a federal correctional facility, in which, typically, all of the needs to the prisoner +can be attended to without placing the prisoner in the community at large; the defendant's proposed +private jail arrangement would have the effect of permanently placing him in just such a highflight-risk circumstance. The risk of a public escape attempt while in the community and involving + + +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 9 of 14 +July 12, 2019 +Page 9 +armed private guards attempting to stop the defendant, potentially by force-rather than the +defendant being in the environment of a federal facility—also greatly magnifies the danger of the +defendant's flight to the public. See United States v. Boustani, 356 F. Supp. 3d 246, 257 (E.D.N.Y. +2019). "This is why, as the Government correctly notes, federal prisoners should be detained in +facilities run by trained personnel from federal correctional facilities." Id. at 258 (citing Sabhnani, +493 F.3d at 74 n. 13 ("To the extent [armed private guards] implies an expectation that deadly force +may need to be used to assure defendant['s] presence at trial ... [s]uch a conclusion would, in fact, +demand a defendant's detention*). +The Second Circuit has held it is not legal error "for a district court to decline to accept," +as "a substitute for detention," a defendant hiring private security guards to monitor him. United +States v. Banki, 369 Fed. App'x 152, 153-54 (2d Cir. 2010). In the same decision, the Second +Circuit noted that it was "troubled" by the possibility of "allow[ing] wealthy defendants to buy +their way out by constructing a private jail." (internal quotation marks omitted)). Id.; accord, e.g., +United States v. Cilins, No. 13 Cr. 315 (WHP), 2013 WL 3802012, at *3 (S.D.N.Y. July 19, 2013) +("*'it is contrary to underlying principles of detention and release on bail that individuals otherwise +ineligible for release should be able to buy their way out by constructing a private jail, policed by +security guards not trained or ultimately accountable to the Government, even if carefully +selected'" (quoting Borodin v. Ashcroft, 136 F. Supp. 2d 125, 134 (E.D.N.Y. 2001))); Valerio, 9 +F. Supp. 3d at 293-94 (E.D.N.Y. 2014) ("There is nothing in the Bail Reform Act that would +suggest that a defendant (or even, hypothetically, a group of defendants with private funding) has +a statutory right to replicate or construct a private jail in a home or some other location."). +The defendant's payment of his guards also raises the conflict of interest inherent in having +the defendant having extraordinary influence over a private security company tasked with guarding +him, leaving the company's incentives entirely aligned with the defendant. See, e.g., Boustani, +356 F. Supp. 3d at 257 (in finding that private armed guards would not reasonably assure the +appearance of a defendant, noting a "clear conflict of interest private prison guards paid by an +inmate" and noting that in a recent S.D.N.Y. case involving private security guards the defendant +"was outside of his apartment virtually all day, every weekday; was visited by a masseuse for a +total of 160 hours in a 30-day period; and went on an unauthorized visit to a restaurant in +Chinatown with his private guards in tow"); see also United States v. Tajideen, 17 Cr. 046, 2018 +WL 1342475, at *5-6 (D.D.C. Mar. 15, 2018) (finding Zarrab "particularly instructive" and further +noting: "While the Court has no reason to believe that the individuals selected for the defendant's +security detail would intentionally violate federal law and assist the defendant in fleeing the Court's +jurisdiction, it nonetheless is mindful of the power of money and its potential to corrupt or +undermine laudable objectives. And although these realities cannot control the Court's ruling, they +also cannot be absolutely discounted or ignored."). +Finally, in Zarrab this Court found that "the Defendant's privately funded armed guard +proposal is unreasonable because it helps to foster inequity and unequal treatment in favor of a +very small cohort of criminal defendants who are extremely wealthy, such as Mr. Zarrab." 2016 +WL 3681423, at *13; see also Boustani, 356 F. Supp. 3d at 258 ("although this Defendant has vast +financial resources to construct his own "private prison,' the Court is not convinced 'disparate +treatment based on wealth is permissible under the Bail Reform Act) (quoting United States v. + + +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 10 of 14 +July 12, 2019 +Page 10 +Bruno, 89 F. Supp. 3d 425, 432 (E.D.N.Y. 2015) (***Even if Defendant had the financial capacity +to replicate a private jail within his own home, this Court is not convinced that such a set of +conditions would be sufficiently effective in this case to protect the community from Defendant, +or that such disparate treatment based on wealth is permissible under the Bail Act.")); Borodin, +136 F. Supp. 2d at 134 (E.D.N.Y. 2001) (Nickerson, J.) ("It is contrary to underlying principles of +detention and release on bail that individuals otherwise ineligible for release should be able to buy +their way out by constructing a private jail, policed by security guards not trained or ultimately +accountable to the government, even if carefully selected."). +If the defendant's appearance can only be assured through use of round-the-clock guards, +the defendant belongs in a federal detention center, not released under bail conditions that +effectively create a private prison of one, using guards to be paid by the defendant himself. It is +frankly outrageous for the defendant to suggest that preventing him from using his vast wealth to +duplicate a private prison that cannot control, monitor, and contain him consistent with the +requirements of the Bail Act would cause him to somehow "bear a special disadvantage." Release +Motion at 12 n.9. Indeed: "What more compelling case for an order of detention is there than a +case in which only an armed guard and the threat of deadly force is sufficient to assure the +defendant's appearance?" Zarrab, 2016 WL 3681432, at *12 (quoting United States v. Valerio, 9 +F. Supp. 3d at 295). +III. +The Defendant Provides No Assurance He is Not a Danger to the Community and a +Risk to Obstruct Justice +A. Danger to the Community +In the first instance, the defendant's argument that 14 years without a criminal conviction +eliminates "any danger presumption" should be rejected. Were that the case— which is certainly +is not—a lack of criminal record for any defendant would automatically rebut the presumption +applicable to crimes such as sex trafficking. That is manifestly incorrect. See United States v. +Artis, 607 F. App'x 95, 97 (2d Cir. 2015) (finding that a defendant's lack of criminal record was +"not so compelling as to defeat the presumption or to manifest clear error in the district court's +determination that no combination of release conditions ... could reasonably assure against +dangerousness and the risk of flight"). Moreover, here, the defendant not only has a criminal +record, but has been convicted of a sex crime involving a minor. +But the ongoing and forward-looking danger posed by the defendant is further +demonstrated by the defendant's maintenance of a substantial collection of photographic trophies +of his victims and other young females in his mansion, as discovered by the Government through +its search warrants. As indicated in the Detention Memo, the many dises found in the defendant's +residence included those with hand-written labels including the following: "Young [Name] + +[Name]," "Mise nudes 1," and "Girl pies nude." Not surprisingly, the Government has found that +such discs contain photographs of sexually suggestive photographs of fully- or partially-nude +females appearing to be underage. + + +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 11 of 14 +July 12, 2019 +Page 11 +B. Danger to Obstruct Justice +The defendant has also already demonstrated a willingness to use intimidation and +aggressive tactics in connection with a criminal investigation. Far from being "musty," Release +Motion at 6 n.6, the defendant's past behavior in connection with being investigated for sexually +abusing children is the best predictor of his likely incentives and activities in connection with being +charged with sexually abusing children. For example, in the incident the defendant now claims +was not attributable to or authorized by him, the contemporaneous police report indicates that +pressure tactics were at the very least coordinated closely with individuals in the defendant's orbit. +See Palm Beach Police Report (the "Police Report") (Ex. B). According to the Police Report, the +parent of one of the defendant's victims was driven off the road by a private investigator. The +Police Report provides further information regarding victim and witness threats and intimidation +reported against an individual who was directly in contact with an assistant of the defendant, +followed "immediately" by a call to that same individual from a phone number associated with the +defendant's businesses and associates. +Separately, and in addition, there are also extensive allegations of obstruction and +tampering in connection with civil lawsuits brought against the defendant following his 2008 +conviction. See Doe v. United States, 08 Civ. 80736 (S.D. Fla.), Dkt. 291-15 at 21-23, 31. +Moreover, police reports suggest that an associate of Epstein's was offering to buy victims" silence +during the course of the prior investigation. Specifically, one victim reported that "she was +personally contacted through a source that has maintained contact with Epstein," who "assured +[the victim] that she would receive monetary compensation for her assistance in not cooperating +with law enforcement." Indeed, the victim reported having been told: "Those who help him will +be compensated and those who hurt him will be dealt with." See Palm Beach Police Report +(Ex. C). +And Epstein's efforts to influence witnesses continue to this day. As in the past, within +recent months. he paid significant amounts of money to influence individuals who were close to +him during the time period charged in this case and who might be witnesses against him at a trial. +By way of background, on or about November 28, 2018, the Miami Herald began publishing a +series of articles relating to the defendant, his conduct, and the circumstances of his prior +conviction and the non-prosecution agreement ("NPA"). Records obtained by the Government +from Institution-1 appear to show that just two days later, on or about November 30, 2018, the +defendant wired $100,000 from a trust account he controlled to an individual named as a possible +co-conspirator in the NPA. The same records appear to show that just three days after that, on or +about December 3, 2018, the defendant wired $250,000 from the same trust account to another +individual named as a possible co-conspirator in the NPA and also identified as one of the +defendant's employees in the Indictment. Neither of these payments appears to be recurring or +repeating during the approximately five years of bank records presently available to the +Government. +This course of action, and in particular its timing, suggests the defendant was +attempting to further influence co-conspirators who might provide information against him in light +of the recently re-emerging allegations + + +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 12 of 14 +July 12, 2019 +Page 12 +IV. The Defendant Raises Legal Arguments Not Relevant Here +Finally, the defendant raises certain legal arguments he contends he will litigate at the +appropriate stage and which he further suggests mitigate in favor of bail. None is meritorious, and +certainly none should give the Court any comfort whatsoever that the defendant would, if granted +bail, refrain from fleeing so he could attempt to vindicate himself via dubious legal strategies. +Nevertheless, the Government will address the defendant's arguments briefly in turn. +A. The Non-Prosecution Agreement Does Not Preclude Prosecution +As an initial matter, as the Court itself noted at the parties' initial appearance earlier this +week, and as the defendant appears to concede, the instant Indictment charges conduct well beyond +the scope of the NPA - that is, alleged conduet that occurred here in New York and involving New +York based victims. D. Tr. 6-8; Release Motion at 2. For present purposes, that alone is sufficient +to put this issue to rest, because even assuming the defendant were to mount a meritorious +challenge to the NPA, he would still have to stand trial on Count Two of the Indictment and +additional charges brought based on New York conduct. +But more generally, the reasons the defendant can be prosecuted in the Southern District +of New York-or anywhere else outside the SDFL—are manifold. The language of the NPA +overwhelmingly refers to the SDFL, and the core terms and text of the agreement are limited to +the SDFL. The prefatory language states: "THEREFORE, on the authority of R. Alexander +Acosta, United States Attorney for the Southern District of Florida, prosecution in this District for +these offenses shall be deferred in favor of prosecution by the State of Florida."? The final +paragraph of the prefatory language also states, among other things, that after fulfilling the terms +of the agreement, "no prosecution for the [sex abuse] offenses set out on pages 1 and 2 of this +Agreement, nor any other offenses that have been the subject of the joint investigation by the +Federal Bureau of Investigation and the United States Attorney's Office, nor any offenses that +arose from the Federal Grand Jury investigation will be instituted in this District." +In its terms section, the NPA further states that Epstein's signature "is not to be construed +as an admission of civil or criminal liability or a waiver of any jurisdictional or other defense" as +to any victim whose identity was not disclosed by SDFL to Epstein, as provided for in the NPA, +and additionally states that neither Epstein's signature nor any resulting waivers or civil +settlements "are to be construed as admissions or evidence of civil or criminal liability or a waiver +of any jurisdictional or other defense as to any person." These provisions show the parties +contemplated possible criminal prosecutions in other jurisdictions and/or based on victims not +initially identified in the Florida investigations (whether in Florida or elsewhere). The final +substantive paragraph of the NPA states that "Epstein hereby requests that the United States +Attorney for the Southern District of Florida defer [...] prosecution." +It is well settled in the Second Circuit that "a plea agreement in one U.S. Attorney's office +does not, unless otherwise stated, bind another." United States v. Prisco, 391 F. App'x 920, 921 +"All emphases relating to the NPA are added unless otherwise specified. + + +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 13 of 14 +July 12, 2019 +Page 13 +(2d Cir. 2010) ("A plea agreement binds only the office of the United States Attorney for the +district in which the plea is entered unless it affirmatively appears that the agreement contemplates +a broader restriction.") (citing United States v. Annabi, 771 F.2d 670, 672 (2d Cir. 1985) (per +curiam)). Moreover, any references in an NPA to the "Government" or the "United States" do not +abrogate these principles. Annabi, 771 F.2d at 672 ("[A] plea agreement whereby a federal +prosecutor agrees that 'the Government' will dismiss counts of an indictment ... might be thought +to bar the United States from reprosecuting the dismissed charges in any judicial district unless the +agreement expressly limits the scope of the agreement.... However, the law has evolved to the +contrary."). "The mere use of the term "government' in the plea agreement does not create an +affirmative appearance that the agreement contemplated barring districts other than the particular +district entering into the agreement." United States v. Salameh, 152 F.3d 88, 120 (2d Cir. 1998) +(citations and internal quotation marks omitted); see also United States v. Brown, No. 99-1230, +2002 WL 34244994, at *2 (2d Cir. Apr. 26, 2002) (in analyzing an SDFL plea agreement, +reiterating the holding of Annabi and noting that it applies "even if the plea agreement purports to +bind 'the Government'" or the "United States") (summary order); United States v. Bruno, 159 F. +Supp. 3d 311, 321 (E.D.N.Y. 2016) ("The Court disagrees with Defendant's argument that the +phrase 'United States" shows an intent to bind all United States Attorney's Offices. Rather, the +plea agreement covers only Defendant's liability in the SDFL.").* +In sum, this issue is a distraction that has little relevance to the bail determination and does +nothing to address the defendant's risk of flight or mitigate the danger he poses to the community. +B. The Defendant Wrongly Argues the Statute Does Not Apply to His Sex Trafficking +Next, the defendant wrongly argues that the "principal conduct" giving rise to the charges +is his payment of underage girls for sex acts, and that such conduct could not possibly fall under +the charged statutes. As the defendant implicitly concedes, Release Motion at 14, this is an issue +for a motion to dismiss. Nevertheless, the defendant's argument is incorrect for two reasons. +First, although the defendant undoubtedly participated on the demand side of the crime, he +was also instrumental on the supply side given his role in recruiting and causing others to recruit +additional victims. He organized, funded, and perpetuated a sex trafficking scheme in two states, +including with co-conspirators. The fact that he did so for his own eventual and frequent sexual +gratification does not vitiate his role in enticing and recruiting victims, consistent with the elements +of the offense with which he is charged. The defendant was the leader of a sex-trafficking +enterprise, not a mere consumer. +8 This analysis similarly extends to a non-prosecution agreement. See United States v. Laskow, +688 F. Supp. 851, 854 (E.D.N.Y. 1988) ("Defendant's argument, in effect, is that unless there is +an explicit statement to the contrary, it is presumed that a non-prosecution agreement binds offices +of the United States Attorney that are not parties to the agreement. This position is at odds with +the law in this Circuit, which presumes a narrow reading of the boundaries of a plea agreement +unless a defendant can affirmatively establish that a more expansive interpretation was +contemplated.") (citing Annabi, 771 F.2d at 672). + + +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 14 of 14 +July 12, 2019 +Page 14 +Second, he is also wrong on the law. Courts have found that Section 1591 applied to both +suppliers and consumers of commercial sex acts. See, e.g., United States v. Jungers, 702 F.3d +1066, 1069 (8th Cir. 2013) (upholding the conviction of a defendant who attempted to pay for oral +sex from an underage girl and explaining: "The sole issue raised on appeal is whether '[t]he plain +and unambiguous provisions of 18 U.S.C. § 1591 apply to both suppliers and consumers of +commercial sex acts.' We conclude they do.") (alteration in original). The lone case cited by the +defendant, Fierro v. Taylor, No. 11 Civ. 8573, 2012 WL 13042630 (S.D.N.Y. July 2, 2012), relied +heavily on the statutory interpretation undertaken by two district courts in the District of South +Dakota, United States v. Bonestroo, No. 11 Cr. 40016, 2012 WL 13704 (D.S.D. Jan. 4, 2012), and +United States v. Jungers, 11 Cr. 40018, 2011 WL 6046495 (D.S.D. Dec. 5, 2011), both of which +were explicitly overruled by the Eighth Circuit decision in Jungers, 702 F.3d 1066. In the seven +years since Fierro has been decided, it does not appear to have been cited by a single other court. +Additionally, other cases in this Circuit and elsewhere have upheld convictions of procurers or +customers. See United States v. O'Connor, 650 F.3d 839 (2d Cir. 2011) (upholding convictions +under Section 1591 of both the buyer and seller of a child); United States v. Cook, 782 F.3d 983 +(8th Cir. 2015) (rejecting a constitutional challenge that Section 1591 would be void for vagueness +if applied to purchasers); United States v. Mikoloyck, No. 09 Cr. 036, 2009 WL 4798900 (W.D. +Mo. Dec. 7, 2009) ("contrary to defendant's argument, 18 U.S.C. § 1591 clearly applies to those +who attempt to purchase underage sex, not merely the pimps of actual exploited children") (citing +United States v. Roberts, 174 F. App's 475 (11th Cir. 2006) (in which defendant was convicted +under sections 1591(a) and 1594(a) even though no actual children were involved)). +CONCLUSION +As set forth above, the defendant's proposed bail package is insufficient and insubstantial +Pretrial Services, victims, and the Government all recommend pretrial detention due to the unusual +and concerning confluence of factors in this case, including the defendant's extraordinary wealth, +demonstrated willingness to interfere with victims and witnesses, continued possession of lewd +photographs of young females, and both the incentive and means to flee prosecution. +Very truly yours, +GEOFFREY S. BERMAN +United States Attorney +By: +Assistant United States Attorney +Southern District of New York +Tel: +Cc: +Martin Weinberg, Esq., and Reid Weingarten, Esq., counsel for defendant + + +Case 1:19-cr-00490-RMB Document 11-1 Filed 07/12/19 Page 1 of 10 +U.S. Department of Justice +United States Attorney +Southern District of New York +July 8, 2019 +VIA ECF +The Honorable Henry Pitman +United States District Court +Southern District of New York +United States Courthouse +Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) +Dear Judge Pitman: +The Government respectfully submits this letter in advance of the bail hearing scheduled +for July 8, 2019, in the above-captioned case. For the reasons set forth herein, the Court should +order that the defendant be detained pending trial; he cannot meet his burden of overcoming the +presumption that there is no combination of conditions that would reasonably assure his continued +appearance in this case or protect the safety of the community were he to be released. +As set forth below, the charges in this case are exceptionally serious: the defendant is +alleged to be a serial sexual predator who preyed on dozens of minor girls over a period of years, +and he now faces a potentially massive prison sentence predicated on substantial and multifaceted +evidence of his guilt. In light of the strength of the Government's evidence and the substantial +incarceratory term the defendant would face upon conviction, there is an extraordinary risk of +flight, particularly given the defendant's exorbitant wealth, his ownership of and access to private +planes capable of international travel, and his significant international ties. Indeed, the arrest of +the defendant occurred when he arrived in the United States on his private jet after having returned +from a multi-week stay abroad. +The defendant thus cannot overcome the statutory presumption that detention is appropriate in this +case, and the Court should order that he be detained pending trial. + + +Case 1:19-Cr-00490-RMB Document 11-1 Filed 07/12/19 Page 2 of 10 +July 8, 2019 +Page 2 +BACKGROUND +A. Overview +On July 2, 2019, a federal grand jury in the Southern District of New York returned a sealed +indictment (the "Indictment") charging the defendant with one count of sex trafficking of minors, +in violation of 18 U.S.C. § 1591, and one count of conspiracy to commit sex trafficking of minors, +in violation of 18 U.S.C. § 371. +As charged by the grand jury, the facts underlying the charges in the Indictment arise from +a years-long scheme to sexually abuse underage girls. In particular, beginning in at least 2002, the +defendant enticed and recruited dozens of minor girls to engage in sex acts with him, for which he +paid the victims hundreds of dollars in cash. +He undertook this activity in at least two different locations, including his mansion in +Manhattan, New York (the "New York Residence") and his estate in Palm Beach, Florida (the +"Palm Beach Residence"). In both New York and Florida, the defendant perpetuated this abuse in +similar ways. Victims were initially recruited to provide "massages" to the defendant, which +would be performed nude or partially nude, would become increasingly sexual in nature, and +would typically include one or more sex acts, including groping and direct or indirect contact with +victims' +genitals. The defendant paid his victims hundreds of dollars in cash for each separate +encounter. +Moreover, the defendant actively encouraged certain of his victims to recruit additional +girls to be similarly sexually abused. He incentivized his victims to become recruiters by paying +these victim-recruiters hundreds of dollars for each additional girl they brought to him. In this +fashion, the defendant created a vast network of underage vietims for him to exploit, in locations +including New York and Palm Beach. +The defendant's victims were as young as 14 years old when he abused them. Many of his +victims were, for various reasons, often particularly vulnerable to exploitation. The defendant +intentionally sought out — and knew that he was abusing minors. Indeed, in some instances, his +victims expressly told him they were underage before or during the period in which he abused +them. +In creating and maintaining a network of minor victims whom he abused, the defendant +worked with others, including employees and associates who facilitated his exploitation of minors +by, among other things, contacting victims and scheduling their sexual encounters with the +defendant, both in New York and in Florida. +B. The Defendant +Jeffrey Epstein designed, financed, and perpetrated this scheme, both as its main participant +and through his direction of others, including certain of his employees, to further facilitate his +rampant abuse of underage girls. + + +Case 1:19-Cr-00490-RMB Document 11-1 Filed 07/12/19 Page 3 of 10 +July 8, 2019 +Page 3 +As has been widely reported, the defendant is extraordinarily wealthy, and he owns and +maintains luxury properties and residences around the world, including in Manhattan, New York; +Palm Beach, Florida; Stanley, New Mexico; and Paris, France. Additionally, Epstein owns a +private island in the U.S. Virgin Islands which, as noted above, is believed to be his primary +residence in the United States. His mansion in Manhattan alone—a multi-story townhouse +reported to be one of the largest single residences in all of Manhattan, which previously housed a +school and which he owns through an LLChas been valued at approximately $77 million. +Entities controlled by the defendant also own at least two private jets in active service, at least one +of which is capable of intercontinental travel. +As described further below, the defendant possesses three active United States passports, +and his international connections and travels are extensive. For example, in addition to +maintaining a residence in Paris, France, as described above, in the past 18 months alone, the +defendant has traveled abroad, via private jet, either into or out of the country on approximately +more than 20 occasions. +C. The Prior Florida Investigation +In or about 2005, the defendant was investigated by local police in Palm Beach, Florida, in +connection with allegations that he had committed similar sex offenses against minor girls. The +investigation ultimately also involved federal authorities, namely the U.S. Attorney's Office for +the Southern District of Florida ("SDFL") and the FBI's Miami Office, and included interviews +with victims based in the Palm Beach area, including some of the alleged victims relevant to Count +One of the instant Indictment.' +In fall 2007, the defendant entered into a non-prosecution agreement with the SDFL in +connection with the conduct at issue in that investigation, which the non-prosecution agreement +identified as including investigations into the defendant's abuse of minor girls in the Palm Beach +area. The Southern District of New York was not a signatory to that agreement, and the defendant +was never charged federally. In June 2008, the defendant pled guilty in state court to one count +of procuring a person under the age of 18 for prostitution, a felony, and one count of solicitation +of prostitution, a felony. As a result, the defendant was designated as a sex offender with +registration requirements under the national Sex Offender Registration and Notification Act. +' The non-prosecution agreement, further discussed below, was entered into at the conclusion of +the SDFL investigation and did not purport to cover any victims outside of the State of Florida. +As noted above, the instant Indictment expressly alleges the existence of dozens of victims who +were abused in this District in addition to dozens of victims who were abused in Florida. +2 While beyond the scope of a bail hearing, as discussed further below, it is well-established in the +Second Circuit that absent an express provision to the contrary in the agreement, one District is +not bound by the terms of an agreement entered into between a defendant and a U.S. Attorney's +Office in another district. See page 6, infra. + + +Case 1:19-Cr-00490-RMB Document 11-1 Filed 07/12/19 Page 4 of 10 +July 8, 2019 +Page 4 +ARGUMENT +1. +Applicable Law +Under the Bail Reform Act, 18 U.S.C. §§ 3141 et seq., federal courts are empowered to +order a defendant's detention pending trial upon a determination that the defendant is either a +danger to the community or a risk of flight. 18 U.S.C. § 3142(e) ("no condition or combination of +conditions would reasonably assure the appearance of the person as required and the safety of any +other person and the community"). A finding of risk of flight must be supported by a +preponderance of the evidence. See, e.g., United States v. Jackson, 823 F.2d 4, 5 (2d Cir. 1987); +United States v. Chimurenga, 760 F.2d 400, 405 (2d Cir. 1985). A finding of dangerousness must +be supported by clear and convincing evidence. See, e.g., United States v. Ferranti, 66 F.3d 540, +542 (2d Cir. 1995); Chimurenga, 760 F.2d at 405. In addition, a court may also order detention if +there is "a serious risk that the [defendant] will ... attempt to obstruct justice, or ... to threaten, +injure, or intimidate, a prospective witness or juror." 18 U.S.C. § 3142(f(2)(B); see also United +States v. Friedman, 837 F.2d 48 (2d Cir. 1988). +The Bail Reform Act lists four factors to be considered in the detention analysis: (1) the +nature and circumstances of the crimes charged; (2) the weight of the evidence against the person; +(3) the history and characteristics of the defendant, including the person's "character ... [and] +financial resources"; and (4) the seriousness of the danger posed by the defendant's release. See +18 U.S.C. § 3142(g). Evidentiary rules do not apply at detention hearings and the government is +entitled to present evidence by way of proffer, among other means. See 18 U.S.C. § 3142(f)(2); +see also United States v. LaFontaine, 210 F.3d 125, 130-31 (2d Cir. 2000) (government entitled +to proceed by proffer in detention hearings); Ferranti, 66 F.3d at 542 (same); United States v. +Martir, 782 F.2d 1141, 1145 (2d Cir. 1986) (same). +Where a judicial officer concludes after a hearing that "no condition or combination of +conditions will reasonably assure the appearance of the person as required and the safety of any +other person and the community, such judicial officer shall order the detention of the person before +18 U.S.C. § 3142(e)(1). Additionally, where, as here, a defendant is charged with +committing an offense involving a minor victim under 18 U.S.C. § 1591, it shall be presumed, +subject to rebuttal, that no condition or combination of conditions will reasonably assure the +appearance of the defendant as required and the safety of the community. 18 U.S.C. +§ 3142(e)(3)(E). +II. +Discussion +The defendant should be detained pending trial. For the reasons set forth below, it is +difficult to overstate the risk of flight and danger to the community if the defendant is released, +and for those reasons, the defendant cannot overcome the statutory presumption in favor of +detention in this case. + + +Case 1:19-Cr-00490-RMB Document 11-1 Filed 07/12/19 Page 5 of 10 +July 8, 2019 +Page 5 +A. The Defendant Poses an Extreme Flight Risk +Each of the relevant factors to be considered as to flight risk - the nature and circumstances +of the offense, the strength of the evidence, and the history and characteristics of the defendant - +counsel strongly in favor of detention. +1. The Nature and Circumstances of the Offense and the Strength of the Evidence +The "nature and circumstances" of this offense plainly favor detention. 18 U.S.C. +§ 3142(g)(1) (specifically enumerating "whether the offense. .. involves a minor victim" as a +factor in bail applications). Indeed, the crime of sex trafficking of a minor is so serious that for a +detendant charged with that offense, there is a presumption that no condition or combination of +conditions will reasonably assure the appearance of the defendant as required and the safety of the +community. 18 U.S.C. § 3142 (e)(3)(E). Here, as specified in the Indictment, the defendant's +conduct was committed serially, over a period of years, and affected dozens of victims. +The seriousness of the charge is also reflected in the penalties the defendant faces, which +include up to 45 years of incarceration for Counts One and Two of the Indictment.? As the Second +Circuit has noted. +1, the possibility of a severe sentence is a significant factor in assessing the risk of +flight. See Jackson, 823 F.2d at 7; see also United States v. Cisneros, 328 F.3d 610, 618 (10th Cir. +2003) (defendant was a flight risk because her knowledge of the seriousness of the charges against her +gave her a strong incentive to abscond); United States v. Townsend, 897 F.2d 989, 995 (9th Cir. 1990) +("Facing the much graver penalties possible under the present indictment, the defendants have an even +greater incentive to consider flight."). Here, the defendant is facing a statutory maximum of decades +in prison. Even in the absence of means —which, as discussed in detail below, the defendant has +in abundancethis fact alone would provide a compelling incentive for anyone to fail to appear. +It is particularly compelling for a defendant who is 66 years old and therefore faces the very real +prospect of spending the rest of his life in prison if convicted. +The likelihood of a substantial period of incarceration is buttressed by the strength of the +evidence. As set forth in the Indictment, the evidence in this case is strong. The Indictment alleges +that the defendant sexually abused dozens of minor victims, and the conspiracy count lists +numerous overt acts committed in furtherance of the defendant's crimes.* +3 The current penalties for violations of 18 U.S.C. § 1591 include a 10 year mandatory minimum +sentence. However, that punishment was created through an amendment to the statute in 2006. +The penalty for a violation of Section 1591 during the period charged in the Indictment, and +therefore relevant here, was a maximum of 40 years' imprisonment. ++ With respect to the evidence in this case, the Court should start its analysis by accepting that the +Indictment is sufficient, on its own, to establish probable cause that the defendant committed the +crimes of sex trafficking and sex trafficking conspiracy. Contreras, 776 F.2d at 54. ("Were an +evidentiary hearing addressing the existence of probable cause required in every § 3142(e) case in +which an indictment had been filed, the court would spend scarce judicial resources considering +that which a grand jury had already determined, and have less time to focus on the application of + + +Case 1:19-Cr-00490-RMB Document 11-1 Filed 07/12/19 Page 6 of 10 +July 8, 2019 +Page 6 +Multiple victims, including several specified in the Indictment, have provided information +against the defendant. That information is detailed, credible, and corroborated, in many instances, +by other witnesses and contemporaneous documents, records and other evidence—including, as +further detailed below, evidence from a search of the New York Residence on the night of the +defendant's arrest that reflects an extraordinary volume of photographs of nude and partially-nude +young women or girls. Such corroborating evidence also includes documents and other materials, +such as contemporaneous notes, messages recovered from the defendant's residence that include +names and contact information for certain victims, and call records that confirm the defendant and +his agents were repeatedly in contact with various victims during the charged period. Put simply, +all of this evidence - the voluminous and credible testimony of individuals who were sexually +abused by the defendant as minors, each of whom are backed up by other evidence - will be +devastating evidence of guilt at any trial in this case and weighs heavily in favor of detention. +Finally, it bears noting that neither the age of the conduct nor the defendant's previous nonprosecution agreement ("NPA") with a different federal district pose any impediment to his +conviction. As an initial matter, all of the conduct is timely charged, pursuant to 18 U.S.C. § 3283, +which was amended in 2003 to extend the limitations period for conduct that was timely as of the +date of the amendment, to any time during the lifetime of the minor victim. See United States v. +Chief, 438 F.3d 920, 922-25 (9th Cir. 2006) (finding that because Congress extended the statute +of limitations for sex offenses involving minors during the time the previous statute was still +running, the extension was permissible); United States v. Pierre-Louis, No. 16 Cr. 541 (CM), 2018 +WL 4043140, at *1 (S.D.N.Y. Aug. 9, 2018) (same). +Moreover, with respect to the NPA, that agreement, to which the Southern District of New +York was not a party, which by its express language pertained exclusively to the SDFL +investigation, and which did not purport to bind any other Office or District, does not preclude +prosecution in this District for at least two reasons. First, it is well settled in the Second Circuit +that "a plea agreement in one U.S. Attorney's office does not, unless otherwise stated, bind +another." United States v. Prisco, 391 F. App'x 920, 921 (2d Cir. 2010) ("A plea agreement binds +only the office of the United States Attorney for the district in which the plea is entered unless it +affirmatively appears that the agreement contemplates a broader restriction.") (citing United States +v. Annabi, 771 F.2d 670, 672 (2d Cir. 1985) (per curiam)). This is true even if the text of the +agreement purports to bind "the Government." See Annabi, 771 F.2d at 672. This analysis +similarly extends to a non-prosecution agreement. See United States v. Laskow, 688 F. Supp. 851, +854 (E.D.N.Y. 1988) ("Defendant's argument, in effect, is that unless there is an explicit statement +to the contrary, it is presumed that a non-prosecution agreement binds offices of the United States +Attorney that are not parties to the agreement. This position is at odds with the law in this Circuit, +which presumes a narrow reading of the boundaries of a plea agreement unless a defendant can +affirmatively establish that a more expansive interpretation was contemplated.") (citing Annabi, +771 F.2d at 672). Second, the Indictment charges conduct not covered by the NPA, namely +the presumptions and the § 3142(g) factors in deciding whether the defendant should be +detained."). + + +Case 1:19-Cr-00490-RMB Document 11-1 Filed 07/12/19 Page 7 of 10 +July 8, 2019 +Page 7 +conduct that occurred in New York. The prior NPA included a list of several dozen victims +identified in the prior investigation, all of whom were abused in the State of Florida, and none of +whom are a part of the conduct charged in Count Two of the instant Indictment. +Each of these factors the seriousness of the allegations, the strength of the evidence, and +the possibility of lengthy incarceration creates an extraordinary incentive to flee. And as further +described below, the defendant has the means and money to do so. +2. The Characteristics of the Defendant +The history and characteristics of the defendant also strongly support detention. The +defendant is extraordinarily wealthy and has access to vast financial resources to fund any attempt +to flee. Indeed, his potential avenues of flight from justice are practically limitless. +As the defendant acknowledged in his most recent New York State sex offender +registration, he has six residences, including two in the U.S. Virgin Islands (including his own +private island), and one each in Palm Beach, Florida; Paris, France; New York, New York; and +Stanley, New Mexico. The most recent estimated value of the defendant's New York City mansion +alone is more than $77 million. The most recent tax-assessed value of the defendant's Palm Beach +estate is more than $12 million. The defendant's primary residence is a private island in the U.S. +Virgin Islands, a place where any sort of meaningful supervision would be all but impossible. +Moreover, the defendant has access to innumerable means to flee. His sex registration +documentation of "current vehicles" lists no fewer than 15 motor vehicles, including seven +Chevrolet Suburbans, a cargo van, a Range Rover, a Mercedez-Benz sedan, a Cadillac Escalade, +and a Hummer II. These cars are registered in various states and territories including the Virgin +Islands, New York, Florida, and New Mexico. The defendant also has access to two private jets, +giving him the ability to leave the country secretly and on a moment's notice and to go virtually +anywhere he wants to travel. He is a very frequent international traveler and regularly travels to +and from the United States by private plane. In particular, between January 1, 2018, and the +present, U.S. Customs and Border Patrol has logged approximately more than 20 flights in which +Epstein was traveling to or from a foreign country. Indeed, he was arrested at Teterboro Airport +arriving on just such a private international flight after having spent approximately three weeks +abroad. Extensive international travel of this nature further demonstrates a significant risk of +flight. See, e.g., United States v. Anderson, 384 F. Supp. 2d 32, 36 (D.D.C. 2005). There can be +no assurance that, upon release, the defendant would suddenly lack access to such means of travel. +Finally, the defendant has no meaningful ties that would keep him in this country. The +defendant has no known immediate family. He is not married and has no children. He has friends +and associates worldwide, as demonstrated by his extensive international travel, and his +professional obligations, if any, can and seemingly are plainly capable of being handled by the +defendant remotely. Simply put, there would be no meaningful reason for the defendant to remain +in the country, while he would have every incentive (and every resource needed) to flee. +Nor would home confinement with electronic monitoring reasonably assure the +defendant's presence as required. At best, home confinement with electronic monitoring would + + +Case 1:19-Cr-00490-RMB Document 11-1 Filed 07/12/19 Page 8 of 10 +July 8, 2019 +Page 8 +merely reduce his head start should he decide to flee. See United States v. Zarger, No. 00 Cr. 773, +2000 WL 1134364, at *1 (E.D.N.Y. Aug. 4, 2000) (Gleeson, J.) (rejecting defendant's application +for bail in part because home detention with electronic monitoring "at best ... limits a fleeing +defendant's head start"); see also United States v. Casteneda, No. 18 Cr. 047, 2018 WL 888744, +at *9 (N.D. Cal. Feb. 2018) (same); United States v. Anderson, 384 F.Supp.2d 32, 41 (D.D.C +2005) (same); United States v. Benatar, No. 02 Cr. 099, 2002 WL 31410262, at *3 (E.D.N.Y. +Oct. 10, 2002) (same). +Finally, there can be little doubt that the defendant is in a position to abandon millions of +dollars in cash and property securing any potential bond and still live comfortably for the rest of +his life. These resources, and the ease with which the defendant could flee and live outside the +reach of law enforcement-particularly considering his vast wealth and lack of meaningful ties to +this District— make the risk of flight exceptionally high in this case, particularly when considered +in conjunction with the strength of the government's case and the lengthy sentence the defendant +could receive if convicted. +B. The Defendant Poses a Risk of Danger to the Community and of Engaging in +Obstruction of Justice +The release of the defendant, under any conditions, would pose a significant threat to the +community and to the ongoing investigation. +As described above, where there is probable cause to believe that an individual has +committed an offense under 18 U.S.C. § 1591, it is presumed that no condition or combination of +conditions can reasonably assure the safety of the community. 18 U.S.C. § 3142(e)(3). Here, not +only is the defendant charged with very serious sex crimes against minors, he has already +previously admitted to and been convicted of engaging in related conduct. Specifically, in +June 2008, the defendant pled guilty in state court to one count of procuring a person under the +for prostitution, a felony, and he currently is a registered sex offender, under +classification level three in New York-defined as presenting a "high" risk of committing another +sex crime and harm to the community. While the conduct presently alleged does not post-date the +2008 conviction, it nevertheless underscores the risk he poses to the community if released. +Additionally, and in connection with the investigation of the defendant's offense in Florida, +there were credible allegations that the defendant engaged in witness tampering, harassment, or +other obstructive behaviors. In fact, according to publicly-filed court documents, there were +discussions between prosecutors and the defendant's then-counsel about the possibility of the +defendant pleading guilty to counts relating to "obstruction," as well as "harassment," with +reference to 18 U.S.C. § 1512, which criminalizes "[t]ampering with a witness, vietim, or +informant." For example, in a communication from the defendant's then-counsel to prosecutors +in SDFL, his counsel set forth a possible factual proffer that included statements that the defendant +had "attempted to harass both [redacted] delay and hinder their receipt of a [redacted] to attend an +official proceeding" and that the defendant "in particular, changed travel plans and flew with both +[redacted] to the United States Virgin Islands rather than to an airport in New Jersey in order to +attempt to delay their receipt of what Mr. Epstein expected to be a [redacted]" and "further verbally + + +Case 1:19-cr-00490-RMB Document 11-1 Filed 07/12/19 Page 9 of 10 +July 8, 2019 +Page 9 +harassed both [redacted] in connection to this attempt to delay their voluntary receipt of process +all in violation of 18 USC 1512(d)(1)." Doe v. United States, 08 Civ. 80736 (S.D. Fla.), Dkts. +361 at 3-4, 361-7 through 361-11. In addition to 18 U.S.C. § 1512(d), prosecutors also proposed +that the defendant could plead guilty to 18 U.S.C. § 403, that is, a knowing or intentional violation +of the privacy protection of child victims and child witnesses, to which the defendant's thencounsel replied: "Already thinking about the same statutes." Id. Dkt. 361-11. They also discussed +a possible obstruction plea that "could rely on the incident where Mr. Epstein's private +investigators followed [redacted] father, forcing off the road." Id. Dkt. 361-10. +The defendant's apparent previous willingness to obstruct a federal investigation, harass or +tamper with witnesses, and hire private investigators that "forcled] off the road" the father of an +individual relevant in the investigation is alarming. It should especially weigh on the Court's +consideration here because the defendant was apparently willing to take those steps before even +being charged and thus facing federal indictment; the incentive to interfere in the Government's +case here, where an Indictment has been returned, is exponentially greater. And as discussed +above, the defendant has nearly limitless means to do so. +Finally, despite having been previously convicted of a sex offense involving an underage +victim, the defendant has continued to maintain a vast trove of lewd photographs of young-looking +women or girls in his Manhattan mansion. In a search of the New York Residence on the night of +his arrest, on July 6-7, 2019, pursuant to judicially-authorized warrants, law enforcement officers +discovered not only specific evidence consistent with victim recollections of the inside of the +mansion, further strengthening the evidence of the conduct charged in the Indictment, but also at +least hundreds-and perhaps thousands of sexually suggestive photographs of fully- or partiallynude females. While these items were only seized this weekend and are still being reviewed, some +of the nude or partially-nude photographs appear to be of underage girls, including at least one girl +who, according to her counsel, was underage at the time the relevant photographs were taken. +Additionally, some of the photographs referenced herein were discovered in a locked safe, in which +law enforcement officers also found compact dises with hand-written labels including the +following: "Young [Name] + [Name]," "Mise nudes 1," and "Girl pics nude." The defendant, a +registered sex offender, is not reformed, he is not chastened, he is not repentant;" rather, he is a +continuing danger to the community and an individual who faces devastating evidence supporting +deeply serious charges. +5 The redactions above are contained in the publicly filed version of the quoted document. +" See, e.g., Amber Southerland, Billionaire Jeffrey Epstein: I'm a sex offender, not a predator, +N.Y. Post (2011) (*'I'm not a sexual predator, I'm an "offender," the financier told The Post +yesterday. 'It's the difference between a murderer and a person who steals a bagel."'); Philip +Weiss, The Fantasist, New York Magazine (2007) (*'It's the Icarus story, someone who flies too +close to the sun,' I said. 'Did Icarus like massages?' Epstein asked."). + + +Case 1:19-cr-00490-RMB Document 11-1 Filed 07/12/19 Page 10 of 10 +July 8, 2019 +Page 10 +CONCLUSION +As set forth above, in this case, the risk of flight in this case is extraordinarily real. The +defendant is extremely wealthy, has extensive foreign contacts, and is charged with serious +offenses that carry a potential statutory sentence of up to 45 years' imprisonment even a fraction +of which could result in the defendant, who is 66 years old, spending the rest of his life in jail. In +sum, the defendant's transient lifestyle, his lack of family or community ties, his extensive +international travel and ties outside the country, and his vast wealth, including his access to and +ownership of private planes, all provide the defendant with the motive and means to become a +successful fugitive. Further, the nature of the offenses he is alleged to have perpetrated—the abuse +dozens of underage, vulnerable girls—along with his demonstrated willingness to harass, +intimidate and otherwise tamper with victims and other potential witnesses against him, render his +dangerousness readily apparent. +Accordingly, the Government respectfully submits that the defendant cannot and will not +Very truly yours, +GEOFFREY S. BERMAN +United States Attorney +By: +Assistant United States Attorney +Southern District of New York +Tel: +Cc: +Martin Weinberg, Esq., and Reid Weingarten, Esq., counsel for defendant +Hon. Richard M. Berman, United States District Judge + + +Date: +Time: +Case 1:19-cr-00490-RMB_ Document 11-2_ Filed 97/12/19 Page 1 o1 2 +M BEACH POLICE DEPARTMENI +Incident Report +Page: +Program: +Case No. . +(Continued) +Entered By.: +On +2006, I received several phone calls throughout the day +from +who stated he had been followed aggressively by a private +investigator. +• stated that as he drove to and from work and +running errands throughout the county, the same vehicle was behind him +running other vehicles off the road in an attempt not to lose sight of +I's vehicle. +I explained to him as Mr. Epstein had retained new legal council it +was possible it would be new private investigators following him to +observe his daily activities. I also explained to him that there was +and +scheduled on +I attempted to call +private investigators following +to inform +of the +however; +I received other phone calls from | +and +who +advised they were able to acquire the private investigators license +plate information. The subject following them was again driving very +aggressively and caused l +to run off the road. +stated +the vehicle is a green Chevy +bearing Florida tag. +The vehicle is registered to +| Florida. +is employed with +Investigations from +Florida. +is a licensed Private Investigator in the State of Florida. +Since the discovery of the threat made against one of the victims in +this case +, I requested subpoenas for all calls made to and +received from +during the month of March 2006 for her +cell phone and home phone. I had confirmed with Florida State +the exact dates of Spring Break +.. The Spring Break +was from March 4, 2006 through March 12, 2006. I received a subpoena +from +with all calls made during the month of +I reviewed the 989 calls made and received during the month of March +2006. I observed on +2006, +made and received thirty +five calls during that day. +Date +Time +Seconds +In/Out +To/From +I-06 11:03 AM +492 +Outbound +06 11:16 AM +6 +Inbound +-06 11:22 AM +887.2 +Inbound +-06 11:37 AM +48 +Outbound +-06 11:39 AM +28.2 +Inbound +-06 12:02 PM +727.2 Inbound +The table reflects the date of the calls, time of day (EST), duration + + +Date: +Time: +Case 1:19-cr-00490-RMB Document 11-2 Filed 07/12/19 Page 2 of 2 +IM BEACH POLICE DEPARTMENL +Incident Report +Page: +Program: +Case No. . . +(Continued) +of call in seconds, inbound or outbound calls and calls made to or +from +phone. +On +| 2006, at 11:03 am, +made a call +to the victim which lasted 492 seconds (8 minutes and 2 seconds) . +The victim then returned the call at 11:16 am which lasted 6 seconds. +The victim then made contact with +at 11:22 am for 877.2 seconds +(14 minutes and 6 seconds) . +These sequences of calls were consistent +with what the victim had described to me on the date of the +intimidation. Immediately after speaking with the victim, +makes +a call to +, Epstein's assistant, which lasts for +forty-eight seconds. A call is then immediately received, a telephone +number registered to a Corporation affiliated with Jeffrey Epstein +located at 457 Madison Ave in New York. An extensive computer check +revealed 457 Madison Ave is a business +, address in which Epstein has +his corporations assigned to. Epstein had corporation attorney, +register the businesses and register himself as an +agent. +I also observed Epstein has his El Zorro Ranch Corporation, +New York Strategy Group, Ghislaine Corporation, J Epstein and Company +and the Financial Strategy Group registered to this same address. +Finally, a third call is received by | +at 12:02 pm from the same +corporate number which lasts 12 minutes and 1 second. It should be +noted that there is no further contact with either the victim during +the month of | +I also noted that there was no +further contact with +Jor Jeffrey Epstein during the +remainder of the month of +2006. +On +2006, +meeting that occurred with Atty. +this case. +telephoned me to inform me of the +and +reference +Inv Continues. +/ + + +Case 1:19-cr-00490-RMB Document 11-3 Filed 07/12/19 Page 1 of 2 +ate: +7/19/06 +ime: 15:01:37 +PALM BEACH POLICE DEPARTMENT +Incident +Report +Page: +82 +Program: CMS301L +**** NARRATIVE # 42 ****** +Reported.: RECY, CA. +on April 5, +**** +4/14/06 +4/18/06 + + +Case 1:19-cr-00490-RMB +Document 11-3 Filed 07/12/19 Page 2 of 2 +ate: +7/19/06 +ime: 15:01:37 +PALM BEACH POLICE DEPARTMENT +Incident Report +Page: +Program: +Ise No. +10, +: 1-05-000368 +(Continued) +2006, at approximately 2:30 p.m., I served pat her residence in +The subpoena was given to her mother, +I learned through one of the victims +• that she was personally +contacted through a source that has maintained contact with Epstein. +The source assured she would receive monetary compensation for her +assistance in not cooperating with law enforcement. +also stated +she was told, "Those who help him will be compensated and those who +hurt him will be dealt with." I told that tampering with a +witness/ Victim 1s an arrestable oftense and very serious. I asked her +who approached her during this encounter. originally was reluctant +to provide the name of the person who approached her to offer her not +to testify because she felt they were still friends. +On April 11, 2006, Det Dawson and I traveled to Tallahassee, Florida +and met with the +victimA +• identified 1 +W/E +F as the person who approached her in +while +she was home during Spring Break in March 2006.C +also stated she +did not want to pursue the intimidation charges on an i +• was +concerned that the defense attorney was given a copy of the report as +certain things she had told me in confidence were repeated to her bu +83 +CMS301L \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/1f8ec923756c620767351798516a7dafd06bd2993902d9c980c7612022851299.receipt.json b/vision-fixhub/ds9-parsed-01/1f8ec923756c620767351798516a7dafd06bd2993902d9c980c7612022851299.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..a4524d081a87ff8772219e31d601aea7d071d737 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1f8ec923756c620767351798516a7dafd06bd2993902d9c980c7612022851299.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -1574, + "dataset": "marble-joined", + "doc_id": "1f8ec923756c620767351798516a7dafd06bd2993902d9c980c7612022851299", + "engine": "marble-apple-vision", + "event_count": 34, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "5a6335bee4fb4c6d2e1442331979e3aaa690b8ac6dda9360f5609b1fbc2f026e", + "output_sha256": "f32d20a8e3496d6a0d44061112695c4418439af3277cad578fb761212952e89c", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1f9efa7a38ce3e85f56771ba7516510e27c0e1000b6ca78f7debfe1f94275dce.md b/vision-fixhub/ds9-parsed-01/1f9efa7a38ce3e85f56771ba7516510e27c0e1000b6ca78f7debfe1f94275dce.md new file mode 100644 index 0000000000000000000000000000000000000000..b9d81367f31808ca22ac23df13b7a01391ddfcbf --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1f9efa7a38ce3e85f56771ba7516510e27c0e1000b6ca78f7debfe1f94275dce.md @@ -0,0 +1,65 @@ +Intake (Rev. 5-23-17) +UNCLASSIFIED +FEDERAL BUREAU OF INVESTIGATION +Intake +, OFFICIAL RECORD +Case ID #: 50D-NY-3027571 +Date: +(U) EPSTEIN, JEFFREY; CHILD SEX +TRAFFICKING +03/22/2021 +Drafted By: +Date/Time Received: 03/22/2021 07:51 PM EDT +Details: +On 3/22/2021, at 7:51 p.m. Eastern Time, +• Cell telephone number +zip code | +, date of birth +, called +the FBI National Threat Operations Center (NTOC) to report being raped by +Jeffery Epstein in 2001 or 2002 in New York, NY. (NY) +provided the following information: +stated that she was a rape victim of Jeffery Epstein. This +incident happened back in either 2001 or 2002, +was taken to a +conference by her parents and was staying at an apartment on the upper +east side, but does not remember who's apartment it was. +was +returning to the lobby one night and an unknown male subject (UNSUB), +believed to be Epstein based on his appearance, was waiting in the lobby +and joined her in the elevator. +During the elevator ride UNSUB stated that he saw her on TV last night. +did not know +at the time, but Epstein had cameras in all his +buildings, and +she think this meant he was watching her on camera. +Once +the +and UNSUB got off the elevator UNSUB said he was always +curious about how the apartment that she was staying at looked on the +inside. +let him in because he seemed trustworthy and she sat down +waiting for him to leave, but he was just staring at her. +UNCLASSIFIED + + +UNCLASSIFIED +Re: 50D-NY-3027571, 03/22/2021 +then decided to try to leave but the man blocked her and demanded +that she take her shirt off and threatened to cut +throat. +took off her shirt and does not remember a lot after this point, +but she remembers being verbally assaulted and "being scratched in her +vagina very hard." +believed at some point that night she was +drugged before these events. +The following night +believes she was drugged again by a man named +Victor Lee who organized the conference, is Chinese, and believes he was +born in the 40s or 50s and lived in Manhattan NY. Lee claimed to be a +herbal doctor and gave her a drink which she accepted, she believes this +was drugged as well. +had no further information on Victor Lee. +.. +UNCLASSIFIED +2 diff --git a/vision-fixhub/ds9-parsed-01/1f9efa7a38ce3e85f56771ba7516510e27c0e1000b6ca78f7debfe1f94275dce.receipt.json b/vision-fixhub/ds9-parsed-01/1f9efa7a38ce3e85f56771ba7516510e27c0e1000b6ca78f7debfe1f94275dce.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..8d7516ad911446cc1fc189505d6d51373658fb60 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1f9efa7a38ce3e85f56771ba7516510e27c0e1000b6ca78f7debfe1f94275dce.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "1f9efa7a38ce3e85f56771ba7516510e27c0e1000b6ca78f7debfe1f94275dce", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "0f1fe97252f6099d5f8f1b5db22c7bc1b9dca3f2c17ea0c8ef355abc42d302a3", + "output_sha256": "e729e2fbddfe8f27396c3658d4166edc902f376e85aa4af0086d4f68d7420430", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/1fdc3bfddfaddd24dd20ffc580ca59309bebd467689b278abf6469d8b101f589.md b/vision-fixhub/ds9-parsed-01/1fdc3bfddfaddd24dd20ffc580ca59309bebd467689b278abf6469d8b101f589.md new file mode 100644 index 0000000000000000000000000000000000000000..e844cc58ee3f95d3f70a1417bb080f04c2f3bd21 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1fdc3bfddfaddd24dd20ffc580ca59309bebd467689b278abf6469d8b101f589.md @@ -0,0 +1,126 @@ +From: +To: " +(USANYS)" +(CRM)" ! +Ce: " +(CRM)" = +Subject: RE: Independent: Prince Andrew: Refusal to talk to Epstein investigators 'straining relations +between UK and America* +Date: Thu, 12 Aug 2021 12:58:39 +0000 +Inline-Images: image001.png +Thanks, +The below looks good to us. On the penalties: +Title 18, United States Code, Section 2423 (transportation of minors) - maximum penalty is 10 years' imprisonment +Title 18, United States Code, Section 2422 (coercion and enticement) - maximum penalty is 5 years' imprisonment +Title 18, United States Code, Section 1591 (sex trafficking) - maximum penalty is 40 years' imprisonment +From: +(CRM) +Sent: Thursday, August 12, 2021 5:49 AM +(USANYS) * +(CRM) + +Subject: RE: Independent: Prince Andrew: Refusal to talk to Epstein investigators 'straining relations between UK and +America' +We also just got the following questions on the new MLA request. I have given preliminary responses +(as noted), but want to confirm with you. +1. +Has the witness consented to the release of the information requested? If so, please a copy of the written +consent. +The witness has not been asked for written consent. However, counsel for the witness has encouraged the prosecutors to seek +this information. In can be inferred from the statements of counsel that the witness has consented. +2. Which +did the witness apply to and what was the year of her application/attendance? +3. How, if at all does this request relate to/impact the material witness MLA request? +This request relates to the charged Maxwell case going to trial. The material witness MLA requests relates to a broader +investigation. +4. What were the sentences which applied at the date of the offences (1994 - 2004), as the penalties provided +with the request apply to conduct that occurred after 27 July 2006? +I will check with the case team to confirm specific periods. The sentences will be greater than one year and less than life (with +no death penalty involved), so is there a need to be more precise? + + +U.S. Department of Justice Attaché - London +United States Embassy +33 Nine Elms Lane +London SW11 7US +From: +To: +(USANYS) +Cd +America' +(CRM) +Sent: Thursday, August 12, 2021 9:03 AM +(CRM) +(CRM) + +Subject: FW: Independent: Prince Andrew: Refusal to talk to Epstein investigators 'straining relations between UK and +You guys have a moment for a brief call this morning? The Ambassador is concerned about the +attached story, and I wanted to see if you have any sense of where this is coming from. Is this coming +from victims' counsel? Anyone in your shop decided to push this? +The quote from the State Department yesterday in the NY Times was unhelpful (and I let them know +it - I think it came from someone spouting off on the European Desk). +I also had the following email from the UKCA yesterday: +We are aware that a civil case has been filed in New York concerning the Epstein investigation with +the material witness as the defendant. Please can you let us know what impact this has on the +material witness's current status, as a witness, in the criminal investigation and in relation to the MLA +request. +I think they are asking whether, in light of the recent allegations, Witness +is now a suspect instead +of a witness (in British parlance). I was going to respond with one word "none" but thought I should +check first. +I am around today whenever you can chat. The earlier the better because the Amb is keen to sort this +out. +Thanks, +U.S. Department of Justice Attaché - London +United States Embassy + + +33 Nine Elms Lane +London SW11 7US +From this morning's Independent +Fears issue over Duke of York could affect wider efforts to collaborate on high-profile legal cases. +US authorities are growing increasingly frustrated with Prince Andrew's failure to cooperate into their probe +into the network surrounding convicted sex offender Jeffrey Epstein, exacerbating tensions between +Washington and London, The Independent understands. +People familiar with authorities' investigations into Mr Epstein's business affairs told The Independent that the +lack of information-sharing had caused diplomatic strain, with US law enforcement and diplomats raising the +matter with their British counterparts. +They said a new civil case brought by +alleging the Duke of York had sexually abused her, will add +further strain over the issue, along with the prosecution of Esptein's former girlfriend Ghislaine Maxwell, who is +set to go on trial for sex trafficking charges later this year. +There are fears that the issue could sour broader efforts to collaborate on high profile legal cases. +The prince has consistently denied the allegations, while Ms Maxwell denies the charges against her. +The lack of cooperation now spans three years of reported attempts by the US authorities to gather facts from +the royal who, in a statement from 2019, said he would be willing to help US law-enforcement with +investigations. However, in January last year, Manhattan US attorney Geoffrey Berman said the country's +authorities had received "zero cooperation" from the prince, who no longer carries out royal duties. +In June 2020, The Wall Street Journal reported that an application had been made by the Department of Justice +(Do) under a US-UK mutual legal assistance treaty in order to win cooperation from the Duke of York. +This avenue has not been effective, according to sources. They contend that Prince Andrew has failed to share +details of the extent of his ties to Mr Epstein, whose death in a Manhattan prison in 2019 was ruled a suicide. +The extent and nature of Mr Epstein's financial network is still being explored in several jurisdictions, including +the US. +Of particular interest to the US authorities is how money transfers may be linked to the movement of young +women and girls. The various interested bodies, including the FBI, believe these may offer insights into ongoing +organised criminal operations. +These probes are significant not only for legal proceedings related to Epstein, but also to ongoing investigations +surrounding Ms Maxwell, who is currently in prison awaiting trial on sex-trafficking charges. +It is also alleged that multiple authorities are seeking details of flights that the Duke of York used to visit Epstein +in a range of locations, so that they can better understand how people may have travelled into and out of the + + +disgraced financier's orbit. The authorities' interests are understood to include multiple trips by the royal to +Epstein's Caribbean island, Little St James, as well as Florida and New York. +Last year, prosecutors in the US Virgin Islands, which includes Little St James, alleged Mr Epstein abused +hundreds of young women and girls up until 2018. +The frustration over the Duke of York's lack of cooperation is said to be amplified by the fact that it appears +unlikely that the royal would be extradited. His cooperation would therefore be a matter of bolstering +diplomatic relations and sharing any information which could help avoid future trafficking of young women and +girls. +The lawyer representing +has accused the prince, who is facing the Queen after arriving at Balmoral +on Tuesday, of "stonewalling" appeals for information after the 15-page lawsuit was filed in New York. The +prince is the only defendant in the suit, which alleges she was "lent out for sexual purposes" by Epstein. David +Boies said his client ultimately wanted "vindication" from the legal action. +In 2019, Prince Andrew told the BBC that he had not had sex with | +said that he had no recollection of having met her. +"It didn't happen," he said. He also diff --git a/vision-fixhub/ds9-parsed-01/1fdc3bfddfaddd24dd20ffc580ca59309bebd467689b278abf6469d8b101f589.receipt.json b/vision-fixhub/ds9-parsed-01/1fdc3bfddfaddd24dd20ffc580ca59309bebd467689b278abf6469d8b101f589.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..aaa611a4bff0d485f4efa225657320a7e0e68753 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/1fdc3bfddfaddd24dd20ffc580ca59309bebd467689b278abf6469d8b101f589.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -48, + "dataset": "marble-joined", + "doc_id": "1fdc3bfddfaddd24dd20ffc580ca59309bebd467689b278abf6469d8b101f589", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "954ef924a05c5f545a6c66132d21e3f9cbe653946be84a6b53a22ecd850a84a8", + "output_sha256": "62a28c248d2cec0967198bbe5b03c45c7f0405d2ef6fdd242d59990b1d8cebd9", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/203cbc80390afdce6ab18ea1b2341cb0b09156fe4d019e9cba57c9a320816f65.md b/vision-fixhub/ds9-parsed-01/203cbc80390afdce6ab18ea1b2341cb0b09156fe4d019e9cba57c9a320816f65.md new file mode 100644 index 0000000000000000000000000000000000000000..1ebb9f5b75d907166a43c073528a48381c9e0e29 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/203cbc80390afdce6ab18ea1b2341cb0b09156fe4d019e9cba57c9a320816f65.md @@ -0,0 +1,36 @@ +From: +Subject: +To: +Cc: +Sent: +All. +| (NY) (FBI) +C-20 request to assist with Maxwell case +NY-NADP +1. (NY) (FBI) +April 8, 2021 10:41 AM (UTC-04:00) +Squad C-20 advised that if you are able to assist on just one of the days that would also work. +assistance is greatly appreciated. +Any +Please let me know if you are able to assist on 4/13, 4/14 or 4/15 +Squad C-20 is requesting two or three agents to assist with Maxwell and her defense team reviewing +evidence at +from Tuesday April 13 through Thursday April 15. This will be from 9:00am +and continue for the entire day for all three days. AUSA +will be present as well for the +review. Please see below for additional info. +Maxwell and her defense team will all be present in the proffer room area on the 5th floor of the +courthouse for the primary review. This review will begin on April 13, 2021 and will continue +every day thereafter until the review is complete. The logistics for this review are as follows: +The Marshals will produce Maxwell to +each morning by approximately 9:30am. +Defense counsel are expected to arrive each morning at approximately 9:30am. We will need at least +one FBI agent with a handcuff key who is responsible for pulling Maxwell from the Marshal cellblock and +monitoring her (the same way an agent would monitor any proffering inmate at +J throughout the +day. Please note that an agent will likely need to escort Maxwell to the bathroom during the day as well. +has reserved three proffer rooms for this review: The largest will be where the FBI can +put the evidence for review. The second largest will be where the defense can meet privately, without +any of the evidence items, to confer among themselves. The smallest will be a break area available for +any agents and/or AUSAs who are not currently monitoring the evidence review or maintaining custody of +Maxwell. diff --git a/vision-fixhub/ds9-parsed-01/203cbc80390afdce6ab18ea1b2341cb0b09156fe4d019e9cba57c9a320816f65.receipt.json b/vision-fixhub/ds9-parsed-01/203cbc80390afdce6ab18ea1b2341cb0b09156fe4d019e9cba57c9a320816f65.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..153f72f308e08927ba2aaa2b46f63217d5c41787 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/203cbc80390afdce6ab18ea1b2341cb0b09156fe4d019e9cba57c9a320816f65.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "203cbc80390afdce6ab18ea1b2341cb0b09156fe4d019e9cba57c9a320816f65", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "054ec65a3055ef92b7a5607e840a6e0981582a2328a6642fc3404888b391db6b", + "output_sha256": "f434e94777a7b8a24384eeabb2d8a43532171e85bccaab465ff5782737c8578f", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/204647119b7c824594c3d4e334268d78c386cb6d3df28f44ecc3c0257fb94e25.md b/vision-fixhub/ds9-parsed-01/204647119b7c824594c3d4e334268d78c386cb6d3df28f44ecc3c0257fb94e25.md new file mode 100644 index 0000000000000000000000000000000000000000..9653551ae621de4691dd193903e53167a7f06083 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/204647119b7c824594c3d4e334268d78c386cb6d3df28f44ecc3c0257fb94e25.md @@ -0,0 +1,690 @@ +NYMDK 530.03* +PAGE 001 +A +T +BUREAU OF PRISONS COUNT SHEET +NEW YORK MCC +QTRG EQ **** +OCTG EQ **** +OUTCOUNT SECTION +• Zb +S +P +TR V +НОны +07-25-2019 +15:44:44 +COUNT +AREA +CENSUS +B-A +C-A +E-N +E-S +G-N +G-S +H-A +I-N +K-N +K-S +R-A +Z-A +Z-B +26 +10 +88 +85 +73 +91 +1 +92 +90 +138 +72 +5 +TOTAL 771 +COUNT +VERIFY +TU +N +T +1 +1 +1 +3 +3 +2 +1 +1 +2 +1 +1 +5 +8 +1 11 13 +XXX +OFFICIAL PREPARING COUNT: +OFFICIAL TAKING COUNT: +COUNT CLEARED TIME: +2 +1 +28 +VERIFY +COUNT +COUNT COUNT AREA +26 B-A +10 C-A +85 B-N +80 E-S +70 G-N +90 G-S +H-A +92 +I-N +88 +K-N +128 +K-S +R-A +70 +Z-A +4 +Z-B +743 +good wobol 4:44 + + +METROPOLITAN CORRECTIONAL CENTER +NEW YORK, MY +OFFICIAL OUT COUNT +7/25/19 +DATE: +FROM: +APPROVED: +COUNT TIME: +LOCATION: +400pm +F/s +(Staff Member Preparing Out Count) +(Operations Lieutenant) +REG # +NAME +UNIT +REG # +NAME + +Clar K +E-s 13. +79965-054 Thomas +2. 60685-050 +Dockers +14. +E-S +3. 51702-069 +Estradi +K-S +15. +16. +# 86535-054 tamara +K-S +5. 50659-018 +Kirk +E-S +17. +$ 85976-054 MaRtinez +.18. +KS +7. 86026-054 +Merchest Ks +19. +889673-053 +mersey +ES +20. +9. 86022-054 +10.08200-070 +Paizan d +K-s +ES +11.85927054 Romero +K-S +21. +22. +23. +24. 4 +1279652-054 Thomas +KV +UNIT +K-S +B-A +I-N +C-A +K-N +E-N +K-S +OUT-COUNT BUNIT +G-N +R-A +Z-A +G-S +Z-B +H-A * +Total Out-Counted: +13 +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected count. +Prepare this form in ink. Group the inmates according to their respective housing units. This form is to be used only as an +Out-Count. No other form will be accepted in lieu of the Out-Count Form. + + +NYMBU 530*05 * + +ASSIGNMENT: FS +OPER "CATG +ASSIGNMENT +OPER +INMATE ROSTER +CATG ASSIGNMENT +NUM ASSIGNMENT REG NO +NAME +0001 FS +68683-066 CLARK +0002 +0003 +60685-050 DOCKERY +51702-069 ESTRADA-RODRIGUEZ +0004 +0005 +86535-054 KAMARA +50659-018 KIRK +0006 +0007 +85976-054 MARTINEZ +86026-054 MERCHANT +0008 +89673-053 MERSEY +0009 +86022-054 REINGOUD +0010 +08200-070 RENE +0011 +85927-054 ROMERO-GRANADOS +0012 +79652-054 THOMAS +0013 +79965-054 THOMAS +* +07-25-2019 +14:41:42 +GROUP CODE: +FACILITY: NYM +OPER CATG ASSIGNMENT +OCT DATE +QTR +07-25-2019 B12-593U +07-25-2019 B07-549U +07-25-2019 K09-025U +07-25-2019 K11-053U +07-25-2019 E07-556U +07-25-2019 K09-0270 +07-25-2019 K1.2-061L +07-25-2019 E12-592U +07-25-2019 K12-078U +07-25-2019 B09-571U +07-25-2019 K10-045U +07-25-2019 K0B-074U +07-25-2019 K10-044L +WRK +ES PM +ES PM +ES PM +ES PM. +FS PM +FS PM +FS PM +ES PM +SUICIDE OR +ES PM +ES PM +LAUNDRY 1 +ES PM +ES PM +FS PM +G0000 + + +OFFICIAL OUT-COUNT FORM +New York, New York 10007 +Date: 07-25-2019 +From: +(Staff Member Supervising Inmates) +Count Time: +4:00 pm +Location: FNYE +Approved: +(Operations Lieutenant) +REG....... IN........EN....... +90325-053 +LOPEZ +LOUIS +B-A_ +_ C-A +H-A_ +, E-N +I-N_ +_ E-S_ +.K-N_1_ +_ G-N_ +K-S — +_R-A +QTR... +K03-118L +G-S _1_ +_Z-A— +. Z-B +Total Out-Counted: +1 +This Form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR +To The affected account. Prepare this form in ink. +Group the inmates according to their respective +housing units. This is to be used only as an Out Count. + + +NYMDK 530*05 * + +ASSIGNMENT: ENYE +•OPER CATG +ASSIGNMENT +OPER +NUM ASSIGNMENT REG NO +NAME +0001 ENYE +90325-053 LOPEZ +INMATE ROSTER +CATG ASSIGNMENT +* +07-25-2019 +15:40:48 +GROUP CODE: +FACILITY: NYM +OPER CATG ASSIGNMENT +OCT DATE +PIR +07-25-2019 K03-118L +WRK +UNIT 11N +UNIT 11NES +GO000 + + +UNITED STATES DEPARTMENT OF JUSTICE +FEDERAL BUREAU OF PRISONS +OFFICIAL OUT-COUNT FORM +Date: +07-25-2019 +From: +Count Time: 4:00 pm +Location: ENYS +(Staff Member Supervising Inmates) +Approved: +(Operations Lieutenant) +REG....... +76276-054 +06600-052 +79984-054 +64662-053 +79412-054 +86164-054 +75954-054 +85928-054 +86260-054 +79407-054 +79471-054 +LN.…... +CASTRO +WILLIAMS +GONZALEZ +ZUBIATE +MILLER +CAVE +GOSWAMI +DAVIS +MORA +BLADES +SCHULTE +FN.. +RICHARD +CURTIS +RICO +MIGUEL +RAHIEM +ETHAN +VIJAY +GARY +KEVIN +CHRISTAN +JOSHUA +QTR...... +E02-514U +E06-542L +E06-548L +G02-714L +G06-742U +G07-753L +K03-120L +K08-022U +K11-055U +Z02-203LAD +Z07-301LAD +B-A +_C-A +H-A _I-N_ +Total Out-Counted: 1L +E-N 3_E-S +_G-N 2 +- G-S 1 +K-N_ 1_K-S _2 +R-A +_Z-A _2 +Z-B +This Form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR +To The affected count. Prepare this form in ink. Group the inmates according to their respective housing +units. This is to be used only as an Out Count. + + +NYMDK 530*05* +INMATE ROSTER + +ASSIGNMENT: ENYS +•OPER CATG ASSIGNMENT +OPER CATG ASSIGNMENT +NUM ASSIGNMENT REG NO +NAME +0001 ENYS +79407-054 BLADES +0002 +76276-054 CASTRO +0003 +86164-054 CAVE +0004 +85928-054 DAVIS +0005 +79981-054 GONZALEZ +0006 +75954-054 GOSWAMI +0007 +79412-054 MILLER +0008 +86260-054 MORA +0009 +79471-054 SCHULTE +0010 +06600-052 WILLIAMS +0011 +64662-053 ZUBIATE +* +07-25-2019 +15:39:37 +GROUP CODE: +FACILITY: NYM +OPER CATG ASSIGNMENT +OCT DATE +QTR +WRK +07-25-2019 Z02-203LAD UNASSG +07-25-2019 E02-514U +UNASSG +07-25-2019 G07-753L +UNASSG +07-25-2019 K08-022U +EDUCATION +UNASSG +07-25-2019 E06-548L +UNASSG +07-25-2019 K03-120L +SUICIDE OR +UNASSG +07-25-2019 G06-742U +UNIT 7NES +07-25-2019 K11-055U +UNASSG +07-25-2019 Z07-301LAD UNASSG +07-25-2019 E06-542L +UNASSG +07-25-2019 G02-714L +UNASSG +GO000 + + +METROPOLITAN CORRECTIONAL CENTER +NEW YORK, NY +OFFICIAL OUT COUNT +DATE: +7-25-19 +FROM: +(Staff Member Preparing Out Count) +APPROVED: +¿Operations Lieutenant) +REG # +NAME, +UNIT +176318-054 Epstein H-A +290791-054 ElANSKY G-AC +378574-054 TArtASToNe LA +4. +5. +6. +7. +8. +9. +10. +11. +12. +B-A +I-N +COUNT TIME: +LOCATION: +400 Pm +Atty +REG # +NAME +UNIT +13. +- +14. +15. +16. +17. +18. +19. +20. +21. +22. +23. +24. +OUT-COUNT BY UNIT +E-S +G-N +R-A +Z-A +C-A +K-N +E-N +K-S +G-S +Z-B +H-A 1 +Total Out-Counted: +his form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected coun +repare this form in ink. Group the inmates according to their respective housing units. This form is to be used only as a +Out-Count. No other form will be accepted in lieu of the Out-Count Form. + + +NYMDK 530*05* + +ASSIGNMENT: ATTY +• OPER +CATG +ASSIGNMENT +OPER +NUM ASSIGNMENT REG NO +NAME, +0001 ATTY +90791-054 ELANSKY +0002 +76318-054 EPSTEIN +0003 +78514-054 TARTAGLIONE +INMATE ROSTER +CATG ASSIGNMENT +* +07-25-2019 +15:36:23 +GROUP CODE: +FACILITY: NYM +OPER CATG ASSIGNMENT +OCT DATE +OTR +WRK +07-25-2019 G01-703L +UNASSG +07-25-2019 H01-001L +UNASSG +07-25-2019 Z06-215UAD UNASSG +G0000 + + +Date +07765-19 +Time: +4o0m +Date +7/25/19 +Time: +4.00 +Unit: _ +Count: +Print Name: +Signature: +Print Name: +Signature. +Unit: +Count: +Print Name: +Signature: +Print Name: +Signature +Date: 1125/2019. +Time: 4:ФФm +Unit: +Count: +Print Name: +Signature: +Print Name: +Signature: +Unit: +GN +Date: 725/19 +Count: +70 +Time: +Print Name: +Signature: +Print Name: +Signature: +7/48/2019 +Time: +888 +_Date 1/2519 +Time: /pm +Count: - +Print Name: +Signature: +Print Name: +Signature +Unit:_ +Count: +Print Names +Signature: +Print Name! +Signature +Unit: +BAt +Count: .. +Print Name: +Signature: +Print Name: +Signature +Date. + +Time: +Date: 705 2019 +Time: +4.00pM +Count: +Print Name: +Signature: +Print Name: +Signature: +Unit: _ +IN +Date _ +Count: +92 +1/2519 +Print Name: +Signature: +Print Name: +Signature. + + +Unit: +Count: +Print Name: +Signature: +Print Name: +Signature +Time: +.C0p +Unit: +Count: +FfS, +Date: +Time: +112/2. +Print Name: +Signature: +Print Name: +Signature: +Unit: ZB. +Count: +Print Name: _ +Signature: +Print Name: +Signature +0 7=215 19 +A0o +Unit: FNAS +Count: +Print Name: +Signature: +Print Name: +Signature. +_ Date 1/25/19 +Time: +400рт. +2450 +Print Name: _ +Signature: +Print Name: +MCC NEW YORK +1/25/19 +Aime: 1108 pm +Unit: +Count: +Print Name: +Signature: +Print Name: +Signature: +Date: +7-25-17 +"Time: 4000M \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/204647119b7c824594c3d4e334268d78c386cb6d3df28f44ecc3c0257fb94e25.receipt.json b/vision-fixhub/ds9-parsed-01/204647119b7c824594c3d4e334268d78c386cb6d3df28f44ecc3c0257fb94e25.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..2938aa36db74da85b400d72ac308b2b961ecfed8 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/204647119b7c824594c3d4e334268d78c386cb6d3df28f44ecc3c0257fb94e25.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -1234, + "dataset": "marble-joined", + "doc_id": "204647119b7c824594c3d4e334268d78c386cb6d3df28f44ecc3c0257fb94e25", + "engine": "marble-apple-vision", + "event_count": 18, + "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "bba406c7e762c0fcc8784de5bd31cd6be4e0d8a2c2d0c4e860ec2a5d1981c6c1", + "output_sha256": "65840049787193e53c4bc96c55c0903b0cddb872dfe2362f678522dda492e2b2", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/204c381d55b36525d6f75652e161215a22fb9c2b1c36808467e95e088dbd9336.md b/vision-fixhub/ds9-parsed-01/204c381d55b36525d6f75652e161215a22fb9c2b1c36808467e95e088dbd9336.md new file mode 100644 index 0000000000000000000000000000000000000000..a2c580d4842b6f767742e4646ee3a6efe5a58a5e --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/204c381d55b36525d6f75652e161215a22fb9c2b1c36808467e95e088dbd9336.md @@ -0,0 +1,139 @@ +Bureau of Prisons +Health Services +Clinical Encounter +Inmate Name: EPSTEIN, JEFFREY EDWARD +Date of Birth: +01/20/1953 +Encounter Date: 08/10/2019 07:25 +Sex: +Provider: +M +Race: WHITE +RN +Reg#: 76318-054 +Facility: NYM +Unit: +Z04 +Emergency Code - Resuscitation Event encounter performed at Special Housing Unit. +SUBJECTIVE: +Emergency Note Provider: +Team Members: +Provider +RN +RN +Role +Team/Code Leader +Code Events: +Type +CPR +EKG/Monitor +Value +Compressions +Lifepak +Date +08/10/2019 06:35 +08/10/2019 06:39 +No shock advised +CPR +Oxygen +IV Access +Compressions +15 L +Peripheral IV +08/10/2019 06:40 +08/10/2019 06:47 +08/10/2019 06:48 +18 g Left AC +Airway +Medications +CPR +Medications +IV Fluids +Medications +CPR +Medications +Medications +CPR +Endotracheal Tube +ET Tube 7.5 24CM to L Lip line Placed by Paramedics +Epinephrine 1mg IV +Epinephrine 3 doses and Sodium bicarb 2 doses administered by paramedics +Compressions +Sodium Bicarbonate 1 mEa/kg IV +Normal Saline 0.9% 1000 ml +Epinephrine 1mg IV +Compressions +Sodium Bicarbonate 1 mEa/kg IV +Epinephrine 1mg IV +Compressions +08/10/2019 07:08 +08/10/2019 07:10 +08/10/2019 07:11 +08/10/2019 07:11 +08/10/2019 07:12 +08/10/2019 07:13 +08/10/2019 07:14 +08/10/2019 07:14 +08/10/2019 07:16 +08/10/2019 07:17 +Comments: +Responded to a body alarm at 0635 for medical emergency on 9S, Upon arrival Inmate was received on the floor of his +cell unresponsive with CPR in progress by correctional officers, Inmate was Cold, with circumferential Bruising around the +neck and posterior mottling, Pupils Fixed and dilated, No Palpable pulses, Call place for EMS, CPR Continued, AED +Placed No shock advised, CPR Continued, inmate transported to HSU treatment room with CPR in progress, 18g hep loc +o LAC, O2 15 Lt ViA BVM, Pulse Check NO SHOCK advised. EMS and Paramedics arrived 0656, Placed on cardia +monitor asystole Resumed CPR, Inmate was intubated by Medics, 3 Rounds of Epinephrine administered, Pulse Check +asystole, Inmate was transported to Local ER with CPR in progress. +OBJECTIVE: +Exam: +General +Appearance +Yes: Unconscious +Generated 08/10/2019 08:10 by Columbo, Joseph RN +Bureau of Prisons - NYM + + +SDNY_00008857 + + +Inmate Name: EPSTEIN, JEFFREY EDWARD +Date of Birth: +01/20/1953 +Encounter Date: 08/10/2019 07:25 +Exam: +ASSESSMENT: +Cardiac Arrest +PLAN: +New Consultation Requests: +Consultation/Procedure +Emergency Room +Subtype: +AMBULANCE +Reason for Request: +Cardiac arrest with CPR in progress +Copay Required: No +Cosign Required: Yes +Telephone/Verbal Order: No +Completed by +RN on 08/10/2019 08:10 +Requested to be cosigned by +MD. +Cosign documentation will be displayed on the following page. +Sex: +M Race: WHITE +Provider: +IRN +Reg#: 76318-054 +Facility: NYM +Unit: +Z04 +Target Date Scheduled Target Date Priority +08/10/2019 08/10/2019 +Emergent +Translator Language +No +Generated 08/10/2019 08:10 by Columbo, Joseph RN + +Bureau of Prisons - NYM + +SDNY_00008858 diff --git a/vision-fixhub/ds9-parsed-01/204c381d55b36525d6f75652e161215a22fb9c2b1c36808467e95e088dbd9336.receipt.json b/vision-fixhub/ds9-parsed-01/204c381d55b36525d6f75652e161215a22fb9c2b1c36808467e95e088dbd9336.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..ff3d946f7c912b88c9b8dd8d73a98932d68adc8e --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/204c381d55b36525d6f75652e161215a22fb9c2b1c36808467e95e088dbd9336.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -70, + "dataset": "marble-joined", + "doc_id": "204c381d55b36525d6f75652e161215a22fb9c2b1c36808467e95e088dbd9336", + "engine": "marble-apple-vision", + "event_count": 6, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "12e36f2eb8b5a5fdbdef572d969f63557ed9cbd9e7ec1a6e711ac4eb698ba3c1", + "output_sha256": "738da3d1f8b6071835b7e8170743937dbc47ad664ea86b1832edb964302da43f", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/209b2747d12114ccfc4a3d9a25dae9a858f7f8d0a1870bf264573289f7c41a31.md b/vision-fixhub/ds9-parsed-01/209b2747d12114ccfc4a3d9a25dae9a858f7f8d0a1870bf264573289f7c41a31.md new file mode 100644 index 0000000000000000000000000000000000000000..698c6cb621d2ba6cd6d822ed502e571192aae629 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/209b2747d12114ccfc4a3d9a25dae9a858f7f8d0a1870bf264573289f7c41a31.md @@ -0,0 +1,70 @@ +From: "Berman, Geoffrey (USANYS)" < +To: 1 +(USANYS) [Contractor]" +(USANYS)" 4 +Subject: Fwd: Private and Confidential +Date: Mon, 15 Jun 2020 20:14:43 +0000 +Begin forwarded message: +From: +Date: June 15, 2020 at 3:19:40 PM EDT +To: "Berman, Geoffrey (USANYS)" ‹ +Cc:/ +Subject: Private and Confidential +Good morning Mr. Berman, +As you might know, I was acquainted with Jeffrey Epstein and Ghislaine Maxwell for more than two decades. I also published +the first media series in the Daily Beast between 2010-2015 and then the first book, TrafficKING, (April 2016) on this child sex +trafficking case. +I mistakenly spoke to Judge Richard Berman awhile back +about the Epstein case. I forwarded him an email and +assuming he did not forward it to you. +Please could you explain why 15 years after the Florida +case was filed, 3 different DOJ administrations continue +to protect a suspected serial child molester, known +politely and for decades in his country, as "Randy Andy"? +Is it because of the special relationship with Great +Britain? +Secondly, as I discussed with DOJ officials during 3 +different administrations (George W.Bush, Barrack +Obama and Donald Trump), why would Justice continue +to grant procurers immunity from prosecution in different +states where crimes were perpetrated? +The procurers include: Ghislaine Maxwell, +In the US the sex crimes +were perpetrated in NY, NM, CA, and USVI. +It seems that after USAO somewhat successfully indicted +Epstein in 2019, almost 15 years after the first arrest, +USAO can also indict the procurers identified in the +complaints by named victims procured in NY. +Ghislaine Maxwell remains themost dangerous saria +procurer. Maxwell personally introduced +to Prince Andrew, organized their sex trips, etc. + + +In this instance according to my conversations with +and Mike Fisten and several depositions, +Epstein paid +for her services to Prince Andrew +when she was 17. Epstein, according to +did not +participate in those particular sex acts with Prince +Andrew. +With your permission Sir, I would like to include a quote +from you in my upcoming book. +Thank you for your time and consideration; and most of +all for shining a light on the most significant child +trafficking case in the US. A case that I risked my +life investigating beginning in 2010. +Breaking News: Epstein case. Daily Beast 6 part series (2010-2015) +https://www.thedailybeast.com/author +https://www.thedailybeast.com/jeffrey_epstein-billionaire-pedophile-goes-free?ref=author +https://www.thedailybeast.com/jeffrey-epstein-how-the-hedge-fund-mogul-pedophile-got-off-easy?ref=author +https://www.thedailybeast.com/exclusive-before-randy-andys-accuser-a-jane-doe-1?ref=author +TrafficKing, book about Epstein case published April 2016 +https://www.simonandschuster.com/books/TrafficKing + +Respectfully vours, +Executive Director +Alliance to Rescue Victims of Trafficking +ATRVT.ORG +Georgetown University +Senior Fellow diff --git a/vision-fixhub/ds9-parsed-01/209b2747d12114ccfc4a3d9a25dae9a858f7f8d0a1870bf264573289f7c41a31.receipt.json b/vision-fixhub/ds9-parsed-01/209b2747d12114ccfc4a3d9a25dae9a858f7f8d0a1870bf264573289f7c41a31.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..cd04b5e3e73d17f7c41fada204c2a57c0845fd46 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/209b2747d12114ccfc4a3d9a25dae9a858f7f8d0a1870bf264573289f7c41a31.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -38, + "dataset": "marble-joined", + "doc_id": "209b2747d12114ccfc4a3d9a25dae9a858f7f8d0a1870bf264573289f7c41a31", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "1e34a4ba6191b3d01a2e428f6f371138643a88bc53659115b91abf1f1d5eaa48", + "output_sha256": "7fc4a13208fa1e0d9954a5508a74818cbf3f973c3e3e6ed61e008760b688476b", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/20a86ccd55664af79203f64ea63c71b2c42d3a55475ce6435a3049ffa1c7bd02.md b/vision-fixhub/ds9-parsed-01/20a86ccd55664af79203f64ea63c71b2c42d3a55475ce6435a3049ffa1c7bd02.md new file mode 100644 index 0000000000000000000000000000000000000000..2e512727e0cfbfd8213ce2699c7f43c93c00b67c --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/20a86ccd55664af79203f64ea63c71b2c42d3a55475ce6435a3049ffa1c7bd02.md @@ -0,0 +1,51 @@ +From: +To: +Ce: +Subject: Re: +Motion +Date: Fri, 03 Apr 2020 19:39:47 +0000 +Sure. I have a 4:30p but imagine we will be finished up by then. Talk soon. +On Apr 3, 2020, at 3:37 PM, +Yes- I'll give you a call around 4 if that works, thanks. +From: +Sent: Friday, April 3, 2020 3:16 PM +To: +Cc: +Subject: Re: +Motion +Yes -I can speak in the next hour if it works for you all? +wrote: +On Apr 3, 2020, at 2:38 PM +wrote: +Hi are you available to discuss this? Let us know when would be convenient for you. Thanks very much. +From: Coyne, Sarah +Sent: Friday, April 3, 2020 12:16 PM +To: +Subject: +Motion +Hi +I hope this email finds you and your families safe and healthy. +As you also know, +has attempted to cooperate on a number of matters at the SDNY, including with the +investigation into the events surrounding Jeffrey Epstein's death. +In light of all these circumstances, I am going to be filing a motion to have +sentence reduced. I have +discussed this with EDNY AUSA +and provided her with a draft of the motion. It is my great hope that she +will join in it. +I am attaching here the portion of the motion that discusses her assistance to your investigation for two reasons. First, +I don't want to misrepresent/misstate any aspect of her assistance or characterize your position on it in any way that + + +you disagree with. Second, while I understand you might not feel a Rule 35 motion is merited, 1 am hoping you will +agree to advise the Court (or allow me to) that she did try to assist you. +Please let me know your thoughts. I am happy to discuss by phone, as well. +I should note that the motion will be filed under seal. +Stay safe, +Sarah +The information contained in this email message is intended only for use of the individual or entity named above. If the +reader of this message is not the intended recipient, or the employee or agent responsible to deliver it to the intended +recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly +prohibited. If you have received this communication in error, please immediately notify us by email, +, and destroy the original message. Thank you. +Provided Assistance Regarding Jeffrey Epstein Death_pdfs diff --git a/vision-fixhub/ds9-parsed-01/20a86ccd55664af79203f64ea63c71b2c42d3a55475ce6435a3049ffa1c7bd02.receipt.json b/vision-fixhub/ds9-parsed-01/20a86ccd55664af79203f64ea63c71b2c42d3a55475ce6435a3049ffa1c7bd02.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..d5532529da0e9fc94a3a23de97efbee33a63d516 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/20a86ccd55664af79203f64ea63c71b2c42d3a55475ce6435a3049ffa1c7bd02.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "20a86ccd55664af79203f64ea63c71b2c42d3a55475ce6435a3049ffa1c7bd02", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "55e6aa794089350f264cebcfcf0acd4f4cd598d851f74a97bda56f57413a041b", + "output_sha256": "794928a4198b9f515b1a437b09c1807a8fc0cb57ec77d6b933b4e490cf2c38c1", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/20aca3b83ef88805f0af668f305511e2ca09af5f85f9fbdc0e4169dfa96f3bc7.md b/vision-fixhub/ds9-parsed-01/20aca3b83ef88805f0af668f305511e2ca09af5f85f9fbdc0e4169dfa96f3bc7.md new file mode 100644 index 0000000000000000000000000000000000000000..5d54192a832e7bef4bd7431446b975a629c13288 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/20aca3b83ef88805f0af668f305511e2ca09af5f85f9fbdc0e4169dfa96f3bc7.md @@ -0,0 +1,139 @@ +From: Gloria Allred < +To: ' +Date: Wed, 14 Aug 2019 20:41:00 +0000 +Inline-Images: image001.png; image002 jpg +I have the answers to your questions. May I call you in one hour at 5:45 P.M. e.s.t.? +Gloria Allred +Allred, Maroko & Goldberg +Los Angeles, CA 90048 +www.amglaw.com +www.gloriaallred.com +Martindale-Hubbell* +PREEMINENT® +AV +Peer Rated for Highest Level +of Professional Excellence +2017 +ALLRED, MAROKO & GOLDBERG +2018 +RECOGNIZED BY +Best Lawyers +From: +Sent: Wednesday, August 14, 2019 9:58 AM +To: Gloria Allred < +Cc: +Gloria, +I meant to ask: is +_currently living in the Los Angeles area? +Thanks, +From: Gloria Allred < +Sent: Tuesday, August 13, 2019 10:56 PM +To: +Perfect. I will call you then. Should I reach you at the C +number? + + +Gloria Allred +Allred, Maroko & Goldberg +Los Angeles, CA 90048 +www.amglaw.com +www.gloriaallred.com +Martindale-Hubbell" +PREEMINENT® +AV +Peer Rated for Highest Level +of Professional Excellence +2017 +ALLRED, MAROKO & GOLDBE +2018 +RECOGNIZED BY +Best Lawyers +From: +Sent: Tuesday, August 13, 2019 7:37 PM +To: Gloria Allred ‹ +Cc: +Subject: Re: August 19th +Thanks — I'm free tomorrow at 12:30 EST/ 9:30 am PST if that works. +Sent from my iPhone +On Aug 13, 2019, at 7:11 PM, Gloria Allred < +> wrote: +Tomorrow morning pacific is fine. What is best for you and which number should I call? +Get Outlook for Android +On Tue, Aug 13, 2019 at 11:32 AM -0700, +Hi Gloria, +Thanks for reaching out. Do you have time to discuss briefly either today or tomorrow? +Thanks, +> wrote: +From: Gloria Allred < +Sent: Monday, August 12, 2019 10:36 PM +To: +1›; Diane Aldrich ‹ + + +Good news. Another one of my clients who is an Epstein victim has agreed to fly to New York to meet with you on +August 19 in the afternoon. Is that time period still available? If so what time would work for you? I do have her +driver's license and I know she would like to fly with me on the Delta flight that I am taking on Sunday from L.A. to +New York. If you will have time to meet with her your federal agent who handles travel may contact my assistant, +Diane , tomorrow to arrange the details of my client's trip. +Gloria Allred +Allred, Maroko & Goldberg +Los Angeles, CA 90048 +www.amglaw.com +www.gloriaallred.com + + +From: +Sent: Friday, August 9, 2019 8:22 AM +To: Gloria Allred < +Cc: +Thanks for letting us know. We understand that coming forward is a difficult decision, and we respect that. +From: Gloria Allred < +Sent: Friday, August 9, 2019 11:17 AM +To: +Cc: +Unfortunately, at this point, she has decided that she does not wish to meet with you. I will let you know if she +changes her mind. Thank you for having followed up on this matter. +Gloria Allred +Allred, Maroko & Goldberg +Los Angeles, CA 90048 +www.amglaw.com +www.gloriaallred.com + + +From: +Sent: Friday, August 9, 2019 8:10 AM +To: Gloria Allred ‹l +Cc: + + +Subject: August 19th +Hi Gloria, +Hop you're doing well. I wanted to follow up on scheduling to see if August 19th at 2 p.m. still works to meet with you +and vour client at our office. We're happy to be flexible on timing if you need to make other arrangements. +Thanks, +Assistant United States Attorney +Southern District of New York +New York, NY 10007 +This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the +addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED +THIS COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER +This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the +addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED +THIS COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER +NAMED ABOVE AT I +1. Thank you. +This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the +addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS +COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER NAMED +ABOVE AT +• Thank you. +This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the +addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS +COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER NAMED +ABOVE AT I +- Thank you. +This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the +addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS +COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER NAMED +ABOVE AT I +• Thank you. \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/20aca3b83ef88805f0af668f305511e2ca09af5f85f9fbdc0e4169dfa96f3bc7.receipt.json b/vision-fixhub/ds9-parsed-01/20aca3b83ef88805f0af668f305511e2ca09af5f85f9fbdc0e4169dfa96f3bc7.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..6350e73cf8e57a501cc8b33bd40139f09f0b162c --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/20aca3b83ef88805f0af668f305511e2ca09af5f85f9fbdc0e4169dfa96f3bc7.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -199, + "dataset": "marble-joined", + "doc_id": "20aca3b83ef88805f0af668f305511e2ca09af5f85f9fbdc0e4169dfa96f3bc7", + "engine": "marble-apple-vision", + "event_count": 5, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "7d097140bf856061d69d526c10e2916309d391569387bb8767ced6a1f4086b1d", + "output_sha256": "917e337fc7dc7a6503772c53bbebdde68e1e4d53bd99f77ef889c5605b9c6c26", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/20bb7d55bcd4369f5deb1f95730318c9d975aa68e2f36efb738bd3debe2a1778.md b/vision-fixhub/ds9-parsed-01/20bb7d55bcd4369f5deb1f95730318c9d975aa68e2f36efb738bd3debe2a1778.md new file mode 100644 index 0000000000000000000000000000000000000000..8e009aebdd82da4cdeee2b54d635a809cf96a533 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/20bb7d55bcd4369f5deb1f95730318c9d975aa68e2f36efb738bd3debe2a1778.md @@ -0,0 +1,19 @@ +From: " +To: " +Cc: "Strauss, Audrey ( +D" +Subject: Epstein OIG/FBI--Document Preservation +Date: Mon, 12 Aug 2019 15:34:33 +0000 +, "Berman, Geoffrey ( +Please forward this to everyone who might have any documents relating to the Epstein suicide, and co me: +Please make sure to preserve any documents you may have relating to Epstein's conditions of confinement. +• Your emails will be adequately preserved, for present purposes, by the regular three-year backup. But let +me know if you have any or not. +• If you have any hard-copy notes, please scan them and send them to me. If you have none, let me know +that too. +• Most particularly, please check to see if you have texted anything pertinent. If so let me know, one way +or the other. If you do have anything, we'll figure out how to preserve that. +Associate U.S. Attorney +United States Attorney's Office +Southern District of New York +New York, NY 10007 diff --git a/vision-fixhub/ds9-parsed-01/20bb7d55bcd4369f5deb1f95730318c9d975aa68e2f36efb738bd3debe2a1778.receipt.json b/vision-fixhub/ds9-parsed-01/20bb7d55bcd4369f5deb1f95730318c9d975aa68e2f36efb738bd3debe2a1778.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..268d9ee52120b947fa0a41acdcb8bd2576949cc6 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/20bb7d55bcd4369f5deb1f95730318c9d975aa68e2f36efb738bd3debe2a1778.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "20bb7d55bcd4369f5deb1f95730318c9d975aa68e2f36efb738bd3debe2a1778", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "9cb60edbbbf5069ae4a5f04b2a8f6b67bd32a047649bc408dbbc40fddd70f4a0", + "output_sha256": "d2550a9dd9a465904e7cfada71386debdb63ea73cbcaa7b3d3f556879ef4fb20", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/20cac8245eddb16c860698b48326f95d0bda574befe40f91e4128d143541aa9e.md b/vision-fixhub/ds9-parsed-01/20cac8245eddb16c860698b48326f95d0bda574befe40f91e4128d143541aa9e.md new file mode 100644 index 0000000000000000000000000000000000000000..9a6faf68607a5f75a420032e2a3f32118410d34b --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/20cac8245eddb16c860698b48326f95d0bda574befe40f91e4128d143541aa9e.md @@ -0,0 +1,20 @@ +From: " +To: " +USAND +Cc: " +Subject: FW: USA v. Epstein, 19-cr-490 +Date: Mon, 08 Jul 2019 14:39:42 +0000 +Importance: Normal +Inline-Images: ATT00001.jpg +USANYS) I +Hey guys, can you please clarify below? The presentment/arraignment will happen this morning???? +From +Sent: Monday, July 8, 2019 10:33 AM +Subject: USA v. Epstein, 19-cr-490 +There will be two proceedings in regards to the above-mentioned matter today, July 8, 2019. +The first will occur this morning in courtroom 23B of the Daniel Patrick Moynihan Courthouse; the Hon. Henry B. Pitman presiding. +The second will occur after in courtroom 17B of the Daniel Patrick Moynihan Courthouse; the Hon. Richard M. Berman presiding. +Seating is available on a first-come, first-seated basis. +Zachary Stern +District Court Executive Office +U.S. District Court/ SDNY diff --git a/vision-fixhub/ds9-parsed-01/20cac8245eddb16c860698b48326f95d0bda574befe40f91e4128d143541aa9e.receipt.json b/vision-fixhub/ds9-parsed-01/20cac8245eddb16c860698b48326f95d0bda574befe40f91e4128d143541aa9e.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..53e5e22e13f983372c5dd1ae0589412e27e991f4 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/20cac8245eddb16c860698b48326f95d0bda574befe40f91e4128d143541aa9e.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "20cac8245eddb16c860698b48326f95d0bda574befe40f91e4128d143541aa9e", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "6bd81dc5e0a9b62074ef6b7c7795a7f9722b29c04bee8a3f6743b4f5e9b693d7", + "output_sha256": "a3caffae21b26493ce24820784009153fad4018c560d8e6ebae2096b161d7e7e", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/20e4cf427ac26ac9b109875fbb919c52722136c3df8544244fc794292064f9a3.md b/vision-fixhub/ds9-parsed-01/20e4cf427ac26ac9b109875fbb919c52722136c3df8544244fc794292064f9a3.md new file mode 100644 index 0000000000000000000000000000000000000000..bf93fbda8d57cf7df0c3fe254ea7d63a3606b103 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/20e4cf427ac26ac9b109875fbb919c52722136c3df8544244fc794292064f9a3.md @@ -0,0 +1,8251 @@ +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +DIGITALLY RECORDED +SWORN STATEMENT +OF +OIG CASE #: +2019-010614 +DEPARTMENT OF JUSTICE +OFFICE OF THE INSPECTOR GENERAL +OCTOBER 27, 2021 +RESOLUTE DOCUMENTATION SERVICES +28632 Roadside Drive, Suite 285 +Agoura Hills, CA 91301 +Phone: +(818) 431-5800 + + +1 +APPEARANCES: +2 +3 +4 +5 +6 +7 +8 +WITNESS: +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +2 +OFFICE OF THE INSPECTOR GENERAL +BY: +BY: +OTHER APPEARANCES: +NONE + + +3 +1 +2 +3 +4 +5 +6 +7 +8 +1: My name is +I'm a Special Agent with the U.S. Department of +Justice, Office of the Inspector General, New +York Field Office, and these are my +credentials. +MS. I +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +1: okay. +: This interview with the +Federal Bureau of Prisons psychologist, Dr. +Did I get that right? +: Is being conducted as part of +an official U.S. Department of Justice, Office +of the Inspector General investigation. +Today's date is October 27, 2021. And the time +is 9:20 a.m. This interview is being conducted +at the OIG, New York Field Officer located on +the 29th floor of One Battery Park Plaza, New +York, New York. Also present is: +: DOJ/OIG Senior Special +Agent +And these are my +credentials. Oops. Here you go. +: This interview will be +recorded by me, Special Agent +Could everyone please identify themselves for +the record, and spell your last name? To + + +1 +2 +3 +4 +start, ( +again, I am DOJ/OIG Special Agent +My name is DOJ/OIG Senior +Special Agent +4 +6 +7 +8 +yourself. +1: Dr. +please introduce +: Yeah. So, my name is Dr. +• I am the chief psychologist at +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +MCC New York. +: Thank you. +: And your last name. Can +you just spell that - +: Yes. +-- for the record? +: I'm sorry about that. +Thank you. +: This is an official DOJ/OIG +investigation into the death of inmate Jeffrey +Epstein. And you are being asked to +voluntarily provide answers to our questions. +Will you agree to a voluntary interview with +the DOJ/OIG? + + +5 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: Thank you. +I'm going to +provide you with the OIG form III-226/2. It +states the following, "United States Department +of Justice, Office of the Inspector General. +Warnings and Assurances to Employee Requested +to Provided Information on a Voluntary Basis. +You are being asked to provide information as +part of an investigation being conducted by the +Office of the Inspector General. This +investigation is being conducted pursuant to +the Inspector General Act of 1978, as amended. +This investigation pertains to job +performance failure, +and security failure. +This is a voluntary interview. Accordingly, +you do not have to answer any questions. No +disciplinary action will be taken against you +if you choose not to answer any questions. Any +statement you furnish may be used as evidence +in any future criminal proceedings, or agency +disciplinary proceeding, or both." The waiver +states, "I understand the warnings and +assurance stated above, and I am willing to +make a statement and answer questions. +No promises or threats have been made to +me, and no pressure or coercion of any kind has + + +6 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +been used against me." +Please review it. And +if you agree, can you please sign where it +says, "Employee Signature"? Also, print your +name right below that. +Please. +1: Mm-hmm. +: Thank you. Thank you. I am +signing on the signature of the Office of +Inspector General, Special Agent. +Okay. And I will - +: Agent -. +- sign as the witness, +and place the date, and time, and place on +there. On the form. +oath. +1: Thank you. Before starting +the interview, I would like to place you under +- te +• can you please +raise your right hand? Do you swear to tell +the truth and nothing but the truth during this +interview? +1: Thank you. Please let me +know if you did not understand any questions, + + +7 +1 +2 +and I will try to repeat it, or try to rephrase +it for you. What is your current home address? +3 +1: +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +of birth? +: Okay. And what is your date +1 l +: Actually, you showed us your +ID. Can you show that one more time? I just +want to -- +: Yes. +1: -- Dr. +has provided me +with the U.S. Department of Justice law +enforcement officer ID, and it has her picture +on it, and her signature. Thank you. What is +your current cell phone number? +: Thank you. Do you recall +being interviewed by the FBI and the OIG in +August 2019, regarding inmate Jeffrey Epstein? +1: Yes, I do. +1: What I have here is called +the FBI 302. It's their report of the +investigation. It's a summary of your +statements that you made in the interview with + + +8 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +them. I'm going to go -. I'm going to read it +out to you. Please let me know if there is any +discrepancies, or you feel that anything is +inaccurate, and we will correct it. +1: okay. +1: On the record. Anything else +before we start? +: Nope. +"Dr. +date of birth:_ +was interviewed at 1 +Saint Andrews Plaza, New York, New York, 10007. +U.S. Attorney's Office. Southern District of +New York. Present at the interview was the +Office of Inspector General, Special Agent +: Assistant U.S. Attorney +(Phonetic Sp. *00:04:54), +and FBI Special Agent +After being advised of the identity of the +interviewing agents, and the nature of the +interview, Dr. +provided the following +statement. +Dr. L +is the chief +psychologist at the Metropolitan Correctional +Center +(MCC). Her background includes a +bachelor's degree in criminology, a master's in +mental health counseling, a master's in + + +9 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +clinical counseling, and a doctorate." What is +the doctorate in? +: Oh. The second master's is +in clinical psychology, not counseling +psychology. And the doctorate is in clinical +psychology. +1: Okay. Thank you for +clarifying that. "Dr. +was the staff +psychologist at East Jersey State Prison for +two years. +*00:05:33) And she completed a oneyear post-doctoral fellowship and internship +working at an in and out - in/outpatient mental +health treatment center. And she did that +externship at Federal Detention Center in +Miami, working with the battered woman' s +program." +Is that accurate? Go ahead. +: Okay. My post-doc was at a +private forensic practice, forensic psychology +practice. The Institution for Behavioral +Sciences in the Law. That was my post-doctoral +internship. My internship was at the +University of Miami. Jackson Memorial Medical +Center. That's where I did inpatient and +outpatient rotations, with a minor in +forensics. +And my externship, when I was in + + +10 +1 +2 +doctoral program, +was at the Federal Detention +Center in Miami. +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +1: Thank you. +1: Sure. +: "Dr. +worked as a staff +psychologist at the Metropolitan Detention +Center, MDC Brooklyn, from 2003 to 2006." +_: Mm-hmm. +: "And as a forensic +psychologist from 2006 to 2008." +: Correct. +1: "Dr. +chief psychologist at MCC for the last 11 +has been the +years." +: Well, now, more. Probably +close to 13. +1: 13. +1: More than 13, probably. +: So, that is still your role +at the MCC? +MS. Uh-huh. Yes. And now that +it's closed. You know -- + + +11 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: - I'm no longer the chief +psychologist there. But up until a day ago, +yes. +Okay. And so, what is the +new role with the -? +1: Well, I am awaiting a +position, likely in central office. +: Okay. And what, do you know +what your role would be? What your title would +be? +: A mental health treatment +coordinator. But it's going through the +paperwork right now. So, it hasn't, you know, +I haven't received official notification -- +1: -- as of yet. +1: Then -. +Will you be able to stay +in New York? +MS. I +: Yes. +: Okay. +Great. +1: But I am doing my IDY work +right now, at Fort Dix. In New Jersey. +- +: So, I am just seeing a 1ot of + + +12 +1 +2 +3 +4 +5 +patients over there now. +: Anything else on that? +Hmm-mm. +oversees three +1: "Dr. +forensic psychologists." This is talking about +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +the time period when you were interviewed. +I guess, before we do, I +don't think it said. When did you first start +working with the BOP? When was your enter on +duty? +1: In 2003. +okay. +Great. Thank you. +1: "Dr. +oversees three +forensic psychologists, one staff psychologist, +a drug abuse coordinator, and a drug treatment +specialist. Her duties include ensuring all +patients are seen, and the appropriate +documentation is completed. She consults on +individual cases, as needed. She ensures the +forensic reports are out on time. She reviews +all the reports she signs off on. At this +time, Dr. +is seeing patients, is seeing +more patients than she normally does, due to +staffing. Her typical hours are 7:00 a.m. to + + +13 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +3:30 p.m. Monday to Friday." +I: Okay. +1: "Dr. +provided +information on the intake process as it relates +to psychological services at MCC. All inmates +complete the psychological services intake +questionnaire" - that's PSIQ - "themselves. It +asks for the inmates mental health history, as +well as any symptoms they are feeling at the +time. Based off the PSIQ, inmates are rated a +care code reading." +1: Okay. First, we interview +them. What we do is, we review the PSIQs once +they are filled out. If significant items are +marked, we will interview the inmate. After we +complete the intake screening, we will classify +them with a care code. And that will determine +how frequently the inmate will be seen. +: Okay. I think it goes into +the codes itself. +: oh, okay. All right. +: "Code one means there are no +concerns about the inmate's mental health +status. They have no needs and will not be +followed up with, unless requested to, by + + +14 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +either the inmate themselves, or staff." +1: okay. +: "Code two means there is some +history of mental health issues, but the inmate +has them under control. Psychological services +will follow up with these individuals monthly." +: "Code three are more severe +cases, and they are seen every week by +psychological services, +to ensure the inmate is +stable. If the inmate isn't stable in general +population, they will be moved to observation. +If they continue to deteriorate, they will go +to the hospital." +: We will try to send them to a +BOP medical center. Or we will try to +stabilize them in the facility. We have a +psychiatrist who is actually, he is a central +office psychiatrist, but he was actually +located at MCC New York. So, if they started +to decompensate the interview, and they were +that acute, we would have the psychiatrist see +them, and potentially medicate them, and try to +stabilize them at our facility. If we cannot +do so, then we will try to do an emergency, + + +15 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +what is called a 770, and have them designated +to one of our medical centers for +stabilization. We don't have a contract with +the hospital here in New York. +: I don't know if you - what's +- what decompensating means? +1: Oh, that means that their +symptoms become more acute, their mental health +functioning is deteriorating to the point where +they display evidence of either severe mood +symptoms, like acute mania, or psychosis, where +they are actively hallucinating, or have +delusions. Or maybe they just stopped taking +care of ADLs, as well. +: And that would cause harm to +them. Because of their illness. +1: Thank you. +that? +Okay. +1: Do you have any questions on +Okay. "Code four inmates are seen every +day by psychological services, and are under +constant psychological observation." +1: Mm-hmm. +- +1: "Dr. +pointed out that + + +16 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +a code one can be on suicide watch. Often +times, those cases involve manipulation +techniques used by inmates to get what they +want from staff. For example, if an inmate is +not getting along with the guard, or they want +a new cellmate, they will claim to be suicidal +to get out of their housing area. If an inmate +does this two or three times, they will be +bumped to a code two, so that a psychologist +will meet with them monthly. Suicide watch +means an inmate is eminently suicidal. If an +inmate is placed on suicide watch, they are +under constant watch by staff. They have a +special mattress, blanket, and smock to wear. +And their cell lights are on 24/7." +: Correct. +: "Suicide observation is a +lower classification." +: Psychological observation. +: Correction. "Psychological +observation is a lower classification. +It is +not at all Bureau of Prisons facilities. +Everything is the same with suicide observation +inmates - psychological observation inmates, +except that they are allowed to have their + + +17 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +clothing, and some materials, such as books. +Suicide watch can be detrimental if a person is +left on it for too long. So, observation is +used to see how an inmate is doing before +releasing them back to general population." +1: Correct. So, psychological +observation, they are observed constantly, with +regard to what they have, they can obtain. +They can have those things that you listed. +But we have to determine, +and sometimes it +might be one thing at a time. Like, we might +give them their underwear, and see how they do +with that. And then, we will, you know, give +them a book. But it's not like once you get +stopped down, you get all of those items. +1: okay. +: Okay. It's determined by a +psychologist, and it is notated on their +logbook, what they can and cannot have. +: Okay. "Any psychologist at +jail can take an inmate off suicide watch, but +they do consult with Dr. +on occasion. +Many times, the executive staff at the jail +meet, and inmate psychological status and +services are discussed." + + +18 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: Can you explain to us a +little bit more about the meeting? What +exactly is discussed? +So, we have, like, +Mondays, we have an opening meeting, and +Fridays, we have a close out meeting. And +Tuesdays, the days may have changed from then +to now. I think it used to be Thursdays, used +to be a SHU meeting. And so, certain members, +all the members of the executive staff are +there. And then, certain department heads +attend these meetings. And during the +meetings, they will ask me, you know, is there +anything for psychology. +And then, I will discuss the inmates that +are on suicide watch. And what my plans is for +those inmates. Or if we were discussing the +Special Housing Unit, I'll discuss inmates that +I feel need to be observed closely. Should +have cellmates. Or may suffer from mental +health problems that I feel we just need to +keep an eye on, or make sure they are in more +visible, highly visible cells. Any mental +health concern I have in the SHU, I would + + +19 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +mention at the SHU meeting. +: Okay. Anything else? +Yeah. I mean, do they +have input into psychology? Like, does the +executive staff, do they get to provide +recommendations, or ask, you know, can this +person be taken off, or this person taken off, +or this person taken on, or is it -? +: Well, we make the decisions +as far as, we're the only ones that make the +decisions whether someone goes on watch, or off +watch. +Right. +: They may, you know, not agree +or whatever, but that's our decision because +that is our profession. +: But with regard to the +logistics in the prison, and how, where the +inmates are housed, and things like that. We +will make suggestions to executive staff. +: okay. +1: A lot of times - and most of +the time - they do listen to psychology. There +may be times they disagree for maybe + + +20 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +correctional reasons that, you know, they may +have their own ways of viewing where they +housed someone. Maybe therey will be an inmate +up there, or too many that they are separated +from, or maybe they are a gang member. I mean, +there may be other reasons why they can't +follow our recommendations. +And so, there might be exceptions to that +rule. So, now, pretty much what we do is, if, +like, let's say we have to house somebody alone +in SHU. We have to - we put whether we +recommend or not recommend. Now, we do that. +And I never recommend an inmate be single +celled. Ever. So, if they decide, that's on +them. And usually, it's because an inmate may +be too violent, or may be Indiscernible +*00:15:59 sept out from all other inmates in +the facility because they are so, in all these +gangs, and they are cooperating. +And there is just too many bloods, let's +say, and there are blood, and they may have to +be by themselves, or they may have assaulted +other inmates, or officers, and they just can't +be celled with somebody. For whatever reason. +Or the U.S. Attorney's Office has said this + + +21 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +person needs to be by themselves. +We're afraid +for their life, at that facility. So, I'm +never going to recommend somebody be by +themselves because +it's never a good idea. But +there might be extenuating circumstances where +someone needs to be housed alone, and in that +case, you know, we would recommend an increase +rounds, or, you know, keeping an eye on that +inmate. +: Now, as far as I +understand, what you are talking about with-is +when they come off of psychological observation +or suicide watch, but when they actually go in +and come off of both suicide watch and +psychological observation, do they get to +provide an input into that, or is that solely a +psychology issue? +: Whether they come off? +1: Go in or come off. +: No. Just a psychology. +: Okay. So, they don't +have any input into that? +: No. +okay. +: I mean, they may make some + + +1 +2 +3 +4 +5 +6 +7 +8 +statements, but if we don't agree, - +Yeah, that's your -- +: -- those decisions are up to +uS. +22 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Okay. +: Thank you. +: Just a question, as a follow +up. You said that sometimes you might make +recommendations on housing an inmate by +themselves, based on a threat or whatever it +is. So, my understanding, based on that +statement, is that means every inmate is housed +with a cellmate, unless specifically +recommended by psychology, that they be housed +by themselves? +: Never by psychology. +: Yeah. +: Psychology -- +That's (Indiscernible +*00:17:38). +: -- is always going to +recommend. +1: +Recommend. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +1: A cellmate. +But there might +be custodial issues. +1: Okay• +: Which preclude them from +being housed with another inmate. +1: So, any inmates that has a +history of possibly havinge suicide watch, or +any, or psychological observation, psychology +recommends that they be - recommends that they +be housed with a cellmate. +: Yes. +Okay. +Now, psychology - +- always they be housed +with a cellmate. +It's the custody may say +that they don't want them with a single cell. +: Got it. +Correct? +: Correct. +1: Thank you. +"Meetings are +held on Mondays, Thursdays, and Fridays. +Generally present at those meetings are Dr. +, the warden, two associate wardens, the +23 + + +1 +2 +captain, supervisory attorney, duty officer, +and the executive assistant. Department head +3 +4 +5 +6 +7 +8 +meetings are held on Wednesdays. Dr. L. +(Phonetic Sp. *00:18:27)?" +7: Mm-hmm. +•: "Completed the PSIQ for +Jeffrey Epstein on July 8, 2019. Epstein did +not mark anything on his PSIQ. And had it not +been Epstein, he would have been sent to +general population, and rated a care code one. +Dr. +consulted with Dr. +about Epstein's risk factors, aside from his +psychological health, including high-profile +case and sex offense charges." Who is Dr. +24 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: He was the suicide prevention +coordinator in central office. Now, he has +been moved up to a higher position, but he is +in central office, +and he called me right away, +when Epstein came, because of his risk factors. +We call those static risk factors. Those are +risk factors for suicidality that can't be +changed. So, in other words, if you come in +and you are a sex offender, and you are highprofile, like Jeffrey Epstein was, that is + + +25 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +going to take place throughout his +incarceration. +It is not like he would just come in +depressed; we could give him medication; he +could get better. Those factors would always +be there. So, you know, he was concerned. +Also, when he came to the facility, that we +should keep, you know, a close eye on him. +And, you know, he was reviewing our notes and +everything, from afar. So, he did call us when +he was placed on watch and everything, and he +oversaw. +1: Okay• +So, he has access to your +notes? Does that go into some kind of a +database? +: Yes. The psychology data +system. +okay. +: I don't know if he reviewed +the notes, but he called -. I'm trying to +remember. +I remember him calling me and just +being in touch with me. You know, is +everything okay? And, you know, making sure we +assessed certain things. + + +26 +1 +2 +3 +4 +5 +6 +7 +8 +okay. So, all throughout +Epstein's stay, he was kind of reviewing your +notes, and - +1: Uh-huh. +-- his status. +1: Or calling me and checking +in. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +And who would have access +to that database, in those notes? +: All the psychologists in the +department. Central office personnel would +have access to it. Other psychologists at +other institutions +can access the notes +because, let's say he was transferred to +another facility, and they wanted to see his +notes from the BOP. They would have access. +: Okay. And when you say +central office, you're talking about just +psychology central office, or do you mean +everyone that is -? +: Yeah. +So, only -- +_: Psychology. +- only psychology -- +1: As far as -- + + +27 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +-- personnel. +-- I know. Yes. +Okay. So, no one outside +of psychology? +1: Not that I know of. +: Okay. +: Because I don't work up +there. But I wouldn't think so. +Great. +: Okay. +: You might have stated +already. I might have missed it. +_: Okay. +: Did Dr. +make any +recommendations to you? Regarding Mr. Epstein. +: No. Just to keep a close eye +on, when I put him on watch. He just called +and just, he asked me various questions on how +he was doing, and everything like that. So, he +just wanted to make us aware that, you know, he +was very high-profile. I mean, obviously, we +knew that. But, you know, also to keep an eye +on him, and to keep us alert to his risk +factors. +: Okay. "When Epstein returned + + +28 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +from court that day, Dr. +ordered he be +placed on watch status, to allow psychology to +make a complete - to complete a thorough +suicide risk assessment." +Is that correct? +: And that was on -- +: And that was precautionary. +: - okay. +: Because of his risk factors. +I wanted him assessed. So, I remember he was +placed on watch, and he was waiting for me to +come in and do his interview. And, you know, I +came into the watch area, and he was, like, are +you Dr. +? And he's, like, get me out of +here. You know? Because he didn't endorse +anything. He didn't say he was suicidal. He +had just come from court, and he was just +waiting to come off of watch because, you know, +watch is very depriving, like we said, you +can't have anything there. +Like, not even clothes. It's just -. You +know, so, for him to be put in that situation. +He was really unhappy about it. And then, you +know, I explained, it was for his safety, and + + +29 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +precautionary, and I just wanted to make sure +he was, he would be celled appropriately, and +that he was okay. So, it wasn't that he had +endorsed anything, or said he was suicidal. It +was strictly precautionary. +: And that was -- +: When he first came in. +- yeah. That was July +8th, 20193 +: Yes. +Just -- +-- for the record. Okay. +: "Dr. +completed the +suicide risk assessment the next day. Epstein +was angry he was placed on observation, but he +continued to report no history of -" +• suicidealy? +: Suicidality. +Yeah. Yeah. +: Suicidality. "No substance +abuse. No major medical concerns. And no +overt risk factors. +Epstein was polite, but +annoyed with Dr. | +• " +MS. I +True. +menareln nas kope in + + +30 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +observation, pending a suitable housing +placement, given his risk factors of being an +alleged sex offender. High-profile, and having +one living brother relative. +She quoted +Epstein as saying, 'Being alive is fun.' Dr. +believed it was a genuine statement." +Is that accurate? +1: A what? +1: A genuine -- +Genuine. +: —- genuine statement. +: Yeah. +: Okay. +"Dr. +provided +the interviewing agents with a copy of the +suicide risk assessment, which was placed into +this case as reference three. On July 10th, +2019, Dr. +met with Epstein in +observation. Epstein was still in observation, +due to housing concerns. +He continued to be +psychologically stable at that time. Epstein +was aware, even if he got bail, he would be at +MCC for several more weeks." That statement, +"Epstein was aware even if he got bail." Was +your understanding that he was going to get +bail? + + +31 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: If I recall, I remember he +was hopeful. Now, I don't have my notes in +front of me, so I don't want to swear to what +was in each note -- +1: Yeah. +1: -- because when I don't have +them in front of me, but from my recollection, +yes, he was hopeful that, you know, he would be +able to get out of jail. +1: okay. +So, based on -- +: At that time. +: -- your conversations with +him, he was expecting - hopeful - to get bail - +- +1: -- from being -. Okay. +"Epstein made several demands and voiced many +complaints to Dr. +, which she passed onto +executive staff." +What kind of demands? +1: I remember a lot of, like, +even his laxative, like, he wanted Colace +(Phonetic Sp. *00:24:50), and he didn't like +the laxative he was getting. And, you know, he +just made a lot of demands. I would have to +refer to my notes, but it was just -- + + +32 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +MR. I +Okay. +: - you know, individual, his +individual needs. Things that he wanted. +1: What about -- +1: You know? +1: -- complaints? It mentions +that he voiced many complaints, also. +: Maybe that he was on watch. +I mean, I remember he didn't want to be on +there to begin with. Things about the jail, in +and of itself, I guess he wanted, I remember +him wanting to go to the Cadre unit (Phonetic +Sp. *00:25:23), because at that time, we had +Paul Manafort (Phonetic Sp. *00:25:25) there. +and his wanted to it - he know +those people were in the prison - so, +he wanted +to go be placed on a Cadre unit, which are +inmates that have already been sentenced, and +are serving small amounts of time. +→ se which we couldn't put him. +in, because he was pre-trial. But he wanted to +be with, like, other inmates he knew that were +there, that were more high-profile. + + +33 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Okay. +: I remember him complaining +about that. +: Anything else on that? +We have all of your notes +and the notes, you know, from psychology. +Would you want those for while we are +discussing, or do you think they are not +needed? +: Well, if there is anything I +think -- +Okay. Just let us -- +: - you know, I have a pretty +good -- +-- know if -- +: +- memory. +-- sure. +: But I mean, if you are going +to ask me on this exact date, did he say this +exact -- +notes. +: Absolutely. +1: -- then I would need my +No. I just -- +1: Yeah. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +-- I just -- +1: Yeah. +- wanted to know if you +would actually prefer them in front of you. +So, while we are talking, you can reference +them. Because if you can, we could easily get +them for you. +: Okay. I will see how the +questions - +Sure. +: - proceed. And if I am +uncomfortable with one, I will let you know. +Absolutely. +1: okay• +1: "Epstein's cellmate for the +Special Housing Unit was decided by the warden +and the associate warden. Dr. +was not +included on that decision. Her thought was +decided upon cellmate, Tartaglione, had a -." +Sorry. I don't know if that wording is wrong. +"Her thought was decided upon cellmate, +Tartaglione, had a lot to lose -." +: Just before we go on. +So, you said that it was decided by the warden +34 + + +35 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +and the associate warden. Do you know what the +names are of those individuals? Like, +would be the warden. +associate warden was? +was the warden. +Do you know who the +: I don't know who, but I know +he meets with the associate wardens. I don't +know which one. I know +was there +during that period of time. And I'm trying to +remember the other one. +: Was it +? +: Yes. Yes. No. +took -. +I don't know if +was +1: M +: - there that early. +came after. +: Yeah. I think it was a +different_AW. +Who was before +That's crazy. +But regardless, they were +the ones -- + + +36 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +1: Yeah. They - +- okay. +: -- they make the housing +decisions. +: You know, and who they felt +he should be placed with. +And then, let me just +read that sentence for you -- +1: Yeah. +-- so that -. It says, +"Her thought was the decided upon cellmate, +Tartaglione, had a lot to lose given his +history and charges, which made him a low-risk +to Epstein." +: Right. I guess that was more +of an opinion. +1: Mm-hmm. +You know, bocause ay thought +was the reason, they placed him with that +inmate is, you know, he is plaeing facing the +death penalty or life. Tartaglione. For these +alleged murders. And when you are pre-trial, +and you are in that situation, you are on your +best behavior, +and not looking to hurt + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +somebody, and get yourself into more trouble. +Okay. So, he was -- +death penalty. +1: So, a lot of times -- +-- he was facing -- +1: +- yeah. +- life in prison? +: Yeah. +okay. +: I think he was facing the +Was he? Okay. And do +you know what he was -- +: I don't know what his +situation is now. I know his attorneys, you +know, fight, has been fighting for him for a +long time. +: Okay. +: You know, to I think not get +the death penalty. +: And do you know if! +anything else about him? Was he law +enforcement -- +- or anything? Okay. +: He was law enforcement, and +37 + + +38 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +it was some drug related thing, and there was +four bodies, I think, and I don't know that +much about his case. I have met with him on a +couple of occasions. +: okay. +1: But, you know, he doesn't +come off as being, you know, he's not, like, +a +gang member, or violent, or trying to prove +anything, per se. +So, his goal was to stay +clean and to do what was right, so he could +potentially beat his case? +: That's what most people do, +pre-trial. +: You know, it's not until they +go to pens that they become that way, unless, +you know, you are very young and antisocial, +you will act out. +Right. +: But -. +: So, just to clarify, he was +pre-trial, or was he already facing a life in +prison? +1: Yeah, I think he was -- + + +39 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +death penalty? +: You said life in prison, and +: -- he was still pre-trial. +They both were pre-trial. +1: Okay. So, he was trying to +avoid the death penalty - +: - and trying to get life in +prison? +1: Right. Or maybe just get off +all together. +1: Got it. +: Yeah. +1: okay. +: In his mind, he felt he could +get off all together, but that is unrelated, +but -. +: Okay. Thank you. "On July +11th, 2019, Epstein was taken off of +observation, and housed in the SHU. Dr. +met with Epstein in the attorney conference +rooms that day, because Epstein was there all +day. Both Epstein and his attorney were +mocking Dr. +for thinking Epstein was +suicidal. Epstein continued to make demands, + + +40 +1 +such as wanting to wear a brown uniform to his +2 +attorney meetings. +DI• +continued to +3 +pass those concerns onto the SHU Lieutenant +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: I think so. +: Yeah. +: "On July 16th, 2019, after +Epstein's bail hearing, he was called for," or, +"he called for Dr. +to come to attorney +conference. Epstein didn't report any +psychological concerns, but chastised her +because his needs weren't being met. Dr. +felt Epstein thought of her as his +personal assistant. Epstein requested a kosher +diet, which she again passed on." +: Wait. Before we go on. +It says he chastised you because his needs +weren't being met. +1: Okay. Well, this is, he, you +know, while he was on watch, and when I would +talk to him, he would tell me all these +different things that he wanted. Like I said, +the special laxative. A certain diet. Certain +housing arrangements. You know, he had a lot + + +1 +of requests. And I guess, in the beginning, +2 +you know, I tried to help him as best as I +3 +could, and when I say personal assistant, I +4 +don't really like that word. But what I was +5 +really trying to say is that the officer's +41 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +would say he would always say, where is Dr. +, where is Dr. +? You know, that, +so that I could, maybe I had pull and could get +certain needs for him met, within the prison +setting. +Mm-hmm. +: So, let me put it that way. +It sounds a little better than that. And then, +you know what? I wanted to follow up with him, +and do a session, but he was in attorney +conference, like, eight hours a day, during my +entire shift. So, I would have to go up there +just to check on him, and make sure he was +doing okay. So, when I would ask if he was +suicidal, he would be, like, I was never +suicidal, and, you know, he would laugh, and +the attorney would laugh at me. You know, so, +it was just kind of - that's what I meant. And +then, when he would chastise, he would become +angry. + + +42 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: You know, because he was very +demanding and entitled. So, if he got angry +when his needs weren't met, because he was used +to that kind of lifestyle, I assume. You know, +in the outside where, you know, at the snap of +his finger, he could have certain needs met. +And in the prison, it didn't work that way. +And just so we are clear +-- when you say "needs," +they are not actual needs that a person would +need. It's his wants, I guess, would be -- +- better. +: Yes. +Because did he have -- +1: okay• +: -- did he have -- +1: +okay. +- everything that he +needed? +inmates had. +: He had everything that basic + + +43 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Okay. +1: I guess one where +psychologists refer to, you know, people engage +in certain behaviors to get their needs met. +So, their wants and needs. So, yeah. +okay. +1: Wants. +But do you believe that +he had everything he needs? Like, he needed. +: Okay. +1: For the most part. I mean, +I +know he wanted a CPAP machine while he was on +watch. And I was, like, no. Because there was +cords, and things like that. So, you cannot +have your CPAP machine. +And he wanted to get +off of watch at the end, because he wasn't +sleeping well, and he said he had sleep apnea, +and he wanted his machine. So, I wasn't going +to take him off until I felt he was ready, or +give him that, until he was off of watch. +: Okay. +| "On July 18th, a SHU review +was attempted on Epstein, but he was not seen +because he was in attorney conference. On July + + +44 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +23rd, 2019, Dr. L +received a phone call +regarding Epstein, because he was found in his +cell with a loose noose around his neck, and +had been placed on suicide watch. She ordered +a suicide risk assessment be completed on him. +DI. +|." Is that -? Did | -? "Completed +the suicide risk assessment later that morning. +During the assessment, Epstein told Dr. +he did not remember what happened. He +denied suicidality. Had future plans. And he +wanted to learn. He wanted to fight his case. +And he was acting like a big kid. Dr. +learned that Epstein had told staff that his +cellmate, Tartaglione, had tried to kill him. +Dr. +kept Epstein on suicide watch." What +was your understanding, and did you have a +conversation with Epstein, after that point, +about his interaction with Tartaglione? What +exactly transpired - +1: -- on that incident? +1: And that was the issue. I +mean, he never retracted that statement. I +mean, he said that he thought he was a +pedophile, and that he had taken this piece -. + + +45 +1 +I don't know if it was a piece, or a piece of +2 +cloth, or whatever. And went like this around +3 +his neck. And -. +4 +Now, he told you this? +5 +: Yes. He told my staff that, +6 +as well. +7 +So, he told both you and +8 +your staff? +1: Yes. I had seen him +10 +subsequently. Again, I don't have my notes in +11 +front of me -- +12 +Sure. +13 +1: -- but I remember him telling +14 +me that. So, at that point, when we were doing +15 +the suicide risk assessment, and Dr. +was, +16 +17 +we had to conceptualize what actually happened. +You know, whether this is something he +18 +19 +20 +inflicted on himself, and you know, the +reasonings why he would do something like that. +Or whether it was there was indeed an assault +21 +22 +23 +24 +25 +of some form. And so, then, you know, it was +referred to SIS, too. So, he wasn't ever +really forthright on what occurred, while he +was on watch that time. +1: Did you ever believe - based + + +46 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +on your conversations with Mr. Epstein -. +Sorry. I'll just end that. Based on your +conversations with Mr. Epstein, did you believe +what he stated, in terms of Tartaglione trying +to kill him? +: Honestly, I did not know what +to believe at that point. So, my mind was +opened that there were potentially three +things, different things going on, and a 33 +percent chance of it being any one of those +things. Because you don't know what happens +behind closed doors, in the SHU, or whether +they did have a disagreement. +: You know what? It actually +goes into your hypothesis -- +Okay. +: -- let me read that -- +: - and maybe you can state -- +: Okay. +: -- if that's right. "Dr. +had three hypotheses, in no particular +order, regarding this incident, of what this +incident meant. One) it was gamey by either +Epstein, Tartaglione, or both. Meaning, there + + +47 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +was something they wanted, and they weren't +getting. So, this is how they were going to +play the system to their advantage. Iwo) it +was rehearsal by Epstein, who really was +suicidal. Three) it was an assault committed +by Tartaglione." +Was that the three? That is +your three hypotheses? +: Was there any one of those +that you were leaning towards? +: At that point, I didn't know +because -- +: - you know, he was just +placed on watch. The SIS investigation hadn't +taken place. I had -. There was enough +evidence it could have been any one of those, +because the phone call I received in the +morning, when he was placed on watch, the +lieutenant at that time had told me it was -. +She was, like, this doesn't - because they have +been around a while - this isn't a real thing. +It was like a little string, and, you know, he +was, he seemed fine. +And then, when I turned around, he would + + +48 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +be rocking back and forth. So, she, you know, +at that initial time, it almost looked a little +gamey. Like, that maybe he just went like this +with a piece of string, at that point. He had +lost his bail. I'm sorry. +: No problem. +: Let me just turn off my +phone. At that point, he had lost his bail +hearing. The judge denied him -. I'm sorry. +1: Bail. +: The judge denied him bail. +So, right before the +23rd, the judge denied him bail, and then this +happened? +1: Right. +: Okay. So -- +: So, there is, that is the +gamey piece. I mean, if you want my +conceptualization, that, you know, that maybe +he did, you know, this sends a message, I can't +take jail, put me on house arrest. I'm either +going to hurt myself or someone else is going +to hurt me. +Get me out of here. Because he +came in very entitled. Like I said, he had a +lot of money. +He was meeting with his + + +49 +1 +attorneys every day. +2 +He had a lot of money at that point. It's +3 +not like he had lost trial. And Tartaglione +4 +had a lot to gain, to save a life, because he +5 +is facing life. You know, when you get a +6 +letter that you save someone's life, that's +7 +helpful in your case. +I'm not saying that's +8 +it, but I mean, I'm just trying to think of +hypotheses. So, that was where the gamey stuff +10 +came in. That was +the gamey piece. +11 +The report from the lieutenant, the gains +12 +that both of them could have by this behavior. +13 +Could that be why that happened? Number two. +14 +He is genuinely upset, and he was, it was a +15 +rehearsal behavior, and perhaps he really +16 +wanted to hurt himself. +So, we need to be +17 +cautious. So, it could be the gamey thing. It +18 +19 +20 +21 +22 +23 +24 +25 +could be the cautious thing. Or maybe Epstein +and Tartaglione had it out that night, and he +said something pompous or whatever, and the +other one got upset, and he did, you know, put +the rope around his neck, and that really +frightened Epstein, and that is why he went +into, like, this fetal position. +Maybe he was scared. You know, could it + + +50 +1 +2 +have been any of those? +And subsequently,I +think one of his attorneys was convinced that +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Tartagliione had assaulted him. Not because, I +guess he told his attorney the same attorney. +So, it could have been any -. I say 33 percent +chance it could have been any of those things. +: Now, I understand that +that's what you thought -- +1: Yeah. +- on the 23rd. Did that +33 percent chance change, after time, that you +believed it was one over the other? +: I never knew. +No? +: I mean, I never -- +So, you still - +: -- knew. +- thought that they were +all equally plausible? +1: Well, I guess towards the end +of watch, I thought the assault wasn't as +plausible. Because that he really wanted to +hurt Epstein, because later on, Epstein was +saying he would go back and cell with him. +So, +why would you want to go back and cell with + + +51 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +somebody that was trying to hurt you? So, but +again, I didn't do the SIS investigation. So, +and I never was privy to it. +: Mm-hmm. +: So, I don't know what the +findings were. But after that, that made that +one less plausible. So, made the other two +more plausible, at that point in time, which +was either it was a rehearsal behavior, or two +it was a game - it was gamey - to get him out +of jail because he was just denied -- +1: Who did he -- +1: -- bail. +: - who did he make that +request to? That he wanted to go back within +the cell with Tartaglione? Was that to you +directly, or -? +: I think he might have +mentioned something like that, because when I +was trying to figure out where to house him +later, I remember him mentioning that to me. +I +don't know if I put it in a note or not. +Mm-hmm. +_: okay. +: But veah. +So, I began to + + +52 +1 +2 +3 +4 +5 +6 +7 +think that that was - it was less -. Why would +you want to go back in a -? But maybe he's not +thinking clearly. I don't know. But that made +me feel less about that. When he said that. +Mm-hmm. +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +1: Anything else on that? +: Now, being that he just +lost bail, had you heard that Tartaglione was +actually the one that notified the SHU staff +that there was an issue with Epstein, and that +is what made them respond to the cell? Had you +heard that? +MS. I +: I mean, I had heard that he +called out. +That's what I mean. +: Yeah. +I had -- +So -- +1: -- I had heard that. +- with those -- +1: But I don't -. +: - factors in play, does +that make you believe that, you know, aside +from the fact that he wanted to go back with +Tartaglione, you know, at the end of his watch, +or observation, does that also make you think + + +1 +maybe it was less likely that he attempted to +2 +harm himself, or does that play into your +3 +decision? +53 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +never know. +1: Still, those two, I just will +At that -- +: +Okay. +1: -- for that particular +circumstance. Was it, you know, a pact between +them, or maybe it wasn't even Tartaglione +trying to get any gain. Maybe it was Epstein +trying to call attention to himself, so that he +could be - so that he could go back to court, +and get that bail, and that they would feel +like he wasn't safe there. +: Right. I guess -- +: And let him go home. +-- my question maybe -- +1: Yeah. +: -- wasn't that clear. +1: Yeah. +: So, I think you used the +example that Epstein, after he was coming off +of observation, and you were looking to see +where he was going to be housed, or who he was +going to be housed with, he mentioned that he + + +1 +was going to go, you know, he would be willing +2 +to go back with Tartaglione, and that was the +3 +reason why you thought, maybe, that one of the +4 +three was probably less likely. +5 +: Yes. +6 +: What I'm saying is, do +7 +the factors that Tartaglione called out to the +8 +staff to say something is going on with +54 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Epstein, come check him out, does that also +play into that, or no, you just placed that +simply in those other two, that -? +: Simply in those other two. +And that -- +Okay. +: - that, I don't know what to +make of that. +: Okay. Sounds good. +: Whether it was going to be +something to help, whether he really was +worried about Epstein. +Okay. I'll never know, +and -. +: Sounds good. +: This may not be something +that you might know. It's more towards health + + +55 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +Well, we have that. +24 +25 +services, but maybe you had a conversation with +health services. Do you know if they ever +medically examined him for any broken bones, +anything, kind of damages? Just, I know he had +here, the ligature mark on his neck, right +after the July 23rd incident. +: Mm-hmm. +Was there any -? Did they +examine him? Like, do you have an xray, MRI, +anything for broken bones in his neck? +1: That -- +: Any kind of injuries? +1: -- I don't know. +1: okay. +: That, I don't know. You +would have to look in BEMR. Yeah. For that. +: In where? +: BEMR. B-E-M-R. BEMR. +: What's that? +1: That's the medical record. +But as far as when you +are meeting him, though, at that time, did you + + +56 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +notice any injuries on him? +1: Just the mark. +: Just the mark. +1: On the back of his neck. +Like -. +Do you remember if he was +complaining about any potential broken bones, +or collar type issues, or anything? +1: No. +No? +: No. +: Okay. +: "On July 24th, 2019, Dr. +(Phonetic Sp. *00:44:22) +-met with +Epstein. Epstein reported he was fearful to +return to his cell with Tartaglione because +Tartaglione had called him a pedophile. +Epstein reported Tartaglione had put - had been +playing with the bedsheet before Epstein fell +asleep. And then, next thing Epstein +remembered, he was waking up snoring. Epstein +denied being suicidal, and reported being +unhappy with this legal situation. He had been +eating, drinking, and sleeping. Dr. +took Epstein off suicide watch, and placed on + + +57 +1 +psychological observation." +2 +: Nowe, on that, when the +3 +inmate goes from suicide watch to psychological +4 +observation, is the executive staff conferred +5 +with? +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: They are? And do they +provide an opinion on that, or was it just to +let them know? +1: No. We just let them know. +Just to let them know. +Okay. So, they don't have to say, oh, yes, we +agree, or please keep him on suicide watch, or +anything like that? +1: If they feel that way, they +can express it, and we will keep it in mind, +though, and again, we make those decisions. +okay. +1: okay• +1: Now, being that this is July +24th, the next day, and he had possibly tried +to hang himself -- +: Mm-hmm. +: -- on July 23rd, and they +took him off - Dr. +takes him off + + +58 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +suicide watch and places him on psychological +observation. Is that normal practice? +: Yeah, because psychological +observation is, he's in the exact same cell, +he's being constantly observed. She spent a +long time with him. I think she interviewed +him, like, over an hour, an hour and a half. +And she just felt that there was no eminent +risk of at that time. Like, while he was in a +suicide watch cell, he wasn't going to do +anything to harm himself. So, we stepped him +down. I think maybe gave him a -. I don't +know if she gave him underwear, or gave him +something, so that he was more comfortable. +So, it wasn't so depriving. Because he kept +adamantly denying wanting to harm himself. +And, you know, she came and talked to me. I +didn't sit in that interview because she's a +licensed psychologist, and she felt it was safe +to step him down, because he would still be by +himself in that cell, constantly observe with +the lights on all night. Nothing would have +changed. +So, I guess - +1: So. + + +59 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +- what he wants to know, +though, is, was that normal? Is that normal +practice -- +1: Yeah. +- for her to do that? +1: We do that. I mean - +Okay. +: - not all facilities have +the step down, the psychological observation. +Some people just have the +suicide watch. And +then, they will give them privileges while they +are on suicide watch. But we have that, so, if +you want, because suicide watch is so strict, +that he couldn't even have a pair of underwear. +He couldn't, you know, have a piece of mail. +Nothing. So, we didn't feel he needed that +strict of supervision, but we still wanted him +constantly observed, to see, and we could +always step him back up, if he engaged in any +behavior, because he would be constantly +watched. +: All right. So, suicide +watch and psychological observation are +extremely similar. +: Very similar. Except that we + + +60 +1 +can give a little more privilege. Like I said, +2 +we could give him a book to read. Or we could +3 +give him a pair of - start with the underwear. +4 +Of, you know, he could have toothpaste, and +5 +give it back to brush his teeth. That type of +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +thing. It wasn't as strict. +: And at the MCC, when an +inmate potentially attempts to harm themselves, +how long are they typically on suicide watch +versus observation, before -- +: Well, that - +- they (Indiscernible +*00:47:51)? +: —- depends on how the inmate +presents. +okay. +: I mean, I have had people on +suicide watch for long periods of time because +they can't verbalize any protective factors, +which would be reasons they have for wanting to +be alive at the time. Reasons they have to +live. Factors that we would look at to say, +hmm, there is more factors here that suggest he +wants to be alive, and that he has reasons to +be alive versus not. Versus risk factors. + + +61 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +So, at that time, he had verbalized enough +protective factors that Dr. +felt +comfortable stepping him down to psychological +observation. I don't have her SRA in front of +me, but if you read it, it would have his +reasons for wanting to be alive, his +presentation of not exhibiting any acute mental +health symptoms, not being depressed. So, she +stepped him down at that point. +: Okay. Now, do you know, +when they are on psychological observation, are +they allowed to have attorney visits? +1: They usually consult with us +to see if we feel comfortable with that. And I +do allow it. A lot of times, as long as, you +know, there is a lieutenant present, or there +is an officer present there. +: Okay. And in this case, +do you know if Epstein was allowed attorney +visits while he was on observation? +: I don't remember. +: Окау. +1: To be honest. +So +-- +: I don't remember. + + +62 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +-- so, it's - +: It's very possible. +: -- okay. And do you know +if the institution was contacted by anyone, +such as Epstein's attorneys, or the judge, +asking that he be taken off of suicide watch +and placed on observation because he wasn't +being afforded attorney visits, or for any +other reason? +: No. I don't recall that +happening. +Okay. And on that same +note, do you recall either the judge, an +attorney, or anyone from the outside, +contacting the institution when he was taken +off of observation and placed back in the SHU? +: I don't recall speaking to +any attorney about that. +: No, not you speaking with +them. But I mean, them contacting - I'm +assuming they would contact the warden. +: That, I don't know about. +: And the warden never had +that, or anyone, any of the executive staff, or +anyone had any conversation with you or staff, + + +63 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +saying, this is what we are getting from the +outside, the judge contacted us, or the +attorney, you know, the attorneys -? +: I don't know. +No? +1: Hmm-mm. +: So, that was - you don't +believe that was at all factored into the +taking off of suicide watch? +: Oh, no. It would never be +factored anyway. +okay. +: Yeah. +So, regardless, if they +contacted you, that wouldn't be a factor? +_: No. +I mean, that wouldn't -. +They would never influence our decision. +okay. +: One way or another. +: Okay. Great. +1: You mentioned before, when +somebody is taken off of suicide watch and +placed back in psychological, step down into +psychological observation, they are given back +one piece of item at a time. + + +64 +1 +2 +3 +4 +5 +6 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +1: Well, no, sometimes it could +be more than one. It depends on the situation. +1: But what I am saying is, when +you were reading the paper -- +1: Yeah. +: — it sounded like we just +give them everything. We make those decisions. +We may step them one at a time, if it is more +significant. We may give them a book. And a +pair of underwear. I mean, we may give them -. +It is just whatever, it is at the discretion of +the psychologists that interview them, on what +they are going to allow the inmate to have. +1: Do you know how it worked +with Mr. Epstein? Was he given one time item +at a time back -? One or two items, or was he +given everything back? +: I don't remember. I don't +think he was given everything back, initially. +That's for sure. But -. +going. +1: Okay. I'm going to keep +: "At that time, Dr. +was + + +65 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +not any clearer on which of her hypotheses +might have been true. Epstein could have been +using his charm to breed doubt about what +happened. Psychology had not been contacted by +Epstein's attorneys with concerns regarding his +mental health. On July 25th, 2019, Dr. +met with Epstein, who was in good spirits. +greeted her by saying, 'welcome back.' Dr. +confronted Epstein on the attempted +And +suicide incident, in an +attempt to get answers. +Epstein said he was baffled over it, and told +Dr. +to give him some ques to help him +remember. He continued with his requests and +complaints, and did not want to go back to the +SHU. Epstein told Dr. +"I have a life, +and want to go back to living my life.' Dr. +kept him on observation because her +questions had not been answered, regarding +their suicide attempt." +Or the suicide attempt. +: "Regarding the suicide +attempt." +Dr. +1: True. +: "After a conversation with +the national suicide prevention + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +coordinator from central office, Dr. +66 +got +involved in Epstein's housing. Dr. +recommended housing Epstein with a sex offender +in SHU, which Dr. +passed, on via email, +to executive staff. On July -." +: Do you know which +executive staff you sent that to? +: No. I know I gave a bunch of +documentation, when I had my last interview. +There may have been +an email. I don't remember +who -- +Sure. +-- it was so. +And did you concur with +his recommendation? +1: Yeah. +Great. +: "On July 26th, 2019, Dr. +met with Epstein. Epstein said he +needed to establish trust with Dr. +1."' +What did he mean by that? +: He kept saying this thing, if +you want -. It was this weird thing he said, +something. "If you want my trust, I have to +trust you." And that was trust that, if he + + +67 +1 +asked for certain things, that I would follow +2 +through with those wants. You know, if I said +3 +I was going to do something, I would follow +4 +through with it type of thing. I just remember +5 +that. +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +1: Basically, he wanted you to +provide something, so he can reciprocate? +1: Right. +: Basically, if you wanted +answers from him, you had to provide him with - +- +1: No. +1: -- is that what -? +: It wasn't like that. It was +just - again, I probably would have to refer to +my notes for that one - but it was just a weird +thing that he used to say. Like, if you want, +if we want to have, like, this trusting +relationship type of thing, then, you know, I +have to trust that you are going to follow +through with your stuff, and you -. And then, +you can trust me. I don't know. It was +strange. I don't really know what he meant by +that. +"He continued with + + +68 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +complaints and jokes, making reference to Dr. +being Jewish, like him. It is against +Jewish religion to commit suicide." Is that +something he mentioned, +or is that a statement +from you? +: No. He joked about it one +time, in attorney conference. I didn't know +how he knew I was even Jewish, but he said +something to me, like, what's a nice Jewish +girl like you doing here? You know, working in +- or some comment like that. +: And -- +: But it is against the Jewish +religion to commit suicide. But he didn't say +anything until that one time in attorney +conference. +: And you were in there, in +the attorney conference, with him? +: Well, because I went to go +check on him, remember, because I - +Mm-hmm. +1: - I know he was never in his +cell. +Okay. + + +69 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +1: He was never available. +And he stated that? +1: Yeah. He made, like, in +front of the attorney, like, a little, a little +joke. +Okay. +: Like that. +And just the way that it +reads in there, it doesn't say that he stated +it, or you stated it. +It just says, "It is +against the Jewish religion to commit suicide." +So, just - +: Maybe -- +-- for context. +: - that might have been in +I don't know if he mentioned +one of our notes. +that. But -- +But he -- +: -- I don't -- +-- but he -- +came from. +: -- I don't know where that +: -- but he said it to you +in the attorney conference? He was with you -- +: Yeah. He didn't -- + + +70 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +- in the attorney -. +: - say anything about it's +against the Jewish -. Oh, maybe he did. I +don't remember. He may have. He may have, in +a joking way, said something like that to me. +I don't remember, to be honest. +Okay. +: I would have to see -- +Okay. +1: -- if that is one of my +notes. Or if it is something that was just in +passing at attorney conference. I just +remember that one incident. About the Jewish +thing. Like, what's a Jewish girl like you +doing here? Or something. +okay. +: "Epstein said he did not like +pain, and didn't want to hurt himself. Epstein +had been interacting with the companions +assigned to him regularly. On July 27th, 2019, +Dr. +met with Epstein, who was anxious +about going back to SHU, due to the fact he did +not know how he got the marks. Epstein did not +answer Dr. +questions about that night. +She had begun working more therapeutically with + + +71 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +him, and provided him with handouts to cope +with housing. Lieutenant Doctor's +investigation into a possible assault regarding +this incident still had not returned any +answers. Dr. +kept Epstein on +psychological observation." +: Just real quick on that. +It just says, "He was anxious about going back +to the SHU due to the fact he did not know how +he got the marks." So, he had changed his +story of how he got the marks, at that point? +: He didn't change the story. +He just didn't say anymore it was Tartaglione. +He was then, I don't know how I got the marks. +So, he - +: So, he went -- +: - he kept changing his +story. +- all right. So, he +went from Tartaglione did it, to I don't know +how I did it?. +1: Right. +1: Right. +: Or how it happened? +: And do you know why that + + +72 +1 +happened, or did you question him about that? +2 +: Yeah, but he just kept being +3 +vague, like he didn't know anything, or that, +4 +like, he blacked out, or he doesn't recall how +5 +it happened. +6 +: Was he questioned, like, +7 +well, before you said that Tartaglione did it, +8 +and now you are saying you don't recall. +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: I don't know if Dr. +confronted him in that way, because we are not, +like, investigators. +Sure. Sure. +: You know, so, we don't -. +Psychologists don't always think that way. +okay. +: So, I don't know, but I +think, likely, she probably mentioned that, and +then, he was, like, oh, well, I don't, I don't +know. He was very vague. +okay. +: In giving us the reason. +okay. +1: That happened. +: "On July 28th, 2019, Dr. +met with Epstein, who appeared the same. + + +73 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +His logbook showed no signs of suicidality, and +he was participating in his legal meetings. +There had been no contact from Epstein's legal +team regarding any mental health concerns." +Okay. So, there it says +that he actually was meeting with his legal +team. +1: okay• +okay. +: So, being that he was on +psych ops, that he wasn't acutely, eminently +suicidal, that he had been denied any current +thoughts of hurting himself, and over the past +several days, while on watch, he hadn't +displayed any self-harm behaviors. Or any odd +or unusual behaviors. Likely, we didn't have a +problem with him going there, as long as there +were staff up there - +okay. +-- to watch him. +: So, he would actually go +from observation to the attorney conference +rooms? +: And then, be escorted back. +Yes. + + +74 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Okay. So, it wasn't that +they were meeting him at the suicide - +_: No. +- watch area. +_: We never do that. +Okay. +1: Yeah. +Okay. +1: Do you know if those are allday meetings? Like, he normally had, or was it +just short meetings? +: I don't know how long the +meetings were. +1: Okay• +: Yeah. Because if you +don't know, he was meeting with the attorneys +from, like, 7:00 or 8:00 a.m., up until, like, +7:00 p.m., every day. At least outside of this +-- +1: Yes. I knew that. Because +that's -- +- but you don't know if +- +: -- that's why I could never +see him, but I don't remember, while he was on + + +75 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +watch, how many hours a day. I think he was +probably there for a significant period of +time. +observation? +While he was on +: Yes. +: Okay. +: But then, he would be +returned to psych ops while someone would sit +on him. +: But is that normal, though? +I mean, someone who is on psych ops be - you +mentioned that somebody who was in psych +observation should be monitored constantly. +Right? There's someone monitoring -- +1: Yeah. +: -- them? +: But he was right in front of +the officer that worked at attorney conference. +He was right there. And right by the +lieutenant's office. So, they could be +observing him the whole time. +1: okay. So, someone —- +: — is sitting there, watching + + +76 +1 +2 +him -- +1: Yeah. +3 +: -- at all times? +4 +1: Yeah. There was somebody +5 +there. Like, the way our attorney. I don't +6 +know. Have you been to our attorney conference +7 +8 +room? +Mm-hmm. +: Do you know where the officer +10 +11 +12 +13 +14 +sits there, there is an +attorney conference +room right next to him, that has windows. +That's where Epstein was every day. +: So, you could see in? +: Full. Yeah. You could see +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +his, like, white - you come off the elevator - +you saw his white hair. Like, he was right +there. +like, he coutd bo seen by the +attorney conference officer. At all times. +And he was with his attorneys. So, I mean, if +God forbid, he started banging his head for one +second, the officer was right outside his +window. +1: Okay• + + +77 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: Yeah. +So, we felt, you know, +it was okay, and again, he wasn't on suicide +watch. We didn't think he was eminently +suicidal. But precautionary, we had him on +psych ops, because we - the vagueness of his +responses. +: Okay. +1: And not feeling completely +comfortable putting him in GP, until we +observed him over a period of time. So, that +is why. +: Because he wasn't on suicide +watch anymore. So. +1: Anything else on that? +: No. I guess just on that +note, if he is meeting his, with his attorneys, +while he was on observation, are his +psychological needs being met? +•: Well, that's why we had to go +up there, and talk to him. +: Right, right, right. +: So, we would go up there and +interview him. +And around how long would + + +78 +1 +those interviews take? +2 +: I guess five to ten minutes. +3 +: Okay. +4 +: Just to check in. But a lot +5 +of times, on suicide watch, they were, too. I +6 +mean, we would review the suicide watch book +7 +throughout the night, because we are not there +8 +24 hours. +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Mm-hmm. +1: So, we would look at his book +from before his visit, through the night. And +then, we would see him daily. +Mm-hmm. +: We would see him -. And +maybe, some of the times we saw him before he +saw his attorneys. +Sure. +: See, I don't, I don't know if +-. I know -- +So, as far as -- +: -- I personally went up there +once or twice. +: -- but what -- +: I don't know if Dr. +maybe went there once or twice, because when + + +1 +2 +attorney. +79 +she went back there to see him, he was with his +3 +4 +5 +: Now, would that be any +different than if he were not seeing his +attorneys? Was that the same amount of time +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +that psychology would see him, if he was with +his attorneys, or staying in the cell where he +was being observed? +: Yeah. We usually, like, 15 +minutes. I mean, it's not a therapy session. +Sure. +: We're just, you know, doing a +mental status, seeing how they are doing. Are +you eating or sleeping? Are you having +thoughts of hurting yourself? We read the +book. +Mm-hmm. +1: In its entirety, for the past +24 hours, to see, did he voice anything to the +companions that he wanted to hurt himself. Did +he take his meals? Did he eat his meals? Did +he shower? Is he, you know, is he displaying +any behaviors that are consistent with +depression? So, we look at all of that. And +then, we interview him. We do the mental + + +80 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +status. We ask him how he's doing. And so, +that would be pretty consistent. It might have +been a little shorter on occasion, if he was up +there with his attorneys, because his attorneys +were there. So, it wouldn't really be +confidential. But we do -- +: Oh, so, when you were +conversing with him, it would be in front of +his attorneys? +-- yeah. +Okay. +: Is that normal? +1: Yeah. Well, because he was +in there with his - he has a right to his legal +meetings - so, he was with his attorneys. It +wasn't every time. +I mean, there might have +been one or two occasions where we had to see +him up there, because he was in the meeting +with the attorneys. So, yeah. We talked to him +in front of his attorney to make sure he was +okay. +: Now, when you say he has +a right to his attorneys, if he was on suicide +watch, would he have the right to his +attorneys? + + +81 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: Normally, I really do try to +get them to meet with their attorney. I mean, +that's only if they are actively, like, +cutting, or - +1: -- wanting to hurt +themselves, then I would have a lieutenant up +there. +Sure. +: Like, I always try to give +people the right to be with their attorneys +because that could make them even more +depressed. +Sure. +: If you deprive them of being +able to work on their legal case. +: Okay. +: All right. "On July 29th, +DI. +visited Epstein. Epstein expressed +that he would like to stay in psychological +observation because it is safe. Epstein had +been requesting his CPAP machine, so that he +could get a good night's sleep. Due to the +machine having a cord, this could not be +accommodated in psychological observation. + + +82 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Epstein was given a chance to stay in +psychological observation -". +: A choice. Not a chance. +1: Sorry. +Epstein was given -. +: "Epstein was given a choice +to stay in psychological observation one more +night without it, or go to the SHU with it. He +chose to stay in psychological observation one +more night. Dr. +consulted with the +executive staff, prior to this decision." +: Yeah. +1: "On July 30th, 2019, Dr. +transitioned Epstein back to the SHU. +DI. +sent an email, updating the +appropriate staff for Epstein's transition off +psychological observation, and the need for him +to be housed with a cellmate." +: Okay. +1: Bear with us. +: So, that contact was at his +cell. It wasn't with the attorney. If there +was, like I said, a couple of contacts that +were in attorney conference, they were field - +most of them were at his cell, we caught him + + +83 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +before he went up to his legal visits. That +last visit was in person. I remember that +visit. +1: Okay• +1: With the CPAP. +1: Now, do you recall, when Dr. +transitioned Epstein back to the SHU, was +that solely the decision of psychology, or was +there any recommendation from executive +management? Like, the warden, the associate +warden, or somebody from the outside, +{Indiscernible *01:04:53)as Agent +asked before. +: No. That was our decision. +After him being between suicide watch and psych +ops for almost a full week. It was our +decision that he was not eminently suicidal, +and could be transitioned. +1: okay• +: And just to, I mean, +Epstein expressed that he would like to stay in +psychological observation because it was safe. +So, he actually preferred psychological +observation over the SHU? +: Because he wasn't being able + + +84 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +to be housed where he wanted to be housed. He +didn't want to go to Special Housing. Like I +said, he wanted to be housed in the Cadre unit. +He wanted to dictate his housing arrangements. +When they weren't what he wanted them to be, +and I guess maybe he heard rumors, or whatever, +that the SHU was, like, +a bad place, or a scary +place, he didn't want to go back there. +But a lot of inmates don't want to go to +SHU, and that is why, earlier, when you said a +lot of people fake mental illness, or fake +suicidality, so that they can come down to our +suicide watch area, and just interact with the +companions, and hope that maybe someone will +slip them something they couldn't have while +they were in the SHU. Or just to get a timeout +because it could be loud up there, because +inmates will scream outside their cells, +because I don't know if you are familiar with +an AD-SEG (Phonetic Sp. *01:06:16) unit, or a +Special Housing Unit, where inmates are in a +cell, with a cellmate, like, 23 out of 24 hours +a day. +So, it gets loud and rowdy. +So, a lot of times, people try to come +down. +It's, like, almost, like, the Marriott, + + +85 +1 +2 +3 +4 +5 +6 +7 +8 +you know, to come to our suicide watch area, +where it is peaceful and quiet, and they don't +have to hear things, or if they are having +problems with officers up there. So, it's not +uncommon for any inmate to try to avoid going +to the Special Housing Unit. +: Okay. +: You know, it's not an +uncommon occurrence. +Yeah. And I'm assuming - +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +- +1: I never have any -- +-- (Indiscernible +*01:06:50). +1: -- inmates say I want to go +back to the, you know, the SHU. +From observation? +1: No. +So, it's bet - +: Very rarely. +: - yeah. +1: Unless they are so sick of it +because they have been deprived for so long +down there, that they feel that their wants and +needs will be met, or better suited up in the + + +86 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +SHU, then they will be, like, okay, I'11 go +back, I'll go back. +Okay. But -- +1: Yeah. +- in observation, he was +housed by himself. Correct? +And he wanted to be +housed by himself. Correct? +MS . +: Not necessarily. Because he +wanted to go to the Cadre Unit, which is a +dorm-style unit. +okay. +: With all the other, with tons +of other inmates. +All right. Yeah. +: He just, there were certain +places he didn't want to go. +SHU. So, he just - +: Yeah. +-- rather be in +observation than the SHU. +MS. L +: Right. I mean, this is a guy +that has never jailed before. +Sure. + + +87 +1 +2 +3 +: He's in, you know, his late +sixties. He's probably afraid, like anybody +would be. +4 +5 +6 +7 +8 +So, he preferred the +general housing unit over the SHU, though? +: Okay. +: Particularly, the dorm-style +Cadre Unit. +Yeah. Maybe I'm not -. +Is that different than the general housing +unit? +: Yeah. +okay. +: Because in the regular +housing units, you are celled with a cellmate - +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +- +Mm-hmm. +: - at night. Whereas in the +Cadre Unit, there are tiers of dorms. So, it +is a bunch of bunkbeds. And so - +: Oh, it's per -- +1: -- it's more open. +: -- it's per tier, would it +be? + + +88 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: I'm not sure per tier. I +know there is about - it can house, like, 100, +120 inmates. The dorms. +not separated? +With no, like, doors, or +1: No. There is just a tier. +There is a -. No. +So, he -. So, we had +always heard, up until this time, that he +wanted to be housed alone. What you are saying +is he wanted to be actually housed with more +people? +: Well, that is where -. Well, +he wanted to be housed there, where Manafort +and other people had been housed, where Cadre +inmates were housed. Maybe because the Cadres +were, he felt they were less dangerous. +: Okay. +: I don't know. I know when he +came in, he didn't like being on the unit. +That was for sure. +And is the Cadre -- +: You know? +-- Unit the low -- +1: Yeah. + + +1 +- security level - +2 +-- yeah. +3 +-- inmates? +4 +: Yeah. Because those are the +5 +ones that have been sentenced, to lower +6 +sentences. +7 +Okay. So, he wanted to +8 +be where the lower sentence inmates were. +9 +1: Yeah. +10 +: okay. +11 +1: That was the only place, I +12 +think, he was wiling to go. In our +13 +conversations. +14 +15 +16 +17 +: Okay. +: Was Paul Manafort still +there, at that point? +: I don't know if he had +18 +19 +20 +recently left. He thought he was still there +because he was only there briefly. +: So, he's not asking -. So, +21 +22 +he, as if he knows +: Paul Manafort, and he wants +to go be housed with Paul Manafort. He just +23 +wants to be -. He just wanted to be in the +24 +25 +same area as Paul Manafort was housed. +89 + + +90 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Okay. +: And there was somebody else. +I can't remember who he said. There was +somebody else, more high-profile, that was +there, and he said he wanted to be where that +person was. +: Okay. +: Maybe he felt it was safer +because they were surviving there, or whatever. +I don't know what his thought process was, but +that's how, that's -. I think it's -. I mean, +it was part of his personality. I mean, he +wants to be associated with higher-level +people, and these were, that was a higher-level +inmate. You know, so, he would feel +comfortable being amongst those type of people. +1: Okay• +: Does that make sense? +: Yes. +: Yeah. Okay. +1: I'm going to keep going. +Yes. +: "Dr. +discussed the +importance of SHU inmates having a cellmate for +the following reasons: it decreases isolation; + + +91 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +it decreases privacy; provides a distraction; +provides a rescue opportunity." +: "At risk settings for +inmates, including housing, single cells, and +private spaces. SHU employees receive training +on suicide prevention quarterly. All employees +receive suicide prevention training once a +provided slides from MCC's +year. Dr. +suicide prevention training to the interviewing +agents, reference that, referred to as +references any denying, attached to his report. +She stated all lieutenants should be aware of +the cellmate policy. Both due to the training +regularly provided, and psychological services +constantly reminding them of the procedure, and +needs of specific inmates. Dr. +noted, +after Epstein's death, his old cellmate's label +was still on his door. That is one of the +things that the psych department looks for, in +their daily rounds in the SHU, that there are +two bodies in each cell." +Now, that label on +the door, if an inmate is removed, should that +label have been removed, too? +: Yes. + + +92 +1 +2 +: How soon? +: It should have been done +3 +immediately, especially since he was housed +4 +with Epstein. +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +1: Why should it have been +removed immediately? +: Because then his cellmate was +bailed out, and wasn't coming back. +: By removing it, would that +also give SHU officers, inform the SHU officers +that there is only one inmate in that cell? +1: That would have helped. Yes. +Most definitely. It wouldn't have been the +only way they should know, but it definitely +would have -helped the situation. +Are we talking about +August 9th right now? +MS. I +: I don't know. +_: Yeah. +Because it says, "Dr. +noted that after Epstein's death, his +old cellmate's label was still on his door." +: Okay. So, who would have +been, on August 9th, the one who would have +done the rounds in the SHU? +1: The psychologist?- + + +1 +2 +3 +4 +5 +6 +7 +8 +93 +I guess, it sounds like - +: Well, psychology, psychology +rounds is weekly. We do weekly rounds. And +monthly SHU reviews, which are more intense +rounds. So, we didn't see Epstein every single +day. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Yeah. Okay. +1: That, we didn't do. We don't +do daily rounds. We do weekly rounds. +Sometimes, we are up there, we are up there +almost every day, especially when we were, our +SHU was full, because there is always inmates +that have concerns or needs. So, if we are up +there, and an inmate has a concern, we go to +that tier and see those inmates. +: Just those -- +: But as far as going cell to +cell, we do that weekly. +: - okay. Because this, +yeah, this last sentence said, "This is one of +the things the psych department looks for in +their daily rounds in the SHU -- +in our zounds - +- that there are two + + +94 +1 +2 +3 +4 +5 +6 +7 +8 +bodies in each cell." +: In our rounds. Like, if we +are doing our weekly rounds, and we notice that +-- +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +okay. +1: -- someone doesn't have a +cellmate, especially if we know that person is +a care two and above, we are going to say +something. Like, why is this inmate housed by +themselves? +So, when they said daily +rounds, you are not doing that every day. +_: Hmm-mm. +They meant your weekly +rounds. +1: Yeah. +: And do you know what day +of the week that was done back then? +: I don't. +: No? +have to look at the SHU logs. +1: I do not know the -. I would +: Okay. And do you know if +it was done on that Friday, on August 9th, the +day before? + + +95 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +1: No. But I do know, on August +8th, before I left for vacation, I personally +went up there, just to check on him, and he had +a cellmate at that time. +Right. Okay. +1: Anything else? +: Nope. +: "Dr. +was aware that +Dr. +attended the close out +meeting that week, +and discussed Epstein's +desire to have a single cell, but his need for +a cellmate. Dr. l +was unaware regularly +rounds by the correctional officers were not +being completed. She is considered executive +staff, so officers would not tell her they were +not being completed, and inmates wouldn't tell +her because of fear of retaliation by the +guards. +DI. +I noted Lieutenant +is very +regimented, and regularly does what she asks. +Dr. +was not aware that Epstein signed a +new will on August 8th. Had she known, it +would have been considered a red flag, and +Epstein would have been placed on psychological +observation. +The attorneys did not tell anyone + + +96 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +from psychological services that it had +occurred." So, we had a couple of questions. +How did you learn that he had signed a will? +: The newspaper. +: In the paper? +: That's not something that you +learned firsthand, from the attorneys, or by +being - +1: No. +: -- okay. +Do you know if he +actually, in fact, signed a new will on the +8th? +: No. Hearsay. +okay. Did you bring that +up during the interview, or did the agents ask +you about it? +: That, I don't remember. +: Okay. +1: How it came up. They may +have asked me a question, if I knew about it. +okay. +: And I may have said, probably +said no. +I didn't know about it directly from + + +97 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +them. I knew about it from reading it in the +paper. +okay. +1: But one thing I did say, +after reading the paper, gee, that would have +been helpful information. Because had I known +that, I would have said, that is a red flag, +and let's put him back on, and just watch him +for a few more days, and see if we can get more +information from him. About why he would do +that, or what was going on. +Should have the attorneys +notified you? +1: Well, the attorneys have +their own ethical, you know, confidentiality +issues. +: Mm-hmm. +1: So, you know, a lot of times, +attorneys call us all the time if they are +concerned about their patients. I mean, I get, +I used to get, like, several a week, where +attorneys would call in and say, you know, I'm +worried, I talked to my client on the phone. +I +don't like how he sounded. Can psychology +check on that inmate? +And I was, like, why + + +98 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +didn't they do that this time? +Because they +always do that. And we do. We go immediately. +So, if that was true, I wish someone would have +called us, but they didn't. +: All right. Thank you +(Indiscernible *01:15:31)Did you have the key +to the restroom?- I think that that's +(Indiscernible t01:15:36)person needed it. +1: Oh. +Is this the only one we +have? +: But, you know, again, like, +attorneys have their own ethical -. Like, they +can't -. I don't know what their ethical +standards are, but I guess, if he didn't say he +was going to kill himself, and he's just +signing a will, they don't -. I don't think +they have to tell, call us. It would be a +choice if they had a concern, that he was going +to hurt himself. +okay. +: But -. +: Well, before -. +1: Yeah. Yeah. + + +99 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: Did he ever bring up changing +his will in any of his your meetings, or the +psychological meeting -- +1: No. +: - psychological meetings +with him? +1: No. +1: That was the first time you +guys had, you ever heard that would be from - +1: Right. +: —- (Indiscernible *01:16:30) . +1: After the fact. I read that, +and I was, like -. +: And now, why would it be a +red flag? +: Because he is in jail. He is +not happy being in jail. He is facing a lot of +time. He's high risk. And he is signing a +will. You know, I definitely would have +interviewed him. I can't say 100 percent he +would be put on psych ops, but if he didn't +give me the answers that I was looking for, he +would have been put on some form of +observation, until we could get the answers +that we were looking for. + + +100 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: "Dr. +mentioned that +was the first day ever, she ever heard about +the will being changed. There was no +discussion with Epstein before -- +1: No. +1: -- about the will." +: Epstein never shared that +with me. It was something that I read after +the fact. +Mm-hmm. +: And again, I don't know if +it's true or not true. +: Sure. +: "On August 8th, 2019, Dr. +attended the SHU meeting. +She couldn't +recall all who was there, but it included unit +team members, executive staff, and attorneys +for MCC. Nothing significant was discussed +about Epstein at the meeting. She conducted +SHU rounds, to see Epstein." Is this what you +mentioned before, that before you went on +vacation? +1: Mm-hmm. +1: Okay. "He had a cellmate at +the time, and Epstein had the lower bunk. He + + +101 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +didn't have any visible problems, appeared in +good spirits, and reported getting along with +his cellmate. He had received his pack number, +which allows him to make phone calls, and he +had asked for his books from psychological +observation." When he received his pack +number, do you know if it was active, and was +he able to make phone calls with it? +: That, I don't know. That, +only unit team would know. +Do you know around what +time the SHU meeting would have been held? +1: Thursdays. Thursdays, at +that time, they say that my meetings have +changed with different -- +Sure. +: +-- every warden changes it. +: And what time -- +: — I believe they -- +- did you work? +: +Like, around 9:00. +- were in the morning. +Okay. +24 +25 +So, if around, like, + + +102 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +3:00, 3:30, the Marshals sent an email saying +that his cellmate was going to be transferred, +that wouldn't have been discussed at that SHU +meeting? +1: Hmm-mm. +about any emails - +1: No. +: And did you know anything +-- regarding -? +: And I didn't know the inmate +was -. The inmate -. I didn't know that he +went to court that day, or anything. I was not +even in town. +Right. I'm saying the +day before -- +1: Yeah. +- on August 8th, there +was emails that were sent from the U.S. Marshal +Service, saying that his cellmate Reyes was +going to be transferred to another institution. +I was just wondering if that was at all +discussed -- +_: No. Not that I -- +-- that wasn't discussed. +: — and I, likely, I don't + + +103 +1 +2 +3 +4 +5 +6 +7 +8 +know. Yeah. I was -. Huh. I don't remember +hearing that at all. +: okay. +: Because that would have been +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Even after the fact? +1: -- that would been something +that, you know, the lightbulb kind of would +have went on. +Sure. +: I was pretty shocked to find +out that he didn't have a cellmate. +: After he killed himself. +That was the first question I asked. When I +was away, and I was went to Vancouver, and the +times difference was off, and my flight was +delayed. I had slept for, like, two hours. It +was very strange. +I went into the restroom, +you know how you bring your phone? I know, +IMI. I pressed my phone, and all these alerts +came on, and everyone was texting me, and then, +I saw that he had hung himself, and I was just, +like, how could that happen? And the first +thing, when I called my associate warden, the + + +104 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +first thing I asked is, did he have a cellmate? +Because that was the first thing that came in +my mind. And she was, like, no. +What -? So -- +: So - . +: - who was this? +: I called | +And what did she say +about that? +: You know, she just said no. +And then, I was just, like, I started, like, +crying, because I was, like, why? Like -. +And did she respond to +where his cellmate was? +: She didn't. She was, like, I +You know, this was all +don't know, Dr. L +just that morning. +: I mean, she was probably, you +know, very upset, too. And that was it. I +mean, later on, I found out what happened, +which was that his cellmate went to court. +He +was -- +And so -- +: - bonded out, and that they + + +105 +1 +didn't replace the cellmate with him. +2 +: - so, that is not +3 +accurate information. So, who told you that he +4 +went to court and bonded out? +5 +1: That was later on. I don't +6 +remember the person who told me that. +7 +: But someone told you he +8 +actually went to court, and not transferred to +9 +a different institution? +10 +: That's what I had heard. +11 +okay. +12 +1: That he had gone to court, +13 +and then he was -. That might not be accurate, +14 +though. He was bailed out, or he wasn't, +15 +didn't come back. +16 +okay. +17 +: That's what I had heard. +18 +Sure. But you don't +19 +remember where you heard that from? +20 +: Hmm-mm. +21 +: okay. +22 +: Well, just to clarify, I +23 +think you mentioned it already. There was an +24 +25 +email that came up the day before, from the +Marshals, on August 8th, in the afternoon, that + + +106 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +stated that he was being +transferred - Reyes +was being transferred - to another facility. +He wasn't going to court. So, that morning, he +would, he wasn't going to court. He was +actually transferred out to another facility. +1: Okay. Okay. So -- +: Now, if an email like that +came out, whose responsibility would it have +been to make those notifications up, hey, +listen, Reyes is now gone? +: I mean, everybody reviews +that. I mean, the captain's review that log. +The warden. The executive staff. I mean, I +guess they would all see that. +: Would psychology have the +court production list? +: I don't always review the +court production list. No. +: Yeah. +No. You weren't +even there. +: No. Yeah. +I'm just saying - +1: No. +: - like, on, like, on the +9th, I guess there would have been a court + + +1 +production list that would have said Reyes, +2 +WAB, With All Belongings. +107 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +1: Right. I mean, I don't have +access to that. Some of my staff have that +correctional services box. +Mm-hmm. +: And they do review it, +sometimes. But I'm not so sure we reviewed it, +anybody in my department. +Yeah. And again, I know +you weren't even -- +1: Yeah. +- there, but so, should +have someone reviewed that? +: That's not something that we +did on a regular basis. +: Okay. +: You know, we - custodial wise +- we don't manage hands-on like that. +Mm-hmm. +: As much. Like, we're not +looking all the time. I think now, since this +event happened, we might become more involved +with that. And review those things. Like, +when I get the Marshal's list, I was, I look to + + +108 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +make sure they don't have any histories of +things, or there is a no Marshal's notices. +Mm-hmm. +: More so than ever now, +because, you know, we are hyper alert. +: Sure. +: But as psychologists, that is +not something that is our job to review, and +then compare it to the SHU list, and make sure +everybody - +Absolutely. +: - is cell, you know, that is +not something we do. +So, when Reyes was listed +as WAB, and was removed from the institution on +the count numbers and everything - - +: Mm-hmm. +-- should someone have +notified psychology? Now, this isn't Epstein. +This is his cellmate. +1: Right. +Reyes. +: I don't know so much as +notified us, but at least made - or I would + + +109 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +think - someone would make arrangements to say, +well, this guy is coming out, we've got to get +someone in with Epstein. There would be no +need to call psychology. Unless Epstein was +demonstrating any psychological issues, because +we were -- +Okay. +: - following him as needed, +and during our weekly rounds, anyway. So, if +he displayed, if he didn't display any mental +health problems, they probably wouldn't just +call us. +: So, were there any +problems, as you see them, that no one notified +anyone in your department that Reyes was gone? +: Well, the only problem is, if +they had planned on housing Epstein alone, and +not replacing Reyes, then we should have been +consulted, and spoken to about, do we think +that is a good idea? +1: So, that is —- +: But -. +1: -- but that whole - not -- +But that was never + + +110 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +changed -- +1: - not likely -- +: - so, he was supposed to +be housed with another cellmate -- +-- so, the fact that his +cellmate was gone, and he is supposed to be +housed with a cellmate, should have they -? +Should someone have contacted psychology to let +you know this cellmate is gone, we need to get +another cellmate in there? Is that something +that you should be a part of, or is that +something that was just custody? +: That is mainly custody. +: Okay. +: That is mainly custody. Now, +things are a little different. I mean, again, +things are put into place. That may not have +been in place before. Things we may not have +been as involved with. +: Mm-hmm. +1: We have become more involved +with. Because of lessons learned. So, now, +when they house anybody alone, they let us +know, do you recommend this? Like I was + + +111 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +telling you, there is a sheet. Do you +recommend this? And we always say no. +Mm-hmm. +: I tell my staff, never +recommend a single cell. Like, if we think +someone is going to be single celled, we are +notified. Oh, this person is going to be -. +DI. +come sign this, this form. But +before, we didn't do that. Okay, when Epstein +was there, we did not do that. +: okay. +: If they had a plan to put him +by himself, we would have been notified. The +fact his cellmate was leaving, we wouldn't have +been notified, unless the intention was not to +replace him with somebody else. Because the +intention was always to keep him in the SHU +with a cellmate. +Now -- +: I think custody's intention +were, too. +staff -- +- as far as people - +: It should have been. +-- that worked in the SHU + + +112 +1 +2 +3 +4 +5 +6 +7 +8 +: Mm-hmm. +- or, for instance, +anybody in custody, do you think there is ever +an excuse, especially in this specific instance +with Epstein, that for people to say, we didn't +know he was supposed to have a cellmate. Is +that - do you believe that that is an excuse? +Or a reason, I should say. Not an excuse. And +this is not, I'm not talking about psychology +now. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +custody or -. +What I'm talking about is +: No. I know what you are +saying. I mean, it comes from management and +it goes down. +Mm-hmm. +: You see what I'm saying? So, +as far as I knew, the lieutenant up there, as +far as what he had shared with me, is that he +let the officer's know. And that there was a +sign up there, from what I understand, on their +desk, that said he had to have a cellmate. +Okay? +Now, did you ever see a + + +1 +sign? +2 +I: I did not see that sign, +3 +because I don't go behind that desk. +4 +: Sure. +5 +: When I go. So -- +6 +: Because we knew that +7 +there was a sign stating that they had to do +8 +rounds on Epstein. It was a big orange sign. +113 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +But -- +Okay. +-- we have never come +across signs saying that he had to have a +cellmate. Aside from the very first day -- +-- I think -- +- that he was actually +housed with Reyes. +MS. L +: Right. But I mean, that is +something that is monitored by the SHU +lieutenant, and the operations lieutenant. +They were aware because the captain was aware, +and sits in executive staff. +: Sure. +: And the captain is under the + + +114 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +warden, and the warden would have wanted him to +have a cellmate. +: A 100 percent. +Absolutely. +: And supported our +recommendation for him to have a cellmate. So, +where the ball was dropped, I'm not 100 percent +sure. But I know executive staff were aware, +and I know that was a +strong recommendation on +our part. Whether the officer's, whether it +went down the chain, that, I will not know +because I am not in custody. +Mm-hmm. +1: How -- +: But didn't you say -- +: - how they advised them, you +know, the morning of their shift, this is what +you need to do. I don't know. +Isn't it something, +though, that you guys discuss, or psychology +discusses during training, saying that, hey -- +: Well, yeah. +-- inmates that are at +risk for suicide need to have, if they are + + +115 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +coming off -- +: oh, absolutely. +-- suicide observation. +So, that is where I mean -- +1: That is where - +- by, like - +: -- like, the yearly training. +I mean, you would think, you know, with the +yearly training, with the annual training, with +the SHU, there is also a SHU training, a +quarterly training that I teach suicide +prevention. So, I teach suicide prevention +quarterly, to SHU staff. Where I have a slide +show that talks about the cellmate, and the +need for the cellmate. So -- +What about during their +annual refresher training? Is it also +discussed? +: Yeah. Also. Yes. +So -. +So -- +: -- it's quarterly and annual. +And you say that same +thing during the annual training? +- Yes. +okay. So, not only are + + +116 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +the SHU staff getting it in their quarterly +training, but every staff is getting it in the +annual training. +Okay. +1: Everybody. +So, that is what I mean +by, is there ever an excuse, saying that we +didn't think he needed one? If they receive +this training, shouldn't have they known -- +: Right. And also, I don't +know, I mean, he was a high-profile inmate. I +think everybody was aware of that. +Okay. +1: So -- +: So, do you -- +: -- if he didn't have a +cellmate, they would know, even if they thought +he wasn't supposed to, they would know that he, +they should be rounding every half an hour, and +checking on, particularly a high-profile +inmate. +: Now, does - +- every single staff + + +117 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +member of MCC, regardless if custody or not, do +they take that annual refresher training? +So, R&D -- +: They are required. +- you know - +: Yes. +okay. +1: They are required. +: Okay. Perfect. +: Okay. "Dr. +never +suggested a cell room with a camera for +Epstein, because she wanted him to have a +cellmate." +1: I don't make those decisions, +as far as who goes on Ten South. Ten South is +a high security unit where we house many of the +SAMs inmates. I don't know if you are familiar +with the SAMs, but they are in Special +Administrative Measures. On occasion, we have +had high profile inmates, but that is at the +discretion of the warden. Not psychology. +Whether he wants to house a high-profile inmate +up there. +We had Bernard Mayta (Phonetic Sp. +*01:30:19) up there. We had El Chapo (Phonetic + + +118 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Sp. *01:30:20) up there. +We had the Russian +arms dealer up there for a while. So, we have +had people there. But the warden - and I don't +know why, because I was not in those meetings - +decided that he was not going to place him in +Ten South. So, if you are not going to be in +Ten South, you are going +• to have a cellmate. +You know, as far as I am concerned. But I did +not -. I was not -. It was not up to me +whether he be placed on Ten South and a camera. +Was that ever -- +: My recommendations were not +sought. +- yeah. I was going to +say, was it ever - +1: No. +-- even discussed with +you? +: No. +: Okay. +: It was told. It wasn't +discussed. +What was told? I'm +sorry. +1: That he was not going on Ten + + +119 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +South. +But that's what I mean. +Did Ten South even come up in discussion? +: Just that he wasn't going to +be housed there. +: Okay. +1: That the warden had decided. +I was informed by legal. And I said, oh -- +And when were you +informed that? +: Earlier -- +Was that before? +: +- earlier in his +incarceration. +Okay. So, while he was +alive? +: Okay. So, at the end -- +: Yeah. Earlier in his +incarceration, I received a phone call that he +wasn't going to be housed in Ten South, that it +was decided, by the warden, that he wasn't +going to put him up there. So, when I was +being told that, knowing if he was going to be +on Nine South, then I would say certainly + + +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +suggest a cellmate. But I would have had no +problem him being on a camera in Ten South. +: Would you have a +preference? +From Ten South or Nine South? +: If I was asked, I would have +preferred, I would have said Ten South because +I had been there for so long, and had seen so +many high-profile inmates up there, and being +on a camera 24/7. +So, you said psychology +always recommends a cellmate, but in this +instance, you would actually recommend him +being housed alone +with +a camera on him? +: I think having a cellmate is +a good thing, but when somebody is this highprofile on other levels, in retrospect, it +would have probably been not a bad idea. +: So, in retrospect, and +obviously, we can all Monday morning - +- quarterback. +Yes. +And unfortunately - +- that is what we are +120 + + +121 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +doing. +: But, like -- +- at the time, do you +believe that you would have thought that Ten +South would have been more appropriate over +Nine South? +: I don't really want to say +because -- +Sure. +-- I don't make those +decisions. +No. +: I mean -- +But you weren't +consulted? They -- +: I wasn't consulted. +: +- no one told you. +1: I was told. So, once that +happened, then of course, I was going to +suggest he have a cellmate. +: Okay. But it was the +warden's call, as far as you know? +: As far as I know. That's what + + +122 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +I was told by legal. Which was the warden has +decided he will not be on Ten South. They are +going to house him on Nine South with +Tartaglione. +Okay. +1: Let me finish that -- +: Yes. +1: -- (Indiscernible *01:33:20). +That's the last paragraph. "Rooms with cameras +aren't always perfect due to the guard having +to maintain a constant eye on the camera +screen. She noted she has never gone to +attorney conference for +any other patients or +inmates. +She believes MCC psychological +services did all they could for Epstein. And +ultimately, the lack of a cellmate, and under +staffing contributed to his death. Three +suicide risk assessments were completed on +Epstein, which is unusual. One of those was +completed due to a judge's order." Is it +normal for a judge to request a psychological - +? +: It is not uncommon, +especially when the judge knew he had been on +watch before. + + +123 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +1: Mm-hmm. +: So, I think, I don't think he +was ordered the first time, to be placed on +watch. I think it -. I don't remember which +time it was that the judge ordered it. But +judges will, if there is, if they have ever +been on suicide watch in the past, when they +leave a court proceeding. If it was the time +that he was denied the bail, I don't know which +was the time that the judge ordered it. +: So, your -. +Would your notes say when +it was? +: Possibly. Possibly. +Possibly. +1: Yeah. +So, you don't think it +was the first time, though? +MS. I +: I thought the first time I +did it precautionary. I don't know if it had +the judge's order. +: Now, when you say there +are three risk - suicide risk assessments were +included, completed on Epstein. + + +124 +1 +2 +3 +Or Epstein. When he +first came on, when he, on July 23rd, what was +the third? +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: I think that is when he came +back and was denied the bail. +: And do you think that was +probably the one that the judge -? Because +obviously, you do it when they come on, right? +And then, you do it if they try to attempt +suicide. +1: Or maybe the judge -. I +don't know if it was the first time. Maybe it +was the first time. +Because I think the second +time was Dr. +Which I really +complimented her on. I think she did it out of +precaution, because of what happened in court. +: Okay. And that was -- +: I think she did it on her own +instinct. Not because she was told to. +: Okay. +: Wait. I have an event that +took place on August -- +: -- August Ist. It looks like +the correctional systems received a form from + + +125 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +the U.S. Marshal Service, the previous day +stating that Epstein had reported suicidal +tendencies. I guess he went to court. And he +reported suicidal tendencies. +So, the Marshal +Service reported that to correctional systems, +and correctional systems notified that to +psychological observations. Psychs. +: That was August Ist. +1: Do you believe that might be +the third time? +: That would have been, +like, the day after he came off of -- +1: Yeah. +- psych observation. +: Right. And they always put +suicidal tendencies on every single one of +them. So, I am thinking, because he was just +coming off watch, he might have said, I was on +watch. +All right. So, that is - +- +1: But I don't -. +: - you think the Marshals +do this frequently? +: Yes. + + +1 +2 +3 +4 +5 +6 +7 +8 +the same thing. +Ist? +126 +This isn't -- +1: They all say -- +- that wasn't -. +-- suicidal tendencies. +okay. +: And there, it's, they all say +All right. So, that +wasn't abnormal that they wrote that on August +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +that. +: Not if he had recently been +taken off of watch, and they were aware of +: Okay. +But you don't know what +the third instance was, with -? Because we +have, again - +into jail. +1: +One was when he first came +-- right. +: Remember, we did, we had him +on -- +Yup. +: -- and he was mad. The + + +127 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +second time, I believe was when, maybe when the +Marshals -. I don't know. I don't know. +So, we know the two. +1: Yeah. +I'm just trying to -- +1: The third one -- +- to figure -. +- was when he had, when he +actually had the - +Yeah, yeah, no -- +-- Marshals -- +- I know. They are my +two that I know. Is when he first came on, +July 23rd. +1: And I think the other one was +when he came back from court. +: On the August Ist? +: Yeah. I think so. I have to +look. It might be. I have to look at my +notes. +times. +: okay. +1: But those were the three +No. Because in +your report, it kind of - because obviously, it + + +128 +1 +2 +3 +was probably taking so long - it kind of jumps +really quickly from July 30th to basically the +end. +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +1: Okay• +: So, that was just -. So, +I was wondering -- +: Okay. +-- if we were missing +something there, and that sounds like maybe +that is what we were missing. +: Okay. If you wanted me to +look at my notes, I could do that. +: This. Do you know? Because +I think -- +I'll just -- +: - that will help you. +: - real quickly cover +this with you. I think we already did. This +was the 302 with I +Who is that? +1: She is the forensic +psychologist that removed him from watch the +first time, and stepped him down to psych ops. +: okay. So, in part of her +302, we're just going to cover this quickly. + + +129 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +1: Mm-hmm. +Just because we're +running out of time. It says, " +stated psychological observation allowed +Epstein to possess hygiene products, two +novels, to attend his legal visits, and to +shower." And as we already stated, he was +authorized legal visits while he was on +observation. +authorizations. +okay. All right. +1: So, she did those +okay. +: After she took him off. +: Okay. +says, and that part says, +So, and then, it +stated she +discussed the decision to step down Epstein +with Dr. +| and associate warden +•" Now, when she says, +stated +she discussed the decision to step down Epstein +with Dr. +I and associate warden +" do you know which step down she is +talking about? +Is she talking about watch_ toed +observation? +That's what -- + + +130 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +MS. I +: Yes. +observation to SHU? +- okay. Rather than +warden +: Correct. +Okay. And with associate +is that a normal thing +that she would discuss that decision? She +would discuss that with an associate warden? +Is that normal? +: Yes. I mean, maybe +gave her a call. Maybe she gave +a call, just because he was who he was. +We don't do it with every single inmate. +We +send out a notification to, like, all executive +staff. And every day, on who is on watch, he +was removed from watch. +An average inmate, +maybe they wouldn't have had a discussion. +: Mm-hmm. +: Maybe it was because it was +Epstein. +: And this is where -- +1: Yeah. +: - it goes into the -. +Do you have any knowledge that around this +time, executive staff, or anybody at the + + +1 +institution, was contacted by either the +2 +attorneys or the judge, saying he needs to be +3 +taken off of suicide watch, and put to +4 +psychological observation, so the attorney +5 +visits may -? +131 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +1: We never got a call like +that. +No? Okay. +1: Yeah. +: And you don't know that +mentioned that to you guys? +1: No. +: Okay. +_: Not that I know of. +stated both +: Okay. It says, +and +concurred with her determination regarding +Epstein. +stated, 'I made the +decision with the consent of l +and +..'" +Is that correct? +: Right. I mean, she came and +discussed it with me. And gave me all of the +reasons she felt he was written to be stepped +down. +Great. + + +132 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +questions. +1: I have a few follow up +So, this is the very end. +1: This is the very end. +Sorry. +: It's okay. +1: That's okay. +It's taking longer than +we expected. +: It's okay. +: When inmate Reyes was chosen +to be Epstein's cellmate after he was brought +back to the SHU, do you know who was involved +in that decision-making? +: Executive staff, most likely. +Or correctional staff. +Probably the captain. +The captain and the AW over programs. +: And do you think that +everyone, in terms of captain, the lieutenants, +and even the SHU staff would have known who +Reyes was, that he was Epstein's cellmate? +1: I mean, I would hope that was +discussed. But again, I don't know if it was +discussed with them. But the captain should +have passed it onto the lieutenants, and the + + +133 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +lieutenants should have passed it to the staff. +: And based on the +recommendation, as you mentioned, from your +office and also through the chain of command, +they should - everyone should have known that +Epstein needed a cellmate? +: And if everyone knew Epstein +needed a cellmate, they should have technically +also known that his cellmate was Reyes? +: I would think so. +1: I would hope so. +1: And when they came up the, +came up with the name, with the list of names +to place as a cellmate for Epstein, did they +have other names also chosen? Or just Reyes? +: Hmm. That, I don't know. +Okay. You are not aware? +1: Because I didn't make those +decisions. +Do you know if there -- +1: At the time. +: - was a plan, if he was +to leave, someone else would go into his place? + + +134 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: I don't know that. +Okay. That was a custody +- +-- decision? +1: Determination. +: Okay. +1: Do know if he was prescribed +any medications? Epstein was prescribed any +medications? +: I would, again, have to see +his chart. +think so. +: I don't -- +1: Not that -. +: -- I don't remember. I don't +okay. +: I mean, from psychiatry. +I want to show -- +1: I don't remember. +- we will jump into +that. +- Yeah. +Just in a couple of + + +135 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +minutes. +1: I just had a quick question. +You mentioned that he told you the first time +that he had a bail hearing. +1: Mm-hmm. +1: Do you recall him mentioning, +in your last meeting with him on August 8th, +that he was scheduled for another bail hearing? +1: I don't recall. +: He didn't mention that? +Okay. +1: I don't recall. He may have. +1: okay• +1: He may have. I know he was +trying to get several hearings, so it is very +possible he did. +: So, what we have here is an +after-action review. It was conducted by the +Bureau of Prisons. +MS. I +the noted -. +: And I'm going through some of +Have you seen this? +No. +okay. + + +136 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: Basically, do you know what +an after-action review is? +1: Yes. I do. +: Okay. So, this was done by +the team that was sent down to do on running +Mr. Epstein's death. And maybe the -- +Immediately after their +death. +: -- immediately after. +: There is a note. "On July +9th, 2019, at 12:35, health services completes +a history and physical for inmate Epstein. +This assessment was done in lieu of an intake +screening, which should have been conducted +within 24 hours of arrival." It looks like he +arrived on July 6th, but the intake screening +wasn't done for him. +: That's medical. +1: That's medical. Okay. +: We did it the next day. We +do them within 24 hours. +1: Okay. "On July 18th, 30-day +psychology reviews are conducted for the entire +SHU population. Inmate Epstein was not in the + + +137 +1 +SHU at the time due to an attorney visit. The +2 +review was never conducted." +3 +: He was probably seen in +4 +attorney conference, but it wasn't conducted if +5 +he wasn't in the SHU at the time. +6 +1: Should they have followed - +7 +psychology - have followed up? +8 +: I would have to see my +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +records. +1: okay. +: To see if there was a reason, +or if we put in a note, subsequently. +: Understood. And you said, +the notification by the U.S. Marshal Service on +August Ist, you said that would be routine, if +he came off of suicide watch or psychological +observation, went to court, and they saw that, +they would normally make a routine +notification? +1: They often do. Yes. +: Okay. +1: Unless they are not privy to +it. You know? But if they are, they would, to +cover everything. +But you don't know -- + + +138 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: Yeah. +- anything specifically +he was doing on August Ist, that would have +caused them to make a note? +1: No. +: Okay. +1: Now, I don't have these +documents in here, to show you, but it was +flagged that, "The psychology intake screening +contains errors in identifying details. Inmate +Epstein is referred to as a black inmate, and a +different inmate's name is used within the +report." +1: Yes. One of the +psychologists made an error. Perhaps. It was +a template-ish error. I don't know. +: Okay. +: To be honest, it was probably +a template error. She was probably writing it +quickly, and when she proofread it, she didn't +catch it. +1: Okay. "There -- +1: Mm-hmm. +1: -- there are errors within +the risk of sexual abusiveness report, such as + + +139 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +referencing an inaccurate program statement, +and noting a history of prior prison sexual +predation." +Okay. Again -- +: (Indiscernible *01:44:50)? +: - again, that is a +checklist. It was probably a typo on the +checklist. +1: Mm-hmm. +: By the psychologist. +It was +a seasoned psychologist. I don't read every +single note that goes into the record. The +only time I read every single note is when +somebody is a probationary psychologist, and +unlicensed. +And who was -- +: Then I will -- +: - the psychologist? +: - the psychologist at the +time was Dr. +Okay. +1: And I just think they were +typos. Looking back and having a conversation +with her, they were typos, but she is a +seasoned psychologist, a forensic psychologist, + + +1 +and I couldn't possibly read every note that +2 +goes in the record. Or else I would never +140 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +sleep. But I read, you know, like I said, if +they are unlicensed, on probationary, then I +read all of the notes that go into the record. +1: So, it is not that +didn't do the intake properly. +It was just, it was a format that she probably +used. +: Yes. +: Okay. Now -- +: Definitely. +: -- there is another incident, +"July 16th, 12:48 p.m., inmate Epstein is seen +by psychology in the presence of his attorneys, +while conducting a legal visit. This visit +recommended no follow up. This visit was at +the request of inmate Epstein, that was wholly +inappropriate. Inmate Epstein attempted to +establish guidelines for communication, and +bring his attorneys into the fray regarding +mental health treatment be provided by the +institution. +It is not typical for the Bureau of +Prisons to provide psychological intervention + + +141 +1 +in the presence of others, nor is it +2 +appropriate for an agency psychologist to meet +3 +with the inmate attorneys." The summary they +4 +put on there is, "On July 16th, 2019, a +5 +psychologist met with inmate Epstein in the +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +presence of his attorneys. This visit was done +at the request of inmate Epstein, that appears +to have been the purpose of airing grievances +with conditions of confinement. +This is a highly abnormal event. It is +not typical for the Bureau of Prisons to +provide psychological intervention in the +presence of others, and agency psychologists +should not - should neither provide mental +health intervention in the presence of others, +nor engage legal representation regarding +institution operations or conditions of +confinement. +Although the specifics of what information +the psychologists are unknown, any items shared +could be viewed as an unauthorized release of +information, both regarding inmate Epstein's +mental health treatment, and institution +operational information." + + +1 +2 +3 +4 +5 +6 +7 +8 +that, I guess? +-? +142 +1: Can you elaborate -? +What is your response to +: I wasn't aware -- +Do you agree with it, or +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: — if one of my +psychologists, or I went up one time, and I +think another one of my psychologists went up, +it was probably just to see that he was okay, +and that he didn't need anything from +psychology. So, the intention was to check on +him. It wasn't to breach any security, or it +wasn't to meet his demands, or anything like +that. It was probably because he did spend +eight hours up there, and it was more well +meaning that we just probably just wanted to +see if he had any needs from our department, at +that time. Or on that one occasion, he was up +there when that psychologist was conducting her +rounds in the suicide watch area, and he wasn't +there. And she went up there to check on his +mental status, to see if he was okay. +1: So -. + + +143 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +one been? +And who would have that +1: I think it was Dr. +that +went up there on one occasion. And I think I +went up there on one occasion. That's when he +made that comment to me. +1: But -. +: Mm-hmm. +: Now, so, what is your —- +: I did not share -- +: - do you agree -- +: -- anything with his +attorneys. He stepped out of the room. Like, +the attorneys were sitting at the table. And +then, there is the door, and he walked up +towards the door. And I just said, you know, I +think when I went up there, you know, are you +okay? Have you been eating and sleeping okay? +I didn't discuss any intimate details of his +childhood, or anything like that. It was kind +of just, like, are you okay? +Do you have any thoughts of harming +yourself? Have you been eating and sleeping, +or do you have any concerns like that. And you +could see my notes, it would probably indicate + + +144 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +what I did ask him. It was well meaning. I +certainly didn't engage. I don't know. I +doubt Dr. +I did, because she is very rigid. +And any discourse with his attorney about +anything. I think his attorneys may have made +a comment to me, but I think I ignored it. +: Okay. +: But yeah. +so, you -. +: If that is what they are +referring to, you would have to re, you know, +show me the contacts, and the context. The +contacts, the actual site contacts that they +are referring to. +1: Yeah, they don't -- +: Well. +1: -- they don't list it on +there. +I mean, so - +- i mean, those are the only... +-- two -- +: — two times that we went up +there, and that was more well meaning, to check +on his mental status. + + +145 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Sure. +: It was certainly -. +: And not a discussion -- +so, do you - +1: - with the attorneys. +Sorry. +But as -- +: No. +: -- this is the BOP's +findings. This isn't on ours. We are just +saying - +1: Yeah. +: - do you agree with that +finding, or do you think that that is +inaccurate, the way that they have that? They +are saying that you should not have done that? +: I would say it is 50/50. I +mean, now, in retrospect, if it could be +perceived that way, it is probably not the best +situation. However, circumstantially, this guy +was in the conference room from dawn until +dusk. And we felt a need to check on him, to +see if he was okay. So - +What -. +: —- I would say we just + + +146 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +probably weren't aware that it wasn't a good +thing to do. +1: Okay• +: We meant it to be -- +Okay. So, and -- +1: -- a good thing. +- and this prior to his +first suicide attempt, it looks like, on, it +says July 16th. +1: Yeah. +Okay. +1: So, that was probably just to +check on him due to our concerns. +Sure. +: In reading that, I probably +would not do that ever again. Because it is +perceived that way. But we weren't aware that +that wouldn't - that that was an unusual +circumstance. +Sure. +: It doesn't spring upon us +frequently. We don't have inmates that have +that kind of money to sit in there for nine +hours a day. + + +147 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +happened before. +: Yeah. +: You know? So, that has never +: So, what, in retrospect, +I guess, what should have happened? Should +have you asked him to be excused, and seen him +a private room? +: I guess we could have done +that, but that would have interfered with his, +and he is paying his attorneys. It is just, I +would have to probably consult on that further. +Has anyone -- +: Because +-. +- spoken with you about +this? +1: No. +: Okay. +: You just mentioned something. +You said it is highly unusual that somebody is +sitting in attorney conference for that long. +Is that not allowed for him? Was that not +allowed for any other inmates? Was he the only +inmate who was, that was allowed to? +: I think he was the only +inmate that had that kind of money. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: Yeah. It's -. +1: okay. +: To pay an attorney for nine +hours. +: okay. +1: To sit in a conference room. +You know, usually, they last about an hour. +So, I had never seen that before in all my +years in the prisons. But it is not like you +can't do it. I guess if you have the money, +and the resources to have different attorneys +come, to cover your whole day -- +1: okay. +: -- then -. +: I just have one more topic, +and then it is done. +1: Okay• +: So, were you aware that Mr. +Epstein was allowed to make an unmonitored +phone call on the evening of August 9th? +1: No. +so, us august 9th, it Locks +like he, his pack and PIN was provided to him, +but it was never set up. So, he requested a +phone call, and it looks like the unit manager +148 + + +149 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +took him to the SHU, brought back from attorney +conference, and placed him in the shower. +_: Mm-hmm. +: Mm-hmm. +: Plugged it into the legal +line. +: Mm-hmm. +: And he said he wanted to talk +to his mother. So, the unit manager dialed out +the number. A guy answered the phone. He +handed the phone, the phone over to Mr. +Epstein. +1: Mm-hmm. +1: And he left. So, Mr. Epstein +was allowed to make the phone call. It was not +monitored. And what do you think? Do you +think that should have ever been allowed? +is not allowed. +: That is never allowed. That +1: Do you think that played any +part into what happened that night, being the +fact that he was allowed to make a phone call, +unmonitored, a phone call? Remember, he +mentioned that it was to his mother. + + +150 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +1: But we learned that his +mother has been deceased for a while. +This isn't really for her +to answer. +1: That, I don't know. +So, as far as, this is +something that we skipped over in your +interview report, though. It says, "On August +8th, 2019, Dr. +attended the SHU meeting. +She couldn't recall all who was there. But +noted," - so, this talks about that meeting, +and it said that, "Epstein had received his +pack number, which allows him to make phone +calls, and he asked for his books from +psychological observation." So, are you aware +that he actually did receive his pack number? +Pack and PIN number, so he could actually make +calls? +: I probably was privy to it, +if it was mentioned in the SHU meeting. But +that wouldn't have any psychological meaning, +other than he could make the calls, and they +would bring the phone to his cell, which is +what they usually do, and he can make the phone +calls. + + +151 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +So, you don't recall if +he was actually provided a pack and PIN number +or not? +: I don't recall. +okay. +1: Because I don't set that up +or anything. It could have been mentioned in +the SHU meeting. But that doesn't directly +impact mental health services. +okay. +1: So. +: So, and you don't know if +it was actually - not only was he given a pack +and PIN number - but you don't know if it was +actually set up or not? +: That, I don't know. +: Okay. Go ahead. +: And I don't know if it played +a role. +Okay. +: You know, I don't know. +: That is the last two. +Yeah. Go ahead. +_: Okay. +So, do you think Mr. +Epstein took his own life? + + +152 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +: Yes. I mean, it would be +highly unlikely that he didn't. I can say that +psychologists, the difficult thing is that we +are psychologists. +We are not psychic. But +the events leading up to it, too, that period +of time, he appeared psychologically stable. +But the information that he received, according +to what I heard the night before, and all of +that information being unsealed, and him being +alone with his thoughts, +and thinking that +maybe, perhaps he would have to spend the rest +of his life in jail, and that all of these +high-profile individuals information was going +to come out about them. +Could he have, at that moment, just felt +completely hopeless, and thought of ending his +life? Yes. That is very possible. You know, +that is very possible. Prior to me leaving, he +wasn't given any of this information, and he +had a lot of hope, he had a lot of resources. +Perhaps he thought, you know, maybe he could +cooperate, or get some kind of a deal. I don't +know what happened at that meeting. But having +been in the prison system as long as I have +been, and being a psychologist, sometimes when + + +153 +1 +people get really bad news, and they feel very +2 +hopeless, and the opportunity is there. +3 +They will take that opportunity. So, yes. +4 +It would be highly improbable, you know, the +5 +way our prison is set up, that someone could +6 +have snuck up there and harmed him, in some +7 +way. The way that the tiers are and +8 +everything. So, I think the higher probability +9 +is that he did kill himself. +10 +1: That leads to my second +11 +question. The last question. +12 +1: Yeah. +13 +1: Do you have any reason to +14 +believe that Epstein did not take his own life? +15 +16 +17 +he didn't. +1: I have no reason to believe +: Do you have any other follow +18 +19 +up questions? +20 +21 +: No. +Is there anything +that we missed, that we should know? +1: Not that I can think of. +22 +Just that, you know, we -. +No. Not really. +23 +No. +24 +Okay. Great. +We can't +25 +thank you enough. + + +154 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +MS. I +1: Yeah. +: So, again, it took longer +than we expected, but you were extremely +helpful. +1: Thank you. +is the case agent, +so if you have any questions or anything -- +1: okay• +- you can {Indiseernible +*01:57:25łgo directly with | +: Thank you. +: Thank you for taking your +time. +: If there is anything else I +can do, or anything I can clarify, with regard +to the case, or it you want me to review some +notes, if anything wasn't clear, because like I +said, I probably, to be more specific, if I had +those notes, I would know when the Marshals +came in, because it is kind of a blur to me. +It has been a few years. It was probably the +most traumatic event in my entire career. +: Oh, wow. Yeah. +- You клон? +Sorry to hear that. + + +155 +1 +2 +3 +4 +5 +MS. I +much for that. +: So, yeah. +Okay. +well, thank you so +6 +7 +8 +: Thank you. +: If anything comes up, or you +have anything that you want to share, please, +reach out. +: Yes. Thank you. +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +Okay. It is currently +11:18 a.m. on Wednesday, October 27th, 2021. +This is Senior Special Agent I +I am turning off the recorder. +21 +22 +23 +24 +25 + + +LIMITED OFFICIAL +USE +1 +2 +3 +4 +156 + + +1 +2 +3 +4 +5 +6 +7 +8 +157 +CERTIFICATE +I hereby certify that the foregoing pages +represent an accurate transcript of the +electronic sound recording of the proceedings +before the Department of Justice, Office of the +Inspector General in the matter of: +Interview of +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Brianna Rose Burto +Brianna Rose Burton, Transcriber \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/20e4cf427ac26ac9b109875fbb919c52722136c3df8544244fc794292064f9a3.receipt.json b/vision-fixhub/ds9-parsed-01/20e4cf427ac26ac9b109875fbb919c52722136c3df8544244fc794292064f9a3.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..8bca86bf81977dae8cb774ac4ccec5880a0e0a5b --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/20e4cf427ac26ac9b109875fbb919c52722136c3df8544244fc794292064f9a3.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -11592, + "dataset": "marble-joined", + "doc_id": "20e4cf427ac26ac9b109875fbb919c52722136c3df8544244fc794292064f9a3", + "engine": "marble-apple-vision", + "event_count": 163, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "2eb08ce649c58ea88058052b9f6a389b63490a3153939b9930d4678183f7946f", + "output_sha256": "2b12865f7e0fe608a6f4a72a530d44bd35000a4d4fc657b71528c2fe9099d146", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/20ea0d41379b3b1bda34cec80c53210c36c559265988f9b7484c5757309e29fa.md b/vision-fixhub/ds9-parsed-01/20ea0d41379b3b1bda34cec80c53210c36c559265988f9b7484c5757309e29fa.md new file mode 100644 index 0000000000000000000000000000000000000000..2152025afb690bebdc3d4f028e7f2178a70ebc2f --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/20ea0d41379b3b1bda34cec80c53210c36c559265988f9b7484c5757309e29fa.md @@ -0,0 +1,29 @@ +From: +To: +Cc: +Subject: RE: [EXTERNAL] Proposed Jury Questionnaires +Date: Sun, 10 Oct 2021 18:25:37 +0000 +Attachments: JOINT_Proposed_Voir_Dire_Sent_(Reponse_to_Defense_v1) doex; +JOINT +Proposed_Jury_Questionnaire_(Gov't_Response_to_Defense_v2).docx +Thanks again for the very helpful guidance. Attaching our proposed drafts to send to the defense. Their language that we +disagree with is in red and our proposed language that they rejected is in blue. We flagged footnote 2 and 3 of the +questionnaire if there is additional language you think we should add. When we email the defense, we plan to talk to +them about the victim names being included in the questionnaire and go from there. We figured it was worth seeing if +they will agree to the small edits in track changes on the charges and on trial length (since we have a letter due on +Tuesday). The questionnaire formatting is finnicky, so if you prefer to chat through something please let us know. We +would like to send the docs to them this afternoon in order to meet the deadline tomorrow. Thanks! +From +To: +Cci +Sent: Sunday, October 10, 2021 T1R23 AM +Subject: Re: [EXTERNAL] Proposed Jury Questionnaires +One other global thought/objection: they have a lot of questions that are framed in a very argumentative way. The court +should ask these things neutrally if at all. +Sent from my iPhone + + + + + + diff --git a/vision-fixhub/ds9-parsed-01/20ea0d41379b3b1bda34cec80c53210c36c559265988f9b7484c5757309e29fa.receipt.json b/vision-fixhub/ds9-parsed-01/20ea0d41379b3b1bda34cec80c53210c36c559265988f9b7484c5757309e29fa.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..f9e8908ea1c4ddda429a96bd28460cef3c9eb9ea --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/20ea0d41379b3b1bda34cec80c53210c36c559265988f9b7484c5757309e29fa.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -48, + "dataset": "marble-joined", + "doc_id": "20ea0d41379b3b1bda34cec80c53210c36c559265988f9b7484c5757309e29fa", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "15958a59da4172fd777f5851b0ff92b36045f58e1ba1a470c199c4909f76a3ec", + "output_sha256": "7c517d337ee0bbbc69f2dce0c88d22d2bfef26f0af9ff7dc91ad27571120ab05", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/212abc3f0dfb8b4602cfb359863ae45efe9fb3843c379afb9ca439e795491183.md b/vision-fixhub/ds9-parsed-01/212abc3f0dfb8b4602cfb359863ae45efe9fb3843c379afb9ca439e795491183.md new file mode 100644 index 0000000000000000000000000000000000000000..de162e4acd019e2136b2c33dfcf73e4711a7799a --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/212abc3f0dfb8b4602cfb359863ae45efe9fb3843c379afb9ca439e795491183.md @@ -0,0 +1,236 @@ +Case 1:20-cr-00330-AJN Document 252 Filed 04/27/21 Page 1 of 9 +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +USDC SDNY +DOCUMENT +ELECTRONICALLY FILED +DOC#:_ +DATE FILED: 4/27/21 +United States of America, +-V- +Ghislaine Maxwell, +20-CR-330 (AJN) +ORDER +Defendant. +ALISON J. NATHAN, District Judge: +Defendant Ghislaine Maxwell seeks an order authorizing a subpoena pursuant to Rule +17(c)(3) of the Federal Rules of Criminal Procedure. As detailed in the subpoena and Maxwell's +moving papers, she seeks authorization to serve a subpoena to the law firm of Boies, Schiller and +Flexner LLP. BSF has filed a letter in opposition to the subpoena request. Additionally, the +Government submitted a letter requesting that it be given notice of all pending and future +subpoenas applications, an opportunity to challenge them, and copies of any documents +produced. For the reasons that follow, the Court denies Maxwell's motion as to Requests 1 +through 8 and Request 12 and reserves judgment on Requests 9 through 11. The Court also +denies the Government's requests, though it will direct the Government to notify the Court of its +views as to Requests 9 through 11. +I. +Legal Standard +Rule 17(c) permits subpoenas ordering the production of "books, papers, documents, +data, or other objects." Fed. R. Crim. P. 17(c)(1). When the subpoena seeks the production of +personal or confidential information about a victim, it may be served on a third party only by +court order. Fed. R. Crim. P. 17(c)(3). +1 + + +Case 1:20-cr-00330-AJN Document 252 Filed 04/27/21 Page 2 of 9 +The purpose of Rule 17(c) is to facilitate the trial by designating a time and place prior to +trial to obtain and inspect evidentiary material. See United States v. Nixon, 418 U.S. 683, 698-99 +(1974) (citing Bowman Dairy Co. v. United States, 341 U.S. 214, 220 (1951)). It is not intended +to provide an additional means of discovery or to serve as a general "fishing expedition." Id. at +698-700. As a result, courts must be mindful not to allow the Rule 17(c) process to become a +"broad discovery device" that would undermine the discovery procedures set forth in Rule 16. +United States v. Cherry, 876 F. Supp. 547, 552 (S.D.N.Y. 1995). Thus, if an item is not +discoverable under Rule 16, a party cannot make it discoverable simply by subpoenaing it under +Rule 17. United States v. Barnes, No. S9 04-CR-186 (SCR), 2008 WL 9359654, at *2 (S.D.N.Y. +Apr. 2, 2008). +To determine whether issuance of the subpoena is appropriate, the Court considers the +factors articulated in United States v. Nixon, 418 U.S. at 699-700. In Nixon, the Supreme Court +explained that in order to require production prior to trial, the moving party must show: (1) that +the documents are evidentiary and relevant; (2) that they are not otherwise procurable reasonably +in advance of trial by exercise of due diligence; (3) that the party cannot properly prepare for +trial without such production and inspection in advance of trial and that the failure to obtain such +inspection may tend unreasonably to delay the trial; and (4) that the application is made in good +faith and is not intended as a general 'fishing expedition."" Id. at 698-700. To clear that hurdle, +the Court considers (1) relevancy, (2) admissibility, and (3) specificity. Id. at 700. +Il. +Discussion +A. The BSF Subpoena +The proposed subpoena makes twelve requests. Some of the requests relate to documents +that Maxwell believes will be relevant at trial. For others, the proffered relevance relates to +2 + + +Case 1:20-cr-00330-AJN Document 252 Filed 04/27/21 Page 3 of 9 +Maxwell's pending motions to suppress evidence. While ordinarily Rule 17(c) is "trial-focused" +and "may be used only to obtain materials admissible as evidence at trial," at least some courts +have held that Rule 17(c) can be used to compel the production of documents in connection with +a suppression hearing. United States v. Louis, No. 04-CR-203 (LTS), 2005 WL 180885, at *3 +(S.D.N.Y. Jan. 27, 2005). Even then, the requests fail for the reasons stated below. +Requests 1 through 5 all fail on the basis that they do not comply with Nixon's specificity +requirement. Requests 1 through 5 all target communications between "any" owner, +shareholder, partner or employee of BSF and government officials or co-counsel in civil +litigation, from 2015 to the date of the subpoena. While the requests focus on a certain subject, +the requests are so overbroad that issuance of the Rule 17(c) subpoena would be improper. As +set forth in the subpoena, the term "communications" encompasses "all forms of correspondence, +including regular mail, email, text message, memorandum, or other written communication of +information of any kind." The use of the terms "all" and "any" "do not evince specificity." +United States v. Tagliaferro, No. 19-CR-472 (PAC), 2021 WL 980004, at *3 (S.D.N.Y. Mar. 16, +2021). Here, the requests do not identify specific lawyers or employees of BSF whose +communications are relevant. See United States v. Wey, 252 F. Supp. 3d 237, 243 (S.D.N.Y. +2017) (discussing that while an originally requested subpoena was insufficiently specific, a new +requested subpoena satisfied the specificity requirement because it identified a specified set of +individuals whose records were sought). The requests also encompass "all" forms of +correspondence without limitation. And while the requested subpoenas are limited to the period +between 2015 and 2021, the timeframe is still overly broad. These requests are precisely the +kind of "fishing expedition" that the specificity requirement is designed to prevent. See Bowman +Dairy Co., 341 U.S. at 221. Indeed, the requests are akin to discovery requests in civil litigation. +3 + + +Case 1:20-cr-00330-AJN Document 252 Filed 04/27/21 Page 4 of 9 +See United States v. Avenatti, No. (SI) 19-CR-373 (PGG), 2020 WL 86768, at *6 (S.D.N.Y. +Jan. 6, 2020). But Rule 17(c) subpoenas are not tools of discovery. Nixon, 418 U.S. at 698; +Wey, 252 F. Supp. 3d at 253. On the specificity prong alone, Requests 1 through 5 fail to satisfy +the Nixon standard. +Requests 1 and 2 fail for the separate reason that, if Maxwell is entitled to the materials +sought at all, they should come from the Government. Requests 1, 2, and 8 all seek documents +that are procurable from the Government. As noted above, Requests 1 and 2 seek +communications between BSF and government officials regarding a certain subject, from 2015 +to the date of the subpoena. Request 8, meanwhile, refers to a specific grand jury subpoena that +the Government issued to BSF. As to all of these requests, Maxwell asserts that the Rule 17(c) +subpoena is necessary to fix what she deems to be the Government's failure to comply with its +discovery obligations. Among the principles set forth in Nixon is that the materials must not be +otherwise procurable reasonably in advance of trial by exercise of due diligence. Nixon, 418 +U.S. at 699. These three requests target information that reasonably can be expected to be in the +hands of the Government. To the extent that Maxwell has a basis to argue that the Government +has not met its discovery obligations, the Rule 17(c) subpoena process is not the proper +mechanism for pursuing that. Rather, with notice to the Government so that the issue is properly +joined, Maxwell must make some showing of that failure and seek specific and appropriate relief +from this Court. +Requests 6 and 7 seek contingency fee agreements or engagement letters between BSF +and two of its clients who are alleged victims. Maxwell has failed to make the required showing +under Nixon that these records would be relevant or admissible for purposes of her Rule 17(c) +application. The only plausible theory of relevance set forth in Maxwell's papers is that these +4 + + +Case 1:20-cr-00330-AJN Document 252 Filed 04/27/21 Page 5 of 9 +documents are necessary for purposes of impeachment. But as a general matter, the need to +impeach witnesses generally 'is insufficient to require [materials'] production in advance of +trial." Nixon, 418 U.S. at 701. Many courts have held that impeachment material does not +become relevant until after the witness testifies. United States v. Skelos, No. 15-CR-317 +(KMW), 2018 WL 2254538, at *2 (S.D.N.Y. May 17, 2018), ), aff'd, 988 F.3d 645 (2d Cir. +2021) (collecting cases); United States v. Scaduto, No. 94-CR-311 (WK), 1995 WL 130511, at +*1 (S.D.N.Y. Mar. 27, 1995) ("Potentially impeaching statements ripen into evidentiary +material ... only if and when the witness testifies at trial ...." (citation omitted)). See also +Avenatti, 2020 WL 86768, at *6 (rejecting the argument that the defendant needed the recordings +in question prior to trial in order "to demonstrate witnesses' bias or self-interest."). The +arguments as to relevance are otherwise specious, and the Court cannot discern what relevance +the materials responsive to Requests 6 and 7 may have. In any event, there is little risk that +review of these materials, if they become relevant and admissible, will lead to a delay at trial, +given their limited volume. United States v. Seabrook, No. 16-CR-467, 2017 WL 4838311, at *2 +(S.D.N.Y. Oct. 23, 2017). For documents that may ripen into relevance if and when the BSF +clients testify, Maxwell presumably could request that the Court issue a subpoena to require +production of the engagement letters to the Court so that the information can be made available +to Maxwell, if appropriate, at the conclusion of each witness's direct testimony. See United +States v. Giampa, No. S 92-CR-437 (PKL), 1992 WL 296440, at *3-*4 (S.D.N.Y. Oct. 7, 1992); +United States v. Ferguson, No. 3:06-CR-137 (CFD), 2007 WL 4577303, at *3 (D. Conn. Dec. +26,2007). +Maxwell also argues that compulsion of the materials' production under Rule 17(c) is +justified because the materials appear not to have been produced by BSF in response to the grand +5 + + +Case 1:20-cr-00330-AJN Document 252 Filed 04/27/21 Page 6 of 9 +jury subpoena at issue in Request 8; she thus contends that the absence of the documents in that +production suggests coordination between the Government and BSF. Other than through +conclusory speculation, she fails to explain how the contents of those letters may be relevant to +her theory of preexisting coordination between the Government and BSF. Furthermore, to the +extent Maxwell argues that the Government may have the documents and has refused to produce +them in contravention of Brady or Giglio, the argument is little more than an attempt to +circumvent the discovery processes that are in place. The production of Giglio material has not +yet happened, and so any claim that the Government has failed to produce these documents +consistent with its Giglio obligations is premature. Furthermore, as set forth in the Opinion & +Order resolving some of Maxwell's pre-trial motions, the Government has represented in good +faith that it is cognizant of its Brady obligations and that it has complied and will continue to +comply with them. This Court knows well that the Government has not always lived up to those +obligations in every case. But nothing has transpired that provides any reason to doubt the good +faith representations that have been made to the Court by the AUSAs appearing here. In sum, +none of Maxwell's theories justify production of these documents under the Rule 17(c) process. +Request 12, which seeks "any" submission to the Epstein Victims' Compensation +Program made by BSF, fails under the relevance prong of the Nixon standard. The request seeks +"any" submission made by BSF to the EVCP. In its reply brief, BSF represents that Maxwell +offered to narrow this request to just those materials submitted on behalf of victims who +ultimately testify in this action. +The request's failure to satisfy the Nixon standard is in part due to its relative lack of +specificity, for even if Maxwell had established the relevance of some evidence captured by this +request, she plainly has not demonstrated the relevance of all materials submitted to the EVCP. +6 + + +Case 1:20-cr-00330-AJN Document 252 Filed 04/27/21 Page 7 of 9 +See United States v. Aguilar, No. CR 07-00030 (SBA), 2008 WL 3182029, at *6 (N.D. Cal. Aug. +4, 2008). Maxwell argues that the materials are relevant because they may reveal monetary +incentives to testify in a particular way. That argument demonstrates that the documents are +being sought for impeachment. As stated above, the mere fact that certain documents might be +impeachment evidence does not render them "relevant" for purposes of Rule 17(c); if at all, those +documents would become relevant only after a witness testifies. See Skelos, 2018 WL 2254538, +at *2. Maxwell's argument that the documents are relevant because their impeachment value is +exculpatory does not get around this general bar. These materials only become relevant if or +when those witnesses testify. She presents no other nonconclusory basis as to why they are +exculpatory. Indeed, Maxwell concedes that the primary purpose of these documents will be for +purposes of cross-examination, leaving little doubt as to the purported claim of relevance. And +to the extent Maxwell posits that statements made as part of the EVCP process may be +exculpatory in themselves, the argument is speculative because she provides no basis for why +that expectation might be reasonable. The "mere hope" that the documents may contain some +exculpatory evidence is insufficient to justify enforcement of a Rule 17(c) subpoena (or, as here, +issuance of such a subpoena in the face of objections). See United States v. Rich, No. S 83-CR- +579 (SWK), 1984 WL 845, at *3 (S.D.N.Y. Sept. 7, 1984). Maxwell's reliance on cases +involving the Government's obligations under Brady and Giglio to produce impeachment +evidence prior to trial are thus inapposite to the current context. Pena, 2016 WL 8735699, at *2- +3. Maxwell thus fails to establish Request 12's compliance with the Nixon standards. Maxwell +may renew her request for these documents once she identifies specific individuals whose +submissions she seeks and spells out with specificity the relevance of all requested materials. At +that time, the Court will determine whether it is proper to require production of these materials to +7 + + +Case 1:20-cr-00330-AJN Document 252 Filed 04/27/21 Page 8 of 9 +the Court so that the information may be made available to Maxwell, if appropriate, at the +conclusion of each witness's direct testimony. See Giampa, 1992 WL 296440, at *3; Ferguson, +2007 WL 4577303, at *3. +The Court will reserve on Requests 9 through 11 in order to allow the Government to +weigh in on the propriety of the requests. The Court assumes that the Government has enough +information, based on the public filings, to provide its views. If the Government seeks the +specific subpoena requests, it shall confer with defense counsel and raise any dispute with the +Court. The Government shall file its response within one week of this Order. +In sum, for Request 1 through 8 and 12, the Court will not authorize service of the +proposed subpoena on the basis that Maxwell has failed to establish that the requests are +sufficiently specific and that the materials sought are relevant or admissible. Maxwell may +renew more tailored requests in compliance with this Order. The Court sees no basis for doing +so on an ex parte basis. For Requests 9 through 11, the Court will reserve its decision until it +hears from the Government. +B. The Government's Subpoena-Related Request +The Government seeks a preemptive, blanket ruling that it be entitled notice of all future +subpoenas, an opportunity to challenge them, and production of any information obtained +therefrom. This request is denied. Assuming Maxwell seeks the issuance of a future subpoena +for which there is no basis to proceed ex parte, the Government will be provided notice and the +Court would likely consider the Government's briefing regardless of standing as part of its duty +to ensure that the subpoena meets the requirements of Nixon. See United States v. Bergstein, No. +16-CR-746 (PKC), 2017 WL 6887596, at *3 (S.D.N.Y. Dec. 28, 2017). But ex parte Rule 17(c) +subpoenas are possible in some circumstances if justified. See Skelos, 2018 WL 2254538, at *8 +8 + + +Case 1:20-cr-00330-AJN Document 252 Filed 04/27/21 Page 9 of 9 +(collecting cases). As a result, the blanket ruling sought by the Government is improper and +denied. +III. Conclusion +The Defendant's motion for an order authorizing the subpoena pursuant to Rule 17(c)(3) +is DENIED. The Government is ORDERED to respond to Requests 9 through 11 of the +proposed subpoena within one week of this Order. +SO ORDERED. +Dated: April 27, 2021 +New York, New York +ALISON J. NATHAN +United States District Judge diff --git a/vision-fixhub/ds9-parsed-01/212abc3f0dfb8b4602cfb359863ae45efe9fb3843c379afb9ca439e795491183.receipt.json b/vision-fixhub/ds9-parsed-01/212abc3f0dfb8b4602cfb359863ae45efe9fb3843c379afb9ca439e795491183.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..dce0364c62197e6d3ee425ec7f47ad78b2677e9e --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/212abc3f0dfb8b4602cfb359863ae45efe9fb3843c379afb9ca439e795491183.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -108, + "dataset": "marble-joined", + "doc_id": "212abc3f0dfb8b4602cfb359863ae45efe9fb3843c379afb9ca439e795491183", + "engine": "marble-apple-vision", + "event_count": 9, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "5ce930b08c0f45936cc7a89b968cd6a26c8f516f153ccd65508ed4a0e1a330f8", + "output_sha256": "3923d091bd4d9bb632ee5422e415ab06919aa68521ff84ed4756fdc52ec7658c", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/21323722dbb02ff8fd51c334c717baa3acf00fe3d94bfa09adc0db0487db6fa2.md b/vision-fixhub/ds9-parsed-01/21323722dbb02ff8fd51c334c717baa3acf00fe3d94bfa09adc0db0487db6fa2.md new file mode 100644 index 0000000000000000000000000000000000000000..3c14be1f57b7b9c1879bc417047cff4ed4e90a56 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/21323722dbb02ff8fd51c334c717baa3acf00fe3d94bfa09adc0db0487db6fa2.md @@ -0,0 +1,350 @@ +stron +MC Truste +MUNICIPAL CREDIT UNION Growing +PO. 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MAXX # 1197 502 86TH ST BROOKLYN NY +Withdrawal - VISA - Visa Purchase +01/28 REDBOX *DVD RENTAL 866-733-2693 IL +Deposit - ACH - AGRI TREAS 310 +TYPE: FED SAL ID: 9101036009 +CO: AGRI TREAS 310 +Withdrawal - VISA - Visa Purchase +01/29 WALGREENS STORE 9408 3R BROOKLYN NY +Withdrawal - VISA - Visa Purchase +01/30 GOURMET GARDEN B BROOKLYN NY +Withdrawal - VISA - Visa Purchase +01/31 MADISON BAGEL & GRILL NEW YORK NY +Withdrawal - POS #057403 +T.J. MAXX # 1197 502 86TH ST BROOKLYN NY +Withdrawal - POS #033340 +BUS WHOLESALE CL 1752 SHORE PKWY BROOKLYN +NY +Withdrawal - ACH - GEICO +TYPE: GEICO PYMT ID: 1530075853 +CO: GEICO +Withdrawal - ACH - CAPITAL ONE AUTO +TYPE: CARPAY ID: 9541719806 +CO: CAPITAL ONE AUTO +New Balance +Statement Period: 01/01/19 - 01/31/19 +Withdrawals +-5.50 +-10.45 +-3.00 +-12.98 +- 13.05 +-15.00 +-20.00 +-16.30 +-7.62 +-14.04 +-5.00 +-11.66 +-10.88 +-44.95 +-253.60 +-483.58 + +(continued) S 02 +Deposits +Balance +98.66 +5,377.86 +88.21 +85.21 +72.23 +59.18 +44.18 +24.18 +7.88 +0.26 +5,378.12 +5,364.08 +5,359.08 +5,347.42 +5,336.54 +5,291.59 +5,037.99 +4,554.41 +4,554.41 +Totals For This Period: +-2,290.38 +5,377.86 +YEAR TO DATE TOTALS +Total Dividends YTD +0.00 +IN CASE OF ERRORS OR QUESTIONS ABOUT YOUR ELECTRONIC TRANSFERS +Write to us at P.O. Box 3205, New York, NY 10007 or telephone us at (212)693-4900 (or (800)323-6713 if outside the five boroughs) if you think +Your statement or coit are han if you sod more information about transfer our same reit wate to sto hobi +Your name and MCU account number (if any); + + +Statement Period: 01/01/19 - 01/31/19 + +USE THE FOLLOWING FORM TO ASSIST YOU IN BALANCING YOUR CHECKING ACCOUNT +LIST CHECKS OUTSTANDING +(NOT CHARGED TO YOUR CHECKING ACCOUNT YET) +PERIOD ENDING +CHECK NUMBER CHECK DATE +$ AMOUNT +1. SUBTRACT FROM YOUR REGISTER ANY CHARGES LISTED ON THIS +STATEMENT BUT NOT DEDUCTED FROM YOUR BALANCE. +3. ENTER DEPOSITS MADE +AFTER THE ENDING DATE OF +THIS STATEMENT. ++ ++ ++ +TOTAL: +4. TOTAL (2 PLUS 3): +$ +5. CARRY OVER OUTSTANDING CHECK § +TOTAL. +6. REGISTER BALANCE (4 MINUS 5): +$ +SHARES ARE TRANSFERABLE ONLY TO QUALIFIED MEMBERS +and backed by the ful tated anil redit of the united States Government +NCUA +National Credit Union Administration, a U.S. Government Agency \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/21323722dbb02ff8fd51c334c717baa3acf00fe3d94bfa09adc0db0487db6fa2.receipt.json b/vision-fixhub/ds9-parsed-01/21323722dbb02ff8fd51c334c717baa3acf00fe3d94bfa09adc0db0487db6fa2.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..58ef9a75855073816356d02509dd4af7644587e4 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/21323722dbb02ff8fd51c334c717baa3acf00fe3d94bfa09adc0db0487db6fa2.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -135, + "dataset": "marble-joined", + "doc_id": "21323722dbb02ff8fd51c334c717baa3acf00fe3d94bfa09adc0db0487db6fa2", + "engine": "marble-apple-vision", + "event_count": 9, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "ab5f72380ef1cc9095430a0ac3154043024832ac15ce1d35af91165a3df041f1", + "output_sha256": "8e919d0a947b30a3d77e0ac2d604a30d24c9624e00969180c277b070e5680f16", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/213ca88477957a30ab55302978a0628c00f567ff537c67d43d643cd3f4bf2cb0.md b/vision-fixhub/ds9-parsed-01/213ca88477957a30ab55302978a0628c00f567ff537c67d43d643cd3f4bf2cb0.md new file mode 100644 index 0000000000000000000000000000000000000000..c70e45040d79389b131b6bf27db5190184cc726f --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/213ca88477957a30ab55302978a0628c00f567ff537c67d43d643cd3f4bf2cb0.md @@ -0,0 +1,17 @@ +From: +To: "bermannysdehambers@nysd.uscourts.gov" < bermannysdchambers@nysd.uscourts.gov> +Cc: " +2, 'Martin +Weinberg', "rweingarten@steptoe.com"' < +'Michael Miller' < +D" +Subject: RE: U.S. v. Epstein, 19 Cr. 490 (RMB), letter motion for order of nolle prosequi +Date: Mon, 19 Aug 2019 19:57:15 +0000 +Attachments: U.S._V. Epstein, _19_Cr. _490, _letter _requesting_ nolle_order_(with _proposed_order).pdf +To the Chambers of Judge Berman: +Attached please find a courtesy copy of the Government's letter motion requesting that the Court approve the enclosed +proposed order of nolle prosequi, in connection with the above-captioned case, filed this afternoon. Defense counsel is +copied. +Thank you, +Assistant U.S. Attorney +Southern District of New York diff --git a/vision-fixhub/ds9-parsed-01/213ca88477957a30ab55302978a0628c00f567ff537c67d43d643cd3f4bf2cb0.receipt.json b/vision-fixhub/ds9-parsed-01/213ca88477957a30ab55302978a0628c00f567ff537c67d43d643cd3f4bf2cb0.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..b8350f1992cfc2fa781c364afe367b67584f7447 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/213ca88477957a30ab55302978a0628c00f567ff537c67d43d643cd3f4bf2cb0.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "213ca88477957a30ab55302978a0628c00f567ff537c67d43d643cd3f4bf2cb0", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "b8bfb87281353387c6c3d8469b87bb5b37ab1abab675b1dbb6eea56640537406", + "output_sha256": "f90fd9cd2383e1fd1b29783da089ed64fff8836d3f5c5e58b0a06f2072610ea0", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/21607026ddec869062dec0e0982ce74543b3fb9673d0da7b8af8fce06b381c4b.md b/vision-fixhub/ds9-parsed-01/21607026ddec869062dec0e0982ce74543b3fb9673d0da7b8af8fce06b381c4b.md new file mode 100644 index 0000000000000000000000000000000000000000..05224a394a5de054367b319bcd08255e9b7e280a --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/21607026ddec869062dec0e0982ce74543b3fb9673d0da7b8af8fce06b381c4b.md @@ -0,0 +1,117 @@ +Suicide Timeline: +RE: Epstein, Jeffrey Edward, Reg. No. 76318-054 +Friday, August 9, 2019 +8:00 am: +departs for +court (WAB-USMS-SDNY) . +• is Epstein's celimate. +8: 30 am: inmate Epstein arrives in Attorney Conference. He is +visited by several attorneys throughout the day. +6:45 pm: inmate Epstein departs attorney conference and returns +to SHU. +7:00 pm: inmate Epstein provided a social call by IDO. IDO +reports inmate Epstein was in good spirits, nothing unusual. +Saturday, August 10, 2019 +6:33 am: Body alarm activated in SHU. Staff found inmate Epstein +unresponsive in cell. Staff reported to bedside of inmate and +attempted to wake him. Control announced medical emergency. CPR +initiated +6:35 am: Medical staff (on duty PA) on site, CPR already in +progress medical staff continues CPR and AED applied +on inmate. Control called for ambulance +6:40 am: +, AW notified +6:45 am: EMS arrives, paramedics continue CPR. Inmate Epstein +remains unresponsive. Inmate Epstein is intubated, given three +rounds of Epinephrine, IV access started, I0 initiated. No pulse +found, no shock advised, inmate prepared for transport to local +hospital. +7:00 am: Institution placed on modified operations +7:10 am: EMS departs institution enroute to Beekman Hospital. +7:19 am: USMS notified of incident. +SDNY _000000824 + + + +7:20 am: SIS It notified. +7:30 am: +, Warden arrives at institution. +1 AW +notified. +7:32 am: PIO notified of incident by the Warden. +7:36 am: Official time of death reported by ER physician. +7:40 am: Acting Chief Psychologist notified. +8:00 am: +• AW and l +, Captain arrives at +institution. +8:10 am: SIS Lt arrives at institution. +8:10 am: CMC and SCSS notified. +8:34 am: FBI notified. +9:00 am: AUSA notified. +9:00 am: +arrives at institution. +9:00 am: SIS +to SHU. Interviews will be conducted +with inmates assigned to tier. +9:15 am: CMC arrives at institution. +9:30 am: Acting Chief Psychologist arrived to the institution. +9:50 am: SCSS arrives at institution. +9:55 am: CMC and IDO depart institution En route to Beekman +Hospital. +10:00 am: CMC and IDO arrive at Beekman Hospital, fingerprints +and photographs taken of inmate Epstein. Inmate clothing secured +and brought back to institution. +10:00 am: Judge Berman notified. +10:15 am: CMC returns to institution. +10:45 am: PIO arrived to the institution. +SDNY _00000825 + + + +11:00 am: Next of kin (brother) notified by Case Management +Coordinator. +11:12 am: Press Release released to media. +11:15 am: Press Release provided to Judge Berman. +11:15 am: Crisis Support Team activated. +12:15 pm: Body released to Medical Examiner (ME) for autopsy +12:19 pm: FBI arrives. +1:35 pm: FBI arrives in Special Housing Unit. +1:40 pm: OIG notified by the Warden and they will be sending an +Agent to NYM. +2:15 pm: Crisis Support Team debrief conducted. +2:45 pm: OIG arrived in Special Housing Unit (SHU) +3:45 pm: OIG and FBI departed from SHU. +5:05 pm: OIG/FBI departed MCC New York. +5:30 pm: CST departed MCC New York. +10:15 pm: Computer Services Manager arrives at institution to +remove hard drives (Computers) from SHU. And replaced with new +ones. +Sunday, August 11, 2019 +8:00 am: Resumed normal operations. Attorney conference visits +and social visits (Unit 3) resume. +12:15 am: Computer Services Manager departs the institution. +10:40 am: +arrives +at institution. +11:15 am: +I, departs institution with two +computers FPS 021407270 and FPS 0214207268. +SONY _00000826 + + + +2:00 pm: +departs the institution. +Monday, August 12, 2019 +1:00 pm: Staff recall conducted +3:14 pm: FBI arrives +7:56 pm: FBI departs +9:45 pm: FBI returns +10:30 pm: FBI departs +Tuesday, August 13, 2019 +8:00 am: Central Office staff arrive +7:30 am: Department Head meeting conducted +8:45 am: Regional Director arrives +SDNY_00000827 + diff --git a/vision-fixhub/ds9-parsed-01/21607026ddec869062dec0e0982ce74543b3fb9673d0da7b8af8fce06b381c4b.receipt.json b/vision-fixhub/ds9-parsed-01/21607026ddec869062dec0e0982ce74543b3fb9673d0da7b8af8fce06b381c4b.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..586146c631978c717630bbc38c358546b2ea5e82 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/21607026ddec869062dec0e0982ce74543b3fb9673d0da7b8af8fce06b381c4b.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -100, + "dataset": "marble-joined", + "doc_id": "21607026ddec869062dec0e0982ce74543b3fb9673d0da7b8af8fce06b381c4b", + "engine": "marble-apple-vision", + "event_count": 8, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "0d168f5e68c83b29cbce5ec0256790f4063d228933d19cb5dc079055dec4e9dc", + "output_sha256": "9a1521ff99b90204d30a5c5368ba6531d66fab6ac2789ea5e21235a575e03277", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/21635665c36cea0ecc50c7c5d69b02e9fab64225327cbc7a7517ae37fe263566.md b/vision-fixhub/ds9-parsed-01/21635665c36cea0ecc50c7c5d69b02e9fab64225327cbc7a7517ae37fe263566.md new file mode 100644 index 0000000000000000000000000000000000000000..b4764fb5fde9efd7b8209febf5b46ffd94169f09 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/21635665c36cea0ecc50c7c5d69b02e9fab64225327cbc7a7517ae37fe263566.md @@ -0,0 +1 @@ +No Images Produced diff --git a/vision-fixhub/ds9-parsed-01/21635665c36cea0ecc50c7c5d69b02e9fab64225327cbc7a7517ae37fe263566.receipt.json b/vision-fixhub/ds9-parsed-01/21635665c36cea0ecc50c7c5d69b02e9fab64225327cbc7a7517ae37fe263566.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..e0d5330d6e2fdf0d18bb69c8c3f7ad0b2c68eb9d --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/21635665c36cea0ecc50c7c5d69b02e9fab64225327cbc7a7517ae37fe263566.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "21635665c36cea0ecc50c7c5d69b02e9fab64225327cbc7a7517ae37fe263566", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "90e81aee5c87737f1d7887470cd932e3512aac2c16021cebcab568fc88fb0a1d", + "output_sha256": "3874328764c818fba06683a6d5ddc2edc2d7850aaf4ba18646f81d3f8420a729", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/217ced3a8deae7f4bf27801c57796cd807bb1d4ba039cc2ea9a97b8fd6f0c56b.md b/vision-fixhub/ds9-parsed-01/217ced3a8deae7f4bf27801c57796cd807bb1d4ba039cc2ea9a97b8fd6f0c56b.md new file mode 100644 index 0000000000000000000000000000000000000000..dfe76add63bcc44c20a1aa03d221b3933d32a04f --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/217ced3a8deae7f4bf27801c57796cd807bb1d4ba039cc2ea9a97b8fd6f0c56b.md @@ -0,0 +1,172 @@ +Case 1:20-cr-00330-AJN Document 407 Filed 11/03/21 Page 1 of 7 +LAW OFFICES OF BOBBI C. STERNHEIM +November 3, 2021 +Honorable Alison J. Nathan +United States District Judge +United States Courthouse +40 Foley Square +New York, NY 10007 +Re: United States v. Ghislaine Maxwell +S2 20 Cr. 330 (AJN) +Dear Judge Nathan: +Counsel for Ghislaine Maxwell renew our request that the Court release the names of +potential jurors, for attorneys' eyes only, as soon as the written questionnaires are distributed. +Based on the Court's statement during the October 21 teleconference, it was counsel's +understanding that juror names would be provided to counsel on the Juror Sheet to be inserted in +the questionnaire. In responding to the Court's order regarding approval of the video to be played +to prospective jurors, the government importuned the Court to deny counsel the opportunity to +properly vet jurors at this critical state of the proceeding. Not knowing the names of the +potential jurors will prevent the parties from conducting necessary background research on the +jurors in advance of voir dire so that they may evaluate potential challenges and strikes. Due to +the large number of potential jurors (600), waiting until voir dire to release the names of the +jurors will make it virtually impossible for the parties to conduct any meaningful research to +uncover issues that may require follow-up questions, lead to additional cause challenges, or +enable the parties to exercise their peremptory challenges in an informed manner. +Recently, in Sines, et al. v. Kessler, et al., 17-CV-72 (KNM) (W.D. Va.), the civil case +brought against the organizers of the Unite the Right rally in Charlottesville, Virginia, the United + + +Case 1:20-cr-00330-AJN Document 407 Filed 11/03/21 Page 2 of 7 +LAW OFFICES OF BOBBI C. STERNHEI AN +States District Court for the Western District of Virginia ordered a semi-anonymous jury (jurors +were publicly referred to by number only) and released the names of all potential jurors to +counsel, plus all pro se defendants (including Richard Spencer and Christopher Cantwell), who +are allegedly prominent white supremacists, neo-Nazis, and the leaders of hate groups that +planned, promoted, and executed the violent acts in Charlottesville. (See Exhibit A, annexed.) +The defendants in Sines included factions of the Ku Klux Klan. The concerns for juror privacy in +Sines dwarf any conceivable concerns in this case and Sines is also the subject of extensive +ongoing publicity. We submit that withholding the names of 600 jurors until the day of jury +selection will deprive Ms. Maxwell of her right to be tried by a fair and impartial jury and is a +procedure that would violate due process in this particular case.' +"An impartial jury is one in which all of its members, not just most of them, are free of +interest and bias." United States v. Parse, 789 F.3d 83, 111 (2d Cir. 2015). In Parse, a case +before Judge Pauley sub nom United States v. Daugerdas, a jury convicted defendant Parse and +three of his co-defendants of numerous financial fraud and tax evasion charges. 789 F.3d at 86. +After trial, all defendants moved pursuant to Fed.R.Crim.P. 33(a) for a new trial on the ground +that one of the jurors, Juror No. 1 (Catherine M. Conrad), "had lied and withheld material +information during voir dire and was biased against defendants. Judge Pauley appointed Bobbi +C. Sternheim, Esq. to represent the juror and conducted an evidentiary hearing in which the juror +was examined, and in a detailed thorough opinion (see United States v. Daugerdas, 867 +F.Supp.2d 445 (S.D.N.Y.2012) found it "undisputed that Conrad lied extensively during voir dire +and concealed important information about her background" (id. at 451), her level of education, +place of residence, criminal history, and other matters. Parse, 789 F.33 at 87-90. +' We are unaware of any other recent high-profile case in which a written juror questionnaire was +used and the Court withheld the names of the jurors from counsel following the completion of +the questionnaires. +2 + + +Case 1:20-cr-00330-AJN Document 407 Filed 11/03/21 Page 3 of 7 +LAW OFFICES OF BOBBI C. STERNHEI/ +Judge Pauley granted a motion for a new trial as to Parse's three co-defendants but held +that Parse had waived his right to an impartial jury because his attorneys had sat on background +research collected before and during trial that suggested Conrad's voir dire answers were false. +Id. at 101. On appeal, the Second Circuit "had no difficulty with the ruling of the district court in +the present case that the jury empaneled to hear the case against these defendants was not an +impartial jury." Id. at 111. Moreover, the Second Circuit reversed Judge Pauley's ruling that +Parse had waived his right to an impartial jury, and vacated Parse's conviction. Id. at 118. +The result in Parse was that a three-month trial, with 41 witnesses and some 1,300 +exhibits, was undone by the falsehoods of one juror during voir dire-falsehoods that could have +been uncovered by thorough background research and prompt action by the parties. Numerous +bar associations have recognized that trial counsel is expected to conduct internet research on +potential jurors. Some bar associations have opined that professional standards of competence +and diligence may require such research. For example, just weeks after Judge Pauley conducted +a post-conviction evidentiary hearing in Parse, the New York City Bar Association stated the +following in Formal Opinion 2012-2: +Just as the internet and social media appear to facilitate juror misconduct, the same +tools have expanded an attorney's ability to conduct research on potential and sitting +jurors, and clients now often expect that attorneys will conduct such research. Indeed, +standards of competence and diligence may require doing everything reasonably +possible to learn about the jurors who will sit in judgment on a case. +Similarly, in 2014, the American Bar Association recognized the "strong public interest +in identifying jurors who might be tainted by improper bias or prejudice," and therefore opined +that it was proper for counsel to research "a juror's or potential juror's Internet presence, which +may include postings by the juror or potential juror in advance of and during a trial... " See +Standing Committee on Ethics and Professional Responsibility, Formal Op. 466 at 1-2, Am. Bar +3 + + +Case 1:20-cr-00330-AJN Document 407 Filed 11/03/21 Page 4 of 7 +LAW OFFICES OF BOBBI C. STERNHEIM +Assn. (2014); see also New York State Bar Association, Dec. 8, 2015 Report of the Social Media +Committee of the Commercial and Federal Litigation Section, at 15 ("I]t is not only permissible +for trial counsel to conduct Internet research on prospective jurors, but [] it may even be +expected."). +Other courts have acknowledged that using the internet to conduct background research +on prospective jurors is a "rudimentary practice" during jury selection. United States v. Stone, +No. 19-0018 (ABJ), 2020 U.S. Dist. LEXIS 67359, at *93 (D.D.C. Apr. 16, 2020); see also +Carino v. Muenzen, No. A-5491-08T1, 2010 N.J. Super. Unpub. LEXIS 2154, at *27 (Super. Ct. +App. Div. Aug. 30, 2010) (trial judge erred in preventing counsel from using the internet during +jury selection). It is so routine that a party who fails to uncover disqualifying information about +a potential juror, despite a reasonable opportunity to do so, risks waiving the right to use that +information in post-conviction proceedings. Stone at *90 (denying motion to vacate conviction +and for a new trial because, inter alia, "the defense could have discovered the [foreperson's +social media] posts as early as September 12, 2019, the day counsel received access to the +completed juror questionnaires, including the foreperson's, which had her name printed legibly +on the signature page."). +Having additional time to conduct background research on each of the venirepersons is +the best way to ensure a fair and impartial jury. Balancing the need to protect juror privacy +against Ms. Maxwell's right to a fair and impartial jury weighs in favor of releasing the names of +potential jurors to counsel upon the completion of their written questionnaires, not at voir dire. +Respectfully submitted, +/s/ +BOBBI C. STERNHEIM +Enc. +cc: All counsel of record +4 + + +Case 1:20-cr-00330-AJN Document 407 Filed 11/03/21 Page 5 of 7 + + + +UNITED STATES DISTRICT COURT +WESTERN DISTRICT OF VIRGINIA +CHARLOTTESVILLE DIVISION +ELIZABETH SINES, et al., +Plaintiffs, +CASE No. 3:17-cv-00072 +V. +ORDER +JASON KESSLER, et al., +JUDGE NORMAN K. MOON +Defendants. +Upon this Court's own motion, upon notice that Plaintiffs' counsel may seek to designate +certain non-lawyers within their list of six (6) persons to be provided electronic access to the jury +questionnaires, and otherwise finding good cause shown, the Court hereby AMENDS Pretrial +Order 1| 3, (Dkt. 1172) as follows: +Plaintiffs, and Defendants represented by counsel collectively, may each designate no +more than six (6) persons, which may be comprised of (1) current counsel of record or (2) third +parties working under their direction, who are formally engaged and supervised by the attorneys +of record, and for whom such attorneys of record will be responsible, and who will have signed +the Court's protective order, Dkt. 167, so long as such persons include at least one attorney +admitted to practice in the Western Distriet of Virginia, to be provided electronic access by the +Clerk to receive and review copies of the jury questionnaires, on a rolling basis. A list including +names and occupations of prospective jurors, and information matching such prospective jurors +with the questionnaires pursuant to Dkt. 1204 9 2, will also be provided to such specifically +designated persons by Plaintiffs and represented Defendants, no more than five (5) days before +trial. Jury questionnaires and such occupation list, and any information contained therein, are +1 + + +Case 3:17 999702 kobb0 981 40d 903029909627 aged#: 21160 +subject to the Court's orders regarding confidentiality in Dkt. 1172 and 1204, and shall not be +disclosed to any other person without prior authorization of Court. +Any pro se Defendant—upon completing a declaration stating, under penalty of perjury, +they will not disclose the contents of such questionnaires or the jury occupation list provided to +such pro se Defendant to any other person—may review the questionnaires and jury occupation +list onsite in the Clerk's Office. A paper copy of the completed questionnaires and the jury +occupation list customarily made available to pro se litigants will be maintained in the Clerk's +Office. +If any party requests specific access to the confidential juror questionnaires in excess of +the provisions outlined above and in Dkts. 1172 and 1204, they shall file a motion to that effect. +In all other respects, this Court's Orders of Dkt. 1172 and 1204 shall remain unchanged and in +force. +It is so ORDERED. +The Clerk of the Court is directed to send a certified copy of this Order to the parties. +Entered this 19th +day of October, 2021. +Name t Mon +VORMAN K. MOI +SENIOR UNITED STATES DISTRICTIUDGI +2 diff --git a/vision-fixhub/ds9-parsed-01/217ced3a8deae7f4bf27801c57796cd807bb1d4ba039cc2ea9a97b8fd6f0c56b.receipt.json b/vision-fixhub/ds9-parsed-01/217ced3a8deae7f4bf27801c57796cd807bb1d4ba039cc2ea9a97b8fd6f0c56b.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..3ec8461bfa1142ecb5ba63345b8b6317817c4dc8 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/217ced3a8deae7f4bf27801c57796cd807bb1d4ba039cc2ea9a97b8fd6f0c56b.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -93, + "dataset": "marble-joined", + "doc_id": "217ced3a8deae7f4bf27801c57796cd807bb1d4ba039cc2ea9a97b8fd6f0c56b", + "engine": "marble-apple-vision", + "event_count": 8, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "f9549eef94b36e953afbaf88ee164886920ebdff9ea85445d88a77032d643dba", + "output_sha256": "8bb23dd4d9d9fae8c329c0b9e581227eb0e58ee07d689742ca7ae176a5a3f017", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/219c92b1ddd22d50c5d55333b46c414192659c2be27baedc90d09ac1f22fa88c.md b/vision-fixhub/ds9-parsed-01/219c92b1ddd22d50c5d55333b46c414192659c2be27baedc90d09ac1f22fa88c.md new file mode 100644 index 0000000000000000000000000000000000000000..d4d545f40404a7325d8f139b613fc790dab4ead8 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/219c92b1ddd22d50c5d55333b46c414192659c2be27baedc90d09ac1f22fa88c.md @@ -0,0 +1,457 @@ +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +X +UNITED STATES OF AMERICA +- V. +GHISLAINE MAXWELL, +Defendant. +SEALED +INDICTMENT +20 Cr. +20 Cr. 330 +COUNT ONE +(Conspiracy to Entice Minors to Travel to Engage in +Illegal Sex Acts) +The Grand Jury charges: +OVERVIEW +1.. The charges set forth herein stem from the role +of GHISLAINE MAXWELL, the defendant, in the sexual exploitation +and abuse of multiple minor girls by Jeffrey Epstein. In +particular, from at least in or about 1994, up to and including +at least in or about 1997, MAXWELL assisted, facilitated, and +contributed to Jeffrey Epstein's abuse of minor girls by, among +other things, helping Epstein to recruit, groom, and ultimately +abuse victims known to MAXWELL and Epstein to be under the age +of 18. The victims were as young as 14 years old when they were +groomed and abused by MAXWELL and Epstein, both of whom knew +that certain victims were in fact under the age of 18. +2. As a part and in furtherance of their scheme to +abuse minor victims, GHISLAINE MAXWELL, the defendant, and +Jeffrey Epstein enticed and caused minor victims to travel to + + +Epstein's residences in different states, which MAXWELL knew and +intended would result in their grooming for and subjection to +sexual abuse. Moreover, in an effort to conceal her crimes, +MAXWELL repeatedly lied when questioned about her conduct, +including in relation to some of the minor victims described +herein, when providing testimony under oath in 2016. +FACTUAL BACKGROUND +3. During the time periods charged in this +Indictment, GHISLAINE MAXWELL, the defendant, had a personal and +professional relationship with Jeffrey Epstein and was among his +closest associates. In particular, between in or about 1994 and +in or about 1997, MAXWELL was in an intimate relationship with +Epstein and also was paid by Epstein to manage his various +properties. Over the course of their relationship, MAXWELL and +Epstein were photographed together on multiple occasions, +including in the below image: +2 + + +4. Beginning in at least 1994, GHISLAINE MAXWELL, +the defendant, enticed and groomed multiple minor girls to +engage in sex acts with Jeffrey Epstein, through a variety of +means and methods, including but not limited to the following: +a. MAXWELL first attempted to befriend some of +•Epstein's minor victims prior to their abuse, including by +asking the victims about their lives, their schools, and their +families. MAXWELL and Epstein would spend time building +friendships with minor victims by, for example, taking minor +victims to the movies or shopping. Some of these outings would +involve MAXWELL and Epstein spending time together with a minor +victim, while some would involve MAXWELL or Epstein spending +time alone with a minor victim. +b. Having developed a rapport with a victim, +MAXWELL would try to normalize sexual abuse for a minor victim +by, among other things, discussing sexual topics, undressing in +front of the victim, being present when a minor victim was +undressed, and/or being present for sex acts involving the minor +victim and Epstein. +MAXWELL'S presence during minor victims' +interactions with Epstein, including interactions where the +minor victim was undressed or that involved sex acts with +Epstein, helped put the victims at ease because an adult woman +was present. For example, +in some instances, MAXWELL would + + +massage Epstein in front of a minor victim. In other instances, +MAXWELL encouraged minor victims to provide massages to Epstein, +including sexualized massages during which a minor victim would +be fully or partially nude. Many of those massages resulted in +Epstein sexually abusing the minor victims. +d. In addition, Epstein offered to help some +minor victims by paying for travel and/or educational +opportunities, and MAXWELL encouraged certain victims to accept +Epstein's assistance. As a result, victims were made to feel +indebted and believed that MAXWELL and Epstein were trying to +help them. +e. Through this process, MAXWELL and Epstein +enticed victims to engage in sexual activity with Epstein. In +some instances, MAXWELL was present for and participated in the +sexual abuse of minor vicțims. +Some such incidents occurred in +the context of massages, which developed into sexual encounters. +5. GHISLAINE MAXWELL, the defendant, facilitated +Jeffrey Epstein's access to minor victims knowing that he had a +sexual preference for underage girls and that he intended to +engage in sexual activity with those victims. Epstein's +resulting abuse of minor victims included, among other things, +touching a victim's breast, touching a victim's genitals, +placing a sex toy such as a vibrator on a victim's genitals, +4 + + +directing a victim to touch Epstein while he masturbated, and +directing a victim to touch Epstein's genitals. +MAXWELL AND EPSTEIN'S VICTIMS +6. Between approximately in or about 1994 and in or +about 1997, GHISLAINE MAXWELL, the defendant, facilitated +Jeffrey Epstein's access to minor victims by, among other +things, inducing and enticing, and aiding and abetting the +inducement and enticement of, multiple minor victims. Victims +were groomed and/or abused at multiple locations, including the +following: +a. A a multi-story private residence on the +Upper East Side of Manhattan, New York owned by Epstein (the +"New York Residence"), which is depicted in the following +photograph: + + +b. An estate in Palm Beach, Florida owned by +Epstein (the "Palm Beach Residence"), which is depicted in the +following photograph: +c. A ranch in Santa Fe, New Mexico owned by +Epstein (the "New Mexico Residence"), which is depicted in the +following photograph: + + +d. MAXWELL's personal residence in London, +England. +7. +Among the victims induced or enticed by GHISLAINE +MAXWELL, the defendant, were minor victims identified herein as +Minor Victim-1, Minor Victim-2, and Minor Victim-3. In +particular, and during time periods relevant to this Indictment, +MAXWELL engaged in the following acts, among others, with +respect to minor victims: +MAXWELL met Minor Victim-1 when Minor +Victim-1 was approximately 14 years old. MAXWELL subsequently +interacted with Minor Victim-1 on multiple occasions at +Epstein's residences, knowing that Minor Victim-1 was under the +age of 18 at the time. During these interactions, which took +place between approximately 1994 and 1997, MAXWELL groomed Minor +Victim-1 to engage in sexual acts with Epstein through multiple +means. First, MAXWELL and Epstein attempted to befriend Minor +Victim-1, taking her to the movies and on shopping trips. +MAXWELL also asked Minor Victim-1 about school, her classes, her +family, and other aspects of her life. MAXWELL then sought to +normalize inappropriate and abusive conduct by, among other +things, undressing in front of Minor Victim-1 and being present +when Minor Victim-1 undressed in front of Epstein. Within the +first year after MAXWELL and Epstein met Minor Victim-1, Epstein +began sexually abusing Minor Victim-1. MAXWELL was present for +7 + + +and involved in some of this abuse. In particular, MAXWELL +involved Minor Victim-1 in group sexualized massages of Epstein. +During those group sexualized massages, MAXWELL and/or Minor +Victim-1 would engage in sex acts with Epstein. Epstein and +MAXWELL both encouraged Minor Victim-1 to travel to Epstein's +residences in both New York and Florida. As a result, Minor +Victim-1 was sexually abused by Epstein in both New York and +Florida. Minor Victim-1 was enticed to travel across state +lines for the purpose of sexual encounters with Epstein, and +MAXWELL was aware that Epstein engaged in sexual activity with +Minor Victim-1 after Minor-Victim-1 traveled to Epstein's +properties, including in the context of a sexualized massage. +b. MAXWELL interacted with Minor Victim-2 on at +least one occasion in or about 1996 at Epstein's residence in +New Mexico when Minor Victim-2 was under the age of 18. Minor +Victim-2 had flown into New Mexico from out of state at +Epstein's invitation for the purpose of being groomed for and/or +subjected to acts of sexual abuse. MAXWELL knew that Minor +Victim-2 was under the age of 18 at the time. While in New +Mexico, MAXWELL and Epstein took Minor Victim-2 to a movie and +MAXWELL took Minor Victim-2 shopping. MAXWELL also discussed +Minor Victim-2's school, classes, and family with Minor Victim- +2. In New Mexico, MAXWELI began her efforts to groom Minor +Victim-2 for abuse by Epstein by, among other things, providing +8 + + +an unsolicited massage to Minor Victim-2, during which Minor +Victim-2 was topless. MAXWELL also encouraged Minor Victim-2 to +massage Epstein. +C. MAXWELL groomed and befriended Minor +Victim-3 in London, England between approximately 1994 and 1995, +including during a period of time in which MAXWELL knew that +Minor Victim-3 was under the age of 18. Among other things, +MAXWELL discussed Minor Victim-3's life and family with Minor +Victim-3. MAXWELL introduced Minor Victim-3 to Epstein and +arranged for multiple interactions between Minor Victim-3 and +Epstein. During those interactions, MAXWELL encouraged Minor +Victim-3 to massage Epstein, knowing that Epstein would engage +in sex acts with Minor Victim-3 during those massages. Minor +Victim-3 provided Epstein with the requested massages, and +during those massages, Epstein sexually abused Minor Victim-3. +MAXWELL was aware that Epstein engaged in sexual activity with +Minor Victim-3 on multiple occasions, including at times when +Minor Victim-3 was under the age of 18, including in the context +of a sexualized massage. +MAXWELL'S EFFORTS TO CONCEAL HER CONDUCT +8. In or around 2016, in the context of a deposition +as part of civil litigation, GHISLAINE MAXWELL, the defendant, +repeatedly provided false and perjurious statements, under oath, +regarding, among other subjects, her role in facilitating the +9 + + +abuse of minor victims by Jeffrey Epstein, including some of the +specific events and acts of abuse +detailed above. +STATUTORY ALLEGATIONS +9. From at least in or about 1994, up to and +including in or about 1997, in the Southern District of New York +and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey +Epstein, and others known and unknown, willfully and knowingly +did combine, conspire, confederate, and agree together and with +each other to commit an offense against the United States, to +wit, enticement, in violation of Title 18, United States Code, +Section 2422. +10. It was a part and object of the conspiracy that +GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others +known and unknown, would and did knowingly persuade, induce, +entice, and coerce one and more individuals to travel in +interstate and foreign commerce, to engage in sexual activity +for which a person can be charged with a criminal offense, in +violation of Title 18, United States Code, Section 2422. +overt Acts +11. In furtherance of the conspiracy and to effect +the illegal object thereof, the following overt acts, among +others, were committed in the Southern District of New York and +elsewhere: +10 + + +a. Between in or about 1994 and in or about +1997, when Minor Victim-1 was under the age of 18, MAXWELL +participated in multiple group sexual encounters with Epstein +and Minor Victim-1 in New York and Florida. +b. In or about 1996, when Minor Victim-1 was +under the age of 18, Minor Victim-1 was enticed to travel from +Florida to New York for purposes of sexually abusing her at the +New York Residence, in violation of New York Penal. Law, Section +130.55. +c. In or about 1996, when Minor Victim-2 was +under the age of 18, MAXWELL provided Minor Victim-2 with an +unsolicited massage in New Mexico, during which Minor Victim-2 +was topless. +d. Between in or about 1994 and in or about +1995, when Minor Victim-3 was under the age of 18, MAXWELL +encouraged Minor Victim-3 to provide massages to Epstein in +London, England, knowing that Epstein intended to sexually abuse +Minor Victim-3 during those massages. +(Title 18, United States Code, Section 371.) +COUNT TWO +(Enticement of a Minor to Travel to Engage in Illegal Sex Acts) +The Grand Jury further charges: +12. The allegations contained in paragraphs 1 +through 8 of this Indictment are repeated and realleged as if +fully set forth within. +11 + + +13. From at least in or about 1994, up to and +including in or about 1997, in the Southern District of New York +and elsewhere, GHISLAINE MAXWELL, the defendant, knowingly did +persuade, induce, entice, and coerce an individual to travel in +interstate and foreign commerce to engage in sexual activity for +which a person can be charged with a criminal offense, and +attempted to do the same, and aided and abetted the same, to +wit, MAXWELL persuaded, induced, enticed, and coerced Minor +Victim-1 to travel from Florida to New York, New York on +multiple occasions with the intention that Minor Victim-1 would +engage in one or more sex acts with Jeffrey Epstein, in +violation of New York Penal Law, Section 130.55. +(Title 18, United States Code, Sections 2422 and 2.) +COUNT THREE +(Conspiracy to Transport Minors with Intent to +Engage in Criminal Sexual Activity) +The Grand Jury further charges: +14. The allegations contained in paragraphs 1 +through 8 of this Indictment are repeated and realleged as if +fully set forth within. +15. From at least in or about 1994, up to and +including in or about 1997, in the Southern District of New YOrk +and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey +Epstein, and others known and unknown, willfully and knowingly +did combine, conspire, confederate, and agree together and with +each other to commit an offense against the United States, to +12 + + +wit, transportation of minors, in violation of Title 18, United +States Code, Section 2423 (a) • +16. It was a part and object of the conspiracy that +GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others +known and unknown, would and did, knowingly transport an +individual who had not attained the age of 18 in interstate and +foreign commerce, with intent that the individual engage in +sexual activity for which a person can be charged with a +criminal offense, in violation of Title 18, United States Code, +Section 2423 (a) • +Overt Acts +17. In furtherance of the conspiracy and to effect +the illegal object thereof, the following overt acts, among +others, were committed in the Southern District of New York and +elsewhere: +a. Between in or about 1994 and in or about +1997, when Minor Victim-1 was under the age of 18, MAXWELL +participated in multiple group sexual encounters with EPSTEIN +and Minor Victim-1 in New York and Florida. +b. In or about 1996, when Minor Victim-1 was +under the age of 18, Minor Victim-1 was enticed to travel from +Florida to New York for purposes of sexually abusing her at the +13 + + +New York Residence, in violation of New York Penal Law, Section +130.55. +c. In or about 1996, when Minor Victim-2 was +under the age of 18, MAXWELL provided Minor Victim-2 with an +unsolicited massage in New Mexico, during which Minor Victim-2 +was topless. +d. Between in or about 1994 and in or about +1995, when Minor Victim-3 was under the age of 18, MAXWELL +encouraged Minor Victim-3 to provide massages to Epstein in +London, England, knowing that Epstein intended to sexually abuse +Minor Victim-3 during those massages. +(Title 18, United States Code, Section 371.) +COUNT FOUR +(Transportation of a Minor with Intent to +Engage in Criminal Sexual Activity) +The Grand Jury further charges: +18. The allegations contained in paragraphs 1 +through 8 of this Indictment are repeated and realleged as if +fully set forth within. +19. From at least in or about 1994, up to and +including in or about 1997, in the Southern District of New York +and elsewhere, GHISLAINE MAXWELL, the defendant, knowingly did +transport an individual who had not attained the age of 18 in +interstate and foreign commerce, with the intent that the +individual engage in sexual activity for which a person can be +charged with a criminal offense, and attempted to do so, and +14 + + +aided and abetted the same, to wit, MAXWELL arranged for Minor +Victim-1 to be transported from Florida to New York, New York on +multiple occasions with the intention that Minor Victim-1 would +engage in one or more sex acts with Jeffrey Epstein, in +violation of New York Penal Law, Section 130.55. +(Title 18, United States Code, Sections 2423 (a) and 2.) +COUNT FIVE +(Perjury) +The Grand Jury further charges: +20. The allegations contained in paragraphs 1 +through 8 of this Indictment are repeated and realleged as if +fully set forth within. +21. On or about April 22, 2016, in the Southern +District of New York, GHISLAINE MAXWELL, the defendant, having +taken an oath to testify truthfully in a deposition in +connection with a case then pending before the United States +District Court for the Southern District of New York under +docket number 15 Civ. 7344, knowingly made false material +declarations, to wit, MAXWELL gave the following underlined +false testimony: +Did Jeffrey Epstein have a scheme to recruit +underage girls for sexual +massages? If you know. +A. I don't know what you're talking about. +15 + + +Q. +List all the people under the age of 18 that you +interacted with at any of Jeffrey's properties? +A. +I'm not aware of anybody that I interacted with, +other than obviously [the plaintiff] who was 17 +at this point. +(Title 18, United States Code, Section 1623.) +COUNT SIX +(Per jury) +The Grand Jury further charges: +22. The allegations contained in paragraphs 1 +through 8 of this Indictment are repeated and realleged as if +fully set forth within. +23. On or about July 22, 2016, in the Southern +District of New York, GHISLAINE MAXWELL, the defendant, having +taken an oath to testify truthfully in a deposition in +connection with a case then pending before the United States +District Court for the Southern District of New York under +docket number 15 Civ. 7344, knowingly made false material +declarations, to wit, MAXWELL gave the following underlined +false testimony: +Q: Were you aware of the presence of sex toys or +devices used in sexual activities in Mr. +Epstein's Palm Beach house? +A: No, not that I recall. • +Q. Do you know whether Mr. Epstein possessed sex +toys or devices used in sexual activities? +A. No. +16 + + +other than yourself and the blond and brunette +that you have identified as having been involved +in three-way sexual activities, with whom did Mr. +Epstein have sexual activities? +A. +I wasn't aware that he was having sexual +activities with anyone when I was with him other +than myself. +2. I want to be sure that I'm clear. Is it your +testimony that in the 1990s and 2000s, you were +not aware that Mr. Epstein was having sexual +activities with anyone other than yourself and +the blond and brunette on those few occasions +when they were involved with you? +A. +That is my testimony, that is correct. +.. = +Q. Is it your testimony that you've never given +anybody a massage? +A. I have not given anyone a massage. +2. You never gave Mr. Epstein a massage, is that +your testimony? +A. +That is my testimony. +You never gave [Minor Victim-2] a massage is your +testimony? +A. I never gave [Minor Victim-2] a massage. +(Title 18, United States Code, Section 1623.) +FOREPERSON +Audy Straws +AUDREY STRAUSS +Acting pnited States Attorney +17 + + +Form No. USA-33s-274 (Ed. 9-25-58) +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +UNITED STATES OF AMERICA +V. +GHISLAINE MAXWELL, +Defendant. +INDICTMENT +(18 U.S.C. §§ 371, 1623, 2422, 2423 (a), +and 2) +AUDREY STRAUSS +Acting United States Attorney +Foreperson +18 diff --git a/vision-fixhub/ds9-parsed-01/219c92b1ddd22d50c5d55333b46c414192659c2be27baedc90d09ac1f22fa88c.receipt.json b/vision-fixhub/ds9-parsed-01/219c92b1ddd22d50c5d55333b46c414192659c2be27baedc90d09ac1f22fa88c.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..818502a4934bb31cce373a0f8767ecb648be8ff9 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/219c92b1ddd22d50c5d55333b46c414192659c2be27baedc90d09ac1f22fa88c.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -216, + "dataset": "marble-joined", + "doc_id": "219c92b1ddd22d50c5d55333b46c414192659c2be27baedc90d09ac1f22fa88c", + "engine": "marble-apple-vision", + "event_count": 18, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "0d1c006e5a4bee5ff8e40b0455e3486ed7efddaa50fb57e63026388f45cc341d", + "output_sha256": "34271951cc0ec356161a7e0acd43c7ca39bbd134453061e757cb88f99ff72997", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/21b065106cac7796546b3d64c356f63a9782108420f3a31980a9a4e318d84854.md b/vision-fixhub/ds9-parsed-01/21b065106cac7796546b3d64c356f63a9782108420f3a31980a9a4e318d84854.md new file mode 100644 index 0000000000000000000000000000000000000000..614a34d9215550c9ea224d0a87c6a74e7940f1c7 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/21b065106cac7796546b3d64c356f63a9782108420f3a31980a9a4e318d84854.md @@ -0,0 +1,2627 @@ +Statement of David E. Patton +Executive Director, Federal Defenders of New York +Before the Judiciary Committee of the House of Representatives +Subcommittee on Crime, Terrorism, and Homeland Security +October 17, 2019 Oversight Hearing on +"The Federal Bureau of Prisons and +Implementation of the First Step Act" + + +Statement of David E. Patton +Executive Director, Federal Defenders of New York +Before the Judiciary Committee of the House of Representative +Subcommittee on Crime, Terrorism, and Homeland Security +October 17, 2019 Oversight Hearing on +"The Federal Bureau of Prisons and Implementation of the First Step Act" +Mr. Chairman and Members of the Subcommittee: +Thank you tot holding this hearing and tor the opportunity to testity. At any given time, +Federal Public and Community Defenders and other appointed counsel under the Criminal +Justice Act represent 80 to 90 percent of all federal defendants because they are too poor to +afford counsel. An overwhelming majority of people incarcerated in Bureau of Prisons +(BOP) are our clients, and we are grateful for this opportunity to discuss the BOP and the +First Step Act (FSA). +The BOP has a long history of acting in ways that result in lengthier and less productive +terms of incarceration despite the obvious will of Congress. For decades the BOP took an +unreasonably restrictive view of good time, resulting in thousands of years of additional +overall prison time. For decades it refused to exercise the authority given to it by Congress +to release incarcerated people who were terminally ill, infirm, or otherwise suffered from +extraordinary circumstances. For decades it has not made nearly full use of its statutory +authority to release people to Residential Reentry Centers (RRCs). And for decades it has +not provided enough vocational, educational, mental health, and substance abuse +programming despite abundant need and lengthy waitlists. +The FSA will solve some of these problems, most notably clarifying the good time credits +and offering an avenue to the courts for compassionate release. But the FSA also provides +the BOP with significant added responsibility and authority. As a result of the Act, the BOP +will now establish and implement a risk and needs assessment system that will directly +determine how long tens of thousands of people serve in prison. If not done wisely, there +are countless ways the system will result in unfair, biased, and overly punitive outcomes. +With history as a guide, this committee should be very concerned about whether the BOP +will rise to the challenge of these new responsibilities. Oversight has never been more +important. +Although the focus of my remarks will be on national BOP and FSA issues, I will start with +a discussion of two BOP facilities in my home district in New York City, the Metropolitan +Detention Center (MDC) in Brooklyn, which is the largest federal pretrial detention center in +the country, and its counterpart in downtown Manhattan, the Metropolitan Correctional +Center (MCC). Repeated problems at the facilities and well-publicized events of the past +1 + + +year are part of a larger story about why strong oversight of the BOP is so desperately +needed +Fire at the MDC +Under the best of circumstances, the MDC is a miserable place to be incarcerated. The +federal jail located in Sunset Park, Brooklyn houses over 1,600 people, most of whom are +pretrial detainees awaiting trial in the Southern and Eastern Districts of New York. The +Federal Defenders of New York represents roughly half of them. Most of the rest are +represented by appointed counsel from the Criminal Justice Act Panel. The vast majority of +those incarcerated at MDC are poor people of color. On a regular basis we witness +inexcusable treatment of our clients: poor medical treatment and psychiatric care, arbitrary +placement in solitary confinement, unnecessary impediments to legal visiting, and even rape +by corrections officers (which have resulted in several indictments). The space itself is +cramped with little opportunity for any exposure to the outdoors. +Even with those conditions as a baseline, during the week from January 27 to February 3, +2019, the MDC reached a new low. On Sunday, January 27, there was a fire at the MDC +that knocked out the electrical panel controlling a sizable part of the institution, including +cell and common area lighting, much of the kitchen equipment, and most of the inmate +phones and computers, among other things. Despite the severity of the situation, the only +thing MDC officials told us (or anyone else) was that attorney and family visitation was +being suspended that day. The next morning, we were once again told that visitation was +suspended with no explanation. We peppered prison officials with questions. We were told +all was okay - just a problem with lighting in the visitation area. Then the calls from our +clients started. The only phones working were the direct lines to the Federal Defenders' +office. "There's no heat in here." "We're being locked down in the dark." "I'm not getting +my medication." Temperatures outside were hovering in the single digits during one of the +coldest stretches in New York City's history. Most of our clients lack money for the +commissary and are relegated to wearing short-sleeved scrub-like uniforms. They are cold +when the heat is functioning properly and set to 68 degrees. When it's 40 or 50 degrees +inside, as we were hearing, merely cold becomes torture. We immediately contacted MDC +officials, and they denied any problem with the heat or medical care. As the reports from +our clients continued, we began filing emergency motions before the trial judges in their +cases, asking for release or removal to safer conditions. We asked the MDC for a tour of the +facility but were denied. As we sought relief in court, federal prosecutors reported to the +judges that MDC officials were telling them that all was fine; our concerns were overblown, +and out clients were lying. +On Thursday, January 31, the New York Times reported on the conditions. In a statement +to the Times, prison officials minimized the problems and stated that "the electrical failure +was related to Con Edison, which it said had been 'dealing with numerous power +emergencies in the community." That, of course, was a lie, and Con Edison quickly refuted +it. The Times story included not just our lawyers' and clients' accounts but those of the +2 + + +correctional officers who work there. According to the officers, temperatures were +"freezing," and people in cells "just stay huddled up in the bed." "We didn't have heat in +the building, we didn't have light." With the press attention and the corroboration of the +officers, our complaints began to be taken seriously. +On Friday, February 1, the Chief Judge of the Eastern District of New York, Dora Irizarry, +ordered that we be given access, and the head of our Eastern District office, Deirdre von +Dornum, entered the facility - now five days after the fire and loss of power. What she +found was horrifying. It was after sunset, and the small cells containing two people each, +were pitch black. The only lighting was emergency lighting coming from the common areas. +Our clients had been locked down in those cells for the past 24 hours and for various long +stretches throughout the week. Some cells had heat; others were frigid. People needing new +medication couldn't get it. People who require Continuous Positive Airway Pressure +machines (CPAPs) couldn't use them because of the lack of power. Their lives were in +danger, and they were terrified. One man with an open wound showed Ms. von Dornum +(and later a federal judge who also toured the facility) his puss-covered bandages that hadn't +been changed in two weeks. Another, who suffered from ulcerative colitis, showed her his +bloody bedding that had not been changed because of the lack of laundry services. +Everyone was scared and cut off from the world: no family visits, attorney visits, or phone +calls other than use of the direct line to the Federal Defenders during the rare moments they +were let out of their cells. +I toured the facility the following day with various local and federal officials, including +Chairman Jerrold Nadler and Representative Nydia Velazquez. Chairman Nadler asked the +Warden, Herman Quay, why there wasn't a better plan for a power outage of this sort and +why there wasn't more of a sense of urgency to fix it - and, in particular, why the electricians +were not working that day, much less around the clock. The warden had no answers. +Representative Velazquez expressed her anger that the previous day when she had come for +a tour, MDC officials only showed her the common areas, not the cells, by falsely telling her +the inmates were locked down for a "count" - a brief, temporary tally of the population. In +fact, they were still locked down as of Saturday afternoon - going on 48 hours. And despite +numerous corrections officers corroborating the lack of heat in certain areas throughout the +week (and the week before), the warden continued to deny any problems. On our tour that +afternoon we saw many of the same problems Ms. von Dornum had seen the night before: +frantic, scared people locked in pairs in tiny, unlit cells. Some cells had heat; others did not. +One cell registered 50 degrees on a portable thermometer. +The next day, on the heels of the press attention and the vigorous prodding of Chairman +Nadler and Representative Velazquez, the power was restored. In the wake of the debacle, +at the request of Chairman Nadler and Representative Velazquez, the Office of the +Inspector General of the Department of Justice (IG) investigated the incident. The IG +Report confirmed and even amplified many of the problems. But its ultimate +recommendations fell well short of real accountability. +3 + + +Let's start with the problems it confirmed and amplified. The power problems had nothing +to do with Con Edison. There were longstanding facilities management and building +maintenance problems, and those problems were the cause of the crisis. There were in fact +serious heat problems - problems that pre-dated the electrical fire and were exacerbated by +MDC employees' mistakes. During the crisis, inmates were being locked down for extended +periods of time. The majority were not given extra blankets or long sleeved clothing. +Medical care was compromised. The provision of food was seriously impacted. There was +no contingency plan for legal or family visitation. There was no plan for people who require +electricity for medical equipment such as CPAPs. There was a serious lack of transparency +and communication with the courts, attorneys, media, and the families of those incarcerated. +Unfortunately, the IG Report failed to discuss MDC officials' lies. The institution lied in its +press release saying Con Edison was to blame. Warden Quay lied about there being no heat +problems. He lied about inmates not being locked down. He lied repeatedly about the +severity of the situation and its impact on medical care and safety. +And predictably, there has been no real accountability. Warden Quay was promoted. He +now overseas multiple federal prisons in Pennsylvania. I say predictably because this lack of +accountability is consistent with many years of IG reports finding severe mismanagement at +the MDC. Earlier reports have detailed serious problems with the MDC's management of +solitary confinement, the treatment of sentenced women housed in the East Building, and +separately, multiple instances of serious sexual assaults of men and women by corrections +officers. Many of the problems identified in those reports (and many others) remain. +Suicide at the MCC +The other pretrial federal jail in my home district that has gained notoriety recently is the +MCC in downtown Manhattan. Media attention has focused on the death of Jeffrey Epstein +whose high profile case and suicide at the MCC brought scrutiny to the management of the +institution. I do not have any personal knowledge regarding the circumstances of +Mr. Epstein's death, and I therefore cannot comment on what failings at the institution led +to it. +But I can say with confidence that a variety of problems, similar to those at the MDC, plague +the institution. Both institutions are chronically short-staffed, or so officials tell us when +legal of social visitation is cancelled or when we wait for hours to be able to visit with clients. +Both institutions have extremely limited educational or vocational programming. +Corrections officers at both facilities have committed egregious sexual assaults against +inmates. And in both, medical care is abysmal. +In addition to those problems, there is the matter of the physical space. The MCC is a +cramped, vertical building with the only "outdoor" recreation located on the roof of the +building in a space covered by thick fencing that barely allows for a view of the sky. The +unit at the MCC where Epstein was housed, "9 South," keeps people in small, virtually +4 + + +windowless cells for 23 hours a day. The MCC was built in the 1970s with a capacity for +roughly half of the number of people now held there. And it was initially built without +rooms for attorney visitation even though it is a pretrial detention facility. The limited +number of attorney visitation rooms now create expensive and aggravating delays. +Here in New York City, the local jail at Rikers Island gets deserved attention for its +deplorable conditions, yet in their own way, the federal pretrial facilities can be worse. I +have often had clients who were initially held on state charges at Rikers and then brought to +the MCC or MDC to face federal charges. Because of the conditions, many have asked me +if it's possible to return to Rikers. Several years ago, the U.S. Attorney's Office for the +Southern District of New York sued the local New York-run Rikers Island over jail +conditions, but the office has never done anything about the MCC, the federal facility where +the U.S. Attorney's Office itself sends people. Indeed, when legal action is taken against the +MCC or MDC, it is the U.S. Attorney's Office that represents the institutions. +There are legal, administrative, and cultural barriers to U.S. Attorney's Ottices playing the +same role with respect to federal jails as they play with state and local facilities. For that +reason, Congress should explore other avenues for providing outside accountability for +laces like the MCC and MDC that have thus far proved entirely resistant to change +The First Step Act +Shortly before the fire at the MDC, Congress passed and the President signed the FSA. The +FSA gives the DOJ, and the BOP specifically, significant additional authority and +responsibility to help prisoners succeed in their communities upon release and thereby +reduce recidivism. But it can only succeed if the DOJ and BOP faithfully implement the will +of Congress. +A Lack of Programming +To meet the twin goals of improved public safety and reduced levels of incarceration, the +FSA relies heavily on the BOP offering substantially increased programming and productive +activities for incarcerated individuals. To date, the BOP has failed to provide adequate +programming to meet current needs, much less the increased demand that will be required to +make the FSA a success. The true extent of the deficit is not known because the BOP has +not been transparent about the number of programs offered, the capacity of these programs, +and the length of the waitlists for these programs. The BOP has failed to respond to +requests from Congress for this information, and provides even less information to the +public. What we do know indicates the BOP is not providing enough individuals with +sufficient quality programming. Available data shows waitlists to participate in the BOP +programs are long: 25,000 people are currently waiting to be placed in prison work +5 + + +programs, ' at least 15,000 are waiting for education and vocational training,? and at least +5,000 are awaiting drug abuse treatment.? And, assuming the sample used to develop the +Prisoner Assessment Tool Targeting Estimated Risk and Needs (PATTERN) is +representative, DOJ data indicates almost half (49%) of individuals serving federal sentences +of incarceration complete no programs; that a vast majority have no technical/vocational +courses (82%) or federal industry employment (92%) and well over half (57%) have not had +drug treatment while incarcerated despite indication of need.* Access to quality programs +also varies from one institution to another. This is unfortunate because programs such as +Federal Prison Industries (also known by its trade name, UNICOR) has been proven to +reduce recidivism by 24%." Participants in FPI are also 14% more likely than similarly +situated individuals who did not participate to be employed after release for prison.? +' See BOP: UNICOR, Federal Bureau of Prisons, +https://www.bop.gov/inmates/custody_and_care/unicor_about.jsp (estimating the participation +rate at 8%). +2 See Oversight of the Federal Burean of Prisons Before the H. Subcomm. on Crime, Terrorism, Homeland Security +and Investigations of the H. Comm. on the Judiciary, 115th Cong. 20 (2018) (BOP Director Inch). +" See Dep't of Justice, Bureau of Prisons, Drug Abuse Treatment Program, 81 Fed. Reg. 24484, +24488 (Apr. 26, 2016) ("over 5,000 inmates waiting to enter treatment"); Charles Colson Task Force +on Federal Corrections, Transforming Prisons, Resforing Lives: Final Recommendations of the Colson Task +Force on Federal Corrections 36 (Jan, 2016) (*at the end of FY 2014, more than 12,300 people +systemwide were awaiting drug abuse treatment"). Substantial waitlists also exist for mental health +programs and trauma therapy programs for female inmates. See Office of the Inspector General, +U.S. Dep't of Just., Revien of the Federal Bureas of Prisons' Use of Restrictive Housing for Inmates with Mental +Illness 51 (2017); Office of the Inspector General, U.S. Dep't of Just., Review of the Federal Bureau of +Prisons' Management of Its Female Inmate Population, 19-22 (2018). +* See Office of the Attorney General, U.S. Dep't of Just. The First Step Act of 2018: Risk and Needs +Assessment System 47, tbl.1 (2019) (DOJ Report). +5 See, eg, BOP, Directory of National Programs, +https://www.bop.gov/inmates/custody_and_care/docs/20170913_Directory_of_National_Progra +ms1.pdf; Office of the Inspector General, U.S. Dep't of Just., Review of the Federal Bureas of Prisons' +Release Preparation Program i (2016) (finding that the BOP "leaves each BOP institution to determine +its own [Release Preparation Program (RPP)] curriculum, which has led to widely inconsistent +curricula, content, and quality among RPP courses"). +"See FPI and Vocational Training Works: Post-Release Employment Project (PREP) at +http://www.bop.gov/resources/pdfs/prep_summary_05012012.pdf; see also Federal Bureau of +Prisons, UNICOR: Preparing Inmates for Successful Reentry tbrough Job Training, +http://www.bop.gov/inmates/custody_and_care/unicor.jsp. +" See Federal Bureau of Prisons, UNICOR: Preparing Inmates for Successful Reentry through Job Training, +http://www.bop.gov/inmates/custody_and_care/unicor.jsp. +6 + + +The BOP has a long history of not providing sufficient programs. Moving forward, because +the recidivism reduction efforts of the FSA are meaningless without adequate programming, +our primary concern is whether the BOP will provide a broad range of programs, and +sufficient program capacity, to comply with the FSA requirement that the BOP "provide all +prisoners with the opportunity to actively participate in evidence-based recidivism reduction +programs or productive activities according to their specific criminogenic needs, throughout +their entire term of incarceration."" The BOP's past performance, with long waitlists, and +inconsistent access and quality across institutions, makes it difficult to have confidence that +the BOP will meet its statutory obligations in this regard. +The Risk and Needs Assessment System +Also critical to the success of the FSA is a risk and needs assessment system that is +transparent, fair, and unbiased. Early signs indicate that the system will not meet any of +those criteria. +The FSA required the DOJ to develop a risk and needs assessment system that, among other +things, would determine "the recidivism risk of each prisoner" and "the type and amount of +evidence-based recidivism reduction programming for each.") The system, through its +impact on the ability of incarcerated people to earn early release credits, will directly govern +how much time people serve in prison. This makes it a high-stakes tool, and testing for +accuracy and bias is crucial. Indeed, Congress understood the stakes and called for +transparency throughout the FSA, including a mandate that the risk and needs assessment +system be "developed and released publicly."1° Congress also repeatedly required that the +system be monitored for bias." +On July 19, the DOJ issued a report announcing the initial development of PATTERN. The +DOJ Report on PATTERN provides very little information about its development. This is +* First Step Act of 2018 (FSA), Pub. L. 115-391, Title I, § 102(a) (Dec. 21, 2018) (codified at 18 +U.S.C. § 3621(h) (6). +" FSA at, Title I, § 101(a) (codified at 18 U.S.C. § 3632(a)). +1'' Id. +"See, eg., FSA at Title I, § 103 (requiring the Comptroller General to conduct an audit of the use of +the risk and needs assessment system every two years, which must include an analysis of "It)he rates +of recidivism among similarly classified prisoners to identify any unwarranted disparities, including +disparities among similarly classified prisoners of different demographic groups, in such rates."); +FSA at Title 1, § 107(g) (requiring the Independent Review Committee to submit to Congress a +report addressing the demographic percentages of inmates ineligible to receive and apply time +credits, including by age, race, and sex); FSA at Title VI, S 610(a)(26) (requiring the Director of the +Bureau of Justice Statisties to annually submit to Congress statistics on "It]he breakdown of +prisoners classified at each risk level by demographic characteristics, including age, sex, race, and the +length of the sentence imposed."). +7 + + +extremely troubling because the development of PATTERN, as with all risk assessment +tools, necessarily relies on both empirical research and moral choices. ' Based on the limited +information provided in the DOJ Report, we have concerns, and even more questions, in +both areas. Additional information is needed to assess many important issues including: +PATTERN's accuracy; its scoring mechanisms; its fairness across age, gender, race and +ethnicity; whether it will exacerbate racial disparity in the federal prison population; its +impact on privacy interests; and whether it is consistent with the congressional mandate to +"ensure" that "all prisoners at each risk level have a meaningful opportunity to reduce their +classification during the period of incarceration."13 +Transparency in the methods for developing, validating and bias testing PATTERN is vital. +Full transparency is a primary way (along with accountability and auditability) to create and +justify confidence by stakeholders and the public. Indeed, across risk assessments in criminal +justice, the secrecy that permeates black box instruments causes significant concerns about +how reasonable they are in practice. Full transparency requires the DOJ to release the same +dataset used by Grant Duwe, Ph.D., and Zachary Hamilton, Ph.D., to create PATTERN. '4 +This is consistent not only with the transparency directives in the FSA, 15 but also with the +advice of leading organizations such as the National Center for State Courts, which +recommends that independent evaluators determine whether their independent "research +findings support or contradict conclusions drawn by the instrument developers."I" For a +fuller listing of the information that must be known and why, I am attaching as Exhibit A +the Federal Defenders' letter to the NIJ. +* Michael Tonry, Legal and Etbical Issues in the Prediction of Recidivism, 26 FED. SENT'G REP. 167, 167 +(2014). +18 U.S.C. § 3632(a) (5)(A). +1 See DOJ Report at 42-43. +15 See supra notes 10 & 11. +' Pamela M. Casey et al., National Center for State Courts, Offender Risk &* Needs Assessment Instruments: +A Primer for Courts 19 (2014) (stressing that third party audits are valued because "it is always helpful +to know whether existing research descriptions about the reliability, validity, and fairness of a tool +have been replicated by others." Any "decisions based on a [risk and needs] tool which grossly +misclassifies the risk levels of offenders may not simply fail to improve outcomes; they may actually +do harm to the offender." As a result, "i]nstrument validation is not only important to ensure that +decision making is informed by data, but to establish stakeholder confidence."); see also Nathan +James, CONG. RESEARCH SERV., Risk and Needs Assessment in the Federal Prison System 11 (July 10, +2018) (Congressional Research Service report concerning risk assessment in the federal prison +system positively citing the recommendation of the Council of State Governments that independent +third parties should be permitted to validate the tool to assess accuracy by race and gender). +8 + + +The importance of transparency is heightened by some of the initial known aspects of the +system. For instance, the DOJ's definition of the central measured outcome in the risk +assessment: recidivism. The definition the DOJ chose is unduly broad, sweeping in +revocations for minor technical violations such as failure to timely report a change of +residence, or failing to timely notify the probation officer of being questioned by police.!? +This broad definition of "recidivism" is inconsistent with the goals of the FSA to +successfully reintegrate individuals in their communities and protect the public. +Another choice that signals the need for vigilance and concern is the decision to release a +risk assessment tool that has a racially disparate impact, particularly on black males. +According to DOJ data, white males are far more likely than black males to fall in the +minimum and low risk categories, 57% versus 27% respectively. 18 We are concerned the +BOP has not, and Will not, take appropriate steps to ameliorate this disparity. +Relatedly, we are deeply troubled that there is still no needs assessment as required under the +FSA, and that the BOP does not expect one to even be available for testing until the second +quarter of 2020,'" Until then, the BOP appears to be relying on its current "needs +assessment" that was criticized by the Office of the Inspector General back in 2016.20 +Management of FSA Timelines and Requirements +We are also concerned that the BOP will not implement other components of the FSA +within the required timeframes, unnecessarily delaying access to programs that reduce +recidivism, and incentives for participating in them. No information has been provided on +whether the risk assessment tool has been finalized following public comment and is now +ready to be used (or is already being used) by properly trained BOP employees to complete +the initial intake for each incarcerated individual by January 15, 2020. No information has +been provided regarding whether training is progressing such that BOP staff will be capable +of completing that initial intake. While the DOJ indicated it would take four months to +develop advanced training, it is not clear whether development efforts have begun. 21 No +information has been provided on whether the BOP has started assessing newly-committed +" See, eg., USSG §5D1.3(c)(4), (c)(5), (c) (9). +1* DOJ Report at 62, tbl. 8. +' DOJ Report at 64, 78. +'"' Office of the Inspector General, U.S. Dep't of Just., Review of the Federal Bureau of Prisons' Release +Preparation Program 14 (2016) ("the BOP's current method [of assessing risk and needs], which relies +heavily on staff discretion to identify and tailor RPP programming efforts to inmate needs, may not +be as effective of efficient as the more systematic tools that many state correctional systems use"). +" DOJ Report at 86. +9 + + +inmates. And critically, no information has been provided on how soon after the +commencement of a sentence, individuals can expect to start participating in programming. +Time and again, the BOP has proven unable to meet even basic standards in the +management and care of the federal inmate population. Indeed, virtually every time the +BOP has been scrutinized—from managing its compassionate release program, to preparing +individuals for reentry? —the agency has proven itself unable to effectively allocate its +resources, collect data, and provide baseline care for the individuals in its keep. +Closing Residential Reentry Centers +Under the FSA, people who complete certain programs in custody will soon begin earning +credits that, in theory, they can exchange for greater prelease time in community corrections, +including the possibility of additional time at Residential Reentry Centers (RRCs). But if +reentry capacity decreases instead of expands, these credits may be worthless. Sadly, because +of the BOP's recent practices, that is exactly what is happening. +My colleague, Lisa Hay, the Federal Defender for the District of Oregon, has detailed this +problem in a letter to the Director of the BOP, Kathleen Sawyer. (Attached as Exhibit B). +In the letter she explains that at least 20 reentry centers have closed or ceased accepting +federal inmates since 2017, and more closures appear likely. This loss of bed space cripples +efforts to enhance successful reentry of incarcerated citizens, undermines the criminal justice +goal of rehabilitation, and consequently threatens community safety. Reentry centers can +provide the opportunity, in a less structured setting than prison, for individuals to engage in +needed treatment, find employment, and continue reconnecting with their family and +community. Once lost, these precious resources are difficult to replace. +The closing of RRCs is in keeping with a long history of the BOP failing to release people as +early as the law provides. The Second Chance Act of 2007 doubled the amount of +sentenced time that federal prisoners were eligible to spend in reentry centers from six +months to up to one year. 18 U.S.C. S 3624(c). During this "prerelease time," the individual +is not released from his or her federal sentence but is serving the sentence in an alternative +2 See, eg., Office of the Inspector General, U.S. Dep't of Just., The Federal Bureau of Prisons' +Compassionate Release Program 53 (2013) ("[WJe found that the existing BOP compassionate release +program is poorly managed and that its inconsistent and ad hoc implementation has likely resulted in +potentially eligible inmates not being considered for release. It has also likely resulted in terminally ill +inmates dying before their requests for compassionate release were decided."); Office of the +Inspector General, U.S. Dep't of Just., Review of the Federal Burean of Prisons' Release Preparation Program i +(2016) ("Significantly, we found that the BOP does not ensure that the [Release Preparation +Programs (RPPs)] across its institutions are meeting inmate needs. Specifically, BOP policy does not +provide a nationwide RPP curriculum, or even a centralized framework to guide curriculum +development... [Further,] the BOP does not have an objective and formal process to accurately +identify and assess inmate needs or determine which RPP courses are relevant."). +10 + + +setting. Defenders were encouraged by this Congressional recognition that our clients and +their communities both benefited when reentering individuals were given more time, in a +gradually less structured setting, to engage in treatment, employment counselling, parenting +classes, and other programs designed to ensure the safety of the community and the success +of the resident after incarceration. Despite this mandate from Congress, however, the BOP +was slow to change, and the amount of prerelease time that individuals were awarded to +spend in reentry centers remained low. In 2011 Defenders wrote to then Director Thomas +Kane to express concern about this failure to implement the Second Chance Act.23 In 2012, +the General Accountability Office issued a report that similarly noted the BOP's failure to +adequately implement Congressional mandated alternative options to incarceration, including +use of reentry centers. 24 +After the GAO report, the BOP did begin to utilize reentry centers more fully, awarding +slightly greater prerelease time to individuals. But the amount of this prerelease time awarded +by the BOP is again declining. According to the most recent report submitted by the BOP to +the House and Senate Judiciary Committees, the average length of placement in reentry +centers decreased by almost 20% from the first quarter measured (April - June 2017) to the +last quarter (January-March 2018), resulting in almost a full month less of reentry time by the +last quarter (an average of 119 days compared to 146 at the start of the year). 25 Notably, +even the high, four-month average represents significantly less time than the one year +authorized by Congress. +The BOP acknowledged in a 2017 memorandum that "due to fiscal constraints," the average +length of stay was "likely to decline to about 120-125 days."20 Anecdotal information from +prisons indicates that counsellors have been told to limit the amount of prerelease time in +reentry centers to even less than 120 days. At one prison, individuals reported seeing a +printed sign on the counsellor's wall reading: "We will put you in for a maximum of 90 days +of RRC time, but it will most likely be less. Yes we know what the Second Chance Act says." +Numerous reentry centers confirm that lengths of stay have declined significantly over the +last few years. The BOP's formal or informal restrictions on prelease time harm individuals +serving federal sentences by limiting their opportunity for structured reentry into the +" Letter of FPD Thomas Hillier to Bureau of Prisons' Director Thomas Kane, dated November 16, +2011. (Exhibit B, Attachment A). +2 Government Accountability Office, Bureau of Prisons: Eligibility and Capacity Impact Use of +Flexibilities to Reduce Inmates' Time in Prison (Feb. 2012) available at: +https://www.gao.gov/products/GAO-12-320. +25 Utilization of Community Corrections Facilities: Report to Congress (Apr. 2017- Mar. 2018). +(Exhibit B, Attachment E). +' Memorandum of Acting Assistant Director, Hugh Hurwitz, Oct. 10, 2017. (Exhibit B, +Attachment C). + + +community. The limits also harm reentry centers because the declining lengths of stay mean +that facilities are not operating at full capacity. Many reentry centers increased capacity with +the encouragement of the BOP and now find they are in difficult fiscal straits as individuals +spend more time in prison and less time in reentry centers. +Conclusion +If past predicts future, there is good reason to question whether the BOP will comply with +either the spirit or the letter of the FSA and take the steps Congress envisioned to reduce +recidivism, improve public safety, and reduce unnecessary incarceration. I began my +testimony with the story of last year's crisis at the MDC because I think it is sadly indicative +of the lack of accountability throughout the BOP. +The stakes tor successtul implementation of the FSA are high. As Congress recognized, the +overwhelming majority of people in prison will get out and become our neighbors again. If +they are treated with harshness, neglect, violence, and inhumanity in prison, they are much +more likely to respond in kind when they get out. Robust programming, use of a fair and +unbiased system to award early release credits, and thoughtful planning for reentry are key to +the FSA's success. It will not happen without vigorous oversight. I thank this Committee +for recognizing that and holding this hearing. +12 + + + + + +52 Duane Street, 10h Floor +New York, NY 1007 +Tel: (212) 417-8738 +Co-Chairs +David Patton +Executive Director +Federal Defenders of New York +Jon Sands +Federal Defender +District of Arizona +September 13, 2019 +David B. Muhlhausen, Ph.D. +Director +National Institute of Justice +Office of Justice Programs +Department of Justice +810 7' Street NW +Washington, DC 20531 +Re: DOJ First Step Act Listening Session on PATTERN +Dear Dr. Muhlhausen: +Thank you for inviting comment from the Federal Public and Community Defenders regarding the +Department of Justice's (DOJ) development of the Prisoner Assessment Tool Targeting Estimated +Risk and Needs (PATTERN) as part of its obligations under the First Step Act (FSA). The Federal +Public and Community Defenders represent the vast majority of defendants in 91 of the 94 federal +judicial districts nationwide, and we welcome the opportunity to provide our views. +PATTERN will directly affect how much time many of our clients spend in prison. This makes it a +high-stakes tool, and means testing for accuracy and bias is crucial. Indeed, Congress understood the +stakes and called for transparency throughout the FSA, including a mandate that the risk and needs +assessment system be "developed and released publicly." Congress also repeatedly required that the +system be monitored for bias." The limited information released by the DOJ in its July 19, 2019 +' First Step Act of 2018 (FSA), Pub. L. 115-391, Title I, § 101(a) (Dec. 21, 2018) (codified at 18 +U.S.C. S 3632(a)). += See, eg., FSA at Title I, § 103 (requiring the Comptroller General to conduct an audit of the use of +the risk and needs assessment system every two years, which must include an analysis of "[t]he rates +of recidivism among similarly classified prisoners to identify any unwarranted disparities, including +disparities among similarly classified prisoners of different demographic groups, in such rates."); +FSA at Title 1, § 107(g) (requiring the Independent Review Committee to submit to Congress a +report addressing the demographic percentages of inmates ineligible to receive and apply time +credits, including by age, race, and sex); FSA at Title VI, S 610(a)(26) (requiring the Director of the +Bureau of Justice Statistics to annually submit to Congress statistics on "It]he breakdown of + + +52 Duane Street, 10% Floor +New York, NY 1007 +Tel: (212) 417-8738 +report (DOJ Report) confirms the need to assess PATTERN for accuracy and bias. For example, +reported data indicates PATTTERN will have a racially disparate impact, particularly on black males. +As illustrated in the charts below, based on the DOJ Report, white males are far more likely than +black males to fall in the minimum and low risk categories. +Racial Disparities in Eligibility +for Full Earned Release Incentives +White Males +Black Males +27% +57% +* Minimum/Low +• Medium/High +* Minimum/Low +• Medium/High +This matters because these are the categories that are eligible for higher rates of earned time credits +and eligibility for supervised release and prerelease custody* +The DOJ Report fails to provide the level of transparency required for meaningfil evaluation of +PATTERN. Below, we detail much of the additional information needed to fully assess PATTERN +for accuracy and bias. We look forward to providing additional thoughts after the DOJ has released +this information and hope our comment here is only the beginning of an ongoing dialogue with the +DOJ regarding PATTERN. +I. +RISK ASSESSMENT +PATTERN is a risk assessment tool "designed to predict the likelihood of general and violent +recidivism for all BOP inmates." It places "individuals into four categories: high, medium, low or +prisoners classified at each risk level by demographic characteristics, including age, sex, race, and the +length of the sentence imposed."). +" See U.S. Dep't of Just., The First Step Act of 2018: Risk and Needs Assessment System 62, tbl. 8(2019) +(DOJ Report) (reporting 57% of white males in the developmental sample fall in the minimum and +low risk categories while only 27% of black males fall in those same categories).| +* See FSA at Title I § 101(a) (codified at 18 U.S.C. § 3632(d) (4)(A), providing more earned time +credits for some individuals in the lowest two risk categories); Title I § 102(b)(1)(B) (codified at 18 +U.S.C. § 3624(g) (1), restricting eligibility to transfer to supervised release or prerelease custody to +individuals in the minimum or low risk categories, absent warden approval under specified +circumstances). +' DOJ Report at 43. +2 + + +New York, NY 1007 +Tel: (212) 417-8738 +minimum."* These risk categories determine the number of credits an individual may earn by +participating in programs and productive activities, and also eligibility to attribute those credits +toward supervised release or prerelease custody.' In other words, the risk categories will directly +affect how much time many individuals spend in prison. +The development of PATTERN, as with all risk assessment tools, necessarily relies on both +empirical research and moral choices." Based on the DOJ Report, we have concerns, but even more +questions, in both areas. Additional information is needed to assess many important issues including: +PATTERN's accuracy; its scoring mechanisms; its fairness across age, gender, race and ethnicity; +how much it will exacerbate racial disparity in the federal prison population; its impact on privacy +interests; and whether it is consistent with the congressional mandate to "ensure" that "all prisoners +at each risk level have a meaningful opportunity to reduce their classification during the period of +incarceration. +A. Transparency & Accountability: Development, Validation and Bias Testing +Transparency in the methods for developing, validating and bias testing PATTERN is vital. Full +transparency is a primary way (along with accountability and auditability) to create and justify +confidence by stakeholders and the public. Indeed, across risk assessments in criminal justice, the +secrecy that permeates black box instruments causes significant concerns about how reasonable they +are in practice. +1. Dataset +Full transparency requires DOJ to release the same dataset used by Grant Duwe, Ph.D., and +Zachary Hamilton, Ph.D., to create PATTERN.'" This is consistent not only with the transparency +directives in the FSA," but also with the advice of leading organizations such as the National Center +for State Courts which recommends that independent evaluators determine whether their +independent "research findings support or contradict conclusions drawn by the instrument +developers."2 +" DOJ Report at 50. +" See supra note 4. +* See Michael Tonry, Legal and Ethical Issues in the Prediction of Recidivism, 26 FED. SENT'G REP. 167, 167 +(2014). +^ FSA at Title I § 101(a) (codified at 18 U.S.C. § 3632(a) (5)(A)). +1' See DOJ Report at 42-43. +" See supra notes 1 & 2. +12 Pamela M. Casey et al., National Center for State Courts, Offender Risk er Needs Assessment Instruments: +A Primer for Courts 19 (2014) (stressing that third party audits are valued because "it is always helpful +to know whether existing research descriptions about the reliability, validity, and fairness of a tool +have been replicated by others." Any "decisions based on a [risk and needs] tool which grossly +3 + + +New York, NY 1007 +Tel: (212) 417-8738 +• Access to the full dataset would permit independent researchers to assess validity and +algorithmic fairness using a variety of measures and calculations." +• Despite recognizing the existence of multiple measures and calculations concerning +validity," the DOJ Report focused mostly on the Area Under the Curve (AUC). The AUC, +however, has limited utility as a measure of relative risk. Further, when tools are assessed +using multiple measures of predictive validity (eg,, correlations, calibration metrics, Somers' +D), results for the same tools vary. +• Access to the dataset would allow interested parties to complete 2 x 2 contingency tables +(number of false negatives, false positives, true negatives, true positives) for general and +violent recidivism at each cutoff (minimum to low; low to medium; medium to high) by age, +gender and race/ethnicity groupings. These contingency tables would provide important +information on the degree to which the categorizations created by the cut-points capture +true positives and true negatives (in addition to the associated recidivism rates that the DOJ +Report included)." +• The dataset would allow independent researchers to compute the algorithmic fairness +measures called balance for the positive and negative classes by calculating average scores by +recidivists versus non-recidivists across each age, gender, and racial/ethnic groupings. +misclassifies the risk levels of offenders may not simply fail to improve outcomes; they may actually +do harm to the offender." As a result, "[i]nstrument validation is not only important to ensure that +decision making is informed by data, but to establish stakeholder confidence."); see also Nathan +James, CONG. RESEARCH SERV., Risk, and Needs Assessment in the Federal Prison System 11 July 10, +2018) (Congressional Research Service report concerning risk assessment in the federal prison +system positively citing the recommendation of the Council of State Governments that independent +third parties should be permitted to validate the tool to assess accuracy by race and gender). +13 For example, release of the full dataset would allow independent researchers to calculate relevant +measures such as false positive rates, false negative rates, positive predictive value, negative +predictive value, equal calibration, balance for the positive class, balance for the negative class, +diagnostic odds ratios, correlations, treatment equality, and demographic parity. The importance of +these various measures are discussed and calculated regarding other risk tools in sources cited in the +DOJ Report. See DOJ Report at 38-39 nn.20-24. +' See DOJ Report at 28 (discussing multiple algorithmic measures of racial bias). +15 See Melissa Hamilton, Debating Algorithmic Fairess, 52 UC DAvIs L. REv. ONLINE 261 (2019); Jay +P. Singh, Predictive Validity Performance Indicators in Violent Risk Assessment, 31 BEHAV. Scr. & L. 8, 16- +18 (2013). +' See generally Sarah L. Desmarais et al., Performance of Recidivism Risk Assessment Instruments in U.S. +Correctional Settings, 13 PSYCHOL. SCI. 206 (2016). +' See Richard Berk et al., Fairess in Criminal Justice Settings: The State of the Art, SOC. METHODS & RES. +(forthcoming 2019). +4 + + +New York, NY 1007 +Tel: (212) 417-8738 +• Access to the dataset would allow interested parties to complete the bivariate correlations +between predictors and risk outcomes which the DOJ Report indicates were completed by +the developers, but are not reported." +• Access to the dataset would permit independent researchers to test for bias, including +comparing each racial/ethnic grouping. As discussed above, the DOJ Report indicates the +need for additional inquiry regarding racial disparity and other biases." First, DOJ data show +that black males are far less likely than white males to fall into the two lower risk categories +that receive the full benefits of earned time credit and eligibility to use those credits for +supervised release or prerelease custody.'" In addition, the relative rate index (RRI) of 1.54 +repotted in Table 8, but not discussed in the text, comparing white to non-white males, also +shows PATTERN has a racially disparate impact." More information is needed, including +data on Native-Americans and Asians, which is not included in the DOJ Report. +Access to the data would allow independent researchers to isolate individual factors and +determine which contributed to any disparate impact. For example, research on the Post- +Conviction Risk Assessment (PRA) found that "Black offenders tend to obtain higher +scores on the PCRA than do White offenders" and that "most (66 percent) of the racial +difference in the PCRA scores is attributable to criminal history."2 Because PATTERN +plays a role in determining how much time a person spends in prison, a similar finding of +racial difference with PATTERN could "exacerbate racial disparities in prison." Identifying +18 See DOJ Report at 65 n.17. +1' See supra note 3 and accompanying text. +2" See id. +21 See DOJ Report at 62, tbl. 8 +2 See William Feyerherm et al., Identification and Monitoring in Dept. of Just. Office of Juvenile Justice +and Delinquency Prevention, Disproportionate Minority Contact Technical Assistance Manual, 1-1, +1-2, 3 (4th ed. 2009) (recommending the RRI be calculated separately for each minority group that +comprises at least 1% of the total population scored); BOP Statistics: Inmate Race, Federal Bureau +of Prisons, https://www.bop.gov/about/statistics/statistics_inmate_race.jsp. +2 Jennifer L. Skeem & Christopher T. Lowenkamp, Risk, Race, and Recidivism: Predictive Bias and +Disparate Impact, 54 CRIMINOLOGY 680, 700 (2016). +2* Id. at 705; see also id. at 703, 705 (explaining that as assessment of whether a tool produces +"inequitable consequences" depends on "what decision they inform" and that "some applications of +instruments might exacerbate racial disparities in incarceration"). +5 + + +New York, NY 1007 +Tel: (212) 417-8738 +which factors generate the disparate impact would open an opportunity to brainstorm with +people across disciplines about how to ameliorate such impact." +• Access to the dataset would allow independent researchers to evaluate test bias employing +the hierarchical modeling method considered best practice in the educational testing +literature as referred to, but not reported in, the DOJ Report.?" +• Access to the dataset would allow interested parties to determine whether there are mistakes +in the DOJ Report regarding the recidivism rates by ordinal ranking. Table 5 reports general +recidivism rates of 9% (minimum), 31% (low), 51% (medium), and 73% (high). Table 9 +reports identical recidivism rates in each of these categories for white males," which might +either be coincidental or a mistake in reporting. +• Similarly, access to the dataset would allow independent researchers to determine the correct +AUC for violent recidivism as defined by the developers. The DOJ Report is inconsistent, +reporting in one table the AUCs for violent recidivism as .78 for males and .77 for females.?* +In another table, they are reversed, indicating AUCs of .77 for males and .78 for females." +These differences are not significant in terms of numbers, but flaws such as these +(reasonable considering the tight time frame which the PATTERN team faced) call for +independent audits to check for other potential errors. +2. Eligibility +Additional information is needed regarding the assumptions behind the assertion that *99% of +offenders have the ability to become eligible for early release through the accumulation of earned +time credits even though they may not be eligible immediately upon admission to prison. That is ... +nearly all have the ability to reduce their risk score to the low category."" Without more information +it is impossible to test this assertion, but it appears suspect in light of: the percentage of the +developmental sample that fell in the medium and high categories (52% of all and 58% of men);" +that high scores are likely driven by static factors such as age of first conviction and criminal history +23 See Richard Berk, Accuracy and Fairness for Juvenile Justice Risks Assessments, 16 J. EMPIRICAL LEG. +STUD. 175, 184 (2019). +2* See DOJ Report at 29 (referring implicitly to what is known as the Cleary method). +27 See DOJ Report at 59, tbl. 5 & 62, tbl. 9. +28 See DOJ Report at 57, tbl. 3. +2' See DOJ Report at 60, tbl. 7. +3" DOJ Report at 57-58. +31 See DOJ Report at 59, tbls. 5 & 6. +6 + + +New York, NY 1007 +Tel: (212) 417-8738 +score; and the limited number of programs/productive activities currently available (with +correspondingly far fewer points allocated by the tool)." +3. Developmental Sample +Additional information is needed regarding the developmental sample. +• Additional information is needed regarding the attributes of the developmental sample. The +DOJ Report includes apparently contradictory, or at least confusing information, about the +composition of the developmental sample. +• The DOJ Report indicates the BOP provided its contractors, Duwe and Hamilton, +with a dataset used to "develop and validate'" PATTERN containing 278,940 BOP +inmates released from BOP facilities between 2009 and 2015," which included "only +those inmates released to the community," and excluded "released inmates who +died" and those "scheduled for deportation."3 DOJ also reports that developers +relied on a smaller "eligible sample size" of 222,970, described as "those who were +released from a BOP facility to a location in the United States and had received a +BRAVO assessment," which may mean that 55,970 individuals from the original +dataset (20%) were excluded from what became the developmental sample because +they had not been scored on BRAVO." More information is needed regarding the +excluded individuals, including demographic characteristics, and reasons they may +have been released but not scored on BRAVO. Such a reduction in the sample size +could introduce sample bias. +• It appears that the training sample contained individuals who were released in 2009- +2013, and the test (or validation) sample contained individuals who were released in +2014-2015.** More information is needed about why the training and test samples +were drawn from different years. Information is also needed regarding what +consideration was given to the possibility that there were risk-relevant differences +between the groups. For example, policy changes, such as the retroactive 2014 +amendment to the drug guidelines, may have resulted in a different composition of +32 See Emily Tiry, Julie Samuels, How Can the First Step Act's Risk Assessment Tool Lead to Early Release +from Federal Prison?, Urban Wire, Crime and Justice (Sept. 5, 2019), https://www.urban.org/urbanwire/how-can-first-step-acts-risk-assessment-tool-lead-early-release-federal-prison. +33 DOJ Report at 43. +3* DOJ Report at 42-43. +35 DOJ Report at 46. +30 See DOJ Report at 49 & 50. +7 + + +New York, NY 1007 +Tel: (212) 417-8738 +individuals released in 2015 than in prior years," It is important for stakeholders to +understand whether the differentials in samples here also embed bias into the tool. +• More information is needed regarding why the size of the developmental sample +used in the DOJ Report is significantly lower than the number of federal prisoners +released in those years, as indicated from another official database. An online tool for +calculating the number of released prisoners offered by the Bureau of Justice +Statistics indicates that 385,405 individuals were released from federal correctional +institutions from 2009-2015. Yet, the DOJ Report specifies that its developmental +sample includes only 278,940 released prisoners." Specifically, it is important to +know whether the reported exclusions for death and deportation' account for the +entire differential or whether there are additional explanations. Similarly, more +information is needed about the size of the training and test groups. The DOJ +Report indicated the training group as 66% of the total developmental sample, with +the test group as 33% of the sample, but also described the training group as +including 5 years of releases, with the test sample including only 2 years of releases. +Information is needed to explain this apparent discrepancy." +• Additional information is needed regarding the sample descriptive statistics (including +recidivism rates). Table 1 provides data on the entire eligible developmental sample, but is +also needed separately for each of the (a) training sample and (b) test sample.* +• Additional information is needed regarding the sample descriptive statistic on "BRAVO-R +Initial: History of Escapes." The total reported percentage is 86%, but no information is +provided regarding whether this means there is 14% missing data on this factor, and if so, +how missing data cases were scored.*3 +• Information is needed regarding the inter-rater reliability scores for the evaluators +concerning the development sample, both training and then test data. These statistics will +provide information relevant to whether PATTERN can be scored consistently, as +$t See Remarks for Public Meeting of the U.S. Sentencing Comm'n, Washington, D.C., at 2 (Jan. 8, +2016) (Honorable Patti B. Saris, Chair) (recognizing that approximately 6,000 ottenders were +released on or about November 1, 2015 as a result of the 2014 amendment to the drug guidelines). +38 These were calculated using an online tool and narrowing to federal prisoners. See Bureau of +Justice Statistics, Corrections Statistical Analysis Tool-Prisoners, +https://www.bjs.gov/index.cfm?ty=nps. +3" See DOJ Report at 42. +4' See DOJ Report at 42-43. +* See DOJ Report at 49-50. +42 See DOJ Report at 46-48, tbl. 1. +43 See DOJ Report at 48, tbl. 1. +8 + + +New York, NY 1007 +Tel: (212) 417-8738 +recognized by the DOJ Report, but for some reason not reported." Low inter-rater reliability +outcomes decrease the utility of a tool. +4. Weighting +The DOJ Report indicates that PATTERN involves "analytically weighting assessment items," but +more information is needed on whether the weights are assigned solely through the points identified +for each of the factors included in Table 2," or are somehow reweighted in an algorithm not +discussed in the report. The DOJ Report provides so few details on weighting, it is uncleat what +type(s) of models were used (such as regressions) and/or whether any type of machine learning +(supervised or unsupervised) was employed. If the former, more information is needed regarding +whether and how step-wise procedures were used, data on intercorrelations, and if multicollinearity +exists. If the algorithm was developed with any form of machine learning, this more "black box" +method has different and profound implications on transparency of the developmental procedures. +5. Overrides +The DOJ Report does not mention overrides. Information is needed regarding whether PATTERN +allows for policy overrides and/or discretionary (also referred to as professional) overrides, and if so, +whether there will be a supervisory approval process for discretionary overrides. Information is also +needed as to whether any of the final scores in the development sample (training and/ot testing) +involved overrides of original scores and the reasons for such overrides. +6. Relevant Research +Copies of two governmental papers cited in the DOJ Report, but not readily available to the public, +must be made available. Specifically, documents detailing the BRAVO-R, from which "PATTERN +builds," and relevant RRI computations are cited as important to understanding PATTERN' but +are not readily available to the public. +7. Definitions & Scoring +More information is needed regarding the definitions of key terms and rules for scoring. +• Recidivism. It appears that for purposes of developing and testing PATTERN, "general +recidivism" is broadly defined to include "any arrest or return to BOP custody following +release."' More information is needed to determine whether this is as (unduly) broad as it +appears, and includes revocations for minor technical violations such as failure to timely +4 See DOJ Report at 27. +* DOJ Report at 50. +* See DOJ Report at 53-56. +* DOJ Report at 44; 64 nn.8 & 9. +4B See DOJ Report at 66 n.25. +'' DOJ Report at 50. +9 + + +New York, NY 1007 +Tel: (212) 417-8738 +report a change of residence, purportedly lying in response to queries from a probation +officer, or failing to timely notify the probation officer of being questioned by police." +Similarly, it appears that for purposes of developing and testing PATTERN, "violent +recidivism" is defined as "violent arrests following release." More information is needed +here, as well, regarding what kinds of arrests are considered "violent." A separate discussion +in the DOJ Report regarding whether the instant offense was violent, appears to cite a +definition of "violent recidivism."2 More information is needed regarding whether this is +also the intended definition of violent recidivism. If so, more information is needed about +what is included in "other violent."53 +Defenders are concerned that revocations, arrests, and misdemeanor convictions are poor +and biased proxies for the kind of serious re-offenses targeted by the recidivism-reduction +programming at the core of the FSA. +In addition, more information is needed regarding whether any mechanism was used to +exclude pseudo-recidivism (prior offenses that were not detected and pursued—-subject to +arrest or return to prison as a result—until after the instant offense). +• Age of First Arrest/ Conviction. More information is needed regarding whether the first +risk factor for purposes of developing, testing and implementing PATTERN is age of first +arrest or age of first conviction. The DOJ Report contains contradictory information, referring +to both arrest and conviction without explanation for the inconsistency.* If looking to +conviction, is the relevant age determined by the individual's age on the date of the alleged +conduct, date of arrest, or date of conviction? More information is also needed about what is +being counted in the "under 18" category. It is unclear whether this factor sweeps in all +juvenile adjudications (including status offenses), or is limited to convictions in adult court. +Among our many concerns with this factor is the relative unreliability of juvenile +5"' See, eg., USSG §5D1.3(c) (4), (c)(5), (c)(9). +" DOJ Report at 50. +* DOJ Report at 46 n. 16; 65 n. 15. +53 DOJ Report at 65 n. 15. +5* Compare DOJ Report at 46, tbl. 1 (age of first arrest) with DOJ Report at 45; 53, tbl. 2; 65, n.14 (age +of first conviction). +10 + + +52 Duane Street, 10th Floor +New York, NY 1007 +Tel: (212) 417-8738 +adjudications" and that "youth of color—and especially black youth-experience +disproportionate court involvement."5i +• Infractions. More information is needed regarding the infraction factors. First, what is +meant by an "infraction," a "conviction" for an infraction, and a "guilty finding" for +purposes of these factors? It is unclear whether the infraction factors will count any and all +disciplinary misconduct. Second, how are infractions scored? Would multiple acts during a +single course of conduct be counted as one or more? Would multiple acts processed at the +same time (whether a single course of conduct or not) be considered one or more? Third, +what is the empirical basis for treating all 100 and 200 level offenses the same, such that +refusing a Breathalyzer and possessing pot are scored the same as killing and taking +hostages? Fourth, is there any limitation on the reach of this factor? For example, does it +look only to infractions in the past year, all infractions while in prison for the instant offense +(and whether serving the original sentence or a revocation sentence), all infractions while +serving any federal sentence, or for any offense ever, regardless of jurisdiction? +We have numerous concerns about counting infractions in any form, and particularly minor +infractions, for the purposes of determining eligibility for earned time credits and release +under the Act. First, there is minimal due process structure over BOP disciplinary actions. +Second, likely varied and divergent infraction cultures and practices from one BOP facility to +another would mean the likelihood of attracting an infraction may be due to luck of the draw +on institutional assignment. In addition, we are concerned about ex post facto use of +infractions to negatively score defendants on PATTERN when individuals had no notice +such infractions would count against them for these purposes, particularly in light of the +ESA provisions indicating past participation in programs will not be counted to positively +score individuals.* +• Programs & Technical/Vocational Courses. More information is needed on the types +and descriptions of the programs and technical or vocational courses for which points were +given for these two variables. For example, information is needed on the name of the +programs/courses, the providers, the personnel involved, the number of hours required, the +length of the programs/courses, the program/course goals, the definition of completion, +5 For example, the vast majority of states do not provide jury trials for juveniles, and "children +routinely waive their right to counsel without first consulting with an attorney." Nat'l Juvenile +Defender Ctr. (NJDC), Defend Children: A Blueprint for Effective Juvemile Defender Services 10 (Nov. 2016); +NJDC, Juvenile Right to Jury Trial Chart (last rev. July 17, 2014), http://njdc.info/wpcontent/uploads/2014/01/Right-to-Jury-Trial-Chart-7-18-14-Final.pdf. +5 Katherine Hunt Federle, The Right to Redemption: Juvenile Dispositions and Sentences, 77 LA. L. REV. 47, +52 (Fall 2016). +57 See Dep't of Justice, Bureau of Prisons, Inmate Discipline Program, Program Statement 5270.09, +tbl. 1, (July 8, 2011). +58 See FSA at Title I, $ 101(a) (codified at 18 U.S.C. § 3632(d)(4)(B)). +11 + + +New York, NY 1007 +Tel: (212) 417-8738 +and the locations where the programs/courses were made available. Information is needed +about why the direction of the points for the number of technical/vocational courses is the +reverse of what might be expected. Specifically, information is needed on why the tool +penalizes an individual for taking a technical/vocational course." In addition, information is +needed on whether there is an error in the description of the technical/vocational factor +when it references the number of courses "created" rather than "completed," and if not, +what is meant by courses "created." +• Drug Treatment and Drug Education. More information is needed regarding the +difference between drug treatment and drug education for purposes of scoring the +PATTERN. More information is also needed regarding how drug treatment "need" is +determined and scored, including whether it is based on self-report. The DOJ Report +suggests it is tied to the BRAVO drug/alcohol abuse indicator, but it is not clear what data +informs this factor, particularly without access to the BRAVO-R document requested above. +• Instant Offense Violent. More information is needed regarding what constitutes a violent +offense. The DOJ Report is unclear on the scope of this factor. The discussion in the text of +the DOJ Report points to endnote 16, though it appears the content of the note is actually +included under endnote 15."' But even this is not clear because, in contrast with the "instant" +offense discussed in the text, endnote 15 defines "violent recidivism" and looks at the nature +of the "arrest."*i! If this definition of violent recidivism is consistent with the definition of +instant violent offense, more information is needed regarding whether an instant violent +offense requires a conviction in the listed categories, and what is meant by the category of +"other violent," In addition, information is needed on the empirical basis for including this +factor. It appears to be contrary to DOJ studies of national samples that show lower risk of +general recidivism for individuals with an instant violent offense, compared with others." Is +this factor essentially operating as a policy override for other purposes? +• Sex Offender. Additional information is needed on how this factor is scored, including +whether it is limited to convictions for sex offenses, or is broader and informed by arrests, +self-report, hearsay, and whether it includes exonerated charges. As with other factors, +additional information is also needed on whether there are any time limits on how recent the +5" See DOJ Report at 54, tbl. 2. +"' See DOJ Report at 46, n.16 & 65, n. 15. The numbering of the Chapter Three endnotes is off, such +" See DOJ Report at 46, n.16 & 65, n. 15. +62 See DOJ Report at 46, n.16 & 65, n.15. +" See Mariel Alper & Matthew R. Durose, 2018 Update on Prisoner Recidivism: A 9-Year Follow-up Period +(2006-2014) (2019) (Special Report, U.S. Dep't of Just.). +12 + + +New York, NY 1007 +Tel: (212) 417-8738 +conduct must be for it to count. In addition, information is needed regarding the empirical +basis for including this factor. It appears contrary to DOJ studies of national samples that +show lower risk of recidivism for individuals convicted of sex offenses than other types of +offenses." Is this factor essentially operating as a policy override for other purposes? +• Criminal History Score. Information is needed on whether this is a static figure based +strictly on the U.S. Sentencing Commission guidelines' criminal history score at the time of +sentencing or whether it can increase at reassessment because of events between sentencing +and reassessment. Further, can the criminal history score be reduced at reassessment +pursuant to a time decay mechanism? +• History of Violence. Information is needed regarding the definition of violence, and +whether it requires a conviction for a violent crime. Specifically, which crimes are considered +"violent" for purposes of this factor? If not limited to convictions for violent offenses, more +information is needed regarding the sources of information that may be considered when +assessing this factor, and whether it permits consideration of arrests, prison disciplinary +records, hearsay, and/or self-reports. In addition, information is needed on whether there is +any time limit for this factor, or some time decay mechanism, as would be supported by +available research on desistence. +• History of Escapes. Information is needed regarding the definition of escape, including, for +example, whether it would include failure to appear in a pre-trial context, or walking away +from a halfway house. Information is also needed regarding whether there is a time limit for +inclusion of old escapes, or a time decay mechanism. +• Education Score. Information is needed regarding the ordinal rankings for the education +score for the violent recidivism tool. +• Databases. Several factors rely on past criminal conduct. More information is needed +regarding the databases that will be accessed to determine recidivism, and the known gaps +and biases in such databases. +• Missing Data. Information is needed regarding what adjustments were made for missing +data, and the rate of missing data for each predictor. In addition, information is needed +regarding the policy going forward when there is missing data in one of more factor in an +individual case. For example, will information about missing data be communicated with the +risk score and classification? +8. Double Counting +More information is needed to determine the scope of double counting under PATTERN, and +whether any consideration has been given about ways to ameliorate it. +" See Matthew R. Durose et al., Recidivism of Prisoners Released in 30 States in 2005: Patterns from 2005 to +2010 (2014) (Special Report, U.S. Dep't of Just.). +13 + + +New York, NY 1007 +Tel: (212) 417-8738 +• Age. Young age will be counted twice for young first offenders, who will be young at time +of first arrest/conviction," as well as at time of assessment. +• Infractions. Information is needed on whether a single "infraction conviction" that is +deemed "serious and violent" would count as both "any" and then again as "serious and +violent" infraction. In addition, would an "infraction conviction" that resulted in a criminal +conviction also count toward a criminal history score if criminal history is not static? And +could an "infraction conviction" also result in points under the history of violence and/or +"sex offender" factors? +• History of Violence. Information is needed on whether a person with multiple violent +priors receives multiple point scores in this single variable. For example, in the male general +recidivism tool, if an individual had a minor violent offense < 5 years and a serious violent +offense > 15 years, would the individual receive 5 points or 7? +• Violence. Information is needed on whether the same violent offense can be counted +multiple times, such as in the criminal history score, infraction convictions, instant offense +violent, history of violence and/or sex offender. +• Sex Offense. Information is needed on whether the same sex offense can be counted +multiple times, such as in the criminal history score, infraction convictions, instant offense +violent, history of violence and/or sex offender. +• Criminal History. Information is needed on whether consideration was given to +ameliorating the repeated counting of criminal history, first in the imposition of the sentence +based on a guideline calculation that relies heavily on criminal history and then throughout +PATTERN, including age of first arrest/conviction, sex offender, criminal history score and +history of violence. We are concerned about the inclusion and weight (repeatedly) given to +this factor for a number of reasons. Some concerns arise from the unique way in which the +guidelines count criminal history, such as including all juvenile adjudications on par with +adult convictions (with some difference in decay periods), and using sentence imposed rather +than time served as a proxy for seriousness of the offense (affecting the number of points +received).'° In addition, as mentioned above, research on other risk tools has shown racial +differences in scores with black individuals obtaining higher scores than white individuals, +where most of the difference "is attributable to criminal history " Criminal history +correlates with race because it reflects prior instances of racial disparity in the criminal justice +system or disadvantage earlier in life. Criminal history is not just the product of participation +in crime, but of biased practices throughout the criminal justice system. Blacks do not sell +as See supra note 54 and related text regarding issue of whether the first predictor looks to age of first +comction or arrest. +" See USSG §4A1.2(d), (e). +" Jennifer L. Skeem & Christopher T. Lowenkamp, Risk, Race, and Recidivism: Predictive Bias and +Disparate Impact, 54 CrImInoLoGy 680, 700 (2016). +14 + + +New York, NY 1007 +Tel: (212) 417-8738 +drugs or possess guns at a greater rate than Whites.'" Studies show that Blacks are stopped +and frisked or searched at higher rates than Whites, but that Whites who are frisked or +searched are found with contraband at higher rates than Blacks who are frisked or +searched. ° And Blacks are arrested more than twice as often as Whites.?" Charging decisions +and bail determinations further compound these racial disparities as individuals move +through the criminal justice system." We urge the DOJ to open discussion to a +multidisciplinary team on methods to ameliorate the overreliance upon, and negative impacts +of, criminal history. +9. Protective & Promotive Factors +Additional information is needed on whether there are any plans to incorporate additional protective +and promotive factors in PATTERN. Currently, program/course participation and educational +attainment appear to be the only proxies for protective factors included in PATTERN. Similatly, +additional information is needed on whether there are plans to incorporate a desistance factor into +PATTERN that would significantly adjust the risk rating according to the literature on the age-crime +curve and the literature on cessation of offending. We urge DOJ to engage with a multidisciplinary +team to consider incorporating more protective and promotive factors to better meet the goals of +the FSA. +10. Policy Decisions +Risk assessments are not simply math. Every risk assessment involves moral choices and tradeoffs. +Some of our questions in this area are incorporated above, such as whether consideration has been +given to ameliorating the effects of certain factors that are unacceptable regardless of predictive +value. In addition, information is needed generally regarding the mechanisms in place to ensure that +issues which have distinct policy implications will be resolved by appropriate personnel—ideally a +"* See Amy Baron-Evans & David Patton, A Response to Judge Pryor's Proposal to "Fix" the Guidelines: A +Cure Worse than the Disease, 29 FED. SENT'G. REP. 104, 112 (Dec. 1, 2016-Feb. 1, 2017). +" See id. at 112-13 (collecting studies); see also Radley Balko, Op-Ed., There's Overbelming Evidence that +the Criminal-Justice System is Racist. Here's the Proof, WASH. PosT, Updated Apr. 10, 2019 (collecting +studies). +' See Bureau of Justice Statistics, Arrest Data Analysis Tool, 2014 (most recent data available), +https://www.bjs.gov/index.cfm?ty=datool&surl=/arrests/index.cfm#. +" See supra note 69; see also USSC, Application and Impact of 21 U.S.C. § 851: Enhanced Penalties +for Federal Drug Trafficking Offenders 7, 33-36, figs. 13-14 (2018). +12 See Cecelia Klingele, Measuring Change: From Rates of Recidivism to Markers of Desistance, 109 J. CRIM. L.. +& CRIMINOLOGY (forthcoming 2019), +https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3142405; Ralph C. Serin & Caleb D. Lloyd, +Integration of the Risk Need, Responsivity (RNR) Model and Crime Desistance Perspective: Implications for +Community Correctional Practice, 7 ADVANCING CORRECTIONS 37, 38 (2019). +15 + + +New York, NY 1007 +Tel: (212) 417-8738 +multidisciplinary team that includes policymakers and stakeholders —rather than solely data +scientists. For example, the decisions on the cut-points, which necessarily impact fairness measures +such as false positive rates and positive predictive values, appear to have been made by the +researchers and based on arbitrary fractions or multiples of the recidivism rates.?* Yet, where those +decisions affect moral and political outcomes with real-world consequences to individuals, they +should instead be made by a multidisciplinary team that has the authority and direct interest in such +consequences. +Risk tool developers have a natural incentive to focus on overall accuracy. However, accuracy may +need to yield to other important goals, such as differential validity, group fairness, and individual +rights. Selecting the right tradeoff between these sometimes competing goals are more rightly within +the power of policymakers and stakeholders. +Here, it appears the cut-points were established somewhat arbitrarily without regard to such +consequences as the false discovery rate and false omission rate (the reciprocals of positive +predictive value and negative predictive value) and equal calibration, among other validity and +fairness measures discussed above Because PATTERN was developed to meet the obligations of +the FSA, a preferable method for setting cut-points would be attuned to the goal of maximizing +incentives for participation in rehabilitative programs and courses. Increasing the cut-point between +low and medium would be more suitable to achieve this goal. Relatedly, information is needed +regarding the process, and who was involved, in setting the rules governing the combined (final) +RL.C. The current rule dictates that the highest risk category from the general and violent scales will +be used to set the final RLC. Different choices could have been made that would be more suitable +to achieve the FSA's goal of incentivizing and rewarding more individuals to complete programs and +courses. For example, a person who scores low or minimum on one scale and medium on the other +should have a final RL.C of low. And a person who scores high risk on one scale, yet medium risk on +another should be classified for purposes of the final RL.C as medium. +Additional information is also needed regarding the process for deciding on the definition of +"recidivism." This is a policy decision that requires identifying the scope of conduct that should be +included, consistent with the purpose of the SA to successfully reintegrate individuals in the +community. Fot example, what was the process for deciding to include all revocations, including +73 See Partnership on AI, Report on Algorithmic Risk Assessment Tools in the U.S. Criminal Justice System 31 +(2019), https://www.partnershiponai.org/wp-content/uploads/2019/04/Report-on-Algorithmic- +Risk-Assessment-Tools.pdf (suggesting an oversight body including "legal, technical, and statistical +experts, current and formerly incarcerated individuals, public defenders, public prosecutors, judges, +and civil rights organizations"); Danielle Kehl et al., Algorithms in the Criminal Justice System 34 (2017), +https://dash.harvard.edu/bitstream/handle/1/33746041/2017- +07_responsivecommunities_2.pdf?sequence=1&isAllowed=y. +14 See DOJ Report at 50. +15 See DOJ Report at 50-51. +16 + + +New York, NY 1007 +Tel: (212) 417-8738 +technical violations, and for looking to arrests, despite the literature showing the serious racially +disparate impact of looking to arrests, rather than convictions?" In light of the FSA's purpose, a +more limited definition of recidivism focused on serious offending would be more appropriate than +the broad definition used to develop PATTERN. +B. Transparency & Accountability: Implementation +Transparency and accountability are both mandated and essential in the implementation of +PATTERN. While much remains unknown in this area, we already have several questions which +warrant the attention of a multidisciplinary team as PATTERN is implemented. +1. Privacy/Confidentiality +It appears that several of the factors in PATTERN, and the yet-to-come needs assessment, may +require interviews and be based at least partially on self-reporting. This raises several questions and +concerns. Additional information is needed on what protections will be in place to honor an +individual's right to be free of self-incrimination. More information is needed on what protections +will be in place to prohibit the use of any interview admissions against an individual, either in a new +prosecution or prison disciplinary proceeding. Information is also needed regarding how scores and +information obtained in the scoring process will be maintained and confidentiality protected. And +information is needed on the data retention policies for risk scores, needs assessments, and +information obtained to complete the tools. +2. Challenges +As discussed above, PATTERN scores and accompanying risk categories will directly affect how +much time many individuals spend in prison. Information is needed on the procedures for +contesting individual scores and category assignments. Risk assessment is unique enough that +treating a challenge like any other grievance is not a sufficient process. Potential concerns include +discovering factual errors, contesting judgment calls, challenging an override decision, and correcting +a scoring miscalculation. +To equip individuals to assess and challenge their PATTERN scores we expect individuals will be +provided not only with their final PATTERN score and related risk category, but also scores on +each of the individual factors, and information on the limitations of the scores, including the +warnings set forth below. And individuals challenging their PATTERN score and category will need +more. Indeed, much of the information individuals will need to challenge their scores tracks the +information requested above regarding the development, validation and bias testing of PATTERN. +In addition, among other information, individuals will need codebooks and scoring sheets, training +materials, and inter-rater reliability scores for those scoring the tool. Additional information is +needed regarding the plans to ensure adequate information and processes are provided to individuals +challenging their PATTERN scores. +' See Jennifer Eaglin, Constructing Recidivism Risk, 67 EMORY L.J. 59, 94 (2017). +17 + + +New York, NY 1007 +Tel: (212) 417-8738 +3. Risk Communication +Information is needed on the manner in which risk scores and categories will be reported both +within and outside the BOP. Studies show that risk communication format matters in how decisionmakers understand the results and can be manipulated." We are concerned that the scores and +categories will not be communicated with sufficient context to make the scoring and results +translatable to those who were not deeply involved in the development of the tool. To that end, we +recommend reporting risk results as the ordinal bins plus that bin's relevant observed (a) recidivism +rate and (b) success rate (1-recidivism rate). The communication should also include the definition +of recidivism to contextualize the meaning of the rates. In addition, we recommend including a set +of warnings to ensure users of the scores and categories understand the tool's limits.?* The following +list includes ideas on the warnings we believe appropriate in light of our current understanding of +PATTERN: +• PATTERN is based on group statistics and cannot assess an individual's probability of +reoffending; +• (as relevant) PATTERN disproportionately judges minorities at higher risk than whites; +• PATTERN relies on arrest data, which may merely replicate biases in policing practices; +• PATTERN does not include all protective or promotive factors that may reduce the +individual's risk prediction; +• PATTERN does not predict the aspects of risk regarding imminence, frequency, severity, or +duration; +• PATTERN's rankings of risk (minimum, low, medium, high) are merely relative to the +population studied; +• PATTERN's score includes criminal history measures that did not require conviction and +thereby may overestimate risk because of faulty data; +• PATTERN's score may be higher based on evidence of juvenile offending; +• PATTERN may increase risk when the individual does not engage in various types of +programming, however, such programs may not have been made available to this individual +for reasons not within the individual's control; +• (as relevant) PATTERN factors can count the same events twice or multiple times; +7 See Ashley B. Batastini et al., Does the Format of the Message Affect What Is Heard? A Two-Part Study on +the Comminication of Violence Risk Assersment Data, 19 J. FORENSIC PSYCHOL. RES. & PRAC. 44, 46 +(2019); Daniel A. Krauss et al., Risk Assessment Communication Difficulties: An Empirical Examination of +the Effects of Categorical Versus Probabilistic Risk Communication in Sexually Violent Predator Decisions, 36 +BEHAV. ScI. &: L. 532, 534 (2018); Nicholas Scurich, The Case Against Categorical Risk Estimates, 36 +BEHAV. SCI. & L.. 554, 558 (2018). +1B See Wisconsin v. Loomis, 881 N. W.2d 749, 765 (Wis. 2016) (identifying necessary cautions, that may +evolve, before considering risk assessment at sentencing). +18 + + +New Yotk, NY 1007 +Tel: (212) 417-8738 +• (as relevant) this PATTERN score represents an override of the algorithm and the reason +for the override. +4. User Buy-In +Research studies and anecdotal evidence indicate that users (eg., those scoring the tool and relevant +decision-makers who receive scores) tend to distrust, and find ways to deviate from, algorithmic risk +results if they are not included enough in the process and program. Information is needed on the +methods planned to achieve sufficient user buy-in to improve compliance and consistency in order +to achieve the FSA's goals in this endeavor. +II. NEEDS ASSESSMENT +A core purpose of Title I of the FSA is to help prisoners succeed in their communities upon release +and thereby reduce recidivism. The Act contemplates accomplishing this by providing all individuals +in prison evidence-based programming that is designed to help them succeed upon release and that +has been shown by empirical evidence to reduce recidivism.'"' We are deeply concerned that the DOJ +has not yet released the needs assessment required by the FSA. We understand from DOJ's Report +that the needs assessment is in the works, and there will be an opportunity to comment on that +aspect of the DOJ's FSA obligations at a later time. In light of that, we raise only a few critical issues +here. +1. Programs +Evidence-based programming is the bedrock of the FSA. Other aspects of the risk and needs +assessment system only make sense if there is programming. Assessing (and reassessing) needs and +assigning (and reassigning) individuals to programming based on those needs require that +appropriate and available programming exist."' In addition, the incentives and rewards identified in +the law are contingent on participation in appropriate and available programming.* DOJ's Report, +however, suggests there are few programs or courses available, as indicated by the relatively few +individuals who were scored on them in the developmental sample.* This is consistent with other +information that waitlists to participate in BOP programs are long: 25,000 inmates are currently +' See Jean-Pierre Guay & Geneviève Parent, Broken Legs, Clinical Overrides, and Recidivism Risk: An +Analysis of Decisions to Adjust Risk Levels with the LS/ CMI, 45 CRIM. JUST. & BEHAV. 82, 83-84 (2018). +"'' See SA at Title I, § 101(a) (codified at 18 U.S.C. §S 3632, 3635(3) and § 102(a) (codified at 18 +U.S.C. 5 3621(h)). +' See FSA at Title I, § 101(a) (codified at 18 U.S.C. § 3632(a) (3)-(4)). +** See FSA at Title I, § 101(a) (codified at 18 U.S.C. § 3632(a)(6), (a) (7), (d)). +* See DOJ Report at 47, tbl. 1 (showing almost half (49%) of the developmental sample had +completed no programs, a vast majority had no technical/vocational courses (82%) or federal +industry employment (92%) and well over half (57%) had not had drug treatment while incarcerated +despite indication of need). +19 + + +New York, NY 1007 +Tel: (212) 417-8738 +waiting to be placed in prison work programs,** at least 15,000 are waiting for education and +vocational training, and at least 5,000 are awaiting drug abuse treatment.*' More information is +needed on how programming will be expanded to ensure the goals of the FSA are met. +2. BOP Current Needs Assessment +The DOJ Report indicates the BOP is using its current needs assessment until one is developed +pursuant to the FSA. More information is needed on BOP's current needs assessment and +processes. +3. Responsivity +Information is needed about how responsivity will be considered in connecting needs to programs. +Relatedly, additional information is needed on the availability of culturally-sensitive programming +(eg, programs in Spanish for those with weak English skills and modification of 10 Step-like +programs for non-Christians). +III. CONCLUSION +PATTERN is a high-stakes tool that directly affects how much time many people will spend in +rison. High levels of transparency, accountability and auditability are both required and critical. W +ppreciate the opportunity to share our questions and concerns and hope there will be additiona +opportunities for feedback and dialogue after we have received the information identified above. +Very truly yours, +/s +David Patton +Executive Director, Federal Defenders of New York +Co-Chair, Federal Defender Legislative Committee +8* See BOP: UNICOR, Federal Bureau of Prisons, +https://www.bop.gov/inmates/custody_and_care/unicor_about.jsp (estimating the participation +rate at 8%). +8s See Oversight of the Federal Bureau of Prisons Before the H. Subcomm. on Crime, Terrorism, Homeland Security +and Inestigations of the H. Comm. on the Judiciary, 115th Cong. 20 (2018) (BOP Director Inch). +"'' See Dep't of Justice, Bureau of Prisons, Drug Abuse Treatment Program, 81 Fed. Reg. 24484, +24488 (Apr. 26, 2016) ("over 5,000 inmates waiting to enter treatment"); Colson Task Force, at 36 +("'at the end of FY 2014, more than 12,300 people systemwide were awaiting drug abuse treatment"). +20 + + + + + +LISA C. HAY +Federal Public Defender +STEPHEN R. SADY +Chief Deputy Defender +Gerald M. Needham +Then L. Heter +FEDERAL PUBLIC DEFENDER +DISTRICT OF OREGON +101 SW Main Street, Suite 1700 +Portland OR 97204 +503-326-2123 / Fax 503-326-5524 +Branch Offices: +Susan Wilk +Kristina Hellman +Fidel Cassino-DuCloux +Alison M. Clark +Brian Butler+ +859 Willamette Street +Suite 200 +514605-7-401 +Fax 541-465-6975 +15 Newtown Stree +ledford, OR 9750 +541-776-3630 +Fax 541-776-3624 +Trina Hughes A +Kurt D. Hermansen A +In memoriam +Namy - 2007 +4 Eugene Office +• Medford Office +* Research/Writing Attorney +Kathleen Hawk Sawyer +Director +320 First Street, NW +Washington, DC 20534 +Re: Request for Assistance to Avert Further Reentry Center Closures +Dear Ms. Sawyer: +This letter is to express the deep concern of the Oregon Federal Public Defender and other +federal defender organizations over the collapsing infrastructure necessary to implement +statutorily-approved expansions of pre-release custody for federal inmates in residential reentry +centers. As a result of Bureau of Prisons' policies and practices, at least 20 reentry centers have +closed or ceased accepting federal inmates since 2017, and more closures appear likely. This loss +of resources cripples efforts to enhance successful reentry of incarcerated citizens, undermines the +criminal justice goal of rehabilitation, and consequently threatens community safety. As a public +defender and a board member of the reentry center in Portland, I have seen first-hand how reentry +centers provide the opportunity, in a less structured setting than prison, for inmates to engage in +needed treatment, find employment, and continue reconnecting with their family and community. +Once lost, these precious resources are difficult to replace. I am requesting your urgent assistance +to end Bureau of Prisons' practices that have undermined and caused closure of reentry centers +and to ameliorate harm already caused. +The background for this request is grounded in the Second Chance Act of 2007, which +doubled the amount of sentenced time that federal prisoners were eligible to spend in reentry +centers (also called "community corrections") from six months to up to one year. 18 U.S.C. +§3624(c). During this "prerelease time," the prisoner is not released from his or her federal +sentence but is serving the sentence in an alternative setting. Defenders were cheered by this +congressional recognition that our clients and their communities both benefited when people +reentering society were given more time, in a gradually less structured setting, to engage in +treatment, employment counselling, parenting classes, and other programs designed to ensure the + + +Page 2 +safety of the community and the success of the resident after incarceration. Despite this mandate +from Congress, however, the Bureau was slow to change, and the amount of prerelease time that +prisoners were awarded to spend in reentry centers remained low. In 2011, Defenders wrote to +then Director Thomas Kane to express concern about this failure to implement the Second Chance +Act.' In 2012, the General Accountability Office issued a report that similarly noted the Bureau's +failure to adequately implement Congressional mandated alternative options to incarceration, +including use of reentry centers.? +After the GAO report, the Bureau did begın to utilize reentry centers more fully, awarding +greater prerelease time to inmates. Defender knowledge of this change comes from interactions +with federal prisoners and from conversations with reentry centers.? Reentry centers report that +during this period, the Bureau encouraged reentry centers to expand capacity in order to serve the +greater number of prisoners needing placement. For example, the long-established reentry centers +in Bangor, Maine, and Portland, Oregon, took out mortgages to remodel their facilities and to +expand bed capacity. +Unfortunately, the Bureau apparently has now reversed its support for reentry centers, and +as a result the system is losing bed capacity just when the First Step Act, enacted by a bipartisan +congressional majority in December 2018, may require even greater use of reentry centers. Under +he First Step Act, prisoners who complete certain programs in custody will soon begin earnins +credits that, in theory, they can exchange for greater prelease time in the community. But if +reentry capacity decreases instead of expands, prisoners may find they have no way to use those +credits. For all of these reasons, I urge you to take immediate action to end the Bureau practices +that have resulted in reentry center closures. +' Attachment A, Letter of FPD Thomas Hillier to Bureau of Prisons' Director Thomas +Kane, dated November 16, 2011. += Government Accountability Office, Bureau of Prisons: Eligibility and Capacity Impact +Use of Flexibilities to Reduce Inmates' Time in Prison (Feb.2012) available at: +https://www.gao.gov/products/GAO-12-320 +3 Actual utilization data was reported by the Bureau to Congress each year pursuant to the +irective in 18 U.S.C. $ 3624(c)(5), which requires an annual report to the House and Senat +udiciary Committees describing use of alternatives to incarceration and the average length o +placements in community corrections facilities. The reports were not immediately available. + + +Page 3 +A. As A Result Of Bureau Practices And Policies, Reentry Centers Have Closed, +Ceased Accepting Federal Inmates, Or Are Critically Endangered. +Bureau of Prisons' actions affect the functioning of reentry centers through many channels. +This letter does not address the effects of ordinary, bureaucratic impediments such as late payments +to reentry centers; outdated or overly technical audit requirements; or increased delays in +processing referrals of residents, although each of these can pose significant hardships to reentry +centers. Instead, this letter identifies three systemic practices - non-renewal of contracts; +solicitation of contracts for fewer beds and with fewer guaranteed beds; and decreased length of +stays for residents-that decrease reentry bed capacity and should be addressed from the highest +level of the Bureau. +Practice 1: The Bureau of Prisons did not renew contracts with reentry centers and did +so without consulting the chief judge of the judicial district affected. +In 2017 the Bureau chose not to renew contracts with 16 reentry centers around the +country. * The Bureau attributed the decision to the "fiscal environment" and budgetary +considerations, and not to any study on the effect of reentry placement on inmates. Numerous +states were affected, including Colorado, Kentucky, Illinois, Michigan, Minnesota, Montana, New +York, Ohio, South Dakota, Texas, West Virginia, and Wisconsin. Although the Bureau reported +that these closures involved only a small percentage of beds under contract nationwide, for the +affected districts, the results were stark. For example, non-renewal of the contract for the Great +Lakes Recovery Center in Marquette, Michigan, which had been in operation for 30 years, left the +geographically isolated community in the Upper Peninsula without a reentry center for federal +inmates. The federal judges in the affected judicial districts were not consulted, and apparently no +provision was made for immediate alternative incarceration options within the districts. As a result, +federal inmates either remained in prison rather than receiving reentry center services, or were sent +to reentry centers far from their home towns and release addresses. +Practice 2: For contracts subject to renewal, the Bureau of Prisons is decreasing the +number of reentry beds it seeks and significantly reducing the minimum number of beds +for which it will guarantee payment. +In recent solicitations ("Requests for Proposals") for bids for renewal of reentry center +contracts, the Bureau of Prisons has reduced the number of beds it is seeking to use in reentry +centers. In addition, the Bureau has sought to significantly reduce the minimum number of beds +* Attachment B, list of reentry centers selected for non-renewal and related media articles. +" Attachment C, Memorandum Of Bureau of Prisons' Acting Assistant Director, Hugh Hurwitz, +October 10, 2017. + + +Page 4 +for which it is contractually obligated to pay. As a result, some well-established reentry center +vendors have determined that bidding on the contract with reduced beds and limited guarantee of +payment is not financially viable, and have chosen not to bid. Other reentry centers have tendered +bids, but the cost per bed has, necessarily, significantly increased in order to cover the overhead +of a large facility now projected to be only partially used. Reentry centers are closing or threatened +with closure as a result. A few examples make the point.° +Honolulu, Hawaii: Closed +TJ Mahoney and Associates, a private non-profit company, operated "Mahoney Hale" (also +called the "Mahoney House") reentry center in Honolulu for many years. Approximately 30 beds +were under contract for the Bureau of Prisons to use for reentry services for federal inmates, and +more inmates in fact were often housed there. When the Bureau issued a Request for Proposals as +part of the contract renewal process this year, however, it sought only 16 beds. TJ Mahoney did +not bid for this contract and neither did any other company, because the 16-bed proposal was not +financially feasible. By the time the Bureau changed its renewal proposal to offer more beds, it +was too late for TJ Mahoney to bid. The facility in Honolulu had already notified its landlord that +it would not renew its lease, and the property was lost. The facility closed September 30, 2019. +The state of Hawaii is now without any federal reentry center. Lack of residential re-entry services +in a whole state or large geographic area defeats the goal of assisting transition to a person's home +community. It does not allow for successful family reunification, undermines the work done to +obtain and maintain employment, and as a result reduces the likelihood of success in transitioning +back into society. And, not only do federal inmates in Hawaii have no option for in-state prerelease +time at reentry centers, but federal inmates from Hawaii who are entitled to serve 4 months in a +reentry center as part of the Residential Drug and Alcohol Treatment Program have no in-state +reentry center option. +Bangor, Maine: No longer accepting federal prisoners +Volunteers of America long operated a successful reentry center for federal prisoners in +Bangor, Maine. The facility was capable of serving about 32 inmates, and in the past had served +that many, but the Bureau of Prisons' contract only covered beds for 12 inmates. During the +• Many individuals involved with currently operating reentry centers were unwilling to discuss +their Bureau of Prisons' contracts, both because the contracts restrict contact with the media and +because reentry centers do not want to jeopardize their relationship the Bureau of Prisons. The +examples offered here are compiled from interviews with judges, probation officers, residents at +federal contracts; and newspaper reports. Many numbers are approximate and based on the +memory of persons formerly involved in the reentry centers. + + +Page 5 +contract renewal process this year, the Bureau declined to increase the number of beds under +contract, despite having encouraged the facility to expand and to increase capacity a few years +earlier. Efforts to negotiate with the Bureau were fruitless, and the facility opted not to bid on the +12-bed contract. No other company bid either, and Bangor, Maine, now lacks a federal reentry +center. +Charlotte, North Carolina: Closed +The McLeod Reentry Center served federal inmates in Charlotte, North Carolina. A few +years ago, they invested in a new building that could serve 130 inmates. According to media +reports, in 2018 the Bureau of Prisons abruptly stopped sending as many residents there. It is +unclear if this decrease was part of a contract renewal, or merely enforcement of the prior contract +cap. In either case, the sudden decrease in beds used by the Bureau of Prisons resulted in a fiscal +crisis for the non-profit, and the center closed in May 2018. Other reentry centers have similarly +reported that the Bureau recently began to strictly enforce the contract cap on beds, even though +the facilities were able and willing to serve many more residents than the contract required. This +change in practice has caused fiscal strain in reentry centers. +Sacramento, California: No longer accepting federal prisoners +The longtime reentry center operated in Sacramento stopped accepting federal inmates this +year. According to a federal judge in the district, the loss of reentry beds came as a complete shock. +The Bureau had not notified the court of any difficulties, and when asked for an explanation, the +Bureau disclosed only that they "could not reach a deal" with the reentry center. It seems likely +that this is one more example of a request for proposals that reduced the number of beds or the +guaranteed minimum of beds and was not economically feasible. +Oklahoma City. Oklahoma: in danger of closing +The Oklahoma City Halfway House is a non-profit that has served Oklahoma residents for +over 30 years. Under their federal contract, they have housed over 100 inmates at times, although +the contract only requires them to hold 54 beds available for the Bureau. Beginning in 2018, in +accordance with the Memorandum of Hugh Hurwitz, the Bureau began to delay placements of +residents at the Halfway House until the facility population was at the contract level of 54, even +though the facility had capacity to serve more residents. The contract is now up for renewal. Rather +than issue a request for proposals to serve 54 or more residents in Oklahoma City, the Bureau +issued a request for one bidder to operate reentry centers in all three judicial districts. The Bureau +proposes requiring that a total of 125 beds be available in the Northern, Western, and Eastern +districts (70, 40, and 15 beds respectively), but agrees to guarantee placement in only 38 beds.? +7 The contract summary is available on-line and in Attachment D. + + +Page 6 +According to Oklahoma's Federal Public Defender, it is not financially feasible for the current +reentry center to bid for this contract with expanded obligations but reduced guarantees. The +contract closing date is November 25, 2019. The deadline for bidding on a previous request for +proposals, also requiring services in more than one location, has passed. +Portland, Oregon: in danger of closing +The Northwest Regional Reentry Center in Portland, Oregon, has served exclusively +federa panad for capril ears on at 1976 In 2016 they andertook amane en the ingriet +Prisons. The facility is highly regarded by the federal court and probation office. The facility's +current contract calls for 50-120 beds to be available for federal inmates, but the Bureau's new +contract solicitation (to take effect in 2020) calls for only 18-72 beds. The drastic decrease in the +guaranteed minimum to 18, along with the overall decrease in expected resident population, makes +operation of the facility as a federal reentry center financially impossible. The NWRRC +nevertheless submitted a bid for the new contract, with the price per bed being necessarily higher +than under the current contract. If the Bureau rejects this contract bid as "too costly," this will have +been a problem of its own making. The NWRRC would have bid to maintain the current number +of beds at a significantly lower price, but the Bureau did not offer this option. Losing 120 reentry +beds in Oregon would harm federal inmates and potentially increase risk to the community, as +residents may return to the Portland area without the structured reintegration provided by the +NWRRC. +Many Other States Have Reentry Centers Facing Contract Renewals +In addition to those described above, the Bureau currently has more than 30 published +requests for proposals for reentry services at sites across the country, including Las Vegas, Nevada; +Albuquerque, New Mexico; Clarksburg, West Virginia; Fort Myers, Florida; Boise, Idaho; +Pittsburgh, Pennsylvania; among others. To the extent these renewal requests decrease the +guaranteed minimum number of beds, or decrease the total beds required, or restructure the +contract to include required reentry facilities in new locations, currently operating reentry centers +in these states may also face financial insecurity that results in closure. +Practice 3: The Bureau of Prisons has decreased the amount of prerelease time it considers +awarding to federal inmates, despite Congress's directive that up to one year of community +corrections be available. +Although Congress authorized the Bureau to allow inmates to spend up to a year of the last +part of their sentence in reentry centers instead of prison, the amount of this pre-release time +awarded by the Bureau is again declining. According to the most recent report submitted by the +Bureau to the House and Senate Judiciary Committees pursuant to 18 U.S.C. § 3624(c)(5), the + + +Page 7 +average length of placement in reentry centers decreased by almost 20% from the first quarter +measured (April - June 2017) to the last quarter (January-March 2018), resulting in almost a full +month less of reentry time by the last quarter (an average of 119 days compared to 146 at the start +of the year).* Notably, even the high, 4-month average represents significantly less time than the +one year authorized by Congress. +The Bureau acknowledged in a 2017 memorandum that "due to fiscal constraints," the +average length of stay was "likely to decline to about 120-125 days." Anecdotal information from +isons indicates that counsellors have been told to limit the amount of prerelease time in reent +enters to even less than 120 days. At one prison, inmates reported seeing a printed sign on tl +counsellor's wall reading: "We will put you in for a maximum of 90 days of RRC time, but it will +most likely be less. Yes we know what the Second Chance Act says." Numerous reentry centers +confirm that lengths of stay have declined significantly over the last few years. The Bureau's +formal or informal restrictions on prelease time harm federal inmates by limiting their opportunity +for structured reentry into the community. The limits also harm reentry centers because the +declining lengths of stay mean that facilities are not being operated at full capacity. Many reentry +centers increased capacity with the encouragement of the Bureau of Prisons and now find they are +in difficult fiscal straits as inmates spend more time in prison and less time in reentry centers. +B. Several Measures Should Be Immediately Implemented To Address The Crisis +Facing Reentry Centers And The Federal Inmates Who Rely On These Key +Resources. +In order to avoid additional loss of reentry centers, I urge you to immediately implement the +following actions: +Regarding New and Pending Solicitations for Reentry Services: +1. Issue a temporary directive prohibiting any decrease in the number of reentry center +eds sought within a judicial district in new contract negotiations or Requests Fo +Proposals. Further mandate that, for any reentry Request For Proposals that has alread +issued, the Bureau of Prisons may not reject the bid of a current reentry center without +first (1) offering an extension of the current contract for six months; (2) consulting with +the Chief Judge of the judicial district or other designee identified by Congress; and (3) +re-issuing the Request For Proposals with the goal of avoiding loss of reentry beds. +& Attachment E, Utilization of Community Corrections Facilities: Report to Congress +(April 2017- March 2018). +° Attachment C, Memorandum of Acting Assistant Director, Hugh Hurwitz, October 10, +2017. + + +Page 8 +2. Establish a committee to review reentry center pricing mechanisms with the goal of +le ved inade vitive required mei surve bale e guar ale should be studied +i beds barred with a redi +for example, that would decrease or increase the price charged per bed based on the +degree of occupancy. The committee should include delegates from the judiciary as +well as small and larger reentry centers. +Regarding Length of Pre-Release Time: +3. Issue a directive that rescinds any Bureau policy (formal or informal) that restricts the +amount of pre-release time that an inmate may serve in a reentry center to an amount +less than authorized by Congress in 18 U.S.C. § 3624(c), unless an individualized +determination establishes that for the specific inmate, less time is appropriate; and +4. Issue a directive that each Bureau facility should engage in an individualized +assessment of inmate needs for reentry services with sufficient time in advance of the +inmate's release date to allow for awarding a full year of pre-release time in reentry +centers or home confinement when supported by the inmate's needs; and +5. Issue a directive that each Bureau facility should report monthly to you on the amount +of pre-release time granted, and that your expectation is that this time should be +increasing rather than decreasing. +These emergency directives may help avoid additional reentry center closures and thereby +ensure that adequate reentry capacity exists for federal inmates eligible for pre-release time in the +community. +C. The Bureau Should Formalize Policies And Practices That Support And Expand +Utilization Of Reentry Centers. +In addition to doubling the available pre-release community corrections time from six to +twelve months, 18 U.S.C. § 3624(c), the Second Chance Act required that, within 90 days of +enactment, the Bureau "shall" implement the reforms to the pre-release community placement +statute through the formal procedures provided under the Administrative Procedure Act (APA). +18 U.S.C. $ 3624(c)(6) ("The Director of the Bureau of Prisons shall issue regulations" regarding +the "sufficient duration" of community corrections) (emphasis added)). "[D]iscretion as to the +substance of the ultimate decision does not confer discretion to ignore the required procedures of +decisionmaking." Bennett v. Spear, 520 U.S. 154, 172 (1997). Here, Congress used the mandatory +word "shall." The Bureau must follow procedural requirements for an exercise of discretion to be +lawful: "[T]he promulgation of [the] regulations must conform with any procedural requirements + + +Page 9 +imposed by Congress" because "agency discretion is limited not only by substantive, statutory +grants of authority, but also by the procedural requirements which 'assure fairness and mature +consideration of rules of general application.'" Chrysler Corp. v. Brown, 441 U.S. 281, 303 (1979) +(citations omitted). +The Second Chance Act explicitly refers to the need for reentry policies to be empirically +based. 42 U.S.C. § 1 754|(d). Congress's intention that the Bureau engage in notice-and-comment +rule-making effectuates this approach by giving the public and interested organizations, like the +Defenders, the opportunity to provide input regarding the duration of community corrections. See +Chrysler Corp.,441 U.S. at 316 ("In enacting the APA, Congress made a judgment that notions of +fairness and informed administrative decisionmaking require that agency decisions be made only +after affording interested persons notice and an opportunity to comment."); see also Conf. Rep. to +Consolidated Appropriations Act of 2010, 155 CONG. REC. HI3631-03, *HI3888 (daily ed. Dec. +8, 2009) (directing the Bureau to consult with the public and experts regarding reentry issues). +Congress also made the judgment that agencies must do more than simply repeat statutory +language: agencies are required to articulate their rationale and explain the data upon which the +rule is based. Burlington Truck Lines, Inc. v. United States, 371 U.S. 156, 167-68 (1962). +The Bureau has yet to issue adequate, evidence-based regulations +addressing the +appropriate length of reentry stays for federal prisoners. Implementing the requirements of the +Second Chance Act through empirically-based research, consultation with interested parties +through the notice-and-comment process, and issuance of regulations should rise to a top priority +within the Bureau. +I appreciate your attention to these important issues that affect thousands of people who +are preparing to reenter our communities. +Sincerely, +Federal Public Defender +LH:jll +cc: +Senator Ron Wyden +Senator Jeff Merkley +Representative Earl Blumenauer +Chief Judge Michael Mosman, U.S. District Court of Oregon +Federal Public Defenders + + +ATTACHMENT A + + +FEDERAL PUBLIC DEFENDER +Western District of Washington +Thomas W. Hillier, I/ +Federal Public Defender +Acting Director, Federal Bureau of Prisons +c/o Rules Unit +Office of General Counsel, Bureau of Prisons +320 First Street, NW +Washington, DC 20534 +Re: +Comment On Proposed Regulations +Pre-Release Community Confinement +76 Fed. Reg. 58197-01 (Sept. 20, 2011) +Dear Director Kane: +This letter is to provide comment on behalf of the Federal Public and Community Defenders +regarding the proposed regulation implementing the pre-release community confinement provision +of the Second Chance Act (SCA). The Defenders represent the indigent accused in almost every +judicial district of the United States pursuant to authorization in 18 U.S.C. § 3006A. The Defenders +viewed as a very favorable development the bipartisan support for the SCA's increase of available +pre-release community corrections from six to twelve months in 18 U.S.C. § 3624(c). We +anticipated that the increased utilization of halfway houses and home detention would promote our +clients' more successful reintegration into the community through earlier family reunification, +establishment of employment, treatment in the community, and separation from the negative aspects +- and dangers - of prison life. The increased length of reentry programming would also reduce +prison over-crowding, resulting in safer prisons and lower prison costs. +In contrast to the optimism generated by the SCA's statutory shift in favor of more prerelease community confinement, the Defenders have been disappointed in the Bureau of Prisons +(BOP)'s failure to implement meaningful change by continuing the informal rule that effectively +limits pre-release community confinement to six months. The proposed regulation does nothing to +correct the BOP's failure to effectuate Congress's directive that the optimum duration of community +corrections should be addressed by regulation and that the available period of community corrections +for individual prisoners should be doubled from six to twelve months. Our comments address three +aspects of the new regulation. First, the regulation appears to violate Congress's requirement that +the BOP "shall" promulgate regulations to ensure that the length of community corrections is "of +sufficient duration to provide the greatest likelihood of successful reintegration into the community." +18 U.S.C. § 3624(c)(6)(C). Second, the regulation should presume that the maximum period of +community corrections should be provided, absent individualized factors disfavoring community +corrections for a particular prisoner. Third, the regulation implementing the SCA should reject the +1601 Fifth Avenue, Room 700, Seattle, Washington 98101 - Telephone (206) 553-1100 Fax (206) 553-0120 +55 of 61 + + +Page 2 +current informal limitation to six months of community corrections, absent extraordinary +circumstances, which is unsupported by empirical evidence and, in effect, nullifies the SCA's +increase in the available time in community corrections. +A. +The Proposed Regulation Does Not Comply With The Congressional Instruction To +Address The Optimal Duration Of Pre-Release Community Corrections. +An essential component of the SCA's change in reentry policy was the doubling of the +("The Director of the Bureau of Prisons shall issue regulations" regarding the "sufficient duration" +of community corrections) (emphasis added)). "[D]iscretion as to the substance of the ultimate +decision does not confer discretion to ignore the required procedures of decisionmaking." Bennett +v. Spear, 520 U.S. 154, 172 (1997). Here, Congress used the mandatory word "shall." The BOP +must follow procedural requirements for an exercise of discretion to be lawful: "IT ]he promulgation +of [the] regulations must conform with any procedural requirements imposed by Congress" because +"agency discretion is limited not only by substantive, statutory grants of authority, but also by the +procedural requirements which 'assure fairness and mature consideration of rules of general +application.'' Chrysler Corp. v. Brown, 441 U.S. 281, 303 (1979) (citations omitted). +The SCA explicitly refers to the need for reentry policies to be empirically based. 42 U.S.C. +§ 17541(d). Congress's intention that the BOP engage in notice-and-comment rule-making +effectuates this approach by giving the public and interested organizations, like the Defenders, the +opportunity to provide input regarding the duration of community corrections. See Chrysler Corp., +441 U.S. at 316 ("In enacting the APA, Congress made a judgment that notions of fairness and +informed administrative decisionmaking require that agency decisions be made only after affording +interested persons notice and an opportunity to comment."); see also Conf. Rep. to Consolidated +Appropriations Act of 2010, 155 CoNG. Rec. H13631-03, *H13888 (daily ed. Dec. 8, 2009) +(directing the BOP to consult with the public and experts regarding reentry issues). Congress also +made the judgment that agencies must do more than simply repeat statutory language: agencies are +required to articulate their rationale and explain the data upon which the rule is based. Burlington +Truck Lines, Inc. v. United States, 371 U.S. 156, 167-68 (1962). Nevertheless, the proposed +regulation provides none of the material required for informed rule-making. Instead, the BOP issued +the informal memoranda with no support in best practices, no social science studies, and no +articulated rationale with any support in the literature. The proposed regulation appears to be +unlawful because it fails to address a critical question that Congress determined should be addressed +by fair and neutral rule-making, not by administrative fiat. +1601 Fifth Avenue, Room 700, Seattle, Washington 98101 - Telephone (206) 553-1100 Fax (206) 553-0120 +56 of 61 + + +Page 3 +B. +The Regulation Should Incorporate A Presumption of Maximum Community +Corrections In Order To Promote Successful Reentry And To Save Taxpayer Money. +The SCA's amendment of § 3624(c) rests on three assumptions apparent from the legislation: +the amount of available time in community corrections should be doubled; the likelihood of +successful reentry will be enhanced by earlier reintegration through family reunification, +employment, and treatment in the community; and the costs of incarceration can be ameliorated by +greater utilization of community resources for those determined not to create substantial risks in the +community. The proposed regulation does nothing to further these legislative goals. The BOP +should promulgate a regulation that furthers the SCA's reentry goals by presumptively permitting +the maximum time available for community corrections, with less time depending on individualized +safety factors and availability of facilities. +Congress's intent that placements be longer is reinforced by the Consolidated Appropriations +Act of 2010, which provides: +Because BOP has indicated that approximately $75,000,000 is required to implement +fully its Second Chance Act responsibilities, the conferees expect the Department to +propose significant additional funding for this purpose in the fiscal year 2011 budget +request, including significant additional funding for the enhanced use of Residential +Reentry Centers (RR) as part of a comprehensive prisoner reentry strategy. The +conferees also urge the BOP to make appropriate use of home confinement when +considering how to provide reentering offenders with up to 12 months in community +corrections. +155 CoNG. REC. at H13887. Congress thus clearly expressed its continued intention that the BOP +fully use its authority to place federal prisoners in the community for as long a period as appropriate +to ensure the greatest likelihood of successful reintegration - including greater utilization of halfway +houses and home confinement. Congress has indicated that funding considerations will not be +tolerated as an excuse for failing to implement fully BOP's responsibilities under the SCA. The six +month limit is inconsistent with the statutory instruction to enhance and to improve utilization of +community confinement for federal prisoners. +save scarce resources, redirecting them toward more effective rehabilitative programs. With the +exception of foreign nationals, almost all of the 217,363 federal prisoners are eligible for community +corrections under the SCA (about 26% of federal prisoners are aliens with immigration holds), with +about 45,000 transferred to the community each year. +1601 Fifth Avenue, Room 700, Seattle, Washington 98101 - Telephone (206) 553-1100 Fax (206) 553-0120 +57 of 61 + + +Page 4 +Besides the greater freedom at stake, enormous saving are available. +For one year, +incarceration in prison costs about $28,284.00; in a halfway house $25,838.00; and home detention +about $3,000.00.' So if prisoners were transferred from prison to home confinement even one month +earlier, the BOP could save about $94.8 million each year.? By increasing the average time in home +detention by three months, the BOP would save about $284.4 million every year. Similarly, the cost +to keep prisoners in halfway houses rather than in prison for an additional month would save about +$9.2 million.' The difference for three months would be $27.6 million. And these savings would +multiply with each additional year that the SCA is fully implemented. The proposed regulation does +not address either the financial or human costs associated with maintaining the status quo. +The BOP should honor both the spirit and letter of the rule-making process. The regulation +should be precise so that the public has a meaningful opportunity to comment. The Defenders +suggest that the final regulation include, or at a minimum address, the following: +• +A presumption of maximum community confinement to facilitate reentry and +to save money, with less time based on individual risk factors and resource +availability; +A description of any studies and analyses considered in arriving at criteria for +the exercise of discretion to maximize the duration for community +confinement to achieve successful reintegration; +Early placement of prisoners in residential reentry facilities to maximize the +home confinement component of community corrections. +In times like these when prisoners are facing great obstacles to successful reintegration, the +BOP, through its policies and regulations, should strive to make the difficult transition easier. The +SCA provides a clear message that up to the full available year of community corrections should be +'Annual Determination Of Average Cost Of Incarceration, 76 Fed. Reg. 57081 (Sept. 15, 2011); +Memorandum from Matthew Rowland to Chief Probation Officers Cost of Incarceration (May 6, +2009). += With 1/12 of the $3000 yearly cost of home confinement equaling $250 for one month, +ubtracted from one month of prison at $2357 (1/12 of the 28,284 annual costs), equals $2,107 +nultiplied by 45,000, the number of prisoners released each year to community corrections, equal +$94,815,000. +" The difference every month of $204.00, multiplied by the 45,000 prisoners released equals +$9,180,000. +1601 Fifth Avenue, Room 700, Seattle, Washington 98101 - Telephone (206) 553-1100 Fax (206) 553-0120 +58 of 61 + + +Page 5 +utilized to reach the greatest likelihood of success on supervised release. The BOP should +promulgate a regulation to achieve the SCA's goal by presuming that the prisoner should receive the +maximum available community corrections, limited by individualized assessments regarding public +safety and available community resources. +C. The Six-Month Informal Rule Should Be Rejected. +The need for a regulation regarding the duration of community corrections is especially acute +because, in the absence of a regulation on the subject, the default directive is the BOP's informal sixmonth rule under memorandums to staff and program statements. The only rationale for the sixmonth rule proffered by the BOP related to the supposed optimum time in a halfway house. In fact, +the evidence presented in the case in which Judge Marsh invalidated the carlier regulation +established that the six-month norm was based on erroneous assumptions. Most glaringly, the +evidence disclosed that the Director of the BOP erroneously believed there were studies supporting +the rule, but the BOP's own records established that no such studies exist: +The Director claimed that "our research that we've done for many years +reflects that many offenders who spend more than six months in a halfway +house tend to do worse rather than better. The six months seems to be a limit +for most of the folks, at which time if they go much beyond that, they tend to +fail more often than offenders that serve up to six months." +The BOP's research department could not back up the Director's claim, +stating "I am trying to find out if there is any data to substantiate the length +of time in a 'halfway house' placement is optimally x number of months. +That is, was the "6-month' period literally one of tradition, or was there some +data-driven or empirical basis for that time frame? ... l've done a lot of +searching of the literature, but so far have not found anything to confirm that +the "6-months' was empirically based." +Because the BOP had no meaningful experience with community corrections greater than six +months, the erroneous assumption regarding "research" was especially prejudicial. Rather than being +^ United States Sentencing Commission, Symposium On Alternatives To Incarceration, at 267 +(July 15, 2008). +s Sacora v. Thomas, CV 08-578-MA, CR 48-9 (D. Or. Mar. 1, 2010) (exhibit in support of +memorandum of law). +1601 Fifth Avenue, Room 700, Seattle, Washington 98101 - Telephone (206) 553-1100 Fax (206) 553-0120 +59 of 61 + + +Page 6 +based in empirical research, the six-month rule may simply be a vestige of litigation positions that +have been superseded by the SCA.® +Even if the erroneous belief regarding halfway house studies had not been debunked, the +SCA could still have been implemented to make a difference: even with a six-month limit on the +duration of halfway house placements, earlier placement would allow for up to six months of +additional time in home detention under § 3624(c)(2). The SCA clearly permits such a change, +which would result in significant savings. More importantly for prisoners, earlier community +corrections would enable them to accelerate their reintegration into the community through family +reunification, work, treatment, and other appropriate community-based programming. The proposed +regulation fails to address this aspect of the SCA, leaving intact the informal and unsupported sixmonth rule. +The six-month informal rule is also irrational because its "extraordinary justification" +exception is indistinguishable from "extraordinary and compelling reasons" under 18 U.S.C. +§ 3582(c). The informal rule states that pre-release community corrections exceeding six months +may be permitted only with "extraordinary justification." Program Statement 7310.04 at 8 (Dec. 16, +1998). But under § 3582(c), the BOP is supposed to alert the district court by filing a motion to +reduce the sentence for "extraordinary and compelling reasons." The informal rule, by using an +indistinguishable standard, creates an irrational and unworkable system in which BOP personnel, +instead of permitting more than six-months of community corrections, should be mooting the +question by moving the district judge to reduce the sentence. +Conclusion +An essential component of the SCA is the doubling of the available time for pre-release +community corrections. By essentially maintaining the pre-SCA status quo, and by failing to +promulgate a regulation on the optimal duration for community corrections, the BOP misses the +opportunity to implement Congress's intent that reentry be eased by increased custody in the +community, with its concomitant promotion of family unity, community-based treatment, and +employment in the prisoner's home region. The Defenders speak in one voice in encouraging the +BOP to implement the SCA by promulgating a regulation on the duration of pre-release community +• Starting in 2002, the BOP has argued that no community confinement could exceed six months. +The pre-SCA litigation depended on two things: the discretion to place prisoners in community +confinement under 18 U.S.C. § 3621(b); and the six-month limitation on pre-release custody under +the former § 3624(c). With the SCA, Congress has reaffirmed the BOP's authority to place prisoners +in community confinement at any time and expanded the pre-release custody to twelve months. +Thus, the informal six-month rule no longer has any basis in the relevant statutes. +1601 Fifth Avenue, Room 700, Seattle, Washington 98101 - Telephone (206) 553-1100 Fax (206) 553-0120 +60 of 61 + + +Page 7 +corrections that abandons the informal six-month limitation and presumes the maximum available +community corrections, limited only by individualized safety and resource considerations. +Very truly yours, +Hill +Thomas W. Hillier, II +Federal Public Defender +TWH/mp +1601 Fifth Avenue, Room 700, Seattle, Washington 98101 - Telephone (206) 553-1100 Fax (206) 553-0120 +61 of 61 + + +ATTACHMENT B + + +CONTRACTOR +LOCATION +COMCOR, INC. +COLORADO SPRINGS, CO +ARC COMMUNITY SERVICES +MADISON, WI +DAKOTA COUNSELING INSTITUTE +MITCHELL, SD +GREAT LAKES RECOVERY CENTER MARQUETTE, MI +LARIMER COUNTY COMMUNITY +CORR. +ORIANA HOUSE, INC. +BANNUM, INC. +ALVIS, INC. +REALITY HOUSE PROGRAM, INC. +VOLUNTEERS OF AMERICA, +WESTERN NY +TRANSITIONS, INC. +TRANSITIONS OF YOUTH, INC. +DULUTH BETHEL SOCIETY +PRAIRIE CENTER HEALTH +SYSTEMS +BANNUM, INC. +FORT COLLINS, CO +AKRON, OH +WHEELING, WV +DAYTON, OH +COLUMBIA, MO +BINGHAMTON, NY +ASHLAND, KY +DURHAM, NO +DULUTH, MN +CHAMPAIGN, IL +BEAUMONT, TX +COMMUNITY COUNSELING & +CORRECTIONAL SERVICES +BUTTE, MT +RRCs Expiring and/or Not Exercising Option Years +BED NUMBERS +Notes +121 +4 +15 +12 +IN HOUSE: 10 +HC: 3 +CONTRACT WILL EXPIRE 10/31/2017 +CONTRACT WILL EXPIRE 10/31/2017 +CONTRACT WILL EXPIRE 12/31/2017 +NOT EXERCISING OPTION YEAR - +CONTRACT WILL EXPIRE ON 1/31/2018 +NOT EXERCISING OPTION YEAR - +CONTRACT WILL EXPIRE ON 11/30/2017 +IN HOUSE: 36 +HC: 18 +NOT EXERCISING OPTION YEAR - +CONTRACT WILL EXPIRE ON 10/31/2017 +GUARANTEE MINIMUM: 12 ESTIMATED +MAXIMUM: 15 +24 +CONTRACT EXPIRED 09/30/2017 +120 +10 +NOT EXERCISING OPTION YEAR - +CONTRACT EXPIRED 7/31/2017 +CONTRACT EXPIRED 06/30/2017 +CONTRACT EXPIRED 08/31/2017 +GUARANTEE MINIMUM: 8 AND ESTIMATED NOT EXERCISING OPTION YEAR - +MAXIMUM: 20 +CONTRACT EXPIRED 06/30/2017 +CONTRACT EXPIRED 05/31/2017 +12 +115 +CONTRACT EXPIRED 05/31/2017 +CONTRACT WILL EXPIRE 10/31/2017 +GUARANTEE MINIMUM IN HOUSE: 21 +ESTIMATED MAXIMUM IN HOUSE: 42 +GUARANTEE MINIMUM HC: 4 ESTIMATED +MAXIMUM HC: 9 +NOT EXERCISING OPTION YEAR - +CONTRACT WILL EXPIRE ON 02/28/2018 +IN HOUSE: 15 +HC: 8 +NOT EXERCISING OPTION YEAR - +CONTRACT WILL EXPIRE ON 02/28/2018 +HC = Home Confinement + + +Exclusive: Trump administration reduces support for prisoner halfway houses - Reuters + +Discover Thomson Reuters +REUTERS Business +Markets +World +Politics +Directory of sites +TV More +Login +Contact +Support +Q +POLITICS +OCTOBER 13, 2017 / 2:41 PM / 2 YEARS AGO +Exclusive: Trump administration +reduces support for prisoner +halfway houses +Sarah N. Lynch, Julia Harte +5 MIN READ +f +WASHINGTON (Reuters) - The administration of President Donald +Trump has been quietly cutting support for halfway houses for +federal prisoners, severing contracts with as many as 16 facilities in +recent months, prompting concern that some inmates are being +forced to stay behind bars longer than necessary. +https://www.reuters.com/article/us-usa-justice-prisons-exclusive/exclusive-trump-administration-reduces-supp… + + +Exclusive: Trump administration reduces support for prisoner halfway houses - Reuters + +FILE PHOTO: The Department of Justice (DOJ) logo is pictured on a +wall after a news conference in New York December 5, 2013. +REUTERS/Carlo Allegri/File Photo +The Federal Bureau of Prisons spokesman Justin Long confirmed +the cuts in response to an email inquiry from Reuters, and said they +only affect areas with small populations or underutilized centers. +'The Bureau remains firmly committed to these practices, but has +had to make some modifications to our programs due to our fiscal +environment," Long said. +Halfway houses have been a part of the justice system since the +1960s, with thousands of people moving through them each year. +For-profit prison companies such as Geo Group Inc have moved into +the halfway house market, though many houses are run directly by +government agencies or non-profit organizations. +A Geo spokeswoman declined to comment for this article. +The bureau, which falls under the U.S. Department of Justice, last +year had about 180 competitive contracts with "residential reentry +centers" run by non-profit and for-profit companies, such as Geo. +https://www.reuters.com/article/us-usa-justice-prisons-exclusive/exclusive-trump-administration-reduces-supp... 10/11/2019 + + +Exclusive: Trump administration reduces support for prisoner halfway houses - Reuters + +The International Community Corrections Association says on its +website there were about 249 separate halfway houses in +communities nationwide that are covered by the 180 contracts. +ADVERTISEMENT +home of +MDY +THE +MIGHTY +MID-CAP +Watch The Middle Bias O +Federal judges who spoke to Reuters said the cuts are having an +impact in their districts, particularly in states with fewer facilities or +larger geographic areas where the nearest center might be several +hundred miles away. +Judge Edmund Sargus of the Southern District of Ohio said it was a +real "stumper" when in July the government ended its contract with +the Alvis facility serving the Dayton area. +https://www.reuters.com/article/us-usa-justice-prisons-exclusive/exclusive-trump-administration-reduces-supp... 10/11/2019 + + +Exclusive: Trump administration reduces support for prisoner halfway houses - Reuters + +Long said that the cuts have not reduced referral rates or +placements, and only impact "about 1% of the total number of beds +under contract." +However, the changes coincide with other major criminal justice +policy shifts by U.S. Attorney General Jeff Sessions, who has pushed +for more aggressive prosecutions of drug offenses and a crackdown +on illegal immigrants who commit crimes. +In May, Sessions ordered prosecutors to charge defendants with the +highest provable offense, a move that is likely to trigger lengthy +prison sentences. +In 2016, of the 43,000 inmates released from federal prison, 79 +percent were released into a halfway house or home confinement, +according to the trade association. +"We need to improve re-entry services .. This move flies in the face +of that consensus," said Kevin Ring, whose non-profit Families +Against Mandatory Minimums has recently launched a Twitter +campaign to raise awareness of the problem. +ADVERTISEMENT +https://www.reuters.com/article/us-usa-justice-prisons-exclusive/exclusive-trump-administration-reduces-supp... + + +Exclusive: Trump administration reduces support for prisoner halfway houses - Reuters + +PAID FOR AND POSTED BY ABERDEEN STANDARD +INVESTMENTS +The Benefits of CEFs +Learn how closed-end funds offer unique advantages and +income potential for investors. +Read More › +Sessions is scheduled to testify next week before the Senate +Judiciary Committee. Ring said he hopes lawmakers will ask +Sessions about the changes underway for halfway houses. +"Is cutting re-entry opportunities really going to make us safer? +Congress needs to ask the Justice Department if this is part of their +strategy," he said. +LONGER PRISON TIMES +For Kymjetta Carr, the cuts have had a personal impact. The 30- +year-old from Cincinnati said she had expected her fiance Anthony +Lamar to get out of prison and go to a halfway house in November, +after serving seven years on a drug charge. +But she now has to tell their 10-year-old son his father won't be out +for Christmas or his birthday because Lamar's release to a halfway +house will not come until late July. +https://www.reuters.com/article/us-usa-justice-prisons-exclusive/exclusive-trump-administration-reduces-supp. 10/11/2019 + + +Exclusive: Trump administration reduces support for prisoner halfway houses - Reuters + +"It seems like the rug has been pulled out from under us," she said, +in an interview arranged through Families Against Mandatory +Minimums, a nonprofit advocacy group. +Halfway houses are low-security residences for thousands of +convicted prisoners serving alternative sentences or on release from +prison into partial freedom programs on the outside. The facilities +are meant to help prisoners reenter their communities, find a job +and get their lives back on track +A study commissioned last year by the Justice Department found +that centers have come under greater strain in recent years, as more +people have been released from prison. +Blair Campmier, executive director of Reality House in Columbia, +Missouri, said he was notified in early June that the center's eightyear-old contract would be terminated. +Some of his clients were sent to halfway houses in Kansas City and +Springfield, more than two hours away. "They were not happy, and +their families were not happy," said Campmier. +Ricardo Martinez, the Chief U.S. District Judge in the Western +District of Washington and Chairman of the Committee on Criminal +Law of the Judicial Conference of the United States, told Reuters he +has sent a letter to the Bureau of Prisons' new Director Mark Inch +requesting discussions. +https://www.reuters.com/article/us-usa-justice-prisons-exclusive/exclusive-trump-administration-reduces-supp... + + +Exclusive: Trump administration reduces support for prisoner halfway houses - Reuters + +"From our perspective, these facilities are not only useful - they are +essential," Martinez said. +Editing by Kevin Drawbaugh and Alden Bentley +Our Standards: +The Thomson Reuters Trust Principles. +MORE FROM REUTERS +REUTERS +https://www.reuters.com/article/us-usa-justice-prisons-exclusive/exclusive-trump-administration-reduces-supp… + + +Bureau of Prisons ending contracts with 16 halfway houses - CNNPolitics + +Bureau of Prisons ending contracts with +16 halfway houses +By Eli Watkins, CNN +Updated 5:04 PM ET, Mon November 20, 2017 +Attorney General Jeff Sessions speaks about domestic security in New York on November 2, 2017. +STORY HIGHLIGHTS +The Bureau of Prisons listed 16 contracts it was +considering ending or had ended +Washington (CNN) - The Bureau of Prisons is cutting +off funding for halfway houses throughout the +country, saving money the bureau says it needs at +the expense of what reform advocates say are vital +programs to help prisoners transition effectively and +safely out of the corrections system. +'I never really got the full story,' said the director of +one halfway house +Some 16 facilities around the country have seen or +will see their contracts with the federal prison +Members of both parties were taken aback +system end. The cuts are coming weeks into the +tenure of newly minted Bureau of Prisons Director +Mark Inch, whom Attorney General Jeff Sessions +tapped earlier this year to lead the federal prison system. Inch, a retired Army major general, hails from +the military's corrections and law enforcement system. +By using this site, you agree to our updated Privacy Policy and our Terms of Use. +https://www.cnn.com/2017/11/20/politics/bureau-of-prisons-mark-inch-jeff-sessions/index.html + + +Bureau of Prisons ending contracts with 16 halfway houses - CNNPolitics + +Halfway houses, or "residential re-entry centers" in federal prison lingo, help manage the transition for +federal prisoners from incarceration to freedom. According to the Bureau of Prisons, the facilities +"provide a safe, structured, supervised environment, as well as employment counseling, job placement, +financial management assistance and other programs and services." +Kara Gotsch, director of strategic initiatives for The Sentencing Project, a criminal justice reform group, +said the cutback won't necessarily mean that prisoners will go straight from prison to the outside world, +but that it could diminish the time they spend getting acclimated to post-prison life. +Asked about the closures, the bureau provided a list of 16 contracts due for expiration around the +country, from West Virginia to Michigan to Colorado. Each is contracted for at most a few dozen beds, +with some managing people in home confinements as well. Some expiration dates had already passed +and others indicated the bureau would exercise its authority to end them soon. +The Bureau of Prisons also issued a statement saying the decision on the 16 contracts "does not reflect +any change in the Bureau's long-standing commitment to provide transitional services to inmates +releasing back to our communities, or to provide the courts with an alternative to incarceration when +appropriate." +The decision affects only a small share of the "total number of beds under contract," the bureau added, +and was the product of a months-long review. +"Over the past several months, the bureau conducted a comprehensive analysis of current RRC +resources to determine how to most effectively use our resources. As a result, we decided to +discontinue some contracts that were underutilized or serving a small population," the bureau said. +'A big surprise' +For at least one contractor, the bureau's decision came as an unwelcome shock. +Tim Hand, the head of Larimer County Community Corrections in Fort Collins, Colorado, runs a halfway +house that he said houses several hundred state offenders along with a "relatively small" federal +contract. +Hand said he got an email from Washington out of the blue notifying him his federal contract would end +in 30 days -- by the end of November. +"I never really got the full story," Hand said. "It sure is sad." +Hand said he pushed back but was unsuccessful, and described his experience working with the +federal government as difficult. He said his facility recently invested resources and time, including +building a new software program, for its federal work -- without getting a heads up from the bureau that +his facility was on the chopping block. +"Everything is secret, top secret," Hand said. "It came as a big surprise to us." +He added that he had not heard any overtures from the federal government about opening a new +contract with them, and if he did hear from Washington, Hand said, "I don't know if I would even be +By using this site, you agree to our updated Privacy Policy and our Terms of Use. +https://www.cnn.com/2017/11/20/politics/bureau-of-prisons-mark-inch-jeff-sessions/index.html + + +Bureau of Prisons ending contracts with 16 halfway houses - CNNPolitics + +Greg Toutant, the executive director of Great Lakes Recovery Centers, Inc., wrote a letter requesting the +bureau reconsider closing its re-entry center in Michigan. The letter said Great Lakes had operated +services for federal parolees going back 30 years and served a wide region. +"Please do not let what appears to be a unilateral, knee-jerk reaction override quality systems of care," +Toutant wrote. +Toutant said he found out his contract was ending in a "very abrupt letter" and that the bureau had not +made itself available to talk about the decision or what would happen to the federal parolees. +"No one has talked with us about what's going to happen," Toutant said. +He said their "minor use" facility cycled about 25 to 30 people from the Bureau of Prisons every year +and that he is "a little scared" for what the decision means for those affected. +Toutant said the facility, based out of the upper peninsula city of Marquette, was important because of +the unique geography of the area and the isolation of its community. He stressed that the relatively +small decision would have an outsize impact. +"Nobody has really picked up on what this is going to do to communities," Toutant said. +Bureau spokesman Justin Long told Reuters last month, when the news agency first reported the +decision, that although the bureau supported halfway houses, it was forced "to make some +modifications to our programs due to our fiscal environment." +Gotsch, the Sentencing Project staffer, challenged the bureau's reasoning that fiscal realities were +behind the decision to close the facilities. +"It's kind of curious to me that BOP is claiming they're having these big financial problems because +they've had a huge dip in their prison population," Gotsch said. "What are they talking about? They +don't have enough funding?" +Gotsch said a quality period of time in a halfway house can be essential to transitioning from prison and +noted that halfway houses offer not only proximity to offenders' home and communities, but that they +can also access counseling and classes to help them acclimate back to society. +"It definitely compromises the re-entry process," Gotsch said of the contracts ending. +Cuts against trend +The Bureau of Prisons' decision to cut funding for halfway houses has alarmed members of both +political parties, who have begun to move toward a consensus that the federal government must +implement some degree of reform to its criminal justice system in order to reduce the US prison +population. The federal prison population makes up about 13% of the overall US prison population, and +the nation's overall incarceration rate is the highest recorded in the world. +A group of eight senators sent a letter in late October to Inch and Deputy Attorney General Rod +Rosenstein, expressing dismay at the cuts and asking for the move to be reversed. +The letter notes concern about eliminating cognitive behavioral programming in addition to the closure +or the bytesagatha 3May JOUS R589 Of updated Privacy Policy and our Terms of Use. +https://www.cnn.com/2017/11/20/politics/bureau-of-prisons-mark-inch-jeff-sessions/index.html + + +Bureau of Prisons ending contracts with 16 halfway houses - CNNPolitics + +"These changes, particularly in the absence of a justification, threaten to make our communities less +safe while increasing BOP operating costs over time," the letter said. +The senators on the letter were a bipartisan group, made up of John Cornyn of Texas and Judiciary +Committee Chairman Chuck Grassley of lowa as well as Rob Portman (R-Ohio), Thom Tillis (R-North +Carolina), Sheldon Whitehouse (D-Rhode Island), Amy Klobuchar (D-Minnesota), Al Franken +(D-Minnesota) and Brian Schatz (D-Hawaii). +The cuts are at odds with public actions and statements by the administration. White House adviser +Jared Kushner, the President's son-in-law, met with members of both parties at the White House in +September to discuss improvements to the federal prison system, including better ways to reintegrate +convicts into society. +And last week, Sessions appeared to offer a mixed assessment of programs targeted at reducing +recidivism when asked in a House Judiciary Committee hearing, but said he believed pre-release +programs can be effective. +"Most of the time, according to my experience, they don't achieve huge results, but if they achieve 10, +15, 20% improvement, that's of value," Sessions told GOP Rep. Doug Collins of Georgia last Tuesday. +By using this site, you agree to our updated Privacy Policy and our Terms of Use. +https://www.cnn.com/2017/11/20/politics/bureau-of-prisons-mark-inch-jeff-sessions/index.html + + +ATTACHMENT C + + +U.S. Department of Justice +Roningeon, Dc 20 Division +October 10, 2017 +MEMORANDUM FOR +REGIONAL DIRECTORS +FROM: +Acting Assistant Director +Réentry Services Division +SUBJECT: +Residential Reentry. Center Operations +This memorandum is being issued to provide information regarding +several measures being taken to ensure the Federal Bureau of +Prisons' (Bureau) Residential Reentry Center (RRC) program remains +within budgetary allocations. These steps include: +• Discontinuing sixteen RRC contracts that were underutilized. +These cancellations affect 146 beds or abouț 1l of the total +bed space. +• Bringing all RRC contracts into compliance with their +contracted operating capacity. Many RRCs are operating above +the population limits specified in their contracts. In order +to address +these overages, Residential Reentry Management +Branch (RRMB) staff are delaying some new placements or +adjusting placements until populations in those facilities +decrease to within contract limits. +• The average length of stay for BOP inmates in RRCs has +increased in recent years to approximately 145 days. Due to +fiscal constraints and the contract actions described above, +the average length of stay is likely to decline to about 120- +125 days. RRMB staff will continue to carefully assess, on a +case-by-case basis, each inmate's programming needs and +determine the appropriate length of stay for each placement. +This action is +consistent with the discussion the RRMB +Administrator, +recently had with all CMCs. +We continue to carefully examine all cases to ensure compliance with +the Second Chance Act and to ensure that inmates who are +participating in the Residential Drug Abuse Program receive the +required amount of community based treatment to remain eligible for +any early release benefit granted under 18 USC 3621 (e). +It you or your staff have any questions or concerns please contact +(bK6.(bKTNC) +Administrator, Residential Reentry Management Branch at +OI + + +ATTACHMENT D + + +Residential Reentry Center (RR) Services and Home Confinement Services Located Within the State of Okla... Page 1 of 4 +AMENT OPE +Residential Reentry Center (RRC) Services and Home Confinement Services Located +Within the State of Oklahoma +Solicitation Number: 15BRRC19R00000247 +Agency: Department of Justice +Office: Bureau of Prisons +Location: Acquisitions Branch +Notice Type: +Solicitation +Posted Date: +September 25, 2019 +Original Response Date: +Nov 25, 20192:00 pm +Original Archive Date: +March 31, 2021 +Original Set Aside: +N/A +Set Aside: +N/A +Classification Code: +G - Social services +NAICS Code: +Original Posted Date: +August 7, 2019 +Response Date: +Nov 25, 2019 2:00 pm Eastern +Archiving Policy: +Automatic, on specified date +Archive Date: +March 31, 2021 +623 - Nursing and Residential Care Facilities/623990 -- Other Residential Care Facilities +Synopsis: +Added: Aug 07, 2019 1:41 pm Modified: Sep 25, 2019 12:21 pm Track Changes +The Federal Bureau of Prisons is seeking concerns having the ability for providing Residential Reentry Center (RRC) services (in-house +RRC beds) and Home Confinement services (home confinement placements) for male and female Federal offenders held under the +authority of United States Statutes located throughout the state of Oklahoma. +Both the RRC services for in-house RRC beds and the Home Confinement services for home confinement placements shall be in +accordance with the Federal Bureau of Prisons Statement of Work entitled, "Residential Reentry Center, April 2017, Revision 1 - April +2019". +This will be for an indefinite delivery, indefinite quantity type contract with firm fixed unit prices with a one year base period, and four oneyear option periods. +The RRC In-House requirement will be for a guaranteed minimum of 38 beds (34 male beds and 4 female beds) and a maximum total of +125 beds (112 male beds and 13 female beds) and will consist of one identified site location within the Northern judicial ditrict of +Oklahoma and one identified site location in either the Western or Eastern judicial district of Oklahoma to include the following maximum +RRC beds: Northern District will consist of 70 RRC beds (63 male beds and 7 female beds) and the Western or Eastern District will +consist of 55 RRC beds (49 male beds and 6 female beds). +https://www.fbo.gov/index?s=opportunity&mode=form&id=27beebdc74tbfa2259b66b101c6945a9&tab=core.. 10/12/2019 + + +Residential Reentry Center (RRC) Services and Home Confinement Services Located Within the State of Okla... Page 2 of 4 +The Home Confinement requirement will be for a guaranteed minimum of 19 home confinement placements and a maximum total of 63 +home confinement placements and will consist of the following maximum Home Confinement Placements: Northern District will consist of +35 Home Confinement Placements and Wester or Eastern District will consist of 28 Home Confinement Placements. +A Day Reporting Center may be proposed to monitor portions of or all of the home confinement population. Day Reporting Center +services shall be in accordance with the Federal Bureau of Prisons State of Work entitles, "Day Reporting Centers, April 2019". +The Home Confinement Radius will be within each judicial district. +It is the intent of the Government to award all line items (RRC in-house beds and home confinement placements) to a single provider, as +these services are interconnected and rely upon each other to ensure adequate programming and case management of offenders. The +Government reserves the right to potentially make an award which is deemed to be in the best interest of the Government. +15BRRC19R00000247 will be available on or about September 25, 2019, and it will be distributed solely through the General Services +Administration's Federal Business Opportunities (FBO) website at http://www.fbo.gov. Hard copies of the solicitation will not be available. +The site provides downloading instructions. Future information about this acquisition will also be distr buted through this site. Interested +parties are responsible for monitoring this site to ensure that they have the most up-to-date information about this acquisition. The +estimated closing date of 15BRRC19R00000247 will be on or about November 25, 2019. +All responsible sources may submit a proposal which will be considered by this agency. No collect calls will be accepted. No telephone +request or written requests for the solicitation will be accepted. +Faith-Based and Community Organizations can submit offers/bids/quotations equally with other organizations for contracts for which they +are eligible. +Solicitation 1 +Type: Solicitation +Posted Date: September 25, 2019 +01 15BRRC19R00000247 Solicitation Cover Letter.pdf (928.54 Kb) +Description: 01 - Solicitation Cover Letter +02 15BRRC19R00000247 Solicitation Cover Sheet.pdf (485.50 Kb) +Description: 02 - Solicitation Cover Sheet +03 15BRRC19R00000247 Solicitation Document.pdf (427.17 Kb) +Description: 03 - Solicitation Document +04 15BRRC19R00000247 Statement of Work - Revision 1.pdf (1,837.18 Kb) +Description: 04 - RRC Statement of Work +05 15BRRC19R00000247 Performance Summary Table.pdf (154.75 Kb) +Description: 05 - Performance Summary Table +06 15BRRC19R00000247 Environmental Checklist.pdf (50.34 Kb) +Description: 06 - Environmental Checklist +07 15BRRC19R00000247 Sample Community Notification Letter.pdf (35.90 Kb) +Description: 07 - Sample Community Notification Letter +https://www.fbo.gov/index?s=opportunity&mode=form&id=27beebde74fbfa2259b66b101c6945a9&tab=core... + + +Residential Reentry Center (RRC) Services and Home Confinement Services Located Within the State of Okla... Page 3 of 4 +08 15BRRC19R00000247 Sample Client Notification Letter.pdf (21.86 Kb) +Description: 08 - Sample Client Notification Letter +09 15BRRC19R00000247 Sample Bank Notification Letter.pdf (20.18 Kb) +Description: 09 - Sample Bank Notification Letter +10 15BRRC19R00000247 Service Contract Business Management.pdf (140.04 Kb) +Description: 10 - Business Management Questionnaire +11 15BRRC19R00000247 Compliance Matrix.pdf (453.34 Kb) +Description: 11 - Compliance Matrix +12 15BRRC19R00000247 RRC Cert of Compliance.pdf (21.89 Kb) +Description: 12 - RRC Certificate of Compliance +13 15BRRC19R00000247 Local Area Concerns.pdf (27.17 Kb) +Description: 13 - Local Area of Concerns Form +14 15BRRC19R00000247 Wage Determinations.pdf (452.30 Kb) +Description: 14 - Wage Determinations +15 15BRRC19R00000247 Subcontracting Plan.pdf (1,182.00 Kb) +Description: 15 - Subcontracting Plan +16 15BRRC19R00000247 DRC Statement of Work.pdf (629.51 Kb) +Description: 16 - DRC Statement of Work +Amendment 1 +Type: Mod/Amendment +Posted Date: September 25, 2019 +Amendment 001.pdf (64.74 Kb) +Description: Amendment 001 +Contracting Office Address: +320 First Street, NW +Washington, District of Columbia 20534 +Place of Performance: +Oklahoma +United States +Primary Point of Contact.: +Kevin J. Hoff, +Contract Specialist +khoff@bop.gov +Phone: (215) 521-7355 +ALL FILES +https://www.fbo.gov/index?s=opportunity&mode=form&id=27beebdc74fbfa2259b66b101c6945a9&tab=core. + + +Residential Reentry Center (RRC) Services and Home Confinement Services Located Within the State of Okla... Page 4 of 4 +Solicitation 1 l +Sep 25, 2019 +01 15BRRC19R00000247 E +02 15BRRC19R00000247 ! +03 15BRRC19R00000247 | +04 15BRRC19R00000247 : +05 15BRRC19R00000247 F +06 15BRRC19R00000247 E +07 15BRRC19R00000247 § +08 15BRRC19R00000247 S +09 15BRRC19R00000247 S +10 15BRRC19R00000247 S +11 15BRRC19R00000247 +12 15BRRC19R00000247 F +13 15BRRC19R00000247 | +14 15BRRC19R00000247 1 +15 15BRRC19R00000247 4 +16 15BRRC19R00000247_! +Amendment 1 U +Sep 25, 2019 +Amendment 001.pdf +Opportunity History +• Original Synopsis +Presolicitation +Aug 07, 2019 +1:41 pm +• Changed +Sep 25, 2019 +12:41 pm +Solicitation +• Changed +Sep 25, 2019 +1:39 pm +https://www.fbo.gov/index?s=opportunity&mode=form&id=27beebde74fbfa2259b66b101c6945a9&tab=core... + + +ATTACHMENT E + + +U.S. Department of Justice +Pederal Bureau 29 18 isons +Office of the Director +Washington, DC 20534 +August 27, 2018 +The Honorable Charles E. Grassley +Chairman +Committee on the Judiciary +United States Senate +Washington, DC 20510 +Dear Mr. Chairman: +The Second Chance Act of 2007 (P.L. 110-199; codified at +Title 18 S 3624 (c)(5)) requires the Bureau of Prisons (Bureau) +to transmit to the Committees on the Judiciary of the Senate and +the House of Representatives an annual report describing the +Bureau's use of community corrections. A copy of the 2018 report +is enclosed. +Sincerely, +Hugh J. Hurwitz +Acting Director +Enclosure + + +Utilization of Community Corrections Facilities +Report to Congress +Status Report: Covering data from April 2017 through March 2018. +Legislative Summary: On April 9, 2008. the President signed the Second Chance Act of 2007 +into law (P.L. 110-199). Section 251(a) of the law, codified at Title 18 U.S.C. § 3624(c)(5), +requires the Director of the Bureau of Prisons (Bureau) to transmit to the Senate and House of +Representatives Committees on the Judiciary an annual report describing the Bureau's use of +community corrections facilities. +The Burcau of Prisons refers to community corrections facilities or halfway houses as +Residential Reentry Centers. Most Federal inmates are placed in a Residential Reentry Center +(RRC) and or home confinement during the final year of their sentence. RRCs and home +confinement, (wo forms of community-based confinement, help inmates gradually re-adapt to the +community afier spending time in prison. Community-based confinement is a critical +component of the Bureau's comprehensive reentry strategy. +Residential Reentry Centers: RRCs help inmates transition to the community by providing a +structured, supervised environment, and by helping individuals find employment and housing, +complete necessary programming (e.g.. transitional drug abuse treatment), participate in +counseling. and strengthen ties to family and friends. +The Bureau makes RRC placement decisions based on each inmate's need for reentry services. +For example, inmates serving long sentences, with limited employment skills, little family +support, no established home to which they can return, and limited financial resources have a +much greater need for RRC placement than do inmates serving short sentences, and having +positive family support. a home. and job skills. +Home Confinement: This program is most appropriate for lower-risk inmates who are not in +need of significant residential transitional services. Inmates on home confinement are subject to +curfews, in-person check-ins, telephonic monitoring, and sometimes electronic monitoring. +Home confinement is substantially less costly than RRC placement; however, it is statutorily +limited to the shorter of six months or 10 percent of' an inmate's term of imprisonmeni.' +Inmates can transition to home confinement directly from a Burcau institution or from an RRC. +Inmates placed on home confinement may be supervised either by RRC staff or by U.S. +Probation staff as part of the Federal Location Moniloring program, Inmates are carelully +screened prior to their relcase from a Bureau institution to determine appropriateness for direct +home confinement placement. Many minimum security inmates who have a viable release +residence and minimal need for residential transitional services are referred for direct placement +into home confinement programs upon reaching their statutory cligibility date. Inmates who +transfer to RRCs are expected to transition into home confinement as soon as adequately +prepared and statutorily eligible. + + +Statistical Summary: Most but not all inmates are referred for transfer to community +confinement (i.c., to RRCs, home confinement, or both). +Ineligible Inmates: +The following list comprises reasons why inmates were ineligible for transfer to RRCs or home +confinement (including the total number for each calegory) from April 2017 through March +2018: +The inmate was released to a detainer (22,304).? +• The inmate had a sentence of six months or less (9,125). +• The inmate refused to satisly his/her obligation under the Bureau's Financial +Responsibility Program (2.243)? +Bligible Inmates: +From April 2017 through March 2018, 34,738 inmates were eligible for transfer to RRCs, or +home confinement. Among these 34,738 inmates, the Bureau transferred 729r (25,000) from +correctional institutions to RRCs or home confinement. Of the 34,738 inmates eligible for +transfer to RRCs or home confinement, 28% (9,738) did not transfer to RRCs or home +confinement during this perioci. +Reasons why these eligible inmates may not have been placed in RRCs or home confinement +include the following: +• The inmate refused RRC placement. +• The RRC denied placement of the inmate. +• The inmate had medical or mental health needs that could not be accommodated at an +RRC or on home confinement. +• The inmate had a pending charge that might have resulted in his/her arrest if placed in the +community. +• There was insufficient time to process an RRC referral (e.g., due to a sentence reduction. +last-minute lifting of a detainer, or resolution of a pending charge).* +• The inmate's behavior in a Bureau institution indicated that he'she was unlikely to +succeed in an RRC. +Among inmates who released through an RRC from April 2017 through March 2018, the +average expecied lengin of stay in an KRC Was 136.8 days. The average expected length of stay +decreased from FY 2017 (149.1) by 12 days. The following table provides data on the average +expected length of stay by quarter. +Fiscal Quarter +April - June 2017 +July - September 2017 +October - December 2017 +January - March 2018 +Average Expected Length of RRC Stay +145.6 days +146.8 days +132.2 days +118.8 days + + +Recent Activities and Future Goals: The Bureau continues to seek ways to expand the ust of +community resources to facilitate effective RRC and home confinement placements for inmates +as part of their community reentry. For example, day reporting centers are non-residential +facilitics that allow for programming and other services to be provided in a centralized location +while providing increased accountability and security functions for inmates on home detention. +This type of facility does not require the zoning typically required of an RRC which allows for +substantial services to be provided in areas where the agency has not been able to site a +traditional RRC facility. +The Burcau has solicited for Day Reporting Centers in three locations: Memphis, TN; +Sacramento, CA; and Richmond, VA. The solicitations are for a maximum placement of 30 +inmates per site. The Memphis location began performance on November 1, 2017, the +Sacramento location is anticipated to begin performance on November I, 2018, and the +Richmond location was determined not to be a viable location. +A new RRC Statement of Work (SOW) was completed in April 2017. The revised SOW +emphasizes cost savings while aiming to provide for the ongoing transitional needs of inmates +related to employment and housing. +The web-based electronic RRC application has been implemented in all RRM offices and RRCs +nationally. The program provides automated processing and tracking of RRC referrals and +provides instant feedback on the status of RRC referrals. It allows for improved inmate RRC +population management via monitoring of movement to and from RRCs. To date over 200,000 +referrals have been processed using this system resulting in significant increases in efficiency +and decreases in costs through the elimination of mailing and processing referral packets from +institution to RRM offices and then to RRC facilities. +Notes: +1. 18 U.S.C. 3624(c)(2). +2. The vast majorily of these detainers were lodged by Immigration and Customs Enforcement +on non-U.S. cilizen inmates. +4. If there is insufficient Lime for the Bureau to process an RRC referral and the inmate requires +the services of a community corrections facility, RRC services can be required by the +sentencing United States District Court as a condition of post-release supervision. +3 \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/21b065106cac7796546b3d64c356f63a9782108420f3a31980a9a4e318d84854.receipt.json b/vision-fixhub/ds9-parsed-01/21b065106cac7796546b3d64c356f63a9782108420f3a31980a9a4e318d84854.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..655ded30e3b45a12434be1504e705ed6861d1dcb --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/21b065106cac7796546b3d64c356f63a9782108420f3a31980a9a4e318d84854.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -3737, + "dataset": "marble-joined", + "doc_id": "21b065106cac7796546b3d64c356f63a9782108420f3a31980a9a4e318d84854", + "engine": "marble-apple-vision", + "event_count": 100, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "66a2c0d884115a2dd5fd79810d39ecd3d65707830edb189767e02e199ea3d620", + "output_sha256": "0530e522d64b80cf8194a43f5420271325aaa733c53b7d80e3547b3fd139d08f", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/21b825506d637f31f67549821f57c6e6dd8c4d4848b42eeeaba719050b99f6af.md b/vision-fixhub/ds9-parsed-01/21b825506d637f31f67549821f57c6e6dd8c4d4848b42eeeaba719050b99f6af.md new file mode 100644 index 0000000000000000000000000000000000000000..fc36b26246bf3240d61a1e98e275d81e7074c85e --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/21b825506d637f31f67549821f57c6e6dd8c4d4848b42eeeaba719050b99f6af.md @@ -0,0 +1,28 @@ +To: +Sent: +Sun 8/11/2019 4:47:27 AM +Subject: Re: Last contact with Epstein +IEXT.htm +Thanks. Feel free to contact me if you need anything at all. +Sent from my iPhone +On Aug 10, 2019, at 7:21 PM, +> wrote: +Thank you +nformation... +•Please er oy yociate yo and him the time to forward thi +MCC New York +New York, NY 10007 +NYM/AW-Programs-@bop.gov +• 8/10/2019 8:28 PM >>> +I visited inmate Epstein in SHU on Thursday. He was getting ready to meet with his +attorneys for the day so I had gone to visit him right after the SHU meeting. He +had a cell mate at the time with whom I saw him interact with. He did not report +any mental health concerns and he denied any suicidal thoughts or intention. He +was asking this writer to go to general population and was making requests for +various needs he had at the time. He wanted social calls without them being on a +speaker phone. He wanted a book he had left in the suicide watch area. His mood +was not depressed or anxious. There were no signs of distress. He had planned on +meeting with his attorneys to work on his legal situation. +Sent from my iPhone + +SDNY_00009045 diff --git a/vision-fixhub/ds9-parsed-01/21b825506d637f31f67549821f57c6e6dd8c4d4848b42eeeaba719050b99f6af.receipt.json b/vision-fixhub/ds9-parsed-01/21b825506d637f31f67549821f57c6e6dd8c4d4848b42eeeaba719050b99f6af.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..562b7d878558d64ef4b1e8964e9ad1d48bea1a63 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/21b825506d637f31f67549821f57c6e6dd8c4d4848b42eeeaba719050b99f6af.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "21b825506d637f31f67549821f57c6e6dd8c4d4848b42eeeaba719050b99f6af", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\"]", + "idempotent": true, + "input_sha256": "429de09da2dde3d0c77bcc1e0968be5fa0e45585f3affd62b572e580b5c627e9", + "output_sha256": "a837f6c3676bb63eeac42b14969ba38f4d9fdb63577ad3c4e365b5e8b24d2deb", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/21c3134941f665f50f086364df31061213393e856b51fa6651b68084b9ba577b.md b/vision-fixhub/ds9-parsed-01/21c3134941f665f50f086364df31061213393e856b51fa6651b68084b9ba577b.md new file mode 100644 index 0000000000000000000000000000000000000000..b4764fb5fde9efd7b8209febf5b46ffd94169f09 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/21c3134941f665f50f086364df31061213393e856b51fa6651b68084b9ba577b.md @@ -0,0 +1 @@ +No Images Produced diff --git a/vision-fixhub/ds9-parsed-01/21c3134941f665f50f086364df31061213393e856b51fa6651b68084b9ba577b.receipt.json b/vision-fixhub/ds9-parsed-01/21c3134941f665f50f086364df31061213393e856b51fa6651b68084b9ba577b.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..b62efc517cc1493cf99bf09c0e50d6277d82866c --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/21c3134941f665f50f086364df31061213393e856b51fa6651b68084b9ba577b.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "21c3134941f665f50f086364df31061213393e856b51fa6651b68084b9ba577b", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "c5fc31c16e5719a22c07f6e483c275820c0ad36a8578cda0d4a4d04f5abbc20e", + "output_sha256": "3874328764c818fba06683a6d5ddc2edc2d7850aaf4ba18646f81d3f8420a729", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/21cfc2de512f5c91e1ddd812de29bd7359a26076a9bfcaa2180f14dd38b02ff5.md b/vision-fixhub/ds9-parsed-01/21cfc2de512f5c91e1ddd812de29bd7359a26076a9bfcaa2180f14dd38b02ff5.md new file mode 100644 index 0000000000000000000000000000000000000000..fe5ae97772d2c99316bd692e61d1d97982968d73 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/21cfc2de512f5c91e1ddd812de29bd7359a26076a9bfcaa2180f14dd38b02ff5.md @@ -0,0 +1,37 @@ +From: + + +Subject +Date +Inline-Images +FOR INTERNAL NSD USE ONLY +NSD Daily News Brief +December 11, 2017 +Warning: NSD Security has identified media outlets are periodically reporting potentially classified documents related to +current events. Please be mindful the below web sites may contain links to articles containing classified information. +Users should always exercise caution when attempting to view documents hosted by an external website and immediately +report a suspicion of classified material to NSD Security and the NSD Technical Solutions Center (formerly the Help Desk). +If users access a site containing classified material, please ensure to clear the internet cache (From Internet Explorer, click +the Tools Button [top right] + Internet Options, then proceed to Browsing History and delete Temporary Internet Files). +Please contact the NSD Service Desk for assistance, +The following summaries have been copied from the Attorney General's News Briefing for December 11, 2017. The full +Attorney General's News Briefing can be accessed here. + + + + + + +Fusion GPS Sought To Link Trump To Convicted Pedophile Epstein. +The Washington Times (12/10, Scarborough, 624K) reports that in addition to the Russia dossier, Fusion GPS "pitched +other stories" about President Trump "to Washington reporters, including an attempt to tie him to a convicted pedophile + + +who was once buddies with former President Bill Clinton." The Times cites "journalist sources" who said the firm's +founder, Glenn Simpson "pushed the idea of a close relationship between Mr. Trump and Jeffrey Epstein, who pleaded +guilty in 2008 to soliciting sex from an underage girl." Fusion also "pushed the story that a special email server existed +between Trump Tower and Moscow's Alfa bank, the journalist source said." + + + + diff --git a/vision-fixhub/ds9-parsed-01/21cfc2de512f5c91e1ddd812de29bd7359a26076a9bfcaa2180f14dd38b02ff5.receipt.json b/vision-fixhub/ds9-parsed-01/21cfc2de512f5c91e1ddd812de29bd7359a26076a9bfcaa2180f14dd38b02ff5.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..0d2c1edb1360dfd4e76548e50c9b029f1943c800 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/21cfc2de512f5c91e1ddd812de29bd7359a26076a9bfcaa2180f14dd38b02ff5.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -96, + "dataset": "marble-joined", + "doc_id": "21cfc2de512f5c91e1ddd812de29bd7359a26076a9bfcaa2180f14dd38b02ff5", + "engine": "marble-apple-vision", + "event_count": 8, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "0951148f04d82db75ff6460a401f6d23808a5a15046245d8c332afa2676c5d61", + "output_sha256": "8e16465d1e132720857768328f5c5b6bc06cc4caa681147a6e5743f98bfbd4db", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/221b31dfac8682cc046b7fc41e3ac9c0cd6b382192766b39a02a74d6de6fbaf7.md b/vision-fixhub/ds9-parsed-01/221b31dfac8682cc046b7fc41e3ac9c0cd6b382192766b39a02a74d6de6fbaf7.md new file mode 100644 index 0000000000000000000000000000000000000000..e524e3de590f0e562ec3df2d5cf9730d0497308b --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/221b31dfac8682cc046b7fc41e3ac9c0cd6b382192766b39a02a74d6de6fbaf7.md @@ -0,0 +1,104 @@ +From: +To: "Tyrrell, Edward (USANYS)" +Subject: RE: travel approval request +Date: Tue, 09 Jul 2019 18:08:52 +0000 +Importance: Normal +Thanks! +From: Tyrrell, Edward (USANYS) +Subject: RE: travel approval request +Ed, +Again in connection with the Epstein investigation, we'd like to please request permission to travel for approximately +three days next week for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly +down Tuesday night and return on Wednesday or Thursday (and will keep the timeframe as short as scheduling allows). +Unfortunately we're still trying to pin down timing for interviewing the victims, so depending on the timing it will either +be me and +or +and +, but we wanted to ask for permission now either way so we weren't doing it +super last minute after the holiday on Tuesday. And also same as last time, we'd like to ask permission to reserve a +conference room at the hotel for the interviews, please. +thanks very much, +From: | +Sent: Wednesday, April 03, 2019 20:57 +To: Tyrrell, Edward (USANYS) | +Subject: RE: travel approval request +Thank you +From: Tyrrell, Edward (USANYS) < +Sent: Wednesday, April 03, 2019 20:46 +To: +Cc:| +Subject: Re: travel approval request +P; Duncan, Michele (USANYS) wrote: +Ed, +For the same case as below, United States v. Epstein, 2018R01618, an investigation relating to enticement of minors for +sexual activity, +and I would like to please request permission to travel for approximately three days next week fo +neetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly down Tuesday night and +return on Friday, though we will shorten the timeframe if scheduling allows. +Please let us know if any other information would be helpful, and thanks very much. +From: +Sent: Thursday, March 14, 2019 18:32 +To: Tyrrell, Edward (USANYS) 4 +Subject: travel approval request +Ed, +and I would like to please request permission for travel for United States v. Epstein, 2018R01618, an +investigation relating to enticement of minors for sexual activity, for two days of meetings and interviews in West Palm +Beach and/or Fort Lauderdale, Florida. As of now we're hoping to fly down next Wednesday night and return on +Saturday. +Please let us know if any other information would be helpful, and thanks as always. +Assistant U.S. Attorney +Southern District of New York +212.637.2415 diff --git a/vision-fixhub/ds9-parsed-01/221b31dfac8682cc046b7fc41e3ac9c0cd6b382192766b39a02a74d6de6fbaf7.receipt.json b/vision-fixhub/ds9-parsed-01/221b31dfac8682cc046b7fc41e3ac9c0cd6b382192766b39a02a74d6de6fbaf7.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..a3247a2a216af2b53c6af4ec8bfb83c425e3057e --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/221b31dfac8682cc046b7fc41e3ac9c0cd6b382192766b39a02a74d6de6fbaf7.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -36, + "dataset": "marble-joined", + "doc_id": "221b31dfac8682cc046b7fc41e3ac9c0cd6b382192766b39a02a74d6de6fbaf7", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "11bdae9cd46a6ed1de566d148e6d51003df069e38b9bf5dd2cc3f9144e3c70ea", + "output_sha256": "a0fcaa961c535414ab752b67992abc23379739911395050caf620db6ed1d4bbd", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/222e50113b680d0874876554ebe434278111f60f750061530128e7cc33fdba55.md b/vision-fixhub/ds9-parsed-01/222e50113b680d0874876554ebe434278111f60f750061530128e7cc33fdba55.md new file mode 100644 index 0000000000000000000000000000000000000000..4023350a67f14e05658a43a67fe3b8565a8edcb7 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/222e50113b680d0874876554ebe434278111f60f750061530128e7cc33fdba55.md @@ -0,0 +1,78 @@ +From: " +To: +Cc: ' +Subject: Fwd: Ghislaine Maxwell 02879-509 +Date: Thu, 02 Sep 2021 19:28:50 +0000 +(USANYS)" +D" < +I accidentally sent this to the wrong email address, sorry. Please let us know when would be good for a call. +Thanks, +Begin forwarded message: +From +Date: September 2, 2021 at 3:26:19 PM EDT +To: " +D" < +Ce: +1" < +Subject: Re: Fwd: Ghislaine Maxwell 02879-509 +P, +(USANYS)" ≤ +H +I believe you sent this to me by mistake. I forwarded it to +wish you the best of luck! +for you. +Attorney +Federal Bureau of Prisons +FMC Butner +Old Highway 75, P.O. Box 1600 +Butner, North Carolina 27509 +> 9/2/2021 3:24 PM >>> +Once you've had the chance to look into this, mind having a call to discuss please? +Thanks + + +Begin forwarded message: +From: BOBBIC STERNHEIM < +Date: Sontember 2 2021 at 3622-46 DWe +To: +Cc: Christian Everdell < +Subject: Ghislaine Maxwell 02879-509 +Good afternoon- +In compliance with the Court's order, dated August 25th (attached), I hereby notify you +of recent third-party interference with the "secure" Webex line used for confidential/privileged communication +between Ms. Maxwell and counsel. +At the conclusion of yesterday afternoon's VTC session, Ms. Maxwell observed +suspicious activity on the VTC monitor. +She alerted MDC staff, and Case Manager +Vitnessed the activity. +This is contrary to the Court's finding that "according to the Government and MDC Legal [Ms. Maxwell]'s +difficulties communicating with counsel have been resolved" and contrary to "MDC's Legal assurances that +[Ms. Maxwell]'s legal communication has not been interfered with..." +Previously, the MDC has disputed such claims concerning interference with +VTC communication between Ms. Maxwell and counsel. +Now, an MDC insider bears witness to complaint by Ms. Maxwell and counsel. +Please provide explanation for this interference and evidence of remediation +before I report this latest problem to the Court. +Thank you- +Bobbi +*Please note my new office address and preferred email address: +Please note my new office address and preferred email address: +BOBBI C. STERNHEIM, ESQ. +Law Offices of Bobbi C. Sternheim +225 Broadway, Suite 715 +New York, NY 10007 +Main +Cell: +Fax: +This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim +that may be confidential and/or privileged +If you are not the intended recipient, you may not read, copy, distribute, or use this information. +If you have received this transmission in error, please notify the sender immediately by reply e-mail and then +delete this message. Thank you. +This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim +that may be confidential and/or privileged. + + +If you are not the intended recipient, you may not read, copy, distribute, or use this information. +If you have received this transmission in error, please notify the sender immediately by reply e-mail and then +delete this message. Thank you. diff --git a/vision-fixhub/ds9-parsed-01/222e50113b680d0874876554ebe434278111f60f750061530128e7cc33fdba55.receipt.json b/vision-fixhub/ds9-parsed-01/222e50113b680d0874876554ebe434278111f60f750061530128e7cc33fdba55.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..98232f49dd8fb79d49a91c948c19390e8517b146 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/222e50113b680d0874876554ebe434278111f60f750061530128e7cc33fdba55.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -36, + "dataset": "marble-joined", + "doc_id": "222e50113b680d0874876554ebe434278111f60f750061530128e7cc33fdba55", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "5857ad03fbddb576790b889444b21ecb0fb4f100920523de6b56fe0c496fe77f", + "output_sha256": "39aad79a38bfbe96ae079061659952583b78a5a9113d88a68ac24df0377f9863", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/22b963804701ccca2c01cfa8d0cb2f8d89d9aef0e4c5fb63bb4968e4ba24ff5e.md b/vision-fixhub/ds9-parsed-01/22b963804701ccca2c01cfa8d0cb2f8d89d9aef0e4c5fb63bb4968e4ba24ff5e.md new file mode 100644 index 0000000000000000000000000000000000000000..4972188d3ee2925b402a8c7986534cf68c0b5b48 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/22b963804701ccca2c01cfa8d0cb2f8d89d9aef0e4c5fb63bb4968e4ba24ff5e.md @@ -0,0 +1,28 @@ +From: "l +To: "l +Ce: +Subject: Re: RE Bill Clinton +Date: Fri, 03 Jul 2020 16:09:45 +0000 +Thank you for this information. +On Jul 3, 2020, at 12:02, +P wrote: +Passing on the below, per our practice. +Thanks, +From: +To: +Sent: Friday, July 3, 2020 12:01 PM +Subject: Fwd: RE Bill Clinton +For you +Sent from my iPhone +Begin forwarded message: +from: Andy Kay , "Jack Alan Goldberger +Cc: "Barry Krischer" ‹ +Subject: Letter concerning Epstein and the Palm Beach Daily News +Date: Wed, 17 Sep 2008 16:04:06 +0000 +Importance: Normal +Attachments: Lefkowitz_080917.pdf +Gentlemen: Please review the attached letter. Thank you. +Assistant V.S. Attorney diff --git a/vision-fixhub/ds9-parsed-01/22e95fcc576b5c6e52389679baa088e2a82941d3354f4eac5ff81963ef32a750.receipt.json b/vision-fixhub/ds9-parsed-01/22e95fcc576b5c6e52389679baa088e2a82941d3354f4eac5ff81963ef32a750.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..db4ecec6979dd991b8829b002aa378dc4dfca67b --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/22e95fcc576b5c6e52389679baa088e2a82941d3354f4eac5ff81963ef32a750.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "22e95fcc576b5c6e52389679baa088e2a82941d3354f4eac5ff81963ef32a750", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "45b9b462596a8b609c3a51126b2d328e4be59b2a0ef9dc31b1a07367879dd91e", + "output_sha256": "eab89bba2d6ca79298c203d8d6fef8b1dcf1818d0f3168a5f9a96d500899ebdf", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/22ea76defb3186f4db9fd4ed10a670026deb805f02e180553c6fc5e557f7e079.md b/vision-fixhub/ds9-parsed-01/22ea76defb3186f4db9fd4ed10a670026deb805f02e180553c6fc5e557f7e079.md new file mode 100644 index 0000000000000000000000000000000000000000..e65b85cabf9c49964a84777be0bc2fe9b126338b --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/22ea76defb3186f4db9fd4ed10a670026deb805f02e180553c6fc5e557f7e079.md @@ -0,0 +1,33 @@ +From: +To: < +Subject: Final Voucher 10892303-1(1) approved by +approval +Date: Mon, 30 Dec 2019 23:48:50 +0000 +Importance: Normal +now awaiting further +Dear +Final voucher 10892303-1(1) has been approved by +now awaiting further approval. +Trip ID: 10892303-1 +Voucher ID: 1 +Voucher type: Final +Traveler name: +Purpose: R20NYS13197 - U.S. v. Epstein - Witness Interview (California) +Destination: Santa Monica, CA, United States +Dates: 2019-12-15 - 2019-12-18 +Current status: Pending Voucher Approval +Voucher total expenses: 2227.40 +Estimated trip cost: 2440.58 +E2 Single Sign On Login (within DOJ Network Only): +https://dojnet.doj.gov/jmd/fs/e2-redirect.html +E2 Manual Login (User ID and Password): +https://e2.gov.cwtsatotravel.com +Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link. +Please note: Replies to this mailbox are not monitored. +Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your +email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the +emails that you receive from us. +Reference ID# V0010 +This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e- +mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments; +any further use of such e-mail or attachments is strictly prohibited. diff --git a/vision-fixhub/ds9-parsed-01/22ea76defb3186f4db9fd4ed10a670026deb805f02e180553c6fc5e557f7e079.receipt.json b/vision-fixhub/ds9-parsed-01/22ea76defb3186f4db9fd4ed10a670026deb805f02e180553c6fc5e557f7e079.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..57552da48f5aa8f6ff3d1409bb9896f89c71dd99 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/22ea76defb3186f4db9fd4ed10a670026deb805f02e180553c6fc5e557f7e079.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "22ea76defb3186f4db9fd4ed10a670026deb805f02e180553c6fc5e557f7e079", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "bd51ad09712a680a0da66552e5048a3c5fa551dca75f24b0b5950dd7dafba02e", + "output_sha256": "e2e9cb8d3b12d9a108a221a8d9161847c6075d4f938e75e641cb55aeb35efbb2", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/22f645cec1f84bc8ec02b296237d10565025a79067b247639e90d40b7290fd69.md b/vision-fixhub/ds9-parsed-01/22f645cec1f84bc8ec02b296237d10565025a79067b247639e90d40b7290fd69.md new file mode 100644 index 0000000000000000000000000000000000000000..9b57cbe030df25e3481f0e0f84e33e7e26f54e2f --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/22f645cec1f84bc8ec02b296237d10565025a79067b247639e90d40b7290fd69.md @@ -0,0 +1,68 @@ +From: +To: +I' < +Subject: RE: hate crimes brainstorming session? +Date: Mon, 03 Dec 2018 16:31:47 +0000 +Importance: Normal +Attachments: 2017.08.28_Potential_LE_Responses_to +_White_Supremacist_Protests_Threats_...pdf +From: +Sent: Monday, December 3, 2018 11:10 AM +To: | +Subject: RE: hate crimes brainstorming session? +Sure - 1 also just emailed | +land +From: +To: +Sent: Monday, December 3, 2018 11:09 AM +Subject: RE: hate crimes brainstorming session? +Perfect! Are you okay with me emailing +land saying that you should definitely be included? +From: +To: +Sent: Monday, December 3, 2018 11:07 AM +Subject: RE: hate crimes brainstorming session? +Actually, I've been pushing the brass to do more on hate crimes, and attended a session at the FBI on this recently. When +you were talking about the domestic terrorism squad when we met, I meant to mention and get your insight and then we +got side tracked. I'm a bit annoyed I wasn't on this email - glad you forwarded! I'll follow up with _ +and and will +forward you something I send the brass recently that +was planning to follow up on. +From: +To: +Sent: Monday, December 3, 2018 11:04 AM +Subject: FW: hate crimes brainstorming session? +Hey - I talked to +going on. +about hate crimes and domestic terrorism, and she kindly included me on this brainstorming +session. Any interest in joining? I know it's not really PSC, but could be interesting. No pressure - know you have a lot +Also, l +good for the HT role. +got added to the Epstein investigation. The brass approved moving forward with an investigation. I think it's +From: Blain, +_(USANYS) +Sent: Friday, November 30, 2018 2:54 PM +To: +(USANYS) < +| (USANYS) < +>; Kennedy, +(USANYS) < + + +Subject: hate crimes brainstorming session? +I know we've talked about this before, but just to confirm - shall we reach out to FBI and I +] (NYPD Hate Crimes Task +Force) to set up a meeting about this/more creative ways to find these cases? I know | +_ would really like to do that as +well, so I'm happy to get the ball rolling if you'd like. Also, +Land I were just chatting with +about something else +and it seems like she gets wind of potential hate crimes in other contexts, so it would be great if she could be looped in +too. (Anyone else? [ +[?) If this sounds okay, please give me some dates over the next couple of weeks that look good +and we'll work it out. Thanks, +Co-Chief, Civil Rights Unit +Assistant United States Attorney +Southern District of New York +86 Chambers Street +New York, New York 10007 diff --git a/vision-fixhub/ds9-parsed-01/22f645cec1f84bc8ec02b296237d10565025a79067b247639e90d40b7290fd69.receipt.json b/vision-fixhub/ds9-parsed-01/22f645cec1f84bc8ec02b296237d10565025a79067b247639e90d40b7290fd69.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..8c991eb7bdc65e1e4edbbe8cf6145cd1cd64d797 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/22f645cec1f84bc8ec02b296237d10565025a79067b247639e90d40b7290fd69.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "22f645cec1f84bc8ec02b296237d10565025a79067b247639e90d40b7290fd69", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "55edd0f643d97fba49a3d9b060bcc3dbe7259c976554d75bb01c2c5608d4c581", + "output_sha256": "eb160ad1e898fa45c4fcf67a3b7b8a784913fb7b95bebf0601cac2d8e27af462", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/22fb5136d515a353f6fda9392d25ec192afec047957168d0ecf899a46136c068.md b/vision-fixhub/ds9-parsed-01/22fb5136d515a353f6fda9392d25ec192afec047957168d0ecf899a46136c068.md new file mode 100644 index 0000000000000000000000000000000000000000..8af69de0d54567b2d82f74f80509f410e35d039b --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/22fb5136d515a353f6fda9392d25ec192afec047957168d0ecf899a46136c068.md @@ -0,0 +1,17 @@ +From: +To: +Cc: +Subject: REl +Date: Thu, 23 Apr 2020 16:33:16 +0000 +We can't stop him, but thanks for the head's up. +From: +Sent: Thursday, April 23, 2020 12:23 PM +To: +Subject: +got time served last week. He told his Probation Officer that media outlets are looking to talk to him about +Epstein. He of course wants to do it because he thinks he can make some money from it. I don't think we can really take +any position on that or forbid him from media contact, but let me know if you guys have any thoughts, and/or if you think +issue (or something we should raise with anyone else). It really won't affect my cases, but to the extent +it will matter to anyone else, there's a chance we'll see him popping up in news stories. +Assistant United States Attorney +Southern District of New York diff --git a/vision-fixhub/ds9-parsed-01/22fb5136d515a353f6fda9392d25ec192afec047957168d0ecf899a46136c068.receipt.json b/vision-fixhub/ds9-parsed-01/22fb5136d515a353f6fda9392d25ec192afec047957168d0ecf899a46136c068.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..9acc16aa5e6a88ad986d3df4de1d0864bfc4335d --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/22fb5136d515a353f6fda9392d25ec192afec047957168d0ecf899a46136c068.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "22fb5136d515a353f6fda9392d25ec192afec047957168d0ecf899a46136c068", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "c38ef916c8c68835d22ee2b6f3700a267f4e5dbfa017666c55bea4df9374e595", + "output_sha256": "a7a58b13d39a8930c149b9d4e3a5c9416fe3bb86df3358d997d1442ed45f8d7c", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2302e965e62abad330f0d46109e154d5003904e64402c0ed506d26ec2c00eab4.md b/vision-fixhub/ds9-parsed-01/2302e965e62abad330f0d46109e154d5003904e64402c0ed506d26ec2c00eab4.md new file mode 100644 index 0000000000000000000000000000000000000000..8c1728ac9c4a3d9fc6ea3f07e944b8267fe3123e --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2302e965e62abad330f0d46109e154d5003904e64402c0ed506d26ec2c00eab4.md @@ -0,0 +1,16 @@ +UNITED STATES GOVERNMENT +MEMORANDUM +Metropolitan Correctional Center, New York, New York +DATE: August 12, 2019 +TO: Warden +FROM: S/O/S +SUBJECT: Passed information from Special Housing Unit +On Friday August 9, 2019 at approximately 1:50 p.m, I S/O/S +passed on to oncoming staff +and present shift staff S/O/S +and Officer +That Inmate +was going WAB and possibly may not return. Also that Inmate Epstein #76318-054 will be +needing a cell mate upon arrival from his attorney visit. + +SDNY_00009482 diff --git a/vision-fixhub/ds9-parsed-01/2302e965e62abad330f0d46109e154d5003904e64402c0ed506d26ec2c00eab4.receipt.json b/vision-fixhub/ds9-parsed-01/2302e965e62abad330f0d46109e154d5003904e64402c0ed506d26ec2c00eab4.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..1d3d1f86512fdc2a5e6b991e956ce920d41a7a6a --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2302e965e62abad330f0d46109e154d5003904e64402c0ed506d26ec2c00eab4.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "2302e965e62abad330f0d46109e154d5003904e64402c0ed506d26ec2c00eab4", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\"]", + "idempotent": true, + "input_sha256": "288a45d75d2fdd22538c022261dc11a7c5f831e5f3b9100d050c3e84d047f944", + "output_sha256": "8a38a886a8ea82402c6b3ac587915c042420fedadbf4e65d3b0156f62e7e6d38", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/23046f0bf713a868ff3e1f64e40067c625678a08f764b9f9999508204f8535c2.md b/vision-fixhub/ds9-parsed-01/23046f0bf713a868ff3e1f64e40067c625678a08f764b9f9999508204f8535c2.md new file mode 100644 index 0000000000000000000000000000000000000000..597a8bea654099b908f1797238375d81e50edcbc --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/23046f0bf713a868ff3e1f64e40067c625678a08f764b9f9999508204f8535c2.md @@ -0,0 +1,99 @@ +From: +To: Gloria Allred < +Cc: ' +D" = +Subject: Re: August 19th +Date: Wed, 14 Aug 2019 02:36:51 +0000 +Inline-Images: image003 jpg; image004 png; image005.png; image006.jpg +Thanks— I'm free tomorrow at 12:30 EST/ 9:30 am PST if that works. +Sent from my iPhone +On Aug 13, 2019, at 7:11 PM, Gloria Allred +• wrote: +Tomorrow morning pacific is fine. What is best for you and which number should | call? +Get Outlook for Android +On Tue, Aug 13, 2019 at 11:32 AM -0700, " +Hi Gloria, +Thanks for reaching out. Do you have time to discuss briefly either today or tomorrow? +Thanks, +> wrote: +From: Gloria Allred < +Sent: Monday, August 12, 2019 10:36 PM +To: +Cc: +>; Diane Aldrich 4 +Subject: RE: August 19th +Good news. Another one of my clients who is an Epstein victim has agreed to fly to New York to meet with you on +August 19 in the afternoon. Is that time period still available? If so what time would work for you? I do have her +driver's license and I know she would like to fly with me on the Delta flight that I am taking on Sunday from L.A. to +New York. If you will have time to meet with her your federal agent who handles travel may contact my assistant, +Diane, tomorrow to arrange the details of my client's trip. +Gloria Allred +Allred, Maroko & Goldberg +Los Angeles, CA 90048 +www.amglaw.com + + +www.gloriaallred.com + + +From: +Sent: Friday, August 9, 2019 8:22 AM +To: Gloria Allred <| +Cc: +Subject: RE: August 19th +Thanks for letting us know. We understand that coming forward is a difficult decision, and we respect that. +From: Gloria Allred < +Sent: Friday, August 9, 2019 11:17 AM +To: +Cc: +Subject: RE: August 19th +Unfortunately, at this point, she has decided that she does not wish to meet with you. I will let you know if she +changes her mind. Thank you for having followed up on this matter. +Gloria Allred +Allred, Maroko & Goldberg +Los Angeles, CA 90048 +www.amglaw.com +www.gloriaallred.com + + +From: +Sent: Friday, August 9, 2019 8:10 AM +To: Gloria Allred < +Cc: +Subject: August 19th +Hi Gloria, +Hop you're doing well. I wanted to follow up on scheduling to see if August 19th at 2 p.m. still works to meet with you +and your client at our office. We're happy to be flexible on timing if you need to make other arrangements. +Thanks, +Assistant United States Attorney +Southern District of New York +New York, NY 10007 + + +This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the +addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED | +THIS COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER +NAMED ABOVE AT +Thank you. +This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the +addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED +THIS COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER +NAMED ABOVE AT +Thank you. +This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the +addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS +COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER NAMED +ABOVE AT I +• Thank you. +'ALLRED, MAROKO A QOLDREND +Best Lawyers +Martindale-Hubbell +Martindale-Hubbell" +AV +PREEMINENT +per Rated for Highest Level 201 +Professional Excellenc +ALLRED, MAROKO & GOLDBERG +2018 +RECOGNIZED BY +Best Lawyers diff --git a/vision-fixhub/ds9-parsed-01/23046f0bf713a868ff3e1f64e40067c625678a08f764b9f9999508204f8535c2.receipt.json b/vision-fixhub/ds9-parsed-01/23046f0bf713a868ff3e1f64e40067c625678a08f764b9f9999508204f8535c2.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..f4714bb31cdae4dca39b6ff15b89e5efb3f0595e --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/23046f0bf713a868ff3e1f64e40067c625678a08f764b9f9999508204f8535c2.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -36, + "dataset": "marble-joined", + "doc_id": "23046f0bf713a868ff3e1f64e40067c625678a08f764b9f9999508204f8535c2", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "a3604e8a31ba7c5dc9be4cd613e4fe49113877da6ce5e97d17db7534ab38b738", + "output_sha256": "5bfe135d213ac8372e85da5fa0bfef0c9cf3d6a4f025837a69f60baa8e16a9c0", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2338913b21033864914eb191d249e80a0fa71cef74f8ac9606d211734e7154b0.md b/vision-fixhub/ds9-parsed-01/2338913b21033864914eb191d249e80a0fa71cef74f8ac9606d211734e7154b0.md new file mode 100644 index 0000000000000000000000000000000000000000..d525eaecf41f686ee1efb114f512078d353790e4 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2338913b21033864914eb191d249e80a0fa71cef74f8ac9606d211734e7154b0.md @@ -0,0 +1,21154 @@ +FD-340 (Rev. 4-11-03) +File Number +3IE-MM-108062/A3 +Field Office Acquiring Evidence +MM +Serial # of Originating Document +JuB-58P - 4 +Date Received +08/15/2006 +From +DAVE RODGERES +AlamaniCaatibutasinterviewee) +reity and State) +To Be Retumed • Yes +A No +Receipt Given +D Yes +Prend y Macia Discinal Coi Pusinto Rico (0) +Federal Rules of Crimufial Procedure +Federal Taxpayer Information (FTI) +• Yes +A No +Title: +Reference: +(Communication Encosing Material) +Description: +Original notes re interview of +JEGE MANIFEST + HyPeRiEn +MaNifest +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000057 + + +JEGE MANIFEST - 2004 & 2005 +3IE-NM-(08862-1A3 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000058 + + +DATE: 2 12.2004 +Type: B-727-31 +FROM JFK +Arrival +Time 11:40 +PM +Pilots: Dave Rodgers, Larry Visoski +Flight Engineer: +Larry Morrison +LFPB +TO +Trip +Number_ +246 +PASSENGERS +1. Jeffrey Epstein +2. Ghislaine Maxwel! +3. VEAN LUK BRUNNEL +4. +5. +6. +7. +8. +9. +10. +11. +12. +13. +14. +15. +16. +17. +18 +19. +FROM Identifier Defined +City. +NEw YORK +State or Country _ +N.Y. +TO Identifier Defined +CiN LE BOURJET (PARiS) +State or Country. +FRANCE +Nautical Miles +3155 +Statute Miles +3628 +CASH +Cations 8027 ev. +ATRFRAME +Pounds 54559 +32860 6 +Flight Time 6 + 35 +6.5 +Alinde FL EL370 32867. 1 +40 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000059 + + +DATE: 2-17 2004 +Dmanue 9.50 +Timo +PASSENGERS +1. Jeffrey Epstein +2. Ghislaine Maxwell +Type: B-727-31 +FROM LFPB +Amia 10 34 +Pilots: Dave Rodgers, Larry Visosk +Flight Engineer. +Larry Morriso +TO +BGR +Timor. 247 +JEAN LUC BRUNEL +7. +8. +9. +10. +11. +12. +13. +14. +15. +16. +17. +18. +19. +FROM Identifier Defined +City +PARIS +State or Country +FRANCE +TO Identifier Defined +City +BANGOR +Statc or Country +ME +Nautical Miles +2384 +Statute Miles_ +2742 +30943 L +Callons 874 +Pounds 56772 +Flight Time G H3 +Altitude Ft 300 +32867 1 +67 +32873.8 +61 +63 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000060 + + +Type: B-727-31 +DATE: 2-17.2004 +De 11:17 CM +PASSENGERS +1. Jeffrey Epstein +2. Ghislaine Maxwell +3. +4. +FROM BGR +Arrival +Time +12.25 +5. JEAN LUC BRUNEL +PM +Plies needers Larry orrison +Flight Engineer: +To JFK +Trip +NoT 248 +7. +8. +9. +10. +Il. +12. +13. +14. +15. +16. +17. +18. +19. +FROM Identifier Defined +City +BANGOR +State or Country +ME +TO Identifier Defined +City NEW YORK +State or Country. +NY +Nautical Miles +332 +Statute Miles +382 +Gallons 2277 +Pounds 10837 +Flight Time 1.07 +Atitude FE 310 +32873 8 + +L1 +Approach ILS +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000061 + + +DATE: 2 12 2001 +a 8:19 +AM +PASSENGERS +1. Jeffrey Epstein +2. +Type: B-727-31 +Pigs Engine Rogers, ry riski +Flight Engineer: +FROM J.E.K. +TO_ +Arrival +Time 10:27 eN +Trip +Number +RBI. +249 +3. BRENT TINDALL +6. +7. +8. +9. +10. +11. +12. +13. +14. +15. +16. +17. +18. +19._ +FROM Identifier Defined +City. +NEw York +State or Country _ +N.Y. +TO Identifier Defined +cir: WEsT PALM BEACh +State or Country +F.L +Nautical Miles +893 +Statule Milcs +1027 +Gallons 2318 +Pounds 18|32 +32874 9 +Flight Time 2+07 +21 +Altitude FL. FL 350328770 +21 +11 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000062 + + +DATE: 222,2004 +Type: B-727-31 +FROM PBI +Arrival +Timo +918 +Pies give Reders Arry torriski +Flight Engineer: +•TO_ JFK +Trip +PM +Number +250 +PASSENGERS +1. Jeffrey Epstein +2. +3. BRENT TINDALL +G. +1. FEMALE +8.- +FEMALE +• FEMALE +10. +11. +12. +13. +14. +15. +16. +17. +18. +19. +FROM Identifier Defined +City WEST PALM BEAcH +State or Country +FL +TO Identifier Defined +City NEW YORK +State or Coultry. +NY +Nautical Miles +893 +Statute Milcs +1027. +Gallons 2933 +Pounds 19071 +32817 ° +Flight Time 2 +09 +2.2 +Altitude FI 370 +32879.2 +2.0 +JL +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000063 + + +DATE: 2-24.2004 +pea 12:51 AM +PASSENGERS +1. Jeffrey Epstein +2. +3. +4 +5.. +G. * +7. +8. +9. = +10. +11.% +12. - +13. +14._ +15. +16.: +17.. +18. +19. +Type: B-727-31 +Pilots: Dave Rodgers, +Flight Engineer: +Larry Morion +FROM JFK. +TO +Arrival +Trip +Mey. +Time +3.29 C Mambor. +251 +FROM Identifier Defined +City. +New York +State or Country. +N.V. +TO Identifier Delined +A MANTRY CA +State or Couhiry. +Nautical Miles +2245 +Statute Milles +2582 +ens. +sallons 6/46 zv +Pounds 46810 32879 +2 +Flight Time +5+31 +5 +Altitude I. EL 390 3288 Y 8 +20._ +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000064 + + +DATE: 2 27 2004 +Type: B-727-31 +FROM MRY +Amal 1 +Time +AM +PM +Pilots:_ Dave Rodgers, _ Larry Visoski +Flight Engincer: +Larry Morriso +TO VNY +Trip +Numbor 252 +PASSENGERS +1. Jeffrey Epstein +2. +3. +4. +3. I MALE +6.... +7. +8. +9. +10. +11. +12. +13. +14. +15. +16. +17. +18. +19. +FROM Identifier Defined +Cy MONTEREY +State or Country +CA +TO Identifier Defined +Cit VAN NUIS +Siaic or Country _ +CA +Nautical Miles +218 +Statute Miles +251 +Gallons_1020 +Pounds +6371 +Flight Time: ++35 +Altitude FL 270 + +6 + +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000065 + + +DATE: 2 29.2004 +2.11 +PASSENGERS +1. 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Jeffrey Epstein +2. +3 GHISLAŁNE MAXWELL +4 +5 +6. +7. +8. +9. +10. +11. +12. +13. +14. +15. +16. +17. +18. +19. +FROM ARQ +Arrival +Time +9 .37 AN +Trip +Number +254 +FROM identifier Defined +City_ALBUQUERQUE +State or Country +NM +TO Identifier Defined +city NEw YORK +Stale or Country +NY +Nautical Miles +1586 +Statute Milcs +1824 +Gallons 4003 MERcUR +Pounds 24831 + +Flight Time 3 +04 +3.1 +Altitude F1 310 32889.8 +Night _ +16 +3 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000067 + + +DATE: 3-3.2004 +De 9: 10 ฿ +PASSENGERS +1. Jeffrey Enstein +2. +3. +4. VALDSON +5. +6... +7. +8. +9. +10. +11. +12. +13. +14. +15. +16. +17._ +18._ +19. +Type: B-727-31 +FROM JFK +TO. +Ama 1:23 Timbor +Pilots: Dave Rodgers, Larry Visost +Flight Engineer. +Larry Morriso +PBI +255 +FROM Identifier Defined +air_ NEw York +State or Country _ +N.Y. +TO Identifier Defined +Cily WEST PALM BEAch +State or Country +Nautical Miles +893 +Statule Miles +1027 +Gallons 1967 +Pounds 19198 +32889.8 +Flight Time 2+13 +'2a +Altitude Fl E2350. 32897 0 +22 +TAL +Approaci +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000068 + + +DATE: 3 31 2004 +Da 11: 55 AM +PASSENGERS +1. 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JEAN LUK BRUNNEL +5. 1 FEmALE +Type: B-727-31 +FROM JEK +A 11:03 AM +Time +Pilots: Dave Rodgers, Larry Visoski +Flight Engineer. +Larry Morrison +TO_ +Trip +Number. +P.BI. +257 +7. +8. +9.- +10. +11. +12. +13. +14. +15. +16. +17. +18. +19.— +FROM Identifier Defined +City _ +NEW YORK +State or Country +Kiy +TO Identifier Defined +diy WEST PALm Bch +State or Country +F.L. +Nautical Miles +893 +Statute Miles +1027 +Gallons 2003 +Pounds 20346 328940 +Ftight Time 2+13 +22 +Altitude 51_ EL 35032896 2 +22 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000070 + + +DATE: 4-11,2004 +Depare 2:17 AM +PASSENGERS +1. Jefffrey Epstein +2. Ghislaine Maxwell +3. Brent Tindall +4. +5. +6. +7. +8. +9. +10 +1. NANNY +12. 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LARRY SUMMERS +4. +5. +6. +7. +8. +9. +10. +11. +12. +13. +14. +15. +16. +17. +18. +19. +FROM Identifier Delined +City_ NEW YORK +State or Country_ +NY +TO Identifier Defined +City BEDFORD +State or Country +MA +Nautical Miles +147 +Statute Miles +169 +Gallons +Pounds 6727 +32898 +Flight Time. ++37 +Attitude FL 170 +32898 +3 +6 +9 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000072 + + +DATE: 416,2004 +Type: B-727-31 +FROM BED +Arrival +Time +4.084 +ilots: Dave Rodgers. Larry Visost +light Engine +Larry Morrison +To PBJ +Trip +) Number +260 +PASSENGERS +1. Jeffrey Epstein +2. +3._ +4. +5. +6. +7. +8. +9. +10. +11. +12. +13. +14. +15. +16. +18. +19. +FROM Identifier Defined +CiY BEDFORD +State or Country . +MA +TO Identifier Defined +ciy WEST PALM BEACH +State or Country +FL +Nautical Miles +1040 +Statute Miles +1196 +Gallons 3213 +Pounds 19608 +Flight Time 2+20 +Altitude FL 390 +32898 9 +23 +32901.2 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000073 + + +DATE: 4.19.2001 +eparture +m3:45PM +PASSENGERS +1. Telirey Enstein +2. +3. +4. 2 FEmale +5. +6. +7. +8. +9. +10. +11. +12. +13. +14. +15. +16. +17. +18 +19. +Type: B-727-31 +FROM PBI +Arrival +Timc +6:06 (M +Pilots: Dave Rodgers, Larry Visosk +Flight Engineer: +Larry Morrisor +TO +JFK +Trip +Numbor _ 261 +FROM Identifier Defined +City WEST PALM BEAch +State or Country. +FL. +TO Identifier Defined +air Jeha F. KENNEDy +State or Country. +N.y +Nautical Miles +893 +Statute Miles +1027 +Gallons 2170 +Pounds 19531 +32901 2 +Flight Time 2+20 +23 +Altitude FL FL370 329 03 5 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000074 + + +DATE: 422,2001 +терати 8:09 АМ +PASSENGERS +1. Jeffrey Epstein +2. Ghislaine Maxwell +3. +4. Brent Tindall +$. MARK EPSTEIN +6. +7. +8. HoUsE KEEPER +9. HOUSe KEEPER +10. MALE +11. MALE +12. MALE +13. +14. +15. +16. +17. +18. +19.- +Type: B-727-31 +FROM JFK +Arrival +Tima 10 2| +Pilots: Dave Rogers, +Larry Visoski +Flight Engineer: +Larry Morrison +PBI +TO +Trip +> Number +262 +FROM Identifier Defined +city NEW YORK +State or Country +NY +TO Identifier Defined +Cy WEST PALM BEACH +State or Country +FL +Nautical Miles +893 +Statute Miles +1027 +Gallons 2610 +Pounds 19580 +32903 5 +Flight Time 2 +12 +23 +Altitade FL 350 +32905.7 +11 +• T/L +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000075 + + +. JEGE, INC. +DATE: 4 27,2004 +Departure +me 11:07 +PASSENGERS +1. Jeffrey Epstein +2. Brent Tindall +3. +4. +5. +6. +7. +8. +9. +10. +11. +12. +13. +14. +15 +16. +17. +18. +19. +Type: B-727-31 +FROM PBI +Arrival +Time +Pigs Engine Rodgers, Larry Morist +Flight Engineer +TO. +VEK +1.04 PM Timber 263 +FROM Identifier Defined +Cir WEST PAlM BEAch +State or Country. +FL +TO Identifier Defined +Gily NEW YORK +State or Country +Ny. +Nautical Miles +893 +Statute Milcs +1027 +Gallons 3252 +Pounds 16628 +Flight Time_1+56 +Altitude FL EL 370 + +20 +32907.7 +25.0 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000076 + + +DATE: 5-1 +- 2004 +pa 8.53 AM +PASSENGERS +1. Jeffrey Epstein +2 +3. +Type: B-727-31 +Flight Engineer: +FROM JFK +To PBI +Arrival +Trip +Time +11.07 PM Number. +264 +6. +7. +8. +9. +10. +12. +13. +14. +15. +16. +17. +18. +19. +FROM Identifier Defined +City NEW YORK +State or Country _ +NY +TO Identifier Defined +city WEST PALM BEACH +State or Country +fL +Nautical Miles +893 +Statute Miles _ +1027 +Gallons 7991 CASH AIRFRAME +Pounds 21784 32907 7 +Flight Time 2 + 13 +2.2 +Alinde F1 350 32909.9 +Night_ +23 +11 +22 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000077 + + +Registration Number: N9O8JE +DATE: 5 4 2004 +Dept 4:4585 +PASSENGERS +1. Jeffrey Epstein +2. +3. +4. +5. +6. +7. +8. +9. +10. +11. +12. +13. +14. +15. +16. +17._ +18. +19. +Type: B-727-31 +Pigs agine Rodgers any rison +Flight Engincer: +JFK +FROM PBI +TO_ +Arrival +Time +6.5/PM +Trip +Number +265 +FROM Identifier Defined +City ... +WEST FALM BEACh +State or Country +EL +TO Identifier Defined +City _ +NEw +YoRk +State or Country +N.Y. +Nautical Miles +893 +Statute Miles +1027 +Gallons O +Pounds 17844 + +Flight Time 2+06 +21 +Alide FL EL 370 3291 2.0 +Night 32909.9 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000078 + + +Type: B-727-31 +DATE: 5 5,2001 +Dear 10:20 PM +PASSENGERS +1. Jeffrey Epstein +2. Ghislaine Maxwell +FROM JFK +Anil 11:00 +Time +Pilots: Dave Rodgers, Larry Visoski +Flight Engineer. +Larry Morrison +TO. +_LFPB +Trip +Number 2,66 +City +FROM Identifier Defined +NEW YORK +NY +3. +4. +6. +T. +8. +9. +State or Country +TO Identifier Defined +s. ARIANE DEVONVOISIN +City +PARIS +State or Country +FRANCE +Nautical Miles +3|55 +Statute Miles +3628 +Gallons 8337 CASH DR +Pounds 56204 329120 +11. +12. +Flight Time 6+39 +Alride EL 370 +13. +14. +15. +16. +17. +18. +19. +22-0 + +3 +25 +Approach ILS +2210 GALLONS WAS FROM DEFUEL +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000079 + + +DATE: 5 - 8 2004 +a 7-25 +Time +PASSENGERS +1. Jeffrey Epstein +2. Ghislaine Maxwell +3. +4. +5. +6. +7. +8. +9. +Type: B-727-31 +Pigs Engine Rodgers, Larry Morrisor +Flight Engineer +FROM LEPB +TO +ESSW +Arrival +Time +7:13 (M Tiber +267 +11.. +12. +13. +14. +15. +16. +17. +18. +19. +FROM Identifier Defined +City +LE BOURJET +State or Country +FRANCE +TO Identifier Defined +City +LUTON +State or Country +U.K. +Nautical Miles +205 +Statute Miles +236 +Gallons /107 GALS +Pounds 8157 +32918, 6 +Flight Time 47 +7 +Altitude Tr EL200 32 919. 3 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000080 + + +DATE: 5-10.2004 +Type: B-727-31 +Pilots: Dave Rodgers, _ Larry Visoski +Flight Engineer: +Larry Morrisor +FROM EGGW +To LKPR +Arrival +Timo +8.03 AM +Trip +Number_ +268 +PASSENGERS +1. Jeffrey Epstein +2. Ghislaine Maxwell +3. +4. +5. +6. +7. +8. +9. +10. +11. +12. +13. +14. +15. +16. +17. +18. +19. +FROM Identifier Defined +City - +LUTON +State or Country_ ENGLAND +TO Identifier Defined +City - +PRAGUE +State or Country .... +CZECH +Nautical Miles +564 +Statute Miles +649 +Gallons +8300- 2193 AIRPRAME +Litres 8300 + +Flight Time +1,30 +15 +Altitude FL. 330 + +Pounds 13620 +21.0 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000081 + + +DATE: 5-12, 2001 +De 2.27 +PASSENGERS +1. Jeffrey Epstein +2. Ghislaine Maxwell +3. +4. JEAN LUK BRUNNEL +5. +6. +7. +8. +9. +10. +IL +12. +13. +14. +15. +16. +17. +18. +19. +Type: B-727-31 +Pilots: Dave Rodgers, Larry Visoski +Flight Engineer. +Larry Morrisor +FROM LKPR +TO +LEPB +Arrival +Time +341 +A Timbor_ 269 +FROM Identifier Defined +PRAGUE +state or conty_ (zEch Rep. +TO Identifier Defined +City - +jE BOURSEt +State or Country +FRANCE +•Nautical Miles +466 +Statute Miles +536 +Galtons 2/37 +Pounds 1162/ +32920 8 +Flight Time_/+14 +12 +Altitudo Fl FL300 32922 0 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000082 + + +DATE: 5-14.2004 +Date 6:17 +PASSENGERS +1. Jeffrey Epstein +2. +Type: B-727-31 +FROM LFPB +Arrival +Time +7:15 +its gene Roder, any Writer +TO. +Trip +Number +CYQX +270 +6 +7. +8. +9. +10. +11. +12. +13. +14. +15. +16. +17. +18. +19. +FROM Identifier Defined +City _ +PARIS +State or Country +FRANCE +TO Identifier Defined +City - +GANDER +State or Country NEWFOUNDLAND +Nautical Miles +2200 +Statute Miles +2530 +Gallons_ 8175 +Littes 30947 +32122. 0 +Flight Time 5.28 +Altitude FL. 340 +Pounds 47976 +21.- + +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000083 + + +DATE: 5 14 2004 +Pipe 7:56 +PASSENGERS +1. Jeffrey Epstein +2. +3. +4. +5. +6. +7. +8. +9. +10. +11. +12. +13. +14. +15. +16. +17. +18. +19. +Type: 8-727-31 +FROM CYQX +Pilots: Dave Rodgers,_ Larry Visoski +Flight Engineer. +Larry Morriso +то PBI +Number +271 +FROM Identifier Defined +City GANDER +State or Country NEWFOUNDLAND +TO Identifier Defined +City WEST PALM BEACH +State or Country +FL +Nautical Miles +1837 +2|13 +e12590 +LITRES +Gallons 3326 +Pounds 31040 +Flight Time_ 4+00 +Altitude Fz 380 +32927 5 +40 +32931.5 +Night. +TAL +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000084 + + +DATE: 6-13,2004 +Departure 4:08 AM +PASSENGERS +1. Jeffrey Epstein +2. +3. GossmAN +4. +5. +6. +7. +8. +9. +10. +11. +12. +13. +14. +15. +16. +17. +18. +19. +Type: B-727-31 +FROM PBI +Arrival +Time +618 +Piles nine Rodgers, any riski +Larry Morrison +TO +JFK +eN Number 272 +FROM Identifier Defined +diy WEST PAlm Bench +State or Country - +FL +TO Identifier Defined +City +New yoRk +State or Country +Nautical Miles +893 +N.y +Statute Miles +1027 +Gallons 3106 +Pounds 18901 +32931 5 +Flight Time 2 +09 +22 +Altitude FL EL 370 32933.7 +TIL +26.- +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000085 + + +DATE: 6-15.2001 +Дератит 9.07 +PASSENGERS +1. Jeffrey Epstein +2. +3. +4. Brent Tindall +5. +6. +1. MALC +8. MALE +9. FEMALE +10. +IL. +12. +13. +14. +15. +16. +17. +18. +19. +Type: B-727-31 +Pilots: +Flight Engineer: +FROM JFK +_ To TIST +A 12:178 Mint 273 +FROM Identifier Defined +City NEW YORK +State or Country +NY +TO Identifier Defined +City +ST. THOMAS +State or Country +USVI +Nautical Miles +1410 +Statute Miles +1622 +Gallons 3935 +Pounds 26080 +32933 +Flight Time 3+09 +3.1 +Altitude Fr 370 +32936.8 +20._ +3 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000086 + + +DATE: 6 20 2001 +manure 3 58 PM +PASSENGERS +1. Jeffrey Epstein +2. +3. +1 BRENT TINDALL +5. +6. +7. +8. +9. +10. +11. +12. +13. +14. +15. +16. +17. +18. +19. +Type: B-727-31 +FROM TIST +Time +GARY ROXBURGH +Pigs name Rodgers Larry Morrisor +Flight Engineer. +TO_ +PBI +Trip +Number +274 +FROM Identifier Defined +CiS ST. THOMAS +State or Country _ +USVI +TO Identifier Defined +City WEST PALM BEACH +State or Country +FL +Nautical Miles +976 +Statute Miles +1122 +Gallons 2965 +Pounds_ 19298 +32936 8 +Flight Time 2+16 +2.2 +Altide FL 390 +32939.0 +22 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000087 + + +DATE: 7-19 2001 +pan 5:35 AN +PASSENGERS +1. Jeffrey Epstein +2. +3. BRENt TiNDALL +4. +5. 17cmalE +6. 17EmAlE +1. 176mAlE +8. +9. +10. +11. +12. +13. +14. +15. +16. +17. +18. +19. +Type: B-727-31 +FROM PBI +TO_ +Arrival +Time +7:58 AM Number. +arry Morriso +TIST +275 +FROM Identifier Defined +City WEST +State or Country. +PAlm BEach +FL +TO Identifier Defined +air St. Thomas +State or Country. +USVI. +Nautical Miles +976 +Statute Miles +122 +Gallons 3410 +Pounds 20183329390 +Flight Time 2+22 +'23 +Altitude 71 FL 370. 329 41 3 +Night. +LO +Approach FLS +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000088 + + +DATE: 7 22.2004 +Dean 7 :26 +PASSENGERS +1. Jeffrey Epstein +2. +3. +4. Brent Tindall +5. +6. +7. +8. +9. +10. +11. +12 +13. +14. +15. +16. +17. +18. +19. +Туре: B-727-31 +FROM TIST +- то +Arrival +Timc +9.50M Timber +Pilots: Dave Rodgers, +Flight Engineer: +PBI +276 +STEVE MILLER +Larry Morriso +FROM Identifier Defined +cily ST. THOMAS +State or Country_ U SVI +TO identifier Defined +ay WEST PALM BEACH +State or Country +FL +Nautical Miles +976 +Statute Miles +1122. +Gallons 2775 +Pounds 19967 32941 +_3 +Flight Time 2 24 +2.4 + +22- +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000089 + + +DATE: 1.25.2004 +De 4 35 AM +PASSENGERS +1. Jeffrey Epstein +2. Brent Tindall +3. +4. +6. +5. JEEMALE +7. +8. +9. +10. +11. +12. +13. +14. +15. +16. +17. +18. +19. +Type: B-727-31 +FROM PRI +Arrival +Timo +6 36 +PM +STEVE MILLER +Pilots: Dave Rodgers, Jarry Visoski +Flight Engineer: +Larry Morrison +то JFK +Trip +Numbor +277 +FROM Identifier Defined +WESTPALM BEACH +City +State or Country +EL +TO Identifier Defined +City _ +NEW YORX +Staic or Country +NY +Nautical Miles +893 +Statute Miles +1027 +Gallons 3261 +Pounds 19810 + +Flight Time 2+00 +2 +Altitude FL. _ +330 +32495 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000090 + + +DATE: 7-29.2004 +Departure +Time +11:06 M +PASSENGERS +1. Jeffrey Epstein +2. +3. +4. +5. +6. +7. +8. +9. +10. _ +11. +12. +13. +14. +15. +16. +17. +18. +19. +Type: B-727-31 +FROM JFK +Arrival +Time +11:30 +Pilots: Dave Rodgers,_ Larry Visoski +Flight Engineer: +Larry Morrison +TO +AM +Trip +Number +LFPB +278 +FROM Identifier Defined +City +New York +State or Country - +_N.X. +TO Identifier Defined +City +LE BOURgET +State or Country. +FRANCE +Nautical Miles +3|55 +Statute Miles +3628 +ZV. CASH" +Gallons 7958 +Pounds 52699 + +Flight Time _6+24 +'6:4 +Altitude F1_ FL370 329 57.1 +40 +24. - +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000091 + + +DATE: 8 3 2001 +Dea 9 52M +PASSENGERS +1. Jeffrey Epstein +Type: B-727-31 +Pilots: Dave Rodgers +Flight Engineer +FROM LFPB +TO LEPA +Arrival +AM Trip +Time 11 245 +Number +279 +Larry Visosk +arry Morriso +3 +4 +5. +6. +7. +8. +9. +10. +11. +12. +13. +14. +15. +16. +17. +18. +19. +FROM Identifier Defined +City +PARIS +State or Country _ +FRANCE +TO Identifier Defined +Cy PALMA DE MALLORCA +State or Country _ +SPAIN +Nautical Miles _ +565 +Statute Miles +650 +Gallons 1457 +Lites 5515 32952.1 +Flight Time 1 +32 +15 +Attitude 1 370 32953.6 +Pounds 13375 +22- +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000092 + + +DATE: 8.3 +→ 2004 +Type: B-727-31 +Pigs are Rodgers any Worried +Flight Engineer: +FROM LEPA +To LPAZ +Arrival +Trip +Time +6.54 AM Number +280 +PASSENGERS +1. Jeffiey Epstein +2. +3. +6. +8. +9. +10. +11. +12. +13. +14. +15. +16. +17. +18. +19. +FROM Identifier Defined +ciry PALMA DE MALLORCA +State or Country +SPAIN +TO Identifier Defined +City _ +SANTA MARIA +State or Country_ AZORES +Nautical Miles +1323 +Statute Miles +152) +Gallons 4630 +Litres 17527 +32953 6 +Flight Time 3+17 +33 +Altitude FL 380 +32956.9 +Pounds 27201 +MC . +Approach VOR +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000093 + + +DATE: 8.3 +_ 2004 +Depare 8:11 A +PASSENGERS +1. Jefffrey Epstein +2. +3. +4. +5. +6. +7. +8. +9. +10. +Type: B-727-31 +ilots: Dave Rodgers,_ Larry Visosk +Flight Engineer: +arry Morriso +FROM LPAZ +TO TIST +Arrival +Time +9.32 AM Number. +281 +12. +13. +14. +15. +16. +17. +18. +19. +FROM Identifier Defined +City SANTA MARIA +State or Country AZORES +TO Identifier Defined +City +ST. THOMAS +State or Country_USVI +Nautical Miles +2372 +Statute Miles +2728 +Gallons 6781 +Litres 25668 +32956 9 +Flight Time S +21 +54 +Atitude Fre 360 + +Pounds 45015 +24 +11 +2.4 +22 +Approach ILS +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000094 + + +GARY ROXBURGH +arry reste +DATE: 8 +-- 6 2004 +Dater 8:12 +PASSENGERS +1. Jeffrey Epstein +2. +3. +4. +5. +6. +7. +8. +9. +10. +11. +12. +13. +14. +15. +16. +17. +18 +19. +Type: B-727-31 +FROM TIST +Amal 10:250M +Trip +Time +> Number +282 +FROM Identifier Defined +City .. +ST. THOMAS +State or Country_U SVI +TO Identifier Defined +city_ WEST PALM BEACH +State or Country +FL +Nautical Miles +976 +Statute Miles +1122 +Gallons 3011 +Pounds 18715 +Flight Time +2+13 +Altitude FL +390 +32962 +3 + +2.2 +18 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000095 + + +DATE: 8-10.2004 +Departure +(AM) +rime 20:23 +_PM +PASSENGERS +1. Jeffrey Epstein +2. +4. LYNN +5. +6. +7. +8. +9. +10. +11. +12. +13. +14. +15. +16. +17._ +18. +19. +Type: B-727-31 +Ple nine rolers, arry rising +FROM PBI +TO JFK +Arrival +Time +12.28RM Timber. +283 +FROM Identifier Defined +City WEST +PALM BEACh +State or Country _ +EL +TO Identifier Defined +City +NEW YORK +State or Country +N.Y. +Nautical Miles +893 +Statute Miles +1027 +Gallons 3386 +Pounds 18353 + +Flight Time 2+05 +Alinder_ +2370 32966-6 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000096 + + +DATE: 8-13,2004 +Type: B-727-31 +FROM JFK +Arrival +Time +7:29 A +Pigh gane Rodgers, ary Worrison +Flight Engincer +Trip +Number +284 +PASSENGERS +1. Jeffrey Epstein +2. +3. +4. DAVID +7. +8. +9. +10. +11. +12. +13. +14. +15. +16. +17. +18. +19. +FROM Identifier Defined +Cily NEW YORK +State or Country _ +NY +TO Identifier Defined +City ALBUQUERQUE +State or Country. +NM +Nautical Miles +1452 +Statute Miles +1670 +Gallons 4144 OR CASH +Pounds 31718 +32966 +Flight Time 3 +53 +39 +Attitude FL 350 + +MC — +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000097 + + +DATE: 8 +-18 2001 +7:14 0 +PASSENGERS +1. Jeffrey Epstein +Type: B-727-31 +Pilots: Dave Rodgers, Larry Visoski +Flight Engineer: +Larry Morrison +TROM ABQ +To_VNY +Arrival +Timo +746( +Trip +Numbor +285 +4. +5. +6. +7. +8. +9. +10. +11. +12. +13. +14. +15. +16. +17. +18. +19. +FROM Identifier Defined +Cy_AL BUE@URQUE +State or Country _ +N.M. +TO Identifier Defined +air VANNUYS +State or Country +C.A. +Nautical Milles +590 +Statule Miles +679 +Galons_ (000+MEACUM TRERAME +Pounds 12621 329705 +Fligh Time / +3/ +1'5 +Altitude fs F1390329720 +Approaca +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000098 + + +DATE: 8.19.2001 +Type: B-727-31 +FROM VNY +Arrival +Time +4.50 +FRANK GAMBLE +Pilots: Dave Rodgers, +Flight Engineer: +Larry Morrison +то _ +PBI +Trip +Number +286 +PASSENGERS +1. Jeffrey Epstein +2.1 +3. +5. +6. +7. +8. +9. +10. +11. +12. +13. +14. +15. +16. +17. +18. +19. +FROM Identifier Defined +City_ VAN NUYS +CA +State or Country +TO Identifier Defined +Cy WEST PALM BEACH +State or Country +FL +Nautical Miles _ +2029 +Statute Miles +2333 +Gallons 5201 +Pounds 35559 329720 +Flight Time 4+26 +4.4 +AMitude F1 370 329764 +Night- +44 +1.6 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000099 + + +DATE: 8 242001 +Ta 10:51 +Time +PASSENGERS +1. Jeffrey Epstein +2. Ghislaine Maxwell +3. +4. +5. +6. +7. +8. +9. +10. +11. +12. +13. +14. +15. +16. +17. +18. +19. +Type: B-727-31 +Pilots: Dave Rodgers, Larry Visoski +light Engineer +Larry Morrison +FROM _ +PBT +TO SEGU +Arrival +Time +144(2 +Trip +Numbor +287 +City +State or Country +FROM Identifier Defined +WEST PALM BEAch +FL +TO Identifier Defined +State or Country +Nautical Miles +Statute Miles +1723 +1981 +Gallons 8421 +Pounds 35353 + +Flight Time 3+52 +3 2 +Altitude FL C390 3298 0 3 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000100 + + +DATE: 8-25.2001 +a 12:23 PM +PASSENGERS +1. Jeffrey Epstein +2. +3. +4. GHZSLAZNE MAXWELL +5. +6. +7. +8. +9. +10. +11. +12. +13. +14. +15. +16.— +17. +18. +19. +Type: B-727-31 +FROM SEGU +TO +Arrival +Time +5.31 AM Number. +Pilots: Dave Rodgers. +Flight Engineer +Larry Visosl +Larry Morriso +288 +FROM Identifier Defined +Cily GUAYAQUIL +State or Country ECUADOR +TO Identifier Defined +cir WEST PALM BEACH +State or Country +FL +Nautical Miles +1723 +Statute Miles +1981 +Gallons 1635 +Pounds 33175 +32980 +Fight Time 4+08 +4 +1 +Attitude FL 390 +_32984.4 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000101 + + +DATE: 9-1 2004 +repartar +ime 5-56 e +PASSENGERS +1. Jeffrey Epstein +2. +3. +4. +5. +6. +7. +8. +9. +10. +11. +12. +13. +14. +15. +16. +17. +18. +19. +Type: B-727-31 +FROM +PB.I. +Anival 8 56 eM Number_ +Pilots: Dave Rodgers, _ Larry Visoski +Flight Engineer: +Larry Morrisor +TRS.T. +289 +FROM Identifier Defined +City_ WEST PAU BEACh +State or Country +FL. +TO Identifier Defined +city_ ST. ThomAs +State or Country +U.S.V.I. +Nautical Miles +976 +Statute Miles +1122 +Gallons 2136 +Pounds 23978 +32984 · +Flight Time 3+00 +30 +Atitude 51 EL410 329874 +20 +11 +-- +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000102 + + +DATE: 9-5.2004 +a 5:01 AM +PASSENGERS +1. Jeffrey Epstein +2. +Type: B-727-31 +FROM TIST +Arrival +Time +8.35 +Pilots: Dave Rodgers, Larry Visoski +Flight Engineer: +RALPH PASCALE +To JFK +Trip +Number +290 +6. +7. +8. +9. +10. +11.. +12. +13. +14. +15. +16. +17. +18 +19. +FROM Identifier Defined +City ST. THOMAS +State or Country USVI +TO Identifier Defined +City NEW YORK +State or Country +NY +Nautical Miles +1410 +Statute Miles +1622 +Gallons 4037 +Pounds 28712 +32987 +Flight Time 3+32 +3 5 +Altitude FL_ FL380 + +1S +MC — +1t +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000103 + + +DATE: 9-/6.2004 +Depare 8:05 AM +PASSENGERS +1. Jeffrey Epstein +2. +3.. +4. +5. +6. +7. +8. +9. +10. +11. +12. +13. +14. +15. +16. +17. +18. +19. +Type: B-727-31 +FROM JFK +Arrival +Time +10:16 +Pilots: Dave Rodgers, +Flight Engineer: +Larry Visosk +arry Morriso +- TO +Trip +Number +PB.I +291 +FROM Identifier Defined +City —_ +NEW YORK +State or Country +N.Y. +TO Identifier Defined +City __. +WEST +PALm BEAch +State or Country +FL. +Nautical Miles +893 +Statute Miles +1027 +DAUE +Gallons_ 3048 cAsA AIRFRAME +нил 19301 379902 +Flight Time 2+1/ +Alinde FL F2390 32993 1 +2.2 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000104 + + +DATE: 9-19.2001 +DeaL 2:36 +PASSENGERS +1. Jeffrey Epstein +2 +Type: B-727-31 +FROM PBI +Arrival +Time +9498 +«оку 20) +Pilots: +Dave Rodgers +Flight Engineer: +PHL +TO +Trip +Number +292 +Larry Visoski +Larry Morrison +4. +5. +6. +7. +8. +9. +10. +11. +12. +13. +14. +15. +16. +17. +18. +19. +FROM Identifier Defined +Cir_ WESt PALm BEAch +State or Country +FL +TO Identifier Defined +air PhiliDelphia +State or Country +Đ.A +Nautical Miles +826 +Statute Miles +950 +Gallons 3908 +Pounds_ 19207 +37993.1 +Flight Time 2 + 12 +22 +Alindo FL 2370 3299 5.3 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000105 + + +DATE: 9-19.2004 +pa 2:46 +Time +PASSENGERS +1. Jeffrey Epstein +2. +3. +4. +5. +6. +7. +8. +9. +10.- +11._ +12.- +13.- +Type: B-727-31 +FROM PHL +Arrival +Time +3 12 +Pilots: +Dave Badgers +Larry Visaski +Flight Engineer: +Larry Morrison +To VER +104, +Trip +PM) +Number +293 +15. +16. +17.1 +18. +19. +FROM Identifier Defined +City +PhiliDelphia +State or Country +P.A +TO Identifier Defined +City_ +WEar yoRk +State or Country. +Nautical Miles +93 +Statute Miles +Gallons E +Pounds +·900 + +Flight Time ++25 +Alitude F_ [110 32995.7 +|24. +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000106 + + +DATE: 923,2001 +pop 8 55( +PASSENGERS +1. Jeffrey Epstein +2-5 +Type: B-727-31 +FROM JEK +Arrival +Time 12:16 +W-Johuson +Pilots: -Đave Rodgets, +Larry Visoski +Flight Engineer: +Larry Morrison +TO +Trip +Number +TIST +294 +5. +6. +7. +8. +9. +10. +11.. +12. +13. +14. +15. +16. +17. +18. +19. +FROM Identifier Defined +City +NEW YORK +State or Country +N.Y. +TO Identifier Defined +City _ +St. ThomAs +State or Country +U.S.V.I +Nautical Miles +1410 +Statute Miles +1622 +Gallons LV.CASH 4028 +Pounds 26990 + +Flight Time 3 20 +33 +Altudo Fi_ 23903299 9 0 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000107 + + +DATE: 10.22004 +Time +D 7:32 +PASSENGERS +1. Jeffrey Enstein +2. +3. +4. DAVIO MULLEN +5. +6. +7. +8. +9. +10. +11. +12. +13- +14. +15. +16. +17. +18. +19. +Type: B-727-31 +FROM TIST +Arrival +Timo +8490 +Pilots: Dave Rodgers, Larry Visoski +Flight Engineer: +Larry Morrison +TO- +Trip +Number +P.BI. +295 +FROM Identifier Defined +cily_ St. ThomAs. +State or Country _ +UIVE +TO Identifier Defined +CiN WEST PALm Borch +State or Country +FL +Nautical Miles +976 +Statule Miles +1122 +Gallons 4130 +Pounds 20385 +32999 0 +Flight Time 2+17 +'23 +Altado FL E L 350 33.00/ 3 +2.3 +LL +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000108 + + +DATE: 10-S 2004 +Departure 8:02 +AM +PASSENGERS +1. Jeffrey Epstein +2. +3. +4. +5. +6. DAVIO MULLEN +7. +8. +9. +10. +11. +12. +13. +14. +15. +16. +17. +18. +19. +Type: B-727-31 +Pilots: +Flight Engineer: +FROM PBI +to JFK +Arrival +Trip +Time +10.07 AM Timber +296 +FROM Identifier Defined +City WEST PALM BEACH +FL +State or Country +TO Identifier Defined +City +NEW YORK +State or Country +NY +Nautical Miles +893 +Statute Miles +1027 +Gallons 1464 +Pounds 17722 +Flight Time 2+07 +Altitude re 370 + +21 +33003.4 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000109 + + +DATE: IO.8,2004 +Time +PASSENGERS +1. Jeffrey Epstein +2. +3. +4. +Туре: B-727-31 +Pilots: Dave Rodgers, Larry Viseski +Flight Engineer: +Larry Morrison +FROMJFK +- то_ +PBI +Arrival +Time +805 +A Romar 297 +1. NANNY +8. MANNY +9. DAvia mulla +10. 1 PAX +11.- +12. +13. +14. +15. +16. +17. +18. +19. +FROM Identifier Defined +City... +State or Country +NEw YoRk +NiY. +TO Identifier Defined +City WEST +Palm BEAch +State or Country +FL +Nautical Miles +893 +Statule Miles +1027 +LANKY +Gallons 2771 CASH +pounds 17128 330034 +Flight Time 0h +00 +20 +• Atitude Fl F2390 33005.4 +1'1 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000110 + + +DATE: 10.10.2004 +Type: B-727-31 +Pigs nine Roles harry orie +FROM PBI +To JFK +Arrival +Time +8.121 +Trip +A Numbor 298 +PASSENGERS +1. Jefirey Epstein +3. +4. +5. +6. +7. +8. +9. +10. NANNY +" NANNY +12. +13. +14. +15. +16. +17. +18. +19. +FROM Identifier Delined +city WEST PALM BEACH +State or Country +FL +TO Identifier Defined +City +NEW YORK +State or Country +NY +Nautical Miles +893 +Statute Miles +1027 +Gallons 2536 +Pounds 18282 +33005 4 +Fright Time 2+11 +2 +. 2 +Attitude FL 370 + +9 +TAL +L_ +4 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000111 + + +DATE: 10 12. 2004 +De 4 53 +PASSENGERS +1. Jeffrey Epstein +N M +5. +6. +7. +8. +9. +10. +11. +12. +13. +14. +15. +16. +17. +18. +19. +Type: B-727-31 +FROM JFK +Arrival +Timo +Pilots: Dave Rodgers, Larry Visoski +Flight Engineer. +Larry Morrison +— то — +TIST +754 (PM) +) Number_ 299 +FROM Identifier Defined +City _ +New york +State or Country +TO Identifier Defined +City. +S1.-ThomAs +State or Country +US.VI. +Nautical Miles +1410 +Statute Milcs +1622 +Gallons 3623 PR CASt +pounds 26/67 33007.6 +Flight Time 3.00 +30 +Alindo 71 FL350 330106 +14 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000112 + + +DATE: 10-16 +_ 2004 +Date 5:54 AM +PASSENGERS +1. Jeffrey Epstein +2. +3. +Type: B-727-31 +FROM TIST +Arrival +Time +8 08 0 +Pies are Rodgers arry Morriski +Larry Morrison +PBI +TO. +Trip +Number +300 +5. +6. LAURA ANDREW +1. LISA ANDREW +8. +9. +10. +IL. +12. +13. +14. +15. +16. +17. +18. +19. +FROM Identifier Defined +City ST. THOMAS +State or Country +USVI +TO Identifier Defined +city WEST PALM BEACH +State or Country +FL +Nautical Miles +976 +Statute Miles +1122 +Gallons 5200 +Pounds 2/610 +33010.6 +Flight Time 2+13 +22 +Atitude FL 310 +33012.8 +-8 +23.- +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000113 + + +Type: B-727-31 +DATE: 10:17.2004 +Departure +Time +8:04 +PASSENGERS +1. Jeffrey Epstein +2. Ghislaine Maxwell +FROM PBI. +TO +Arrival +Time +(AM) +10•15 +Trip +Numbor +V.F.K. +301 +4. LAUrA ANDrEW +3. LisA +AmbRad +6. +7. +8. +9. +10. +11. +12. +13. +14. +15. +16 +17. +18. +19. +FROM Identifier Defined +CITy WEST PALM BEACH +State or Country +EL. +TO Identifier Defined +City - +New York +State or Counity +N.L. +893 +Nautical Miles +Statute Milcs +1027 +Gallons 2223 +Pounds _ +19525 330128 +Flight Time 2+10 +2.2 +Altitude El_F4330 330/5.0 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000114 + + +Registration Number: N908TE +DATE: 10.20.2001 +Da 9:46A +PASSENGERS +1. Jeffrey Epstein +2. +3. +4. +5. +6. +DAVIO MULLEN +7. +8. +9. +10. +11. +12. +13. +14. +15. +16. +17. +18. +19. +Type: B-727-31 +FROM JFK +Arrival +Time +10:17 +Pilots: Dave Rodgers, Karry Visoski +Flight Engineer: +Larry Morrison +To_LFPB +AM Trip +Number +302 +FROM Identifier Defined +City NEW YORK +State or Country. +NY +TO Identifier Defined +City. +PARIS +State or Country +FRANCE +Nautical Miles +31S5 +• Statute Miles +3629 +Gallons 8407 DR CAS, INFRAME +Pounds S3867 + +Flighe Time_ 6+30 +6.5 +Altitude Fz 370 +33021.5 +40 +TAL +40 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000115 + + +DATE: 10-25.2004 +O 5 24 (1) +PASSENGERS +1. Jeffrey Epstein +2 +3. +4 DAVIO MULLEN +5. +Type: B-727-31 +Pilots: Dave Rodgers, Larry Visoski r +Flight Engineer. +Larry Morrison +FROM LE.P.B +TO VEK. +Arrival +Trip +Time +6.44 PM Minter. +303 +7. +8. +9. +10. +11. +12. : +13. +14. +15. +16. +17. +18. +19. +FROM Identifier Defined +City_ +PARiS +State or Country FRANCE +TO Identifier Defined +City .. +NEw +YoRk +State or Country +VEw York +31S5 +Nautical Miles +Statute Miles +3628 +Gallons_ 8202 +Pounds 59265 +Flight Time Z:20 +Altitude FL EL 360 + +73 +33028 8 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000116 + + +DATE: 10.25.2004 +Departure +Timo +" 8 26(M +PASSENGERS +1. +2. +3. +4. +5. +6. +7. +8. +9. +10. +11. +12. +13. +14. +15. +16. +17. +18. +19. +Type: B-727-31 +FROM_ JFK +Time +Am 10:13 +Pilots: Dave Rodgers,_ Larry Visoski +Flight Engineer. +Larry Morrison +JAX +— то. +Trip +e Number. +304 +FROM Identifier Defined +City _ +NEw YOnK +State or Country +TO Identifier Defined +CIL VAXONVILLE +State or Country +FL +Nautical Miles +120 +Statuto Miles. +828 +Gallons 2:130 LVersh ARFRAME +Litres +Flight Time 1 46 +33022,8 +Alinde Fl E1390 33030.6 +Pounds +18 +Repositroal +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000117 + + +DATE: 11 +-2D 2004 +Tima 12:18 +Timc +PASSENGERS +1. TEST FLIGHT TAWS +2. +3. +4. +5. +6. +7. +8. +9. +10. +J1. +12. +13. +14. +15. +16. +17. +18. +19. +Type: B-727-31 +TROM_JAX +Arrival +Timo +2:40 +Pilots: Dave Rodgers, _ Larry Visosk +Flight Engineer: +Larry Morriso +TO JAX +Trip +Numbcr +305 +FROM identifier Defined +City JACKSONVILLE +State or Country FL +TO Identifier Defined +City_ JACKSONVILLE +State or Country +FL +Nautical Miles +NA +Statute Milcs +NA +Galions +4206 +Litres +Flight Time_ +_+. +Altitude FT 330 +Pounds +22 +33030 6 +2.4 +33033.0 +3 +ILS +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000118 + + +DATE: 11 +_20,2004 +Departure 5:30 +Timo +PASSENGERS +1. +2. +3. +Type: B-727-31 +light Enginee +FROM JAX +_ o PBI +Arrival +Timo +6:17 +AM Number +306 +5. +6. +7. +8. +9. +10.- +11. +12. +13. +14. +15. +16. +17. +18. +19. +FROM Identifier Defined +City JACKSONVILLE +State or Country +FL +TO Identifier Defined +city_WEST PALM BEACH +State or Country +FL +Nautical Miles +245 +Statuto Miles +282 +Galions +Litres +33033 +Flight Time ++46 +8 +Altitude FL. 280 +Pounds 7811 +33033 +EMC +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000119 + + +Registration Number: N9OSJE. +DATE: // 23,2004 +PASSENGERS +1. Jeffrey Epstein +N +5. DAVID MULLEN +7. +8. +9. +10. +11. +12. +13. +14. +15. +16. +17. +18. +19. +Type: B-727-31 +Pilots: Dave Rodgers, Larry Visoski +Flight Engineer. +Larry Morrison +FROM PBT +Arrival +Time +5 42 +TO _ +Trip +Number +TIST +307 +FROM Identifier Defined +Cily WEST PALM BEACh +State or Country +FL +TO Identifier Defined +City +St. ThomAs +State or Country _ +_a.S.V.I +Nautical Miles. +976 +Statute Miles +1|22 +Gallons 300/3307 +Pounds _ +18303 33033 8 +Flight Time 2.06 +2.1 +Altitude L EL350 33035 q +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000120 + + +DATE: 11-28.2004 +Type: B-727-31 +FROM TIST +Ai 8 13 +Time +AM +PM +Pilots: Dave Rodgers, Karry Visostsi +Flight Engineer. +Larry Morrison +TO- +JFK +Trip +Number, +308 +PASSENGERS +1. Jeffrey Epstein +2. Ghislaine Maxwell +3. +4. DAULD MULLEN +8. +9. +10. +11. +12. +13. +14. +15. +16. +17. +18. +19. +FROM Identifier Defined +City +ST. THOMAS +State or Country_ US VI +TO Identifier Defined +City +NEW YORK +State or Country +NY +Nautical Miles +1410 +Statute Miles +1622 +Gallons 5318 +Pounds 31269 +Flight Time 3+40 +Ander 380 +20._ +22- +33035 +9 +3 +7 +33039 6 +20 +20 +Appiroach +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000121 + + +DATE: 12-03.2004 +орание 5:04 (5) +PASSENGERS +1. Jeffrey Epstein +2.50 +3. +4. +/ FEmALE +5. +G. +7. +8. +9. +10._ +11. +12. +13. +14. +15. +16. +17. +'18. +19. +Type: B-727-31 +Pilots: Dave Rodgers, Larry Visoskä +Flight Engineer: +Larry Morrison +FROM JFK +TO +Arrival +Time +734 pm +Trip +Number +PBI +309 +FROM identifier Defined +City +JOHN F. KENNEDY +State or County _ N.y. +TO Identifier Defined +City _ +WEST PALm BEACh +State or Country +EL. +Nautical Miles +893 +Statute Miles +1027 +Gallons 2502 +Pounds 21/68 + +Flight Time 2+30 +2.5 +Altade FL EL 350. 33042 1 +LO +26. DEpARtURE ARO * 11164 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000122 + + +P. 001/020 +Registration Number: N905JE +Туре: 8-727-31 +DATE: 1-11 2005 FROM PBI +Pр 8:030 +PASSENGERS +1. Jeffrey Epstein +апу Могтію +. To TIST +310 +4. +5. +7. +8. +9. +10. +11.- +12 +13. +14. +15. +16. +12. +18. +19. +#FEMALE +I FEMALE +FROM Ideatifier Delined +• Giy WESt PALM BEACH +State or Calmtry +FL +TO Identifier Delied +CY ST. THOMAS +State or Country_ USVI +Manical Malices 275 +Statute Miles 122 L +Gallores_ 340 +Pounds_ 18669 +Plei Time 2:10 +Alitente FL 370 +23.. +33042.1 +23 +33044.3 +Night. +23 +TA. +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000123 + + +P. 002/020 +Registration Number: Nº08JE, +Турс: B-727-31 +igtit Enginee +DATE 1 14 2001 FROM TEST +- то- +PBI +$440 6:18 a 311. +PASSENGERS +1. Jeffiey Epstein +8. +9. +10. +IL. +12, +13. +14.- +15. +16, +I7- +18. +19. +FROM Ideatiber Defied +state or county USKI. +TO Identifier Defined +air west Palm Bench +State or Country. +EL +Nartical Miles 925 +Statue Miles 1. 2| +Cations. 3869 + +Flight Tina 2+34 +25 +Alicio I F2 350.330468 +Night. +TIL +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000124 + + +P. 003/020 +Registration Number, N918JE +Type: B-727-31 +Flight Engincer +DATE: L:17,2005 =80M PRT +- то_ +JFK +De 5:10 +Arival +Time +7-396 Min 312 +PASSENGEES +1. Jefirey Epstein +2, Chisisine Mexwell +FROM Identifler Delined +C WEST PALM Bch +State or Country _ FL +TO Idcatificr Delined +151gD Myster +8. / Rap +11, +12. +13. +I4, +15. +16. _ +17... +18. +19. +Stale of Contry _ +Maurical Miles_ 894. +SEstE Miles 1028 +Gallons 245. +Ponds 21200 +3304Y6.E +Flight Time 2+28 +25 +AlimE FL570 33049,3 +22 +Approuch +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000125 + + +P. 004/020 +... +Registration Number: N908JE J +уре: B-727-31 +Plight Engineer: +DATE: + +-19:200 FROM JEK +• то PBF +Pa 9.32 M to 1:5280 me 313 +Namber 3/3 +PASSENGERS +1, Jefficy Enstein +FROM Identifier Defined +2. +3. +7. +8. +9. +10. +IL. +12. +13. +14. +15. +16. +I7. +18. +19. +State or Country __ +Nay. +TO Ideatifer Delined +City_WESt PAla Bondh +Stato or Country _ +EL +Neutical Miles._ +854 +Statute Miles_ +1028 +Gallons— +3200 UKATy AREAME +Founds_ 12980 + +Fight Timo 2 +3 +Attitudo F7. FL380 +20.- +3305/5 +Night. +TIL +Approech +24.. +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000126 + + +AU6-14-2006(MON) 14:32 +P. 005/020 +Registration Number; Nº08JE +DATE: 1 - 20,2001 +Time Le : 45 A +PASSENGERS +1. toffrey Fipsteits +2. Ghinlaise Déamuell +3, Brent Tindell +4. +5. +6. +7. +8. +9. +10- +11.. +12, +13.- +14. +15. +16.. +17,. +18. +19. +Type: 13-727-31 +Pi ime des, la Maria Bin hammed +Larry Morrison +FROM PRI +TO PAL +Arrival +_/1.e2 M Mimbo3.14 +FROM Identifier Defined +City . +West Palm BenaL +Stale or Coutty. EZ +TO Identifies Defloed +cir West Pelm Besch +State or Country EL +Nautical Mils _& +Statale Miles A +Gallons 500 +Pounds 670 % +AIRERAME +3305L 5 +Flight Time 0+37 +Altitude Fl 2,500 +22 +23-- +3305 2 0. +24.. +Traing Frigat +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000127 + + +AUG-14-2006(HON) 14:32 +p. 006/020 +Type: 8-727-31 +i give Bodes arry tortil +Flight Engineer: +DATE: 1 27 2005 FROM PBI +_ то TIST +pan 1.46 d +i 10538 Time +315 +PASSENGERS +1. Jeffrey Epstein +2. +3. +4. +5. +6, +7. +8. +9. +10. +11. +12, +13. +14. +15. +16. +17. +18. +19. +FROM Identitler Defined +ciy WEST PALM BEACH +Stale or Country +FL +TO Identiller Defined +ciry ST. THOMAS +State or Country. +USVI +Nautical Miles _ +975 +salute Miles ). 1 2/ +Gallas 3210 +Pounds 18274 +33052.0 +Flight Time 2+06 +2 +Alriude FL 370 +33054 +Night. +2.1 +TIL +LI +8 +Approachs +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000128 + + +AUG-14-2006 (HON) 14:33 +P. 007/020 +. PASSENGER MANIFEST +Registration Number: NH8JY, +Type: 15-717-31 +DATE: |31.2001 FROM TIST +ma 5:38 00 +Arrival +Time +PASSENGERS +1. Jeffrey Epstein +2, +3. +Pios: Dave Rodgers,_ Larry Visosk +Flight Engincer. +Larry Morrison +To_ LEK +8:28/ Mto 316 +FROM Identifier Defined +cir St.ThomAs. +Star or Contry__ U.S.KT +TO Tecatifier Defined +8, +9. +10. +11._ +12. +13. +14. +15. +16, +17. +18. +19. +Nautical Miles 1412 +Saneo Mica 1 6 23 +Gillons +ponts_ 3/328 + +Fight Timo 3+49 +3.8 +Altitude FL EL 370 + +20, +Night - +3.0 +21 +TIL +22 +• 23._ +24, +55.. +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000129 + + +P. 008/020 +Date LoLZ/2005 +AIRCRAFT LOG +B-727-31 +AIRCRAFT 100 +JEGE, INC, +Registration Number, NOOBIE +Type: B-727-31 +DATE: 2-3.2005 +Pan. JEK +_ To CM.H +a 616 A mi 3117 +Timo +PASSENGERS +1, Jeffrey Epstein : +FROM miler Tried +4 JEAN LULBRUNEL +- DAVID MULLEN +-. FEMALE +•. FEMALE +• FEMALE +10._ +16 +18 +19, +TO Identifer Defiand +Do COLUMBUS +Nasical Mia_419 +Satie Miles +477 +cline 22052470052)415 +AIRFRÄME +Ponds 11414 +_ 33057 9 +Fit a L.06 +L1 +Alinda fl 360 +33059 0 +Night. +21._ +TIL. +22 +3._ +25._ +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000130 + + +AUG-14-2006 (HON) 14:33 +P. 009/020 +-. +Registration Number; N968JE Type: B-727-31 +Priots: Dave Rodgtis,_ Larry Visosk +Flight Engincer: +Larry Morrison +DATE 2 3,2005 FROM. CMH +par 0:53 +Arrival +Time +les 40 +PASSENGERS +1. Jefficy Epstein +2. +3.. +- 10- +i Nimi +Number +318 +5... +Davin mullEa += fanale +"Fe mal +• femell +9. +10. +Il. +12. +13.- +14. +15. +16. +17. +18. +19._ +FROM Ydentilier Deftned +ais Colimbas +Stute or Country _ +TO Identifier Defined +air west Paten Besach +State or Courir... +FL +Nautical Miles_ 810 +Starte Miles 93L +Gallons A +Portads 16885. +Plight Tito 2 +47 +Altitude FL. +33059.0 +1E +33060.8 +Niets. L.8 +111 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000131 + + +AU6-14-2006(NON) 14:33 +P. 010/020 +Type: 13-727-31 +DATE: 22:7.2005 FROM PBI +TO _ +_VEK +Arrival +Time +7:54 (84) Tiber. +319 +Time +PASSENGERS +1. Jeffrey Epstein +2 +3. +5.. +1. DAUTO mUllER) +LANSEN +7. +8. +9. +10,_ +11. +12. +13. +14. +15. +16. +17, A +18. +19, +FROM Ydentifier Deftoed +ay_ WESt PALm Boh. +State or Country _.... +FL +TO Identifler Defined +ci New York +Suste or Cauntry _ +N.f +Nautical Miles_ +Statile Miles +Gallots. +Portads. +19868 +33060.8 +Plier Time 22+25. +247. +AlindoFL_ FL.370339630 +Night 1.5 +22... +Approuch, +24 L +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000132 + + +P. 011/020 +Regis +DATRi +Departe +Time +PASSE +Type: 3-727-31 +FROM. +Arrival +Time +JFK +Flight Engineet: +TO +PBL +umbe 320 +53: +30. +1L. +13. +15. +16 +17 +18 +19, +FROM Identitier Defined +i New your +State or County. My +IO Ideatiflor Defined +ai West Palm Besol +State or Country FL +Nautical Miles _ +894 +Stato Miles 10.28 +Gallons 2900 +Pariss 17,257 +33063 e +Flight Time Zt12 +2.2 +Attitude FL 34 e +33045 2 +2,2 +TIL +22 +WEBE :6 +5082'6 " +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000133 + + +AUG-14-2006 (MON) 14:33 +P. 012/020 +Deparan +Time +- 15.2005 +Type: B-727-31 +FROM... +PBI +Tine +9. +10. +11. +13 +To: Dave Badgers, Larry Visorld BahAmmm +Fight Engiooor +Larry Monbu +VEK. +TO. +AM Namber +321 +FROM Ideutifier Defued +cly_ WEST PALM BEACH +State or Cotatry_ +EL. +TO Ideutifler Delined +al de peek +State or Country. +Nautical Miles. +894 +Statute Miles_ +1028 +Gallions 2955 +ATRERAME +Boande 18720 230652 +Flight Tios. Z+/d +22 +Altitude 2. 4390 33067 4 +20.- +21, +22 +Apprancha +36... +WHE616 +5e0zs 2w +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000134 + + +P. 013/020 +Degertare +Time +PASSENGERS +-4332 +I0. +12. +I3 +14 +15. +16, +17. +18 +19. +Type: B-727-31 +Pilots: Deve Rodgers, Larzy Visoukd +Flight Enginser: +Larry Morrison +TROM JFK +- TO TLST +Ae 18.50 d5 Mite 322 +ATWice +fusst +EROM Identifier Defined +aly__ KJEK NEwyorry»y +Stata or Comary. NEw yunt +IO Identier Detioed +Cüty_JIST ST Thımşs +Stade or Comntry _ +USKI +Nautical Miles +1478 +Stutute Miles +1700 +Gellans.. +Pounda _ +Pisin Tirao 3+47 +Altitcue FL 330 +33077.4 +3.L +33070 5 +- UL +Approach_F +234°CN +D DE T +HHBE:6 +5002 4 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000135 + + +AU6-14-2006(MON) 14:34 +P. 014/020 +Departan +Time +PASSENGOES +2005 +44 +6. +7. +9. +10. +12. +13. +14. +15. +16. +ZANL +stanley +tarley +tanley +18. +19 +Type: 1-727-31 +Tatz: Darve Rodgers, Karry Visou +Flight Brigineer +aITE Morrise +FROM_ +TIST +Tine +Am 8 ,05 +TO. +Trip +Number +PBI +323 +FROM Identifier Detiued +cy ST. ThoanAs +State or Cosatry - +USKI +TO Identifier Defined +cay wEst PALm BEACh. +State or Country - +FL. +Neurical Miles. +976 +Statute Miles_ +1122 +Gallars 5305 +• AIRFRAME +Ponds 23557 + +Pigir Tino 2,23 +23 +Altodo rz FL340 33072.8 +20._ +seht 2.0 +-4 +IMIC +2A. +9°d +W0: S0026 20 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000136 + + +AU6-14-2006 (MON) 14:34 +P. 015/020 +Departire +PASSENI + +1.270 +od +9. +10. +11. +I3. +14. +15. +16. +17. +18. +19. +S'd +INTENANCE +ST +FLIGHT +Туре: 8-727-31 +Flo Dave Roders, Larry Visoeks +Plight Enginec: +Larry Morrisun +PBI +FROM PAl +Aurival . +Time +4.45 +то- +Trip +Number +324 +FROM Identifer Defined +a West Palm Besol +Sinate or Conatry. FL +TO Identifier Deflued +cin WesT Palas DEnod +State or Country EL +Mestical baile.... +Galloss _ +Parande_ +3500 + +Flighr Timas. 2+17 +Altado iI 2500' +33073.1 +Night — +21._ +TAL +22 +IMC - +Approach._ +34... +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000137 + + +AUG-14-2006(NON) 14:34 +P. 016/020 +DATE:_ +3 +-L2005 +1 10:50 +Time +PASSENGERS +1.Jeflrey ostein +7. +8. +9. +10.. +11. +12, +13._ +14. +15. +16. +17-. +18, +19. +Type: B-727-31 +Plati ne Rodecta, Kry Morit +Larry Morriso +PROM_ PBI +_ io_ JFK +im 1253 eT 325 +FROM Identifier Defined +Ciy WEST PALM BeACH +State or Comay_. FL.. +TO Identifier Defined +City _ +NEW YARK +State or Country... +NY +Nastical Miles _ +894 +Staten ils 1028 +Gallone 2717 +Pounds 10799 +Attado t. 370 +21, +33073 1 +2.1 + +Night. +I/L +MC +3 +Approach ILS +89410N +BLE:6 +900216 2 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000138 + + +P. 017/020 +Egistracion Number: N9OBJE +Type: B-727-31 +BIll HAMMIN +ilots: Dace Redger +Larry Visoski +Flight Boginces: +Larry Morrison +DATE: 3-4 2005 FROM JFK +TO PAI +до 2:38 M +1 11 45 0 Minte 336 +PASSENGERS +1. Jollrey Epstein +FROM Ideutilier Defined += Ghis/orner maxwall. +3. +Panio mullen +NEWYORK +5. +6. +7. +8. +9.- +-10._ +11. +12 +13. +14. +15, +16. +17. M +18, +19. +State or Country My. +TO Identifier Defined +Cy WEST. +PAEm BEACH +State or Country FL +Nuatical Miles _ +894 +Statute Milos _ 1028 +Gallans : 2 0 27 +Pounds 19,82 6 33075 a +Fight Time 2+18 +2.3 +Altitude Fa_ 380 +33077 5 +20, +Night 2.3 +T/L, +22 +E'd +WHLE:6 + +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000139 + + +P. 018/020 +Registration Number, NOUSE +DATE: 3-8,2005 +pa 11: 42 +PASSENGERS +1. Jeffrey Epstein. +2. +3. +Type: B-727-31 +Flight Bagineer, +TROM PBT +TIST +Arrival +Time +2.500 be 377 +5. +6. +7. +9. +10- +11. +12. +13. +14, +15. +16. +17. +18. +19. +FROM Identifier Defined +GIry WEST PaLEs +State a Country _ +FL. +TO Ideatifier Defined +Cily 54. ThomAs +Stato = County. US.VI. +Nautical Milles 976 +statute Miles faz +Gallons 3227 +Pounds 1860₴ +High Time 2+08 +Almo i E4370 +20.- +21, +33079.5 +2.1 +33079.6 +Night — +, Approach +2°d +094°0N +WOZE:6 +5002:520 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000140 + + +P. 019/020 +Registration Number: N969JE +Type: 13-727-31 +Pilots:_Dave Rorizera, Larry Vboski +Fllght Engleer. +Larry Morrian +DATE: 3/1.2005 FROM TIST +pe 10.22 +PASSENGERS +Tal 1051 EM Nimbe322 +1. Jeffrey Bostein +2 +3. +4. +5. +6. +7. +8. +9. +10. +11. +12. +13. +14. +15, +16. +17, +18, +19. +FROM Identifier Deftued +aySr Thomas +State ar County VSKI +TO Identiffer Defined +ayST._mRARTEN +State or Country NETHERLANA A. +Nectical Miles, +200 +115 +Ststute Miles _ +Galloas (600 +Perands 10,722 +Flight Ticas_D + 23 +Alidade EL 11, 000 +TIL. +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000141 + + +AUG-14-2006(NON) 14:34 +P. 020/020 +Registration Number: N908JR Typo: B-727-31 +DATE: 3-IL 2005 TROM T NCM +a 5,31 0 +Lariva +PASSENGERS +Pilots alamos Lary Volt +Flight Engineet: +Larry Morrisom +TO_ +TIST +5.56A Min 319 +6. +7. +8. +9.. +10, +11. +12. +13, +14. +15. +16, +17. +18. +19. +FROM Identiffer Defined +CHYST. MATRIEN +State or Castry NEt heeland Argellar +TO Identifer Defired +City_ST Thamad +State ox Country _ USVE +Nautical Miles _ +10º +Statute Miles. +Pounds 6392 +Altiane Et 14000 +20.. +24.. +Night. +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000142 + + +P. 001/024 +Registration Nuber: NOGSJE +DATE: 3 -14.2005 +a 4: 00 0 +PASSENGERS +1. Jeffrey Epstein +2 +3. +4 DAViO MULLEN +5.- +6,, +7. +9. +10. +11. +12. +13. +14, +15. +16. +17. +18. +19. +Type: B-727-31 +FRON TISI +то. +AN lo:39 e Number. +Hitos mn, tany Voost +Flight Engineer: +Larry Morrtso +V.F.K. +330 +FROM Identitler Dellaed +CIy ST. ThomAs +SESOT GENAY US V. I. +XO Identifier Detined +Cly NEW YORK +Stato or Country... N.Y +Nautical Millos 1978 +Statute Miles 1 700 +Gallors 3055 +Porunds 31522 +33080.4 +Flight Time 3 39 +37 +Altdo PL. EL340 33084 +Approsch. +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000143 + + +P. 002/024 +Bell Hammond +Rogistration Number: N908JE +Туре: B-727-31 +• DATE: 3-18.2005 FROM KJFK +. то КВАІ +Dom 10: 02.1 +12.48.N0 Mi +33L. +PASSENGERS +1. Jeffrey Epstein +2. Ghielore +// +5. +6, +7. +8. +9. +10._ +11.. +12,. +13. +14, +15, +16. +17. +18. +19. +FROM Identifier Defined +CY MEW YORK +State or Cotty_ ~Y +TO Identißer Defined +cir WESt Palm Benel +State or Country FL +Nautical Miles._ +894 +Statute Miles. +6028, +Gallons 3425 +Pounds 23013 +Fight Time 2,4° +Altinade BL 220 +20,_ +33084.1 +27 +33086.8 +Night_ +T/L, +Approsch, +23.- +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000144 + + +AU6-14-2006(MON) 14:37 +P. 003/024 +DATE: 3.22.2005 +Depurture +Time. +PASSENGERS +ana Bantein +Хуре: B-727-31 +Pilot: Dave Rodgcr,_ Larry Visouki +Plight Entres. +Larry Morrisoa +FROM PBI +- то. +JEK +Arrival +Time +3:260 Minha 332 +FROM Identifer Defined +City. +NEST PALM PEACh +State or Contry _ +TO Idebtifier Defined +5. / ZOMALE +6. +7. +8. +9. +10._ +1L. +12. +13. +14. +15. +16. +17. +18. +19. +State or Country +Mentical Milos 894 +Staute Miles 2028 +Gallos .. +Pows 18510 +33086.8 +Flight Time 2a+ Q9 +22 +AREANO E ELAIa 33082.0 +21.. +I/L +, Approsch, +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000145 + + +P. 004/024 +. Registration Number: N908JE Type: B-727-31 +Pilote: Dave Rodgers, Lamy Viscaki +Flight Engincer: +Larry Morrison +DATE: 3-24.2005 KROM_KJFK +_ TO TIST +par G:21A +Tine +Ami 10:38 EM Minter. +333 +PASSENGERS +I. Jeffiey Epstoin +2. +3. PARID +Mullen +4. +7. +9. +10. +11. +12 +13. +14, +15. +16. +17. +18. +19 +FROM Identifier Defined +CINNEW YORK +seste or Comaty MY - +TO Identifler Deliood +dIy ST ThomAs +State or Coustry - +_USUE +Nautical Miles_ +1412 +Stante Miles +1623 +Gellars 4/73 +Ponds_ 27960 +Flight Timae 3+11. +Atindo FL 370 +22 + +32 +33092.2 +Nigh 3.2 +TIL +-/IL +_L +2A.. +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000146 + + +AUG-14-2006 (MON) 14:37 +P. 005/024 +JEGE, ING. +Registration Number: N908E +DATE: 3.29.2005 +Dopatr 9 :09. +PASSENGERS +1. Jeffrey Epstein +2. +3. DAVID MULLEN +Type: B-727-31 +FROM TIST +Ted 11 34 +Time +BILL HAMMOND +Pilote:_ Dare Rodęcn, Łgad +Flight Enginpor: +Larry Morrison +- TO_J FK +4 Tri +Number +334 +7. +8. +9. +10. +12, +13. +14. +15. +16. +17._ +18. +19.. +KROM Identiffer Deflaed +CY_ST. THOMAS +State or Courry USVT +TO Identifler Deflacd +City NEW YORK +State or Country. +NY +Nautieal Miles_L412 +Starto Mils 1623 +Galluns_ $112 +Ponads 29853 +Plight Tirio 3 +24 +Attinde FL 380 +21., +33092.3 +35 +33095.6 +.2 +Approacs SLS +24.- +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000147 + + +AUG-14-2006 (NON) 14:37 +P. 006/024 +Ragistration Number: Nº68IE +Type: B-727-31 +DATE: 3 31 2005 +Ta 8 :43 +PASSENGERS +1. Jeffrey Epstein +3. +5. +6. +7. +8. +9. +10,_ +11._ +12. +I3. +14. +1S. +16. +18. +19. +Plight Engiscer: +_ TO +PBI +Anel. +J1:10 +rio 335 +MAXWELL +FROM Identiffer Defined +Vark +sate or comay N.y. +TO Identifier Defined +Cly WEST PALM BEAch +State or Country FL +Nousical MiTos 89,7 +• Statuto Miles 1028 +Gellons 2102 +AIRERAME +powads. 20609. 33095€ +Plight Time 2+27 +25 +Atido 2 1L 400 33098.1 +Approsch. +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000148 + + +AUG-14-2006 (HON) 14:37 +P. 007/024 +Registration Number: NOBRE Type: I8-727-31 +DATE: 4-62005 +1 0,54 8 +Time +PASSENGERS +1. Jetirey Epstein +2. +Flight Enginee +FROM PRI +_ To JFK +Al1:0580 Mina 336 +3. DAVED MULLEN: +5. +6. +7. +8. +9. +10. +11. +12. +14, +15. +16. +17. +18 +19. +FROM Identitter Defined +cio WEST PALM BEACH +State or Country _ +fL +TO Identifier Defined +Ciry NEW YORK +State or Country _ +NY +Naurical Miles_ +894 +Stanto Mios_L028 +Gallons 31/7 +Pounde 18274 +33098.1 +night Tino 2+10 +2.2 +2 +Atinale t 370 +33100.3 +TMC +Approach _. +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000149 + + +AUG-14-2006 (MON) 14:37 +P. 008/024 +Registration Number: N908N Type: B-727-31 +Pilots: +511 Homem dar Vagala +Flight Engineer: +Larry Morrison +DATE: 423.2005 +YROM_ JFK +- то +ABQ +1 10:148 337 +PASSENGERS +I. Jefficy Epstein +2. +3. +¿DAViD MULLEN +6. NEAN LUK BRuNnEl +1.1.FOMALE +8. +9. +10. +11.- +12. +13. +14._ +IS. +1б.... +17. +18.. +19. +FROM Identifier Defined +CIy NEW YORK +State or County.... +N.y. +TD Idcotifer Defined +CiY ALBUQUERQUE +State or Country +N.M. +Nautical Miles +1636 +Statute Miles 1881 +Gallens_ 472/ +Poinnde 3/023 +33100 3 +Hight Tino 4,05 +Altitude F1. 4 +3310K 7 +2D._ +Nieht.. 20 +21, +T/L. +22 +™MC +Approest +2A. +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000150 + + +P. 009/024 +Registration Number: N90BJE +Type: I-T27-31 +Bell Hammons +Pilos: DaraRodgers, Karry Visorid +Plight Engineer: +Larry Morrison +DATE: 4-25 2005 FROM_/ +ABQ +, TO. +aparture +Tia 10.498 +Trịp +Number. +TEK +338 +PASSENGERS +1. Jeffiey Epstein += Chislacas Marcoall +4. +6. PAvie Mullad +7. JEAN LuA BANANaL +3I Femala Luest +9. - +10._ +11.- +12 +13. +14. +15, +16. +17. +18. +19. +FROM Identifier Deflned +CiY REBUGUERRUS +State or Country _ NEM +TO Identifler Defined +CIL NEW YORK +State or Country _ +_NX +Nautical Miles. +163% +Statute Miles_ +1881 +Galions 4746 +Pousas 28,257 +Fligh Time 3+24 +Altitude fl. 2.90 +21, + +3.4 +33197.8 +15 +T/l, +LIL +MC +1 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000151 + + +P.010/024 +BILL HAMMOND +Registrațion Number: N908TE +Typs: 1-727-31 +Pilots: Dave Rodgers, +Flight Enginder: +Lany Morrion +DATE: 5.12.2005 +FROM_JFK +To TIST +(0 7,53 0 +339. +2 I.ll d n 339 +PASSENGERS +I. Jeffrey Epstein +2 +3. DAVID MULLEN +5. +6. +7. +B. +9. +10, +11.. +12. +13. +14. +15, +16, +17. +18. +19. +FROM Identifier Defined +Cy NEW YORK +State or Caumny _ +NY +TO Idcutifier Defined +City_ +ST. THOMAS +State ar Country +USVI +Nautical Miles +Statute Miles +Gallos_ 4204 +Pounds 27409 +Righ Tino 3+17 +Altoade T 390 +21.- +33107.8 +3.3 +33 | 11.1 +Nipht 2.5 +T/. +22, +29 +33... +24.. +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000152 + + +P. 011/024 +DATE: 5. 16.2005 +Departure +PASSENGERS +1. Jeffrey Epstein +Z. +3. Dero MulleN +Type: 1-727-31 +FROM +TIST +Arrival +Time +2:44200 Tumber. +Pilots: +Flight Bogineer. +KJFK +340 +6. +7. +8. +9. +10. +11.. +12. +13.. +14. +15. +16. +17. +18. +19. +FROM Identifier Defined +City_ST. Thommi +State or Country _ USV L +TO Identifler Defined +Giy NEw fIRK +State or Country_ +Ny +Nautical Miles +1484 +Statute Miles +1,708 +Gallons 4729 +Pounds 29,783 +Fight Tinie_ 3-22 +Altitude Fl. 380 +20.. +22 +3311L L +3 +33/14 +Night. 2.° +TIL +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000153 + + +85/19/2885 12:4B + +JEGE OR HIPERION AIR +P. 012/024 +PAGE B2 +Registration Nomber: N908JE +Type: B-727-31 +Ight Enginac +DATE: 6 - 82005 FROM_JEK +IO +_PBI +pa 8:24 +Arrival +Time +10.33 8 +Tip +Nimbe_ 341 +PASSENGERS +1. Jeffrey Epstein +2. +3.. +DARiA MULLEN +MARK ZEFE +7.. +8. +9. +10. +11. +12, +13- +14. +15. +16.. +17.— +18. +19. +Dout ShottLE +FROM Identifter Defined +City_... +NEW YORK +state or Contry Ny. +TO Identiğer Defined +Cy WEST DALM BEACt +State or Couty _. EL.. +Nantical Miles _. +894 +Statute Milles +1028 +Gallons +Pounds 18646 +33114.6 +Fligin Time 2+09 +2.L +Atino _ EL380331167 +20... +Night 2.- +MC +Approsch, +25., +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000154 + + +P. 013/024 +DATE: 60-207-2005 +De 9:00 M +PASSENGERS +1. Кренеуварстік +2. +3. +Type: 13-727-31 +Pilots: Dave Rodgers, Larry Visoski +Flight Engineer: +Larry Morrison +FROM PBI +To LCQ. +Arrival +9.45 Mine 342 +7. +8. +9. a +10. +11. +12. +13. +14. +15. +16. +17. +18. +19. +FROM Identifier Defined +Ciy. 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MAINtENANCE TEST +FLIGHT +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000157 + + +P. 016/024 +Registration Number: N908JB +- DATR: 10-12.2005 +se 112 S +PASSENGERS +Type: B-727-31 +Pilot: +Flight Bogineer: +4, Lary Vietki +Lany Morrice +FROM LCQ +TO- +Amival +Timo +3.01 M Mimber +VEK +345 +2. +3, +4. +5. +б. +7. +8. +9. +10. +11._ +12 +13. +14. +15. +16. +17. +18. +19. +FROM Identiler Dellaed +City +Latt City +state or Coatty _..: EL +TO Ideatilier Deflaed +ais New York +State or Coutitry +N.y. +Nantical Miles 760 +Statute Miles _ +874 +Galons ·500 +Poucos 16690 3311902. +Flight Ti_1+49. +18 +Altitudo rz E6350 3312/.O +Night._ +TIL +22, +2. NO PASSERIGERS +25. MAINTENANCE +26. PELOCAtiON AFTER ERGUE. +REPRiR +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000158 + + +P. 017/024 +.JEGE, INC. +Registration Number: N9SJE +Typo: B-727-31 +Flight Engitect: +DATE 10.12.2005 FROM JEK +о_ TIST. +po 12:04 ( +A 3.17 A Me 346 +PASSENGERS +1. Jefficey Eostein +Larry Morrieens +5. +6. +7. +8. +9. +10. +11. +12. +13._ +14. +15. +16. +17. +18. +19. +FROM Identifer Definod +City +NEW YORK +TO Identitier Defined +cIN_St. ThomAs +State or Cory _ 6S. V. I +Norical Miles 1412. +Statute Miles_ 1.623 +Galtons 5704 +Pud 26556 33121_0 +Fight Tine 3+13 +- 32 +Alindo . EL 39033124 2 +20, +Night. +22 +25., +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000159 + + +AUG-14-2006(MON) 14:39 +P. 018/024 +Registration Nutaber: N908JE +DATe: 10.17.2005 +Bell Hammond +Type: B-727-31 +Pilots: Deve Rodgers,. +Larry Visoaki +Flight Engineer: +Larry Morrise +FROM TIST +To TIST +PASSENGERS +4. +IRMININE +6. +7. +8, +9. +10. +11. +12 +13. +14. +15. +16. +I7.. +18. +19. +FROM Identifer Delined +CYST Themans +State or County. 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T HernAs +Serto or Contry VIVI +TO Identiller Delined +GINEW YORK +State or Contry +Nautical Miles +Statute Milles . +1486 +1702 +Galions_ +Pounds (475 +Fiete TIme 3,23. +Altitude F._. _.3k° +22- +33134 4 +3.4 +33/27.8 +-=- +T/l +Appconct +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000161 + + +AUG-14-2006(MON) 14:39 +P. 020/024 +Rogistration Number: N988J7 +DATE: 10 27.2005 +p 8:47₴ +PASSENGERS +1. Tot +cor Enstein +2. +•L7EMALE +5. +ImALE +6. +1. LZEMALE +3L MALE +9.. +10. +11. +12. +I3. +14. +15. +16. +17. +18. +19. +Type: 18-727-31 +Flight Engineor: +FROM_ JEK +To T.I. S.TI +Ai 12:10 mnr 349 +FROM Identifier Definad +NEW YORK +Sua or County N. Y. +TO Ideutilier Defleed +CIo ST. ThomAS +State or County _. +U.S.V.I +Nantlenl Miles +2486 +Stetute Miles._ +1209 +Gallos 4292 xv + +poio 29307 331218 +Fligtt Time 3+23 +34 +Altitude T_ EL3903313/2 +3,4 +TIL +Approach IleS +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000162 +EFT A00066677 + +P. 021/024 +Registration Number: NºOBJE +Type: 18-727-31 +DATE: 10:29.2001 FROM TIST +Pe 5:29 1 +Time +Anive +Lito - +Flight Engineer: +70_ +KJFK +8:48 +A M 3,50 +PASSKNGERS +1 TEREREI ELSTEIN +Larry Morrisoa +3. +4. Juan Maly Noux +FROM Identifier Delined +ao St. Thawes +State or Contry _ +ASVI +TO Ilestifiex Deflood +S. +9. +10, +11._ +13 +14. +15, +16. +17. +18. +15. +State Ex Country, +му +Nautical Miles +1484 +Statute Miles_ +1204 +Gallas 4345 +Litros 37,338 +Plete tese, 3+29 +Altitode FL380 +Forada. 2,7338 +21, +2A. +ATRERAME +33/312 +33 +33/34.5 +Night _ +IlL +Z +, Approach. +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000163 + + +AUG-14-2006(MON) 14: 39 +P. 022/020 +Rogistration Number: N90RJE +Type: B-727-31 +DATE: 11.3 2005 FROM JFK +p840 € +PASSENGERS +1. Jetter Postein +Prete Redes any Monti +to TIST +351 +3. +FEMALE +s. MALE +6. +7. +8. +9. +10. +12.- +13. +14.. +15. +16. +17. +18, +19. +FROM Identifier Defined +City. +NEW YORK +State or Country. +NY +TO Identitler Deftoed +CIN ST. THOMAS +State or Couttry. +USVI +Nautical Miles +Statute Miles +Gallons 4278 +Pounds 30248 +Flight Time 3-16 +Alcinde FL 390 +33134.5 +3 +3 +33|378 +33 +30 +23.. +Approuch +24... +26... +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000164 + + +P. 023/024 +Registration Number: N90SJE +Type: B-727-31 +DATE: 11-82005 +TROM TIST +"Arrival +Time +Fell Hammond +Pilots: Dave Rodgers, +Flight Engincer: +Larry Morrison +TO_ KIFE +Trip +9:36 PM +Nunber +352 +PASSENGERS +1. Jeffrey Epstein +2. +5 IGUR +6. +1. VALOSON hOTRIN +8. +9. +10. +11. +12. +13. +14. +15. +16. +17. +18. +19- +FROM Identifier Defined +Cy ST THOMAS +State or Country__ USV L +TO Identifier Defined +CI_ NEW YORK +State or Cotaitry +NY +Nautical Miles _ +1470 +Statute Miles. +1690 +Gallons _ +4708 +Porads 29947 +Flight Time _ +3+34 +Altitude FL _ +22 +23.— +33137.8 +3.6 +33141.4 +25._ +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000165 + + +*Registration Number: N908JE +DATE: 11.19.2005 +a 6: 078 +PASSENGERS +1. 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THOMAS +State or Country USVI +TO Identifier Defined +city_ST. JOHNS +State or Country ANTIGUA +Nautical Miles +Statute Miles +Gallons 2156 +Pounds 7008 +Flight Time _ ++34 +Altitade FL 2,10 +33144 4 +6 +33145.0 +TIL +/ •d +688B-LLL (0₺E) +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000167 + + +• Registration Number: N908JE | +DATE: 11 20.2001 +Do 2:59 A +PASSENGERS +• JEFFREY EPSTELN +2. +3. +4. +5. +6. +7. +8. +9. +10. +Il. +12. +13. +14. +15. +16. +17. +18. +19. +Type: B-727-31 +FROM TAPA +_ To TIST +Ama 335€ Member +355 +FROM identifier Defined +City. +ST. JOHNS +State or Country - +ANTIGUA +TO Ideatifier Defined +City_ ST. THOMAS +State or Comtry_ USVI +Nautical Miles +Static Miles +Gallons +Litres +33145 +Flight Time ++38 +Attitude Ft. 200 +Pounds 7831 +6 +33145.6 +9-d +6888-LLL (06€) +dES: 90 90 ₺I Ing +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000168 + + +• Registration Number: N908JE +Type: B-727-31 +DATE: 11-28.2005 FROM TIST +Deparare 9 : O5 +Time +Arrival +Time +PASSENGERS +1. Jeffrey Epstein +2 IGOR ZiNOVIEW +3. JuAN molyNeux +4. +5. MANk ToFoyA +6. +7. +8. +9. +10. +11. +12. +13. +14. +15. +16. +17. +18. +19. +JEGE, ING. +Bill Hammond +Pilots: Dave Rodgers, Latey Windoki +Flight Engineer: +Larry Morrison +TOL +KJFK +Trip +AM Member 3560 +FROM Identifier Defined +City ST. ThomAs +State or Country _USVI +TO Identifier Delined +City NEW YORK +State or Country NE u +Nautical Miles +(470 +Statute Miles +1690 +Gallons 4687 +Pounds_ 30,276 +Flight Time +3.37 +Altitude FL 380 +peRs +33145 +-6 +3 +33149.2 +LL +3 +6888-LLL (06E) +d£9:90 90 ₺I ªng +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000169 + + +Jan 10 06 10:10p +St. Thomas Jet Center +(340) 777-8889 +P. 024/024 +P.6 +DATE: 12-157.2005 +Departure +Time +"1L54 +PASSENGERS +6. L ChILD +7L NANNU +8. +9. +10 760R: +11. 1 FEMALE +12 +1 7EMALE +13 +14. +15. +16. +17, +18. +19. +Bill Hammond +Type: B-727-31 +Pilos: Dana Digers, Larry Visoski +Flight Engineer: +Larry Morrison +PROM_JEK +To TIS.T. +Arrivisl +Trip +Time +4.05 () Number. +357 +FROM Identitier Defined +City _ +NEW YORK. +Stile or Country _ +-Ny +TO Identifier Defined +Ciy ST. ThomAs +stator CountryU.S.V. I. +Nautical Miles 14.70 +Statute Miles 16 90 +Callons 466524CAS ATRPRAME +Pouni: 27724 33149 2 +Flight Time 3.05. +3.1 +AMIUDO FL. EL330 331524 +2D. +22 +Appronch +- 25. +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000170 + + +DATE: 112.2004 +Depai b: 15 AM +PASSENGERS +1. Jeffrey Epstein +2. +3. +4. +5. +BRENT +6. +7. +8. +9. +10.- +11. +12. +13. +14. +15. +16. +17. +18. +19. +Type: B-727-31 +FROM PBI +Arrival +Timo +Pilots:_ Dave Rodgers, _ Larry Visoskc +Flight Engineer +Larry Morrison +TO +Trip +: 23 (PM) Nimbor. +JFK +241 +TiNDAHL +FROM Identifier Defined +cis WEST PALM BEAch +State or Country +F.L +TO Identifier Defined +City - +NEW +YoRk +State or Country +N.p +Nautical Miles +893 +Statute Miles +1027 +Gallons 3045 +Pounds 18552 +32849 6 +Fligh Time 2+07 +No FL370 328511 +2/ +1'1 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000171 + + +DATE: 1.15.2001 +Time +PASSENGERS +1. 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THOMAS +State or Country +USVI +Nautical Miles +976 +1|22 +Statute Miles +Gallons 1400 +Pounds 8346 +Flight Time_ +2.08 +Altitude FL 4SO +96159 +21 +96280 +TAKE-OFF POWER +Flex Take-OF 2.15 +Min Take-Off +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000201 + + +4 +-10. 2004 +Departure +Time +10:38 +PM +PASSENGERS +1. Jeffrey Epstein +2. +Type: G-1159B +FROM +TIST +Arrival +Time +1:23 +AM +Pilots: Dave Rodgers, Larry Visoski +TO. +Trip +Number +PBI +1706 +3. BRENT TiNDALL +9. +10. +11. +12. +13. +COMMENTS +FROM Identifier Defined +Ciy ST. ThoMAs +State or Country U.S.V. I. +TO Identifier Defined +City WEST PALM BEACH +State or Country +FL +Nautical Miles +976 +1\22 +Statute Miles +Gallons 1200 +Pounds 10534 +9618.0 +Flight Time 2 45 +'28 +Altitude FL FL450 9620 8 +TAKE-OFF POWER +Flex Take-Off +T/L. +Min Take-Off +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000202 + + +DATE: 5-15,2004 +Departure +Time +33 +PASSENGERS +1 LARRY MORRISON +N +RON +Type: G-1159B +FROM +PBI +Arrival +Time +12.00PM +Pilots: +TO +Trip +Number +Dave Rodgers, Larry Visoski +PBI +1707 +10. +11. +12. +13. +COMMENTS +24 MONTH INSPECTION +MAINTENANCE FLIGHT +FROM Identifier Defined +City WEST PALM BEACH +State or Country +FL +TO Identifier Defined +Cy WEST PALM BEACH +State or Country +FL +Nautical Miles +NA +NA +Statute Miles +Gallons +900 +Pounds 2377 +Flight Time ++27 +Altitude FL +160 +96208 +S +9621.3 +TAKE-OFF POWER +Flex Take-Off +Min Take-Off +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000203 + + +DATE: 5-17.2004 +Time 4:22 +Time +Type: G-1159B +FROM/ +P.BZ. +Arrival +Time +7:19 +Pilots: Dave Rodgers, Larry Visoski +T.EB. +TO +Trip +Number +1708 +PASSENGERS +1. Jeffrey Epstein +2. +3. +LMALE PAR +4. +5. +BreNT TINDAL +6. +7. +8. +9. +10. +11. +12. +13. +COMMENTS +FROM Identifier Defined +City WEST PALM BEACh +State or Country _ +FL +TO Identifier Defined +City TeTeRBoro +State or Country +N. J. +Nautical Miles +900 +Statute Miles +1035 +Gallons 2550 +Pounds 10473 +9621.3 +Flight Time 2+57 +3.0 +Altitude FL EL 420 9624.3 +TAKE-OFF POWER +Flex Take-Off +Min Take-Off +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000204 + + +DATE: 5 21.2004 +Demanure 8:00 +Time +Type: G-1159B +FROM +TEB +Arrival +Time +10.13 +Pilots: +TO +Trip +Number +Dave Rodgers, +Larry Visoski +PBI +1709 +PASSENGERS +1. Jeffrey Epstein +2. +3.- +BRENT TINOALL +4. +5. | FEMALE +6. | FEMALE +7. +9. +10. +11. +12. +13. +COMMENTS +FROM Identifier Defined +Ciy TETERBORO +State or Country _ +NJ +TO Identifier Defined +Ciy WEST PALM BEACH +State or Country +FL +Nautical Miles +900 +Statute Miles +1035 +Gallons +2000 +Pounds +8769 +96243 +Flight Time 2+12 +2.2 +Altitude FL 430 9626. 5 +TAKE-OFF POWER +Night |.3 +Flex Take-OM 2 IS +Min Take-Off +13 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000205 + + +DATE: 5.24.2004 +Depare 9:31 +Time +PASSENGERS +1. Jeffrey Epstein +2. +3. +4. / FEMALE +Type: G-1159B +Pilots: Dave Rodgers, Larry Visoski +FROM +P.BI. +TO +Arrival +Ai //:57 +Trip +Number +TIST +2720 +6. +7. +8. +9. +10. +11. +12. +13. +COMMENTS +FROM Identifier Defined +City WEST PALM BEACH +EL +State or Country _ +TO Identifier Defined +Ciy ST. ThomAs +State or Country +U.S.V.I. +Nautical Miles +916 +Statute Miles +1|22 +Gallons +1400 +Pounds +8862 +96265 +Flight Time 2 - 25 +25 +Alitude F1 E4450 9629.0 +TAKE-OFF POWER +Flex Take-Off +Min Take-Off +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000206 + + +DATE: 5-31 2004 +Da 1 28 0M +PASSENGERS +1. Jeffrey Epstein +2. +Type: G-1159B +Pilots: Dave Rodgers, Larry Visoski +FROM TIST +— то ТЕВ +Arrival +Trip +Time +5.22 (M Number. +1711 +6. +7. +8. +9.. +10. +11. +12. +13. +COMMENTS +FROM Identifier Defined +City ST. THOMAS +State or Country. +USVI +TO Identifier Defined +city_ TETERBORO +State or Country +NJ +Nautical Miles +1427 +Statute Miles _ +1641 +Gallons 2300 +Pounds 14440 +9629.0 +Flight Time 3+53 +3.9 +Altitude FL 430 +9632 9 +TAKE-OFF POWER +Flex Take-OR 2 41 +Min Take-Off +IMC _ +Condition WGIGHT +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000207 + + +DATE: 6 4,2001 +Depatu 10:30 +PASSENGERS +1. Joffrey Epstein +2. BrENT TiNDALL +3. +4. +5. +6. +7. +8. +9. +10. +11. +12. +13. +COMMENTS +Type: G-1159B +FROM TE B +Arrival +Time +10 51 +Pilots: Dave Rodgers, Larry Visoski +TO +H.V.N +Trip +Number_ +1712 +FROM Identifier Defined +City _ +TETER BOrO +State or Country _ +N. J. +TO Identifier Defined +Cily NEWs HAVEN +State or Country +c.T. +Nautical Miles +59 +Statute Miles +68 +Gallons_ 200 +Pounds2004 +96329 +Flight Time_ +_21 +-3 +Altitude Fl F060 +9633.2 +TAKE-OFF POWER +Flex Take-Of +Min Take-Off +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000208 + + +DATE: 6.4 +- 2004 +Dimanure 12: 29 +Time +Type: G-1159B +FROM_H.V.N. +Arrival +Time +59 +All +PM +Pilots: Dave Rodgers, Larry Visoski +TO +P.B.I. +Trip +Number +1713 +PASSENGERS +1 JEFFrEY EPSTEiN +BreNT +TENDALL +9. +10 +11. +12. +13. +COMMENTS +FROM Identifier Defined +City . +NEW HAVEN +State or Country +C.T. +TO Identifier Defined +Ciy WEST PALM BEACh +State or Country +F.L. +Nautical Miles +945 +Statute Miles +1087 +Gallons 1276 +Pounds 9397 +9633.2 +Flight Time 2 29 +25 +Altitude FL. EL 450 9635. +7 +TAKE-OFF POWER +Flex Take-Off +Min Take-Off +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000209 + + +DATE: 6-7.2004 +Dear 10: 19 +PASSENGERS +1. Jeffrey Epstein +2. +3. BRENT TINDALL +4. +5. +6. +7. +8. +9. +10. +11. +12. +13. +COMMENTS +Type: G-1159B +Pilots: Dave Rodgers, Larry Visosti +FROM PRI +то ТЕВ +Arrival +Trip +Time +12.47 e Number. +1714 +FROM Identifier Defined +City WEST PALM BEACH +State or Country +FL +TO Identifier Defined +City - +TETERBORO +State or Country +NJ +Nautical Miles +900 +Statute Miles +1035 +Gallons 1400 +Pounds 9138 +Flight Time 2 28 +Altitude FL 450 +TAKE-OFF POWER +Flex Taka- OR 2 15 +Min Take-Off +96357 +2.5 +9638 +1. 2 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000210 + + +DATE: 6-9.2004 +a 2:11 40 +Time +PASSENGERS +1. Jeffrey Epstein +2. +3 +4. 1 FEMALE +5. +б. +7. +8. +9. +10. +11. +12. +13. +COMMENTS +Type: G-1159B +Pilots: Dave Rodgers, Larry Visoski +FROM TEB +TO_ +BED +Ana 1251 Mimber 1715 +FROM Identifier Defined +CIY TEtERBORO +State or Country _ +N. V. +TO Identifier Defined +City BEDFORD +State or Country +MA +Nautical Miles +158 +Statute Miles +182 +Gallons 200 +Pounds 3556 +96382 +Flight Time _ +_40 +Altitude FL FL250 9638.8 +TAKE-OFF POWER +Flex Take-Off +Min Take-Off_ +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000211 + + +Registration Number: N909JF +DATE: 6-9.2004 +Depature 8:38 eM +Time +PASSENGERS +1. Jeffrey Epstein +2. +3. +4. L FEMALE +5. +6. +7. +8. +9. +10. +11. +12. +13.- +COMMENTS +Type: G-1159B +FROM BED +Amival 9 14 +Time +Pilots: Dave Rodgers, +• Larry Visoski +TO_ +Trip +Number +TEB +17/6 +City - +FROM Identifier Defined +BEDFORD +MA. +State or Country +TO Identifier Defined +CiY TEtERBORO +State or Country +N. J +Nautical Miles +158 +182 +Statute Miles +Galloss 900 +Pounds 3204 +9638.8 +Flight Time_ ++36 +16 +Altitude 11 EL 160 9639.4 +TAKE-OFF POWER +4 +Flex Take-Off_ +11 +Min Take-Off +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000212 + + +DATE: 6 11 2001 +mature 8.22 A +PASSENGERS +1. Jeffrey Epstein +2. +Type: G-1159B +FROM TEB +Arrival +Time +903 +9:03 +Pilots: Dave Rodgers, +, Larry Visoski +то_ MOW +Trip +Number +1717 +4. +5. +6. +7. +8. +9. +10. +11. +12. +13. +COMMENTS +FROM Identifier Defined +CY TETER BOR O +State or Country +NJ +TO Identifier Defined +City _ +CHICAGO +State or Country +IL +Nautical Miles +62| +Statute Miles +114 +Gallons 1600 +Pounds 7361 +9639.4 +Flight Time_| +40 +17 +Alitude Tz 450 +9641.1 +TAKE-OFF POWER +Night_ +Flex Take-Of 2.15 +Min Take-Off. +5 +Approach_ ILS +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000213 + + +6 11 +, 2004 +Dimature O 25 +Time +Type: G-1159B +FROM MOW +Arrival +Time +Pilots: Dave Rodgers, Larry Visoski +TO +PBI +Number +1718 +PASSENGERS +1. Jeffrey Epstein +10. +11. +12. +13. +COMMENTS +FROM Identifier Defined +City +•CHICAGO +State or Country +IL +TO Identifier Defined +City +WEST PALM BEACH +FL +State or Country +Nautical Miles +980 +1127 +Statute Miles +Gallons 006 +Pounds +9208 +Flight Time 2+25 +Altitude FL. 410 +TAKE-OFF POWER +Flex Take-Off +AIRPRAME +9641 +24 +96435 +24 +Min Take-Off +4 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000214 + + +DATE: 6.21.2004 +Repature 11: 23 +PASSENGERS +1. JEFFREY EPSTEIN +2. +3. +4. 1 FEMALE +3. BRENT TINDALL +6. +7. +8. +9. +10- +11. +12. +13. +COMMENTS +Type: G-1159B +Pilots: Dave Rodgers, Larry Visoski +FROM P.BI. +TO +TE.B. +Arrival +Time +141A +Trip +Number 1719 +FROM Identifier Defined +City_ WEST PALM BEACH +State or Country _ +FL. +TO Identifier Defined +City _ +TETER BOrO +State or Country +N.J. +Nautical Miles +900 +Statute Miles +1035 +Gallons 1355 +Pounds 9320 +9643.5 +Flight Time 2+23 +2.4 +Avitude FL_EL 450 9645.9 +TAKE-OFF POWER +Flex Take-OfF. +Min Take-OFF +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000215 + + +DATE: 6.23,2004 +Dimature 10:24 +PASSENGERS +1. Jeffrey Epstein +2. +3. +4. +5.- +FEMALE +6. FEMALE +7. +8. +9. +10. +11. +12. +13. +COMMENTS +FROM TEB +TO +Arrival +Time +12.34 e +Trip +Number +Pilots: Dave Rodgers, Larry Visoski +SAF +1720 +FROM Identifier Defined +Ciry TETERBORO +State or Country +NJ +TO Identifier Defined +City_ SANTA FE +State or Country +NM +Nautical Miles +1537 +Statute Miles +1768 +Gallons 2100 +Pounds_ 15800 +9645.9 +Flight Time 4+09 +•4.2 +Atitude FL 430 +96501 +TAKE-OFF POWER +Flex Tako-OFf 2.15 +Min Take-Off +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000216 + + +DATE: 7 +-2,2001 +Type: G-1159B +FROM SAF +Amial 4 55, +GARY ROXBURGH +Pilots: Dave Rodgers, +Larry Viseski +то_ LAS +AM +Trip +Number +172) +PASSENGERS +1. Jeffrey Epstein +2. +3. +4. +5. +6. +8. _ +FEMALE +9. +10.- +11. +13. +COMMENTS +FROM Identifier Defined +City SANTA FE +State or Country_ NM +TO Identifier Defined +City LAS VEGAS +State or Country +NV +Nautical Miles +443 +Statute Miles +509 +Gallons 1100 +Pounds 6000 +9650 1 +13 +Minto. 4308 965L4 +TAKE-OFF POWER +Night. +Flex Takc-Of +Min Take-Of 2.40 +Condition DENSDY AUT. Approach +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000217 + + +DATE: 7 2.2001 +Time +PASSENGERS +1. Jeffrey Epstein +2. +3. +4. +5. +6. +7. +8. FEMALE +9. +10. +11. +12.— +13._ +COMMENTS +Type: G-1159฿ +FROM LAS +Arrival +Time +1 43 +GARY ROXBURGH +Pilots: Dave Rodgers, barry Vigesti +To SAF +Trip +Number +1722 +FROM Identifier Defined +City _ +• LAS VEGAS +State or Country +NV +TO Identifier Defined +City _ +SANTA FE +State or Country +NM +Nautical Miles +443 +Statute Miles +509 +Gallons +900 +Pounds +5000 +9651.4 +Flight Time_| +04 +Altitude FIz 410 +TAKE-OFF POWER +Flex Take-Off +Min Take-Off +96525 +Night 1.1 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000218 + + +. DATE:7-42004 +Deparue 12: 18 0 +Time +PASSENGERS +1. Jeffrey Epstein +2. +3. +GARYROKBURGH +Type: G-1159B +Pilots: Dave Rodgers, tarry-Visustet +FROM SAF +TO_ +ASE +Arrival +Time +1.04 +Trip +AM Timber +1723 +5. +6. +7. +8. +9. +10. +11. +12. +13. +COMMENTS +FROM Identifier Defined +CiY SANTA FE +State or Country. +NM +TO Identifier Defined +ASPEN +City. +State or Country +Nautical Miles +Co +220 +Statute Miles +253 +Gallons _ +300 +Pounds_ +3800 +9652.5 +Flight Time ++45 +7 +Abitud 1 260 9653 2 +TAKE-OFF POWER +Flcx Takc-0# 235 Tr +Min Take-Off +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000219 + + +DATE: 7-4.2004 +Departure 4:45 +Time +PASSENGERS +1. Jeffrey Epstein +Type: G-1159B +FROM +ASE +Arrival +10 20 +GARY ROKBURGH +Pilots: Dave Rodgers, Laca Visoulei +TO +PBI +Number +1724 +6. +7. +8. +9. +10. +11. +12. +13. +COMMENTS +FROM Identifier Defined +City ASPEN +Co +State or Country +TO Identifier Defined +ciy_ WEST PALM BEACH +State or Country +FL +Nautical Milcs _ +1538 +Statute Miles +1769 +Gallons +1600 +Pounds +13000 +9653.2 +Flight Time +3+34 +3.6 +Altitude FL. 450 9656 8 +TAKE-OFF POWER +_1.0 +Flex Takc-Of 2.48 +Min Take-Off +3 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000220 + + +DATE: 7-1L.2004 +Departure +10:47 +PASSENGERS +1. Jeffrey Epstein +Type: G-1159B +FROM PBI +1 10 +LARRYVISOSKE +Pilots: Dave Rodgers, Laray Vinoeli +TO +TEB +Trip +Number _ +1725 +4. +1 FEMALE +5. 1 mALE +6. +7. +8. +BRENtTINDALL +9. +10. +11. +12. +13. +COMMENTS +FROM Identifier Defined +City_ +WEST PALM BEACH +EL. +State or Country _ +TO Identifier Defined +City _ +•TETERBorO +State or Country +N. J. +Nautical Miles +900 +Statute Miles +1035 +Gallons 2500 +Pounds 9365 + +Flight Time 2+22 +2.5 +Altitude F1. F2450 9659.3 +TAKE-OFF POWER +Flex Take-Off_ +Min Take-Off +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000221 + + +DATE: 7 16 +- 2004 +Departure 7 +Time +38 +PASSENGERS +1. Jeffrey Epstein +2. +Type: G-1159B +FROM +TEB +Arrival +Time +10 02 +Pilots: +Dave Rodgers, Larry Visoski +TO +PBI +Trip +Number +1726 +4. Brent Tindall +5. +6. JEAN LUC BRUNEL +1. 200 2SA +8. +CZIFRIK +9 +10. +11. +12 +13. +COMMENTS +FROM Identifier Defined +City +TETERBORO +State or Country +NJ +TO Identifier Defined +City WEST PALM BEACH +FL +State or Country. +Nautical Miles +900 +1035 +Statute Miles +Galions +1600 +Pounds 9|69 +9659 3 +Flight Time 2 24 +24 +Altitude FL +450 +96617 +TAKE-OFF POWER +7 +Flex Take-Om 2 IS +Min Take-Off +7 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000222 + + +DATE: 9-2. 2004 +Time +PASSENGERS +1. Jeffrey Epstein +Type: G-1159B +FROM +Arrival +Time +PBI +11:10 +Pilots: Dave Rodgers, Larry Visoski +TO +TEB +Trip +Number +1727 +5. +6. +7. +8. +9. +10. +11. +12. +13. +COMMENTS +FROM Identifier Defined +City +WEST +PAlm Boach +FL +State or Country _ +TO Identifier Defined +aIs TETERBORO +State or Country - +N.J. +Nautical Miles +900 +Statute Miles +1035 +Gallons /80d +Pounds _ +9234 +96617 +Flight Time 2+16 +23 +Alinde 1. PL410 966,40 +TAKE-OFF POWER +Flex Take-Off +Min Take-Off_ +HUNNICANE fRANCES +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000223 + + +DATE: 10.13 +→ 2004 +Dimenure 11: 08 +Time +Type: G-1159B +FROM +ТЕв +Arrival +Time +1 24 +PM +Pilots: +Dave Rodgers, Larry Visoski +то РВІ +Trip +Number +1728 +PASSENGERS +2. Ghislaine Maxwell +3 +4 +7 +8. +9 +10 +11. +12 +13. +COMMENTS +FROM Identifier Defined +City +TETERBORO +State or Country +NJ +TO Identifier Defined +City +• WEST PALM BEACH +State or Country +FL +Nautical Miles +900 +Statute Miles +1035 +Gallons 2300 +Pounds 8819 +Flight Time +2.16 +Altitude FL 430 +TAKE-OFF POWER +Flex Take-Off +9664 0 +23 +9666 3 +23 +1 +Min Take-Off +6 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000224 + + +DATE: 10-2 +_ 2004 +Departure +Time +5:14 +PASSENGERS +2. +3. +Type: G-1159B +FROM PBI. +Arrival +Time +1:40 +Pilots: Dave Rodgers, Larry Visoski +TO +Trip +Number +T.EB. +1729 +7. +8. +9. +10. +11. +12. +13. +COMMENTS +REpOSiTiON TO TEB. +FROM Identifier Defined +City WEST PALM BEACH +State or Country +FL. +TO Identifier Defined +City TETERBoro +State or Country +N. J. +Nautical Miles +900 +1035 +Statute Miles +Gallons +900 +Pounds 1016/ +Flight Time 2+25 +Altitude FL EL 410 +TAKE-OFF POWER +9666 3 +2.5 +9668 8 +5 +Flex Take-Off +Min Take-Off +NO PAXS +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000225 + + +DATE: 10-29 +_ 2004 +Departure +Time +16:3/ +PASSENGERS +1. Jeffrey Epstein +2. +Type: G-1159B +FROM TEB +Arrival +Time +12,366 +9 +10. +11. +12 +13. +COMMENTS +Pilots: Dave Rodgers, Larry Visoski +TO +PBI +Trip +Number +1730 +FROM Identifier Defined +City - +State or Country +TETER BOrO +N. J. +TO Identifier Defined +City WEST PALm BEAch +State or Country +FL. +Nautical Miles +900 +1035 +Statute Miles +Gallons 1350 +Pounds 7733 +96688 +Flight Time 2.05 +20 +Altitude FL F2430 8676 8 +TAKE-OFF POWER +20 +Flex Take-Off +11 +Min Take-Off +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000226 + + +. 1 +- 2004 +Time +Timeture 1:50 +Type: G-1159B +FROM PBI +Arrival +Time +11 14 +PM +Pilots: Dave Rodgers, Larry Visoski +TO TIST +Trip +Number +1731 +PASSENGERS +1. Jeffrey Epstein +2. +3 +5. +6. +7 +8. +9. +10. +11. +12. +13. +COMMENTS +FROM Identifier Defined +Cil WEST PALM BEACH +State or Country +FL +TO Identifier Defined +City ST. THOMAS +State or Country +USVI +Nautical Miles +976 +Statute Miles +1|22 +Gallons 1400 +Pounds_ +8877 +Flight Time 2 24 +Altitude FL 450 +TAKE-OFF POWER +Flex Take-Of 2 +15 +Min Take-Off +9670 8 +2 +4 +96732 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000227 + + +11-2. 2004 +Departure +Time +3:53 +PASSENGERS +1. Jeffrey Epstein +Type: G-1159B +FROM +Arrival +Time +TIS.T. +6:44 +AN +Pilots: Dave Rodgers, Larry Visoski +TO +T.E.B. +Trip +Number +1732 +5. +6. +7. +8. +9. +10. +11. +12. +13. +COMMENTS +FROM Identifier Defined +City _ +ST. THOMAS +State or Country _ +U.S.V. I. +TO Identifier Defined +City TEtERBOrO +State or Country +N. J. +Nautical Miles +1427 +Statute Miles +1641 +Gallons +2100 +Pounds_ +14566 +9673 2 +Flight Time 3+50 +3 8 +Atitude Fl. FL400 9677.0 +TAKE-OFF POWER +30 +Flex Take-Off +11 +Min Take-Off +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000228 + + +DATE: 11-5.2004 +Departure +AM +Time +8:19 +PASSENGERS +1. Jeffrey Epstein +Type: G-1159B +Pilots: +Pete RAthSEB +Dare Rodgers, Larry Visoski +FROM +Arrival +Time +TEB. +10.460 +TO +PB.I. +Trip +Number +1733 +$. JEAN LUK BrUNNEL +6. Z 7EMALE +1. VOLDSON +8. I MALE. VEFF +9. +10. +11. +12. +13. +COMMENTS +FROM Identifier Defined +City .. +TETERBORO +State or Country +N. J. +TO Identifier Defined +Ciy WEST PALM. BEACH +State or Country +E.L. +Nautical Miles +900 +Statute Miles +1035 +Gallons 1500 +Pounds +9373 +96770 +Flight Time, +226 +25 +Altitud L. EL 430 9679 5 +TAKE-OFF POWER +Night 2 +Flex Takc-Off_ +/11 +Min Take-Off +IMC — +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000229 + + +PIA TRUSELL +tany Visookt +DATE: 11-9 +- 2004 +Departure +Time +5 32 +Type: G-1159B +FROM +PBI +Arrival +Time +7.59 PM +Pilots: Dave Rodgers, +то ТЕВ +Trip +Number +1734 +PASSENGERS +1. Jeffrey Epstein +2. +6. +7. +8. +9. +10. +11. +12. +13. +COMMENTS +FROM Identifier Defined +City WEST PALM BEACH +State or Country +FL +TO Identifier Defined +City TETERBORO +State or Country +NJ +Nautical Miles +900 +1035 +Statute Miles +Gallons 1300 +Pounds +9267 +9679.5 +Flight Time +2+27 +2.5 +Altitude FL 450 9682. 0 +TAKE-OFF POWER +Flex Take-Off +Min Take-Off +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000230 + + +PIA TRUSELL +harry Visosts +DATE: 11-10.2004 +Dimanture 10. 08 +Time +Type: G-1159B +FROM +TEB +Arrival +Time +12.21 +Pilots: Dave Rodgers, +TO +PBI +Trip +Number +1735 +PASSENGERS +1. Jeffrey Epstein +2. +4. +5. +6. +7. +8. +9. +10. +11. +12. +13. +COMMENTS +FROM Identifier Defined +City +TETERBORO +State or Country _ +NJ +TO Identifier Defined +City WEST PALM BEACH +State or Country +FL +Nautical Miles +900 +1035 +Statute Miles +Gallons 1500 +Pounds +8322 +Flight Time +2,12 +Altitude FL +430 +TAKE-OFF POWER +Flex Take-Off +9682. 0 +2. +2 +9684.2 +2.2 +L1 +Min Take-Off +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000231 + + +DATE: 1/-14.2004 +Departure +12:13 +CPM +PASSENGERS +1. Jeffrey Epstein +2. +3. +4.1 +VOLSAN +5. +6. +7. +8. +9. +10. +11. +12. +13.. +COMMENTS +Type: G-1159B +FROM PBI +To_ +Arrival +Time +118 8 +Trip +Number _ +Pilots: Dave Rodgers, Larry Visoski +ABY +1736 +FROM Identifier Defined +City WEST +PAlM BEAch +State or Country +74 +TO Identifier Defined +City _ +ALBANY +State or Country +GA +362 +Nautical Miles +Statute Miles _ +416 +Gallons 200 +Pounds_5167 +9684.2 +Flight Time 1+05 +10 +Avitude 1 FL370 968 5.2 +TAKE-OFF POWER +Flex Take-Off +Min Take-Off +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000232 + + +DATE: 11-14.2001 +Departure +Time +PASSENGERS +1. Jeffrey Epstein +Type: G-1159B +FROM ABY +TO_ +Arrival +Trip +Time +6: 51(1) Mimor. +Pilots: Dave Rodgers, Larry Visoski +TEB +1737 +s. VOLDSON +6. +7. +8. +9. +10. +11. +12. +13. +COMMENTS +FROM Identifier Defined +City ALBANEY +State or Country _G A +TO Identifier Defined +Cily STEtErBoro +State or Country _ +N.J +Nautical Miles +743 +Statute Miles +854 +Gallons _900 +Pounds 7720 +96852 +Flight Time / +56 +20 +Atitude 71 22 418 96872 +TAKE-OFF POWER +Nigh 1 7 +Flex Take-OFF +111 +Min Take-Off +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000233 + + +DATE: 11 16 2001 +Time +Departure 9:16 +PASSENGERS +1. Jeffrey Epstein +Type: G-1159B +FROM TEB +Arrival +Time +9.55 +Pilots: Dave Rodgers, Larry Visoski +To_BED +Trip +Number +1738 +3. +4. +5. +6. +7. +8. +9. +10. +11. +12. +13. +COMMENTS +FROM Identifier Defined +City_TETERBORO +NJ +State or Country - +TO Identifier Defined +City _ +BEDFORD +State or Country +MA +Nautical Miles +158 +182 +Statute Miles +Gallons_ +800. +Pounds_ 3647 +Flight Time ++39 +9687.2 +6 +Altitude FL 130 +9687.8 +TAKE-OFF POWER +• Night +Flex Tako OfF 2.15 +TAL +Min Take-Off +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000234 + + +DATE: 11-16.2004 +pau 10:34 +PASSENGERS +1. Jeffrey Epstein +2. +3. +4. +5. +6. +7. +8. +9. +10. +11. +12. +13. +COMMENTS +Type: G-11595 +FROM BED +Arrival 11:10 +Time +Pilots: Dave Rodgers, Larry Visoski +- то TEB +Trip +PM +Number | 739 +FROM Identifier Defined +Ciy BEDFORD +State or Country +MA +TO Identifier Defined +City _ +TETERBORO +State or Country +NJ +Nautical Miles +158 +182 +Statute Miles +Gallons 300 +Pounds +3058 +9687.8 +Flight Time ++36 +Altitude FL 160 +9688" +4 +6 +TAKE-OFF POWER +Flex Take-Of 2.15 TI +Min Take-Off +Night_ +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000235 + + +DATE: 1/ -/8.2004 +Departure +Time +10:01 +PASSENGERS +1. Jeffrey Epstein +2. +3. +DAVID MULLEN +Type: G-1159B +FROM +Arrival +Time +TEB +12:10 +Pilots: Dave Rodgers, Larry Visoski +TO +PBI +Trip +Number +1740 +6. +7. +8. +9. +10. +11. +12. +13. +COMMENTS +FROM Identifier Defined +City +TETERBOFO +State or Country +N. J. +TO Identifier Defined +Ciy WEST PALM Bsach +State or Country. +F.L. +900 +Nautical Miles +1035 +Statute Miles +Gallons 1300 +Pounds_ +7940 +9688 4 +Flight Time 2-08 +21 +Altitude FL_FL430 +9690 5 +TAKE-OFF POWER +Night 2./ +Flex Take-Off +Min Take-Off +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000236 + + +DATE: 1l +Departure +Time +.26.2004 +50 +PASSENGERS +Type: G-1159B +FROM PBI +Arrival +Time +501 +Pilots: Dave Rodgers, Larry Visoski +TO_TIST +Trip +Number +1741 +2. Ghislaine Maxwell +8 +9. +10. +11. +12. +13. +COMMENTS +FROM Identifier Defined +city WEST PALM BEACH +State or Country _ +FL +TO Identifier Defined +ST. THOMAS +City +State or Country +Nautical Miles +USVI +976 +1122 +Statute Miles +Gallons +1300 +Pounds_ +8569 +Flight Time +2.10 +Altitude FL 450 +TAKE-OFF POWER +Flex Take-Of 2 I5 +Min Take-Off +9690 5 +22 +96927 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000237 + + +DATE: 12-13 +_ 2004 +Departure +Time +4:35 +PASSENGERS +1. Jeffrey Epstein +2. DAND MULLEN +Typ: G-1159B +FROM +Arrival +Time +TIST +6:11 +Pilots: +TO +Trip +Number +Bill Hannond +Đave Rodgers, +Larry Visoski +PBI +1742 +5. 1 FEmALE FAX +6. +7. +8. +9. +10. +11 +12. +13. +COMMENTS +FROM Identifier Defined +City. +St. ThomAs +State or Country - +TO Identifier Defined +City WEST +PALM BEACh +State or Country +EL. +Nautical Miles +976 +Statute Miles +1122 +DR FuEL +Gallons 600 +) +Pounds _ +9768 +Flight Time 2+33 +Altitude FL FL 430 +TAKE-OFF POWER +9692 7 +2'.5 +9695.2 +5 +11 +Flex Take-Off_ +Min Take-Off +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000238 + + +DATE: 12.14 +_ 2004 +Departure +Time +1012 +PASSENGERS +1. Jeffrey Epstein +2. Ghislaine Maxwel +Type: G-1159B +FROM +PBT +Arrival +Time +12.22 PM +Bill HammaD +Pilots: +Dare Rodgets, +Larry Visoski +TO +Trip +Number +TER +1743 +3. ВАкоК +6 1 55. SOChel SERVICE. +1. / S5. SEnCRET SERUCE. +8. / FEMALE +9. / 70mALE +10. +11. +12. +13. +COMMENTS +FROM Identifier Defined +cis wEst PALm Bch +State or Country +TO Identifier Defined +CiN TEtERBOrO +State or Country +N.J. +Nautical Miles +900 +Statute Miles_ +1035 +Gallons 100(1127-04) +Pounds +8238 9685 2 +Flight Time 2 10 +2 / +Altitude Fl F4410 9697 3 +TAKE-OFF POWER +Night 2! +Flcx Takc-Off_ +T/L LI/ +Min Take-Off +IMC _ +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000239 + + +DATE: 12-17.2004 +Departure +Time +8:10 +PASSENGERS +1. Jeffrey Epstein +2 +Type: G-1159B +FROM TEB +Arrival +Time +10:35 +PM +Pilots: +TO +Trip +Number +BILL HAmmOND +Dare Rodgers +Larry Visoski +PBI +1744 +8. +9. +10. +11. +12. +13. +COMMENTS +FROM Identifier Defined +ciy TEtER Boro +State or Country +N.V. +TO Identifier Defined +city wist PALm Bch +State or Country +F.L. +Nautical Miles +900 +Statute Miles +1035 +Gallons /300 +Pounds +9483 +9697.3 +Flight Time +225 +25 +Altitude FL FLB90 9699. 8 +TAKE-OFF POWER +Night_ 2.5 +Flex Take-Off +Min Take-Off +IMC _ +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000240 + + +DATE: 12 21,2001 +Departure 8.44 +PASSENGERS +1. Jeffrey Epstein +2. Ghislaine Maxwell +3. +4. +5. +6. +7. +8. +9. +10. +11. +12. +13. +COMMENTS +Type: G-1159B +FROM PBI +A 11530 +Time +STEVE LESTER +Pilots: Dave Rodgers, Harry Visusta +TO TIST +Trip +Number +1745 +FROM Identifier Defined +CiE WEST PALM BEACH +FL +State or Country +TO Identifier Defined +City _ +ST. THOMAS +Stato or Country _USVI +Nautical Miles +976 +Statute Miles +||22 +Gallons 1300 +Pounds_ +9173 +Flight Time 2 + 08 +Altitude FL +450 +TAKE-OFF POWER +Flex Tako-OIl 2.15 +Min Take-Off +9699.8 +21 +9701.9 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000241 + + +DATE: 12 29.2001 +Departure +Time +" 10.21 S +PASSENGERS +1. Jeffrey Epstein +2. Ghislei +3. +4. +5. +6. +7. +8. +9. +10. +Il. +12. _ +13. +COMMENTS +Type: G-1159B +Pilots: Dave Rodgers, Larry Visoski +FROM TIST +TO INCM +me 10:48 A Tip +Time +Number +1746 +FROM Identifier Defined +City _ +ST. Thones +State or Country - +USVI +TO Identifier Defined +City _ +St. MAARTEN +State or Country _ +NETHERLANOS ANTILLES +Nautical Miles +108 +Statute Miles +124 +Gallons 1302 +Pounds 2702 +Flight Time. +_+26 +97019 +Altitude EL ELI1O +_ 9702.4 +TAKE-OFF POWER +Flex Takc-Off +Min Take-Off +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000242 + + +DATE: 12.29.2004 +Depare 4: 09 AM +Tine +PASSENGERS +1. Jeffrey Epstein +2. Guislaine Ifaowel! +Type: G-1159B +FROM TNCM +Arrival +Time +4:38 A +Pilots: Dave Rodgers, Larry Visoski +TO_ +Trip +Number_ +TIST +1747 +5. +6. +7. +8. +9. +10. +11. +12. +13. +COMMENTS +FROM Identifier Defined +cir St. MAARtEN +State or Country +NETHORLANAS ANT. +TO Identifier Defined +City St. ThomAs +State or Country +U.S.V.I. +Nautical Miles +108 +Statute Miles +124 +Gallons +AIRERAME +Pounds +2789 +9702.4 +Flight Time ++28 +5 +Atitude FI F4100 9702.9 +TAKE-OFF POWER +Flex Takc-Off +Min Take-Off +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000243 + + +AUG-14-2006 (MON) 14:41 +81/89/2805 16:15 5614785553 +P. 001/029 +PAGE 0Б +'Registration Nuraber N909JE Type: G-1159B +Pilots: Dave Rodgers Karry Visoskl +DATE:L-1.2003 +TROM TIST +TO TQPE +Ami 10 :17 +(AM) Trip +Tinber 1748 +PASSENGERS +1. Jeffrey Epsteit +4. David Mullen +5. +6 JEAN LUC BRUNEL +7. +8. +-- +10. +Il. +12. +13._ +COMMENTS +EROM Identificr Detined +Cil_ ST. THOMAS +Stato or Country. USVI +TO Identifier Delined +Cy_ WALL BLAKE +state ur Country ANGUILLA +Nautical Miles_ +110 +Statute Miles +127 +Galons, +1302 +Ports 2.699 +rieta ime_ + 26 +Althude FL 150 +TAKE-OET POWER +Flex Take-Off +Min Take-Off +ATRFRAME +9702.9 +4 +9703.3 +Night_ +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000244 + + +AU6-14-2006(MON) 14:42 +81/89/2885 15:15 + +P. 002/029 +PAGE 05 +Type: G-1159B +DATE: 1-2005 +Tamar 2: 11 +Time +FROM TQPE +Time +Amia 4:09 +PASSENGERS +1. Jeffrey Epstein +2 +3. +4. David Mullen +5. +6. JEAN LUC BRUNEL +7. +8. +9. +10. +11. +12. +13.- +COMMENTS +• - +Pilots: Dave Rodgers, Larry Visoski +то РВІ +Tabee 1749 +FROM Ideatider Deflued +ay WALLBLAKE +State or Country ANGUILLA +TO Ideptifier Delined +GWEST PALM BEACH +State or Country. +FL +Netical Mile. _... +1073 +Statute Milles _ +1234 +Gallons _ +Pounds 10345 +9703.3 +Flighe Time 2,5B +3.0 +Altitude FL +430 +9706 +- 3 +TAKE-OFF POWER +Nighe__ +Flex Take-Off__— +T/L. +Min Take-Off__:- +TMC +2 +Coudition _ +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000245 + + +AU6-14-2006(MON) 14:42 +01/89/2885 15:15 5614786553 +P. 003/029 +PAGE B4 +Rogistration Number: N909JE +DATE: 1- 3,2005 +10 4 0488 +PASSENGERS +1. Jeffrey Epstein +2. +3. +Type: G-1159฿ +FROM PBI +Amial 6.320 +Time +Püots: Dave Rodgers, Larry Visoski +1 GhishamE +MARNELL +7. +8. +9. +10. +1L. +12 +13. +COMMENTS +Number +1750 +FROM Identifier Deflaed +Cir WEST PALM BEACh +State or Country FiL +TO Ideotifer Delised +cily TetERBora +State or Country - +N.J. +Nautical Miles _ +900 +Statute Miles_ +1035 +Gallons_ 18.00 +Porado 9520_ +9706.3 +Fight Tine 2t28 +25 +TAKE-OFF POWER +Flex Take-OfF__. +Mio Tako-Off_ +NightL.0 +T/L. +Approach — +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000246 + + +81/89/2885 15:15 5614786553 +P. 004/029 +PAGE 83 +Registration Number: Nº09JE +DATE: 162005 +Dimera 9:22 +Time +PASSENCERS +1. Jeffiey Epstein +2. +3. +Type: G-1159฿ +mOM TEB +A 11:50 +Time +Pilot: Dave Rodgers, Larry Visorki +• TO +PBI +Number +11S) +6. +7. +8. +9. +10. +11._ +12. +13._ +COMMENTS +FROM Ideatifler Defiacd +CY TETER BORO +State or Country _ +_NJ +TO Identifier Defined +CRy WEST PALM BEACH +fL +State or Country. +Nautical Miles +900 +Statute Miles, +1035 +Gallons 1400 +9o1s +9708.8 +Pounds +Flight Time 2,28 +2.5 +Altitude ET 430 +9711.3 +TAKE-OFF POWER +Night.. +2.5 +Flex TakeOF 215 TA. +Min Take-OfT. -_ +2 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000247 + + +81/89/2885 15:15 5614786553 +P. 005/029 +PAGE 82 +Registration Number: N909J8 Type: G-1159B +DATE: 172003 +Degene 8 : 09 +AM +Time +FROM PBI +Pilots: Dave Rodgers, Larry Visoskl +PSW +AM +me 8:30 P +TO _ +Trip +Number +1252 +PASSENGERS +9. +10. +11. +12. +13. +COMMENTS +FROM Identifier Defined +ay west Palm Bch +Stats or Country - +_FL +TO Identidler Defined +cry 7t. MysAs +State or Country +FL. +Nautical Miles_ +89 +Sante Miles_ +102 +Cations 500 +Pounds 2/89 +921L3 +Flight Time_+ 2/ +Altitude Fl. ELIZA +TAKE-OFF POWER +Flex Take-Off _ :_ +Min Take-Off —: +Condition. +9711.7 +IL. — +LMC - +com SCAN INSP. +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000248 + + +81/89/2885 15:15 5614706553 +P. 006/029 +PAGE 81 +Registration Number: N909JE Type: G-1159B +DATE: 1-8 2005 FROM RSW +Time +4.59. +Pilots: Dave Rodgers, Larcy Visoski +PBI +TO +Trip +Number, +1753 +PASSENGERS +2 +3. +9. +10. +11- +12 +13. +COMMENTS +FROM Identifier Defined +City, +ET. MYERS +State or Country _ +FL +TO Ideatifier Deloed +Cir_ WEST PALM BEACH +State or Country _ +FL +Nautical Miles. +89 +Statute Miles +102 +Galloas _ +Pounds 1803 +AIRPRAME +9711 +Flight Time _ ++23 +Altitude FI_ +070 +TAKE-OFF POWER +Flex Tako-O#—:_ +Min Take-Off_ +Condition _— +4 +9712 L +Night_ +T/L. +Appcosch +RETURN FROM COMSCAN INSPECTION +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000249 + + +AU6-14-2006(NON) 14:42 +P. 007/029 +DATE: 2-10_2005 +Time +Time 10:37 +PASSENGERS +1. NEIL +2. BIGGIN +3. +Type: G-1159B +FROM PBI +Arrival +Time +1123 +PETE RATHGEB +Pilots: Dave Rodgers, any Yaos +PBI +TO +Trip +Number +1754 +5. +6 +7. +8. +9. +10. +11. +12. +13. +COMMENTS +TESS FLIGHT +ENGINE FUEL FLOW +AUTOPILOS +FROM Identifier Defined +City WEST PALM BEACH +State or Country FL +TO Identifier Defined +City WEST PALM BEACH +State or Country +FL +Nautical Miles +Statute Miles, +Callons 850 +Pounds 4000 +Flight Time _ +_+45 +Altitude FL. 150 +9712.1 +8 +9 +9712 +TAKE-OFF POWER +Flex Take-Ort 2.15 +Min Take-Of__ +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000250 + + +P. 008/029 +DATE: 2.192005 +Departure +Time +_05 +PASSENGERS +Type: G-1159B +FROM PBI +Arrival +Time +1:16 +GARY ROXBURGH +Pilots: Dave Rodgers, tany timeshir +TIST +TO +Trip +Number +1755 +2 + 1 FEMALG +3. +5. +6. +7. +8. +9. +10. +11. +12. +13. +COMMENTS +FROM Identifier Defined +Ciry WEST PALM BEACH +State or Country FL +TO Identifier Defined +Ciy ST. THOMAS +State or Country _ +USVI +Nautical Miles _ +Statute Miles +Gallons 1200 +Pounds_ +8564 +9712.9. +Flight Time 2+11 +2.2 +Altitude FL. 430 +971S 1 +TAKE-OFF POWER +Flex Take-Ort 2.15 +Min Take-Of_- +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000251 + + +P. 009/029 +DATE: 2-192005 +Deper 6 :18 +Time +Type: G-1159B +FROM TIST +Arrival +Time +7.58 +PASSENGERS +.GHISLAINE MAKWELL +AM +GARY ROXBURGLI +Pilots: Dave Rodgers, Łarry Tsuski +TO +PBI +Trip +Number, +1156 +3. CRES VALDEZ +9. +10. +11. +12. +13. +COMMENTS +FROM Identifier Defined +Ciry_ ST. THOMAS +State or Country_ USUI +TO Identifier Defined +CIy WEST PALM REACH +State or Country +fL +Nautical Miles _ +Statute Miles +Gallons_ +1400 +Pounds 11856 +9715 1 +Flighe Timo 2 39 +2 +Altiude FL. 2,60 +9717 +.7 +TAKE-OFF POWER +Nigh_L0 +Flex Takc-OfF l.. +Min Take-Off 2.40 +_.8 +Condition WZNOS IK-AL Approach +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000252 + + +84/87/2885 16:53 + +P. 010/029 +PAGE 01 +DATR: 22 22,2005 +Depasture +Time +12 37 +PASSENGERS +1. Jeffrey Epsteit +Type: G-1159B +FROM_PBI.. +Arrival +Tine +12.566 +B. MAMMOHO +Pilots: Deme Rodgor, Larry Visosk +TO_ +Trip +Number +TEB +1257 +• VAmES Stalay +5. SaphiA Strarley +6. ALEXA StaulEy +StANLEY +8. DARiO MULLEN +9. +10. +11. +12. +13., +COMMENTS +FROM Idostilier Defined +Ci WEST. PALM BEACH +State or Country EL +TO Identifier Defined +CAy PEtERRORO +State or Country N. J +Nautical Miles _ +Statute Miles _ +Gallons 1.700 +Pounda 8895. 9727.7 +Flight Time 2+18 +23 +Ahinude Fl EL 410 9720.0 +TAKE-OFF POWER +Flex Take-Of_ +TAL +Min Take-OIT_ +Coodicion_ +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000253 + + +84/87/2885 16:53 + +P. 011/029 +PAGE 82 +DATE: 22024 2005 +Пера 1: 04 +Time +PASSENGERS +1. Jeffrey Epstein +Type: G-1159฿ +FROMTEB. +3:400 +Pilots: Dave Rodgers, Larry Visoski +TO PBI +Trip +Number +1258 +6. +7. +8. +9. +10. +11. +12. +13. +COMMENTS +FROM Identifier Defined +Ci TEtEn Boro +Stas or Coudy N.J. +TO Ideatifer Defined +cy_WEST PALM Beach +Suare or Country EL +Nautical Miles +Statute Miles +Callons 1500 +Posads 9765 +9720.0 +Flight Time 2-36. +26 +Aliade FL EL 430 9722.6.. +TAKE-OFF POWER +Flex Tako-Off _ +Min Thic-Off _.: +Condition . - Approach — +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000254 + + +AUG-14-2006 (MON) 14:42 +84/07/2885 16:53 5614786553 +P. 012/029 +PAGE 83 +Registration Nazaber: N909JE Type: G-1159B +DATE: 3 8 2005 FROM PBI +peat 6:10, +Atival +Time +835 +PASSENGERS +BAL MURPHY" +Pilots: Dave Rodgers, Attry Ybosks +TO. +SAN +Trip +Number +1759 +2. Ghislaine Maxwell +3. +4. +5.. +6... +7. +8. +9. +10. +11. +12 +13.- +COMMENTS" +FROM Identifier Defloed +cir WEST PALM BEACH +State or Country. FL +TO Identifier Defined +IT SAN DIEGO +State or Country. +CA +Nautical Miles +Statute Miles +Gallons 3,291 +Pounds 19427 +97226_ +MA F50 97280 +TAKE-OFF POWER +Nistet.. +Flex Take-Off_.i +Min Take-OR_ +3 +Approscta Loc +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000255 + + +AUG-14-2006 (MON) 14:43 +84/07/2885 16:53 + +P. 013/029 +BILL MURPHY +Registratiuu Number: N90BJE +Type: G-11598 +Pilots Dave Rodgers, tenny tiroute +DATE: 3:13.2005 +EROM SAN +To MDW +a 2:230 a 7.40% m 1760. +• PASSENGERS +z Ghislaine Maxwell +3. +4. +5. +6. +7. +8. +9. +10. +I1. +12. +13.- +COMMENTS +FROM Identilier Defined +CIO SAN DIEGO +• State or Country __ +CA +TO Identifier Defined +cy CHICAGO +State or Contry - +IL +Nautical Miles +Statute Miles +Gallons_ 1700 +Pauds 13332 9128.0 +Flight Time +3.1 +3.83 +Avituado s 330 +9731 +3 +TAKE-OFF POWER +3 +Min Take-Off _- +IMC _ +Approsch_ +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000256 + + +AUG-14-2006 (MON) 14:43 +84/87/2285 16:53 5614766553 +JEGE OR HYPERIEN AIR +P. 014/029 +PAGE 85 +Registration Nuraber: N909JE +DATE 3.14,2005 +a 3.01 AN +PASSENGERS +Туре: G 1159B +FROM MOW +Arrival +Time +530 Miner. +BELMURPHY +Pilots: Dave Rodgers, bang Ybootim +TEB +1761 +2. Ghislaine Mextell +3. L MALE +4. +5. +6. +7. +8. +9. +10. +11. +12. +13. +COMMENTS +EROM Identifier Defined +City +CHICAGO +State or Country - +IL +TO Ideutifier Delined +City _. +TETERBORO +Saite or Country +NJ +Nautical Miles +Statute Miles +Gallos_ 1300 +Pouca +6348 +Atitudo Ft 330 +TAKE-OFF POWER +Тох тако-ОП 2.15 +Min Tako-Off_.- +9731.3 +1.5 +9732 8 +IMIC +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000257 + + +84/87/2885 17:29 5614786553 +JEGE OR HYPERTON AIR +P. 015/029 +PASE 81 +Registration Number. N909JE . Type: G-1159B +DATE: 3-17.2005 FROM TEB +To TEE +тро 4 : 03 +Amival +Tlate +4.31 M Tator. +1762 +PASSENGERS +1. Jefficg Lestein +arry Visos +5. +6. +7. +8. +9. +10._ +11- +12, +13. +COMMENTS +MAINTENBNCE +TEST- PRESSUrEATION +FROM Identifier Defed +City TETERBORO +State or Country_ +NT +TO Identifier Deflned +City TETERBORO +State or Country NS +Nautieal bales _ +Statute Miles_ +92 +Galton 3,59 +Ponds 2409 +-9732.8 +Flight Time _0+28 +Atinde sz 12,092 +9733 3 +KAKE-OEF POWER +Night_ +Fox Takc-Off.3.15. IlL +Min "Take-Off +Condidon_ +. Approsch +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000258 + + +AU6-14-2006(MON) 14:43 +84/87/2085 17:29 + +P. 016/029 +PAGE 82 +Registracion Number: N909JE +DATE: 3-2Z2005 +Переше 7:49 +Tirae +PASSENGERS +1. Jeffiery Epatein +2. Giste-Max well +Bill HAm-ens +Type: G-1159B +Pilots: Dave Rodgeis, Larry Visoskd +FROM TETERBORO TO TETERIORO +Arrival +Tiave +8:33 +Trip +Numbe: 17 6 4 +5. +6. +7. +8. +9. +10. +11. +12. +13. +COMMENTS +MEINTENANCE +FROM Identifier Defined +City TETERBORO +State or Comnry_NJ +TO Idestiler Delined +CiY TETERBORO +State or Contry N5 +Nautical Miles_/ 2 6 +Suante Miles _ 146 +Cations 517 +Pounds_ 3465 +92333 +Flighe Tine 0.44 +..7 +Alitude FL 200 +9134.0 +TAKE-OFF POWER +Night . 7 +Flex Take-OFF 2,15 +Min Take-Off_ +Condicion_ U PA +- Approach +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000259 + + +O S +ЗНАЛНЯТА +2458 +190 3030 +027 г3BP223 +А МОІЯЗЧУН +T23 +I solstiga +Bill Hammond +cotrit som +49% +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000260 + + +04/87/2085 17:29 + +P. 017/029 +PAGE 83 +DATE: 3223,2005 +Depate 12 : 224 +AM +Time +PASSENGERS +1. Jetincy ERstein +2. Ghislnice M +well +Type: G-1159B +FROM +KTEA +Arrival +Time +1:34 +AM +Bell Hammons +Pilotx: Isme-Redgers, Linry Vinosid +To... +KTEA +Trip +Number_ +- 1764 +9. +10. +11. +12. +13. +COMMENTS +MAINTENANE & +IEsT FLyhT +FROM Ideatifier Defloed +Cly I ETERAORO +State or Country N$ +TO Identifier Delined +City TETERAIRO +State or Country NT. +Nautical Miles 2 5° +Statute Miles _ +287 +Gallons _ +:990 +Pounds6600 +Plight Time_ L+07 +Altitudo FL 2/0 +TAKE-OFF POWER +Flex Taks-OF_...: +Min Tako-Off_- +T/. 411. +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000261 + + + +P. 018/029 +DATE: 3-25,2005 +Departure +Time +2:19 +PASSENGKRS +1. Jeffrey Epstein +2 G +well +Type: G-11598 +FROM TEB +Anival +Time +4:08.000 +Pilots: Dave Rodgers, Jarry Visostal +TO_KSAV +Trip +Number 1765 +6 +7. +8. +9. +10._ +11.- +12. +13. +COMMENTS +MAMTENANCE +POLITIeN flught +I. LuLfsTerAm +SERVICE CONTEr +FROM Identifler Defined +Cly TETERBORD +State or Country NJ. +TO Identifier Delioes +ciy SAugiNa 2 +State or Country GA.. +Nautical Miles 752 +Statute Miles 8 65 +Gallons (327 +Pounds _ 8 2 2 3 +Flight Time_L+4 9 +Altitude FL 370 +TAKE-OFF POWER +97351 +1.7 +9736.8 +Nigh__ +Flex Tako-Off_ +Min Tako-OfF_ +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000262 + + +84/87/2885 17:29 5614786553 +P. 019/029 +PAGE 85 +Registration Number: N9091E +DATE: _ +4.22005 +Depesture +Titue +3.59 +PASSENGERS. +1. Schirey Besteis +2 +Type: G-1159฿ +FROM +Arrival +Time +Pilots: Dave Rodgers, Larry Visorki +SAV +- TO PRI +5:00 m +Trip +Number +1766 +10. +11. +12 +13. +COMMENTS +AMAiNTENANCE +REpoStioN +FROM Identifier Defined +CIYSAVANMAL +State or County... 6, A +TO Ideatifier Defined +ay west PAlm Bench +State or Country +EL +Nautical Miles +Statute Miles +Gelions +Pounds_ 5/669 +Flight Time_/+00 +Altinado FL FL 320 +TAKE-OFF POWER +Flcs Take-OFF_ +Min Tako-Ofr..._.- +9736.8 +LO +9737.8 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000263 + + +84/87/2085 17:29 + +P. 020/029 +PAGE 06 +Registration Number: N9U9JE. Type: G-1159฿ +DATE: 45 .2005 PROM PBI +Deputa 3:36 +Time +Ama 4.59 +PASSENGERS +Pilots: Dave Rodgers, Lacty Visoskd +XO PPK +Trip +Number +1767 +2. Ghislaine Maxwell +3. +6. +9. +10. +11. +12. +13. +COMMENTS +FROM Identifler Deflaed +ci_ WEST PALM BEACH +State or Country +FL +TO Ideotlfer Defined +Cy ATLANTA +State or Country +GA +Nautical Milles +Statute Miles +Galons. 900 +AIRERAMI +Ponds_ 6600 +9737.8 +Flight Toe 1 .22 +1.4 +Altido FL 410 +9739.2 +TAKE-OFF POWER +Night.. +Flex Take-Off_ +T/L. +_.. +Min Taka onr 2.15 +IMC — +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000264 + + + +P. 021/029 +PAGE 87 +Registration Nuraber: N909JE Type: G-1159B +DATE: 4.5,2005 +FROM POK +Dopen 6.51 +Arrival +Time +8.29, +Plot: Dave Rodgers, Larry Vboski +- то ТЕВ +Timber_ +-1768 +PASSENGERS +1. +2 Ghislaine Maxwell +6. +7. +8. +9. +10. +11.. +12. +13. +COMMENTS +FROM Identifer Detined +OTO ATLANTA +State or Country _.. +GA +TO Ideadfler Defined +Cly. +TETERBORO +State or Country — +NJ +Nautical Miles_ +Statute Miles +Callos_ 400 +Potada, +7500 +9739.2 +Flight Time 1.37 +1.6 +Altade FL +4/6 +97408 +TAKE-OFF POWER +Nigh 3 +Flex Take-OE 2.12 +. T/. —/ +Min Take-Off __— +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000265 + + + +P. 022/029 +PAGE 8B +DATE: 4.8.2005 +De 7 : 41 +Tipe +PASSENGERS +1. Jeffrey Epstein +2. Chris +Type: G-11598 +FROM TEB +Tiroe +Ama 10 02 +B. HAMOND +Pilots: Dare Rodgers, Larcy Visosk +TO_ +PBI +Tribos 1769 +FROM Ideatifier Defloed +CIY TETERBORO +9. +10. +11. +12. +13. +COMMENTS +TO Identiller Defined +O WEST PALM BEAch +State or Constry EL. +Nautical Milles, +Statnte Milles +Gallom 1400 +Ponds_ 8900 +97408 +Flight Time 2.21 +2:3 +Altitude FL. FL430 +97431 +TAKE-OFF POWER +Nighe_L O +Flex Take-Of —— +Min Take-Off_— +Condition —_ +_ Approach — +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000266 + + +AUG-14-2006 (MON) 14:44 +85/28/2885 13:08 + +P. 023/029 +PAGE 18 +Plots: +4.122.2005 +Departure +Time +6:20 +PASSENGERS +1. Jefficy Epstein +2. +Type: G-1159B +FROM PBI +Arrival +Tane +8 26 +Trip +Number +I. Hamo +Dere-Rodgoms, Larry Visosk +TIST +1270 +7. +8. +9. +10. +1l. +12. +13. +COMMENTS +FROM Identifier Defised +CHy WEST. PALM BEACH +State or Country EL +TO Identifier Delined +cry ST. ThomAs +State or Country +UNKI +Maciol Miles 975 +Stanate Miles /12| +Gallons 1200. +Pounds 6425 +Flight Time 2.D5 +Altitude Fl. EL410 +TAKE-OFF POWER +Flex Take-Off —_ +Min Take-Of__. +97431 +2L +97452 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000267 + + +AU6-14-2006(MON) 14:44 +85/28/2885 +13:80 + +P. 024/029 +PAGE 68 +DATE: _ +4-172005 +Deperture +Time +10.08 +PASSENGERS +1. Jeffrey Epstein +Type: G-1159B +FROM +TIST +Arrival +Time +139 +Pilots: +Bute-Rodgers, Larry Visoske +TO_ +TGB +Trip +Number_ +1771 +7. +8. +10. +11. +12. +13. +COMMENTS +FROM Ideattler Delined +CHY_ST. ThomAS +State or Country_ +USVI +TO Identifier Defined +CIN TETERBURO +State or Country ... +Nautical Miles_/ 42/ +Stacute Miles 16 39 +Gallons 2000_ +Pounds 11030 +2745.2 +Flight Time 3+30 +3.5 +Alioude TL E2400 9748 7 +TAKE-OFF POWER +Night_ +Condition.. +IMC . +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000268 + + +05/20/2005 13:08 + +P. 025/029 +PAGE 86 +Rogistration Number; N909JE Type: G-1159฿ +DATE: 4 +--27 2005 +Pe 9 :17 +FROM TEB +AmvE +Time +11 S8 +PASSENGERS +1. Jeftrey Epstein +2. Ghislaine Maxwell +D.AlAmna +Pilots: +Dave Rodgers, Larry Visogki +TO. +PBI +Tríp +Number _ /772 +5. L MALE +6. 1 moLe +1. Lemalt +8. +9. +10. +1L +12. +13. +COMMENTS +FROM Ideatifier Defined +CiyTeteRBoro +State or Country N.T. +TO Ideatifier Defined +CAy WEST PALM BEACh +State or Country ELa +Nautical Milles _ +Statute Mlles _. +Gallons 2/00. +Ponds 1/085 9748 7 +Figin Tioe 2+40 +2.6 +Altinude FL EL400 975/.3 +TAKE-OFF POWER +Night — +Fles Take-Off- +Min Take-Of_..: +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000269 + + +05/20/2005 13:08 + +P. 026/029 +Registration Number: N909JE Type: G-1159B +DATE: 429 +→2005 +FROM PBI +Deperso g +Time +22 +Arrival +Time +10:28(M +PASSENGERS +1. Jeffrey Epstein +Pilots: Dave Rodgers, Larry Visoski +Io TIST +Trip +Number_ +1773 +5. VALOSON COTRIN +9. +10. +I1- +12 — +13. +COMMENTS +FROM Identificr Defiued +Cir WEST PALM BEACH +State ur Couty_ FL +TO Identifier Defined +Giy ST. THOMAS +Stale or Country_ USVI +Nautical Miles +Statute Miles_ +Galtons_ 1650 +Pounde_8900 +9751.3 +Flight Time 2 +06 +Atritude FL. 390 +9753.4 +TAKE-OFF POWER +Nigte 2.1 +Flex Teko-OE 2 15 +-Tl 1/1 +Min Take-Off ___:— +MC 1.9 +Approsch, +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000270 + + +85/28/2805 13:00 +. 5514786553 +P. 027/029 +PAGE 82 +DATE: 5.4,2005 +Do 3 07 +Time +PASSENGERS +1. Jeffrey Epstein +Type: G-1159B +FROM TIST +Arrival +7.01 +Pilots: Dave Rodgers, +то ТЕв +Trip +Number +1774 +3, VALDSON COTRIN +9. +10. +11. +12 +13. +COMMENTS +FROM Identifier Delived +Cy ST. THOMAS +State or Country_ +USVI +TO Identifier Defined +City +TETERBORO +State or Country — +NT +Nautical Milles +Statute Miles +Gallons_ +3081 +Pounds 17265 +9153.4 +nige Tie 3.54 +39 +Altitude FL. +380 +91513 +TAKE-OFF POWER +Night → +Flex Take-Of—__ +I/L +... +Min Take-OFF 2.41 +Condition FuLL FUeL +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000271 + + +85/28/2885 13:08 + +P. 028/029 +PAGE 17 +Registradon Number: N909JE +DATE: 5-6 2005 +Dete 9 : 10 +Time +PASSENGERS +1. Jeffrey Epstein +2. +3. +Type: C-11598 +FROM TER +Artel // +Time +27 +Pilots: Dave Rodgers, Larry Visosk +TO BBI +Trip +Number +1725 +1 ZENALE +'Leory morrison +9. +10. +11. +12. +13. +COMMENTS +FROM Identifier Defined +City _ +TEtERBORO +State or Country _ +N.J. +TO Identifier Delined +CIY WEST PALM BEALI +State or Country. +Ele. +Neutical Miles +Starute Miles +Gallons +500 +Pounde 8926 +97573 +Flight Time 2+1a +2.3 +Altitude FL E430. +91596 +TAKE-OFF POWER +Night_ +23 +Flex Take-Of__ +Min Taio-OFT..:- +IMC - +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000272 + + +85/28/2885 13:88 + +P. 029/029 +PAGE 15 +Registration Number, N909JE Type: G-1159฿ +S.10.2005 +FROM PRI +де 4.34 +AM +6:57 +PASSENGERS +1. Jefficy Epstein +Pilots: Deve Rodgers, Larry Visosk +то TEB +Time 1.776 +4. David Mulleu +9. +10. +11- +12. +13._ +COMMENTS +FROM Ideatifier Defined +cir WEST PALM BEBCH +State or Country +FL +TO Identifier Delined +CIr TETERBORO +State or Country _ +NJ +Nautical Miles_ +Statute Milles +Gallons +1300 +Pounds +9850 +9759.6 +Flight Time 2+23 +2.4 +Atade FL._ 45° +97620 +TAKE-OFF POWER +Night _ +Flex Tato-OB 2.15 +I/L +Min Tako-Off —— +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000273 + + +85/28/2085 +13:00 + +P. 001/032 +PAGE 13 +Registration Number, N909JE +DATE: 5.19,2005 +Departure 75 l +Time +PASSRNGERS +1. Jeffrey Epstein +Type: G-1159฿ +FROM TEB +A 1012 AM +Time +BILL HAMMONO +Pilos: Dave Rodgers, +TO PBI +in 1777 +9. +10. +11. +12 +13. +COMMENTS +FROM Idestitier Defeed +CY TETERBORO +State or Coutry: NJ +TO Identifier Defined +cly WEST PALM. BEACH +Stute or Country FL +Nantical Miles_ +Statute Miles +Gallons_ 1600 +Pounds 9782 +_ 9162 0 +Fight Time 2 20 +2.3 +-. +Altitude FI 430 +9764.3. +TAKE-OFF POWER +Night 8 +Fer Take-OF 2.15 +TIL +Min Take-OF—- +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000274 + + +P. 002/032 +DATE: 5242005 +Deperture +Time /1:14 +PASSENGERS +1. Jeffhey Epstein +FROM PBI +Arrival +Time +e1 38 A +TO TEg +Numbe2778 +5. +6. +7. +8. +9. +J0. +11. +12 +13. +COMMENTS +FROM Ideatiber Delloed +Ciy WEST PALM BEACH +State or Country _ +TO IdentiGor Defined +CiyTETER BORa +State or Country N. J. +Nautical Miles +Statule Milles +Gallons 1350 +Pounds 9936 +Fligh Tine 2.83 +Altitude FL FLK5O +TAKE-OFF POWER +Flex Tako-Off _ :- +Mis Tako-Oft __— +97643 +2.3 +9766.6 +Nigh +T.. - +IMC — - +Approsch _. +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000275 + + +P. 003/032 +Registration Number: N909JE Type: G-1159B +DATE: 5_26,2005 +Deperture +Time +7:28 +FROM TER +Arrival +Time +11:00 +PASSENGERS +1. Jeffrey Epstein +2. Ghislaine Maxwell +Pilots: Dave Rodgers, Larry Viseski +_ To TisT. +-- +Trip +1229 +6. PARAO MULLEN +9. +10. +Il. +12. +13. +COMMENTS +FROM Identifier Defined +cy. TEtERBORO +State or Country _ N.d. +TO Identifier Delined +cly ST. ThoMAS +State or Coumary_ US.K.T.. +Nautical Miles 1426 +Statute Miles 1639_. +Gallons 1900 +Pounds 12330 +Flight Time 3 32 +Attitude FL EL 44O +TAKE-OFF POWER +'3'5 +9770 1 +Night 3.0 +Flex Tako-OF—_ +Min Take-Off__ +Condition .. +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000276 + + +P. 004/032 +Registratin um 993 +DATE: 5_029,2005 +Type: G-1159B +FROM TEST.. +Arrival +Time +la: 07 +Pilots: Dave Rodgers, Larry Visoski +. TO PBI +Trip +Number +2780 +PASSENGERS +1. Jeffrey Epsteio +2 David Mullen +3. Shistsie +MAKHELL +7. +8. +9. +10. +11. +12. +13. +COMMENTS +FROM Ideatifler Debued +City ST. ThomAs +State or Country U.S.V. T. +TO Ideatifler Delined +Cy WEST. PALM BEACH +State or Country E.L. +Nautical Miles _ 9.75 +Statute Milles: U2) +Gallo 1564 +Pounds 11089 9770.1 +Flighe Time 2-29 - +25 +Altitude 1 E640a 9272.6 +TAKE-OFF POWER +Night __ +Flex Take-Off_ +TA. +Min Taio-OFT- +Condition — +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000277 + + +P. 005/032 +DATE: 6-1.2005 +Time +Depetir 4.3) +PASSENGERS +1. Jeffiey Epstein +2. +Type: G-1159฿ +FROM PBI +A 2:50A +Pilots: Dave Rodeers Larry Visoski +TO_ +TEB +Tamber_ +1781 +5. +6. +7. +8. +9. +10. +11. +12. +13. +COMMENTS +FROM Idestißer Defined +Cy WEST PALM BEACH +Stade or Country FL +TO Identifier Delined +City +, TETER BORO +State or Country... +NS +Nautical Miles _ +Statute Miles +Gallons _ +1600 +Pounds 9470 97726 +Flighe Time 2+19 +23 +Altitude FL._ +450 +9174.9 +TAKE-OFF POWER +Night_ +Flex Taka-OFf 2.15 +Min Tako-Off_-_ +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000278 + + +AUG-14-2006(HON) 14:48 +P. 006/032 +Registration Number: Nº09JE. Type: G-115933 +DATE: 6-18,2005 +pa 8: 19. +Bill Hennno +Pilots: Damefogers, Larry Visosk +FROM TEB +TO_ +PBI +Arrival +Time 10.35 +Trip +Number_ +1282 +PASSENGERS +1. Jefficy Epstein +2. +3. +4, +5. +б. +7. +8. +9. +10. +11. +12. +13. +COMMENTS +FROM Identifier Delined +cy TETERDORO +Site or Courry N. d. +TO Identitier Dellned +State or Country. +E.L. +Nautical Miles +Statute Miles +Gallons 1400 +Pounds _9434 +- 2724.9 +Flight Time 2+/ke +23 +Altaders EL43092772 +TAKE-OFF POWER +Flex Tako-OF, +T/l. +Min Take-Off, +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000279 + + +P. 007/032 +Type: G-1159B +Pilots: Dave Rodgers, Zurry Visoski +DATE: 6-020,2005 FROM_PBI +TO +TEB +Дерати 4: 39 (м +Arrival +Time +Time +_AM +6:55 PM +Trip +Number, +1283 +PASSENGERS +1. Jeffrey Ensteit +2. +41. Femode +*5. +6. +7. +8. +9. +10._ +11. +12.- +13.. +COMMENTS +FROM Identiller Deflaed +City WENT +. State or Country _ +TO Identifler Defined +Palm Beach +Fle: +State or Country _ Nas). +Nattical Miles. +Statute Miles +Callons 1500 +AIRPRAME +Pounds 2537 +9222.2 +Fight Time 2+15 +2.3 +Alindo FL EL 450 9722.5 +TAKE-OFF POWER +Night_ +Flex Take-Off___ +Min Take-Off +Apptoach +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000280 + + +P. 008/032 +PASSENGER MANIFEST . +Registration Number, N909JE +DATE: la 24. 2005 +pa 7:35 +Time +PASSENGERS +1. Jeffrey Epstein +2. +Type: G-1159฿ +Plots: +EROM TEB +FiST. +a 11:030 +Number. / 284 +Larry Visoski +4. David Mullen +5. +Prottesen +6. +7. +8. +9. +10. +11- +12. +13. +COMMENTS +FROM Identifier Defined +CY TEtERBORO +State or Country _ +AL.J. +TO Ideatifler Defined +Ciy ST. ThomAs +State or Country +U.S.V. T. +Neutical Miles +1426 +Statute Miles _ +1639 +Gallons 1800 +Pounds. 1365897795 +Flight Mmo 328 +35 +Alinde I 6450 9783.0 +TAKE OFF POWER +Night 3.0 +Flex Take-Off_ +IAL +Min Take-OBS +1/I d 166L0N +Nds1:9 9007 L •1NC +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000281 + + +P. 009/032 +AUG-14-2006 (MON) 14:49 +Registrasion Number: N909JE Type: G-11598 +DATE: 6.27,2005 FROM T.T.S.T +parturo +ш 428* +Arin 8.00 +PASSENGERS +1. Jeffrey Epstein +2. +KROM Identifier Defined +Plots: Dave Rodgens, Larry Visork +_ To_T.E.B. +S timber 2785 +4. David Mullen +5. +6. +7. +8. +9. +10. +1I, +12. +13. +COMMENTS +TO Identifler Defined +CiY TErERBaRO +Nantial Milas 1426. +Statute Miles 14 39 +Gallons 2203 +Pounds 14284 97830 +Flight e 3+31 +3.5 +Alinde Fl. 4 380 9286.5 +TAKE-OFF POWER +Night_ +Flex Teke-Off +TAL +Min Tako-OFf_ +Condicion. +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000282 + + +P. 010/032 +Registration Namber: N909JE +Type: G-11.59฿ +DATE: 6.30,2005 +Depen 7,50 +FROM TEB +Ama 10.01 +Time +PASSENGERS +1. Jeffrey Epstein +2. +3. +4. FEMALE +S. +6. +T. +8. +9. +10. +11. +12. +13. +COMMENTS +Pilots: Dave Rodgers, Larry Visoski +PBI +TO +Trip +Number +1786 +FROM Identifier Delined +CRY TETERRORO +State or Contry. N.J. +TO Identifier Defined +Cly WEST PALM BEACH +State or Country +FL +Navical Miles_900 +Statute Miles 1035 +Gallons +1400 +Pounds. +8863 +Plate Tone 2+11 +Altitude FL._ +TAKE-OFF POWER +Flex Take OB +Min Take-OF__ +9786,5 +22 +9188.2 +Night L2 +I/ / +1.0 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000283 + + +AUG-14-2006 (MON) 14:49 +P. 011/032 +Registration Number: N909JE Typo: G-1159฿ +Pilots: Davo Kodgore, Larry Viaski +DATE: 7.5.2005 +IROM PBI +no- +TER +Do /1: 29. +Arrival +Time +1-4684 H +1287 +PASSENGERS +I. Jeffney Epstein +2 +FROM Identider Defined +. WEST PALM BEACH +3. +1 17EmaLE +MALE +5. +7. +9. +10. +11. +12. +13. +COMMENTS +TOldentinor Denined +CI$ TETERBORO: +State or Country +_N.V.. +Nuutical Milas/ +200 +Statite Miles +035 +Galpas 1300 +AIRPRAME +pouses 9897-92887 +Fight Time 2+12 +- 2 3 +Atado E FL410 9791.0 +TAKE OFF POWER +Mii prako-OfF, +Condition. +92°d +B2:ET 5002 LZ 2ny +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000284 + + +AUG-14-2006 (HON) 14:49 +P. 012/032 +Registration Nuruber: N9D9TE. +• DATE: 7-72005 +7:27.6 +PASSENGERS +1. Jeffrey Epstein +2. +3. +4. +5. +6. +7. +8. +9. +10._ +11. +12. +13- +COMMENTS +DARREN RothEL +Pilots +Dere-ledgers, Larry Visos +10_ T./.S.T.: +Trip +) Number_ +1788 +Type: G-1159B +FROM TER +n 10.500 +FROM Identifer Defined +CIY TETER BORO +stador County Noce +TO Identifier Defined +Ciy ST. ThomAs +State or Count .. +Us.kI +Nautical Miles 1426 +Galtons 2,100 +portats 1320497910 +Men Timo 3.23 +3.3 +Ansio FL. FL410 97943 +TAKE-OFFPOWER +Night 3.0 +Flex Take-OfF +Mir Take-OBT +Coridition +Approaci +tz-d +G88BLLL0TE +9 130 A I5 +BZ:61 S00Z L2 20g +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000285 + + +P. 013/032 +AUG-12-2006(MON) 14:49 +• HYPERION AIR, INC. +Registation Number: N909JE ( +Type: G-1159B +DATE: 2.10 ,2005 +FROM TEST +F35 8 +Te7:43 A +› Nutaber +PASSENGERS +I. Joffrey Epstein +2. +3. +BILL HAMMOND +Pyos: Dave Rodgers, deag-ismet +TEB +1789 +7. +8. +9. +10. +1!.- +12_ +13.- +COMMENTS +FROM Identifier Deftoed +GIN ST. THOMAS +Stade cr Coruntry USVI +TOrdeutler Deficed +CIN TETER BORO +State or Courtry _ +NJ +Nasical Miles +1426 +Stanice Milos" L6a39 +Galba 2150 +Poules_ 15262 9794.3 +regis tao 3 -46 +3.8 +AVERUITE PA 400 +9798 +TAKE-OFF POWER +Flex Taio-DAF 2.- +Min Taka-off 2.41 +IMC. +Consttion +28 •d +6884440+E +Ba101 S00Z 42 2NE +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000286 + + +P. 014/032 +HYPERION AIR, INC +Registration Number: N909JE Type: G-1159B +DATE: 7:15,2005 +TROM TEB +De /0:07 +Ant 22:19 +PASSENGERS +1. Jeffrey Epstein +M +Plots: BeveRledgers, Larry Visal +BBI +•Number, +1790 +9. +10. +11. +12.. +13. +COMMENTS +FROM Identifler Defined +CH TETERBORO +Star or Commy NaL. +TO Ideatiber Defined +ON WEST PALM BEnCh +Stade or County +ELe +Testical Millen +900 +tatute Miles +2035. +on 1300 +pa. 8569 +9798.1 +Fishe Time 22+11 +22 +Aloudo T EL450 9800 3 +TAKE-OFF POWER +Night. 2,2 +Fles Take-OfF. +TIL +11. +Mid Take-Off +02°d +6888LLL0E +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000287 + + +P. 015/032 +Rogistration Number: N909J Type: G-1159B +DATR: 7_- / 6,2005 +De 5 : 03 80 +FROM PRi +Arrival +Time +Pilots: 1 +Larry Visoskd +To P$1 +5:10 AM Taber 17.91. +PASSENGERS +1. Jeffrey-Fipstcin +3. +MAINTENANGE +S. +6. +9. +10._ +11._ +12. +13. +COMMENTS +. +FROM Ideat Ter Defined +CH WEST PAuM +Stade or County _ FL +TO Identier Dellued +cy WesT PaLm +State or Country __EL +Nagitical Miles +25 +Statute Miles +30 +Gallons _ 3_0 Q +Postade 1921 +ht Time +Altitude FI. +TAKE-OFF POWER +Plex Tako-OFF +Min Take-Off +Night, +600840E +ST THOMAS JET CENTER +Rug 27 2005 13:28 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000288 + + +P. 016/032 +AUG-14-2005(HON) 14:49 +Registration Number: N909JE Type: G-1159B +DATE: 7 .1B_2005 FROM PBI +то +PaE 1490 +Arrival +Time +4.15 c +D Nutaber +Pilots: Dave Rodgers Larry Visoski +TEB +1792 +PASSENGERS +I. Jeffrey Epstein +2. +3. +4. +5. +б. +7. +8. +9.. +10. +11. +12- +13. +COMMENTS +FROM Identier Detined +ay WEST PALM BEACH +state or County... FL. +TO Identifier Defined +C TETERBORO +Suste or Country. +_N.J +Naufical Miles +900 +Statite Miles +1033 +Galtods 1.500 +Pondo 9964 +9800.4 +Right Timo 4+26 +24 +Atriade FI 450 +9802 8 +TAKE-OFF POWER +Night_ +Meitaio OFR.15 IH +Mia Mako-OLP. +3 +Approsch ILS +• 9T°d +G8BBLLLOTE +BENNS IS SN S +LZ ET S002 La DNE +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000289 + + +P. 017/032 +AUG-14-2005(MON) 14:49 . +i +HYPERION AIR, ING +PASSENGER MANIFEST • +Registration Number: N909JE Type: G-X159B +DATE: 7.20.2005 FROM_TEB +Depe B .41. +Arrival +9.42 +JEM DoWD +Pies: Dave Rodgers, taniy Vorsts +BKL +Thi +Nulher_ +1793 +PASSENGERS +14 +2 GHISCAINE MAXWELL +3. IAN +4 +5. +6.. +7. +8. +9. - +10._ +11._ +12- +13. +COMMENTS +FROM Identifier Detined +Cy TETERBORO +Stale or County NS +TOjXdeatißer Defined +CY CLEVELAN +Stale or Coumary +OH +Nautial Mikes +348 +Statute Miles +400 +Gallons_ 1,000 +Roros 5406 +Hight Time_L-OL +Attitudo rz 340 +TAKE-DEF POWER +Pho Tato-ON 2.15 +Min Take-OIT +Condition. +9802.8 +10 +9803.8 +T7. — +Approtch +*I •d +68B8LLLDE +AE1 SO03 L2 SNE +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000290 + + +P. 018/032 +JIM DOWO +Registrstion Namber: N909JE Type: G-11593 +Pile: Dave Rodgers, +DAVE: 2 +.202005 FROM BKL +ro TEB +Pepere 2 50. +Atrival +Time +3,52 tew +j Momber +1794 +PASSENGERS +«GHISLAINE MAXWELL +3. IAN +S. +6. +7. +9. +10: +11. +12._ +13. +COMMENTS +FROM Identiter Defined +cl CLEVELAND +seia or Couny._ O H. +TO Ideatifer Deffned +Ey TETERBORO +Stale or Cosmtty - +NJ +Nuttica| Miles +348 +stafate Miles. 4-00 +Galins 650 +Pornds_ 5372 +9803 8 +Fuge Time |. +01 +Altinde FL. _ +$50 +10 +9804.8 +TAKE-OFF HOWER +Fles Take-Oel 2.15 +Ti —I +Min Take-Off +Coefitioza. +Approsct_ VOR +ET id +ST THOMAS JET CENTER +Б88BLLLO+E +Rug 27 2005 13:27 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000291 + + +P. 019/032 +PASSENGER MANIFÉST • +BILL HAMMONO +DATE: 7.22.2005 +Pao 9: 11. +PASSENGERS +1. Jeffiey Epstein +Type: C-1159B +FROM TEB +A 11 :26 +Pilots: Dave Rodgers, +PBI +S To 1795 +10. +11. +12. +13. +COMMENTS +FROM Identitier Defined +Can TETERBORO +Sale or Coury NT +To Identifier Dedined +a WEST PALM BEACH +Stade or Country +FL +Nautical Miles +900 +Starate Milles +1035 +Gations 1500 +Pounds 9061 +Flight Time 2.15 +Altitude FL, +450 +TAKE-OFF HOWER +Flex Tiko-OM 2,15 +Mir, Take-OfF +Condition. +9804.8 +2. +3 +9807 +.1 +Night _.. +23 +™ 1/1 +мс 1.1 +Approsch, +TI*d +6888LLLD*E +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000292 + + +AUG-14-2006(NON) 14:50 +P. 020/032 +Type: G-1159B +FROM PBI +TO +Time +A 7340 +) Number +Pilots: Dave Rodgers, +TEB +1796 +BILL HAMMOND +Registration Number: Nº09JE +DATE: 1 25.2005 +Deputie 5:09 +Tims +PASSENGERS +1. Jeffiey Epstein +2 +3. +4. +5. +6. +7. +8, +9. +10. +1L._ +12. +13. +COMMENTS +FROM Idcat Ger Delined +coy WEST PALM BEACH +State or Country _ +•FL +• TO Identiber Detined +Cil TETERBORO +State or Country. +NJ +Natical Miles +900 +Starte Miles +1035 +GitoRs 1500 +pounds 10058 9807.1 +Fight Timo 2 +24 +24 +AHE . 4150 +9809.5 +TAKE-OFF POWER +Min Take-OFF. +Conilition. += +E-d +S8BBLLLOVE +98 EI 00Z 8 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000293 + + +RUG-14-2006(MON) 14:50 +P. 021/032 +PASSENGER MANIFEST • +BILL HAMMANO . +Registration Number: N909TE +Typo: G-1159B +DATE: 728.2005 +FROM TEB +Pa 7:540 +Am 11 +360 +PASSENGERS +1. Tofffey Enstein +2. +3. +5. +6. +7. +8. +9. +10._ +11._ +12 .. +13._ +COMMENTS +Piles: Dave Rodzers, +To TIST +, Natabe +1797 +FROM Identifier Defined +CI TETERBORO +Stato or Courey .... +NJ +o Identifier Detinod +a ST. THOMAS +sto or County USVI +Nadial Mite 1426 +sesito Miles 1 639 +Galons 2+41 +Posinais 14997 +| 9809.5 +3.7 +Atendo EI 400 +_ 98132 +TAKE-OFF POWER +Neste 2.7 +Mid Take-Off +IMC _ +2.7 +A +Lid +68BBLLLO+E +S2:EI S002 Lz 2ny +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000294 + + +AUG-14-2006(NON) 14:50 +P. 022/032 +Registration Number: Nº09JE( +DATE: 8- 1.2005 +- 6:42 +PASSENGERS +1. Jeffier Enstein +PASSENGER MANIFEST • +Tp:: G-11595 +FROM TIST +"Time +A 10 1 +BZLL HAMMOND +Pilots: Dave Rodgers, Besen +TEB +D Trip +Nataber +1798 +8. +9. +10. +11- +12.. +13. +COMIMDENTS +FROM Identifer Deltued +ai ST. THOMAS +Stato or County_ USVI +TO Ideatißer Detined +Cy TETERBORO +State or Couistry _ +NJ +Naitical Miles +1426 +Stafute Milas +1639 +cratons 22.01 +Perdas 14091 9813.2 +3 C +Alando FL 450 +TANT-OFF POWER +9816.8 +Night_ +Mid Tako-Ose! +Candition +Approschn ILS +68884440E +SE ET 5002 42 2n +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000295 + + +AUG-14-2006(HON) 14:50 +P. 023/032 +Registration Number: N909JE Type: G-Ł159B +DATE: 8.2 +→ 2005 +FROM TEB +pe L: 11. AM +Arriva] +Tine +12 37€ +Trip +→ Number +PASSENGERS +1. Jeffiey Enstein +2. +3. +4. +.5. +6. +7. +3. +9. +10. +11, +12 +13. +COMMENTS +BILC HAMMONO +Pilots: Dave Rodgers, 1 +SAF +1799 +FROM Identifier Defined +Ci TETERBORO +State or Conty _ +NJ +TO Ideatifier Deficed +Cry_. SANTA FE +State or Couny_ NM +Nautical Miles- +1609 +Statuta Miles. +1850 +Galons 2000 +Potad: 146/6 +mitr Timo 3 .26 +ARtodo T, S100 +TAKT-OXY ZOWEH +Mei Tako OM2.21 IH +Mir Tako-OFF +Cordition +9816.8 +3.4 +9820.2 +E*d +SE•ÉT S008 4z 2nb +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000296 + + +P. 024/032 +Registration Number: N909DE +Type: G-l159B +DATE: 8. 82005 FROM SAF +- то. +Dee 9: 41 S +Arrival +1 Trip +Time +10:20PN +Number +Pilets: Dave Rodgers, Larry Visostd +ASE +1800 +PASSENGERS +1. Jeffrey Epstein +26. MAXWELL +3.1 +5. +6. +7. += IMALE +10. +11. +12. +13. +COMMENTS +FROM Ident Ger Deffaed +MY SANTAFE +stape or County. N.M. +To Idcatifier Defined +State or Consty - +C.O. +Natical Me 219 +Stafuro Miles 2.51 +Gattons 600_ +Pounds 3340 9820.2 +Flight Tims+39 +TAKE-OFF POWER +Night_ +Min Take-Off +I -d +5888LLOTE +9Z=EI S00Z 4z Dng +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000297 + + +AUG-14-2006(HON) 14:50 +P. 025/032 +HYPERION AIR, INO. +PASSENGER MANIFEST • +Registration Nuber: N909JE Type: G-1159B +Pioes: +: Dave Rodgers, Larry Visoski +DATE: 8-8.2005 FROM ASE +LAS +3 : 0 20) +Time +3:IC Rmber. +1801 +PASSENGERS +1.Jefficy Epstein +2. +3. +GhisLAiNE MAXwELL +L7EZALE +5. +6. +7. +sI'MALE +9. +10. +11. +12- +13- +COMMENTS +FROM Ideatifier Defined +City. +ASPEN +State or Comcay.... +_co +TO Identilie Defoed +City. +LAS VEGAS +Stite or Country -. +N.V. +Marical Mile_ 437 +santo MECO 499 +Gallms #00 +Pasads 5255 +9820 9 +Figar Tine 1+15 +13 +Alitao+1:_ FL430 9822.2 +TAKE-OFF POWER +Fox Tak-0t. +TAL +Min Teko-Of +Coodition +Lt-d +G4AOE +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000298 + + +09/14/2005 14:16 FAZ +P. 027/032 +0007 +Registration Number: NºЮ9ЛЕ ' Type: G-1150# +DATE: 8-8,2005 +Departure +Time +12.00 +LAS +Arrival +Time +12:09 +Bill Hamuroad +Pilots: Dave Rogers, Jarry Visosi +TO +SAE +Number +180z +PASSENGERS +1, Jeffrey Enstein +3. GEisLAINE MAXWELL +4 +LmAlE +1. 1. 7omplE +8 L FemalE +2. / FRaALE +10. +11. +12. +13. +COMMENTS +FROM Identifier Delined +City LAS VEGAS +Stars or Country NAV.: +TO Identifier Defined. +CIr SANtA. FE +State or Country +Nauical Miles +448, +Stitute Miles +491 +Gallans 1000" +Ponds 5.500 +Might Taus 1 + 09 +• Alándo EL FL390 +TAKE-OFF POWER +9822 z +11 +9823.3 +Night... a +Min Talt-OfF. +Condition, +Agproach +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000299 + + +AUG-14-2006 (MON) 14:51 +P. 028/032 +HYPERION AIR, INC +PASSENGER MANIFEST • +Registation Number: N909TE Type: G-11598 +DATE: 8-14.2005 +PROM SAF +Am 12.01 +Pilots: DereRodgar, +Bate, Parry Vota +TEB +Numbe +1803 +PASSENGERS +1. Jeffrey Epstein +21 +ChisLainE +3. +4 Austial +mALE. +6. +7. +9. +10. +11. +12 +&/MALE +13, +COMMENTS +Macarelli +FROM Identitler Defmed +CISANTA FE +TO Identifies Defined +Cy TEZERBORO +Nanical Miei 1545 +Ststute Miles +1776 +Galions. 1999 +Pos K$266 9823,3 +Fligie time 3 + 46 +3.7 +Andrado 7, F241098270 +TAKE-OFF POWER. +Night_ 3:0 +Mia Taka Off +Mc 1.0 +Approach 12s +*I*d +Be88LL40+E +SE:ET SO0Z 2Z 2ny +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000300 + + +P. 029/032 +Registration Namber: N909JE +DATE: 8-18.2005 +Type: G-1159B +FROM TER +• Arrival +3.191 +Dave Rodgers, Larry Voskd +_ no PBI +M pater 18.04 +PASSENGERS +1. Jeffiey Epstein +8. +9. +10. +11. +12. +13. +COMMENTS +FROM Ideatifier Defined +Cy TETERBORO +State or Comer ... +NT +TO Identifier Defined +Cy WEST PALM BEACH +State or Country. +FL +Naucal Na 9,00 +Statute Miles. +1035 +Gallons 1400 +Rounds_ 9064 +9827,0 +Tighe Tine 2+07 +21 +Altitude FL., +1450 +9829. L +TAKE-OFF POWER +Night.. +Flex Take-OF__ +Min Take-OfF +IMC - +2I-d +88884LL0E +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000301 + + +P. 030/032 +HYPERION AIR, INE. +Registration Number: N909J +DATE: - 222005 +Departure +AM +Time +1:39 +PASSENGERS +1. Jeffrey Tipadcia +2. David Müllen +3. +Type: G-1159B +FROM +Anival +TO- +2.06 +PRI +18.05 +6. +7. +8. +9. +10. +11. +12.. +13. +COMMENTS +TRAILINg +FROM Identifier Defined +ci WasT Palos +State or Comery EL +TO Ideatilet Defined +ay West Paeme +State or Coumary. Fe +Neutical Milke +Statute Miles +48 +Gallons _ +419 +Pounds 190 le +9229 1 +Flight Time +0+07 +Altitude FL. +2,800 +TAKE-OFF POWER +Flex Taka OF +Min Take-Off +98292 +- Approach... +01 'd +6888LLE +ST THOMAS JET CENTER +Rug 27 2005 13:34 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000302 + + +P. 031/032 +DATE: 8:2022005 +Ta 3.57 +Tine +PASSENGERS +finer Epstein +Type: G-1159B +FROM P.BI +Arrival +Tine +6:16 +Pilos: Dave Rodgers, Larry Visoski +TER +Staber. +1806 +3. +4._ +5. +6. +7... +8. +9.. +10. +1l.. +12. +13. +COMMENTS +FROM Idcpfer Dellacd +Cy_ WEST PALm Bch +State or Country EL +TO Identifies Defined +Ciy TETER BarO +State or Country _ +N.V. +Neutical Miles +900, +Statute Miles +L033 +Gallons 1100 +Pounts 9533- +- 2829.2 +Flight Time 2+19 +'23 +Atindo FL £L 450. 78.31.5 +TAKE-OFF POWER +Flex Takaos +TIL +Min Take-Off +8 •d +68884440+E ++E=EI SODE LZ 2ny +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000303 + + +P. 032/032 +PASSENGER MANIFEST • +Registration Number: N909JE Type: G-1159฿ +DATE: 824.2005 +FROM TER +12.14 A +12.53 +PASSENGERS +1. Jeffrey Epstein +PIpes: Dave Rodpers, Karry Viscaki +to FOK: +1807 +10. +11. +12. +13. +COMMENES +FROM Idensifier Deflaed +Siy TETERBORO +State or Cornay _ +NJ +TO Identifies Delined +Cy_ FREDERICK +State or Courity... +MD +Nuatical Miles +Statute Miles +Gallon. +400 +Round 3595 98315 +Flight Tire ++38 +6 +Altitude FL +180 +9832.1 +TAKE-OFF POWER +Flex Take 0B_ +Min Tako-Oft +_ . IMC +'Condition +Approsch. +g-d +688844DE +tE:ET 5002 LE 2ny +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000304 + + +AUG-14-2006(MON) 15:07 +P. 001/042 +Registratien Number: NºDIE Type: G-1159฿ +DATE: 8 24,2005 FROM FOK +a 3 24 eM +Artival +Time +4:03m +PASSENGERS +1. JeiGey Epstein +el +Dave Rodgers, Larry Visoski +- по +TER +_18.08 +8. +9. +10. +11. +12. +13._ +COMMENTS +FROM Idemilier Defised +Cy FREDERICKE +State or Cournery +MD +TO Ideatific- Defined +Giy TÉTERBORO +State or Couty _ +NJ +Nantical Miles... +.Stitute Miles +Gallons 450 +Pounds 3613 +Flight Tine ++38 +Attitudo 17 180 +TAKE-OFF POWER +Min Tako-OF +98321 +6 +98327 +Appmach +g•d +68886440+E ++E=ET S00Z LZ 9ny +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000305 + + +P. 002/042 +AUG-14-2006(MON) 15:07 +Registration Naber: N909JE Type: G-1159B +DATE: 8 26.2005 FROM TEB. +pea /2: 13. +Time +Arrival +Timo +12.51 +PASSENGERS +1. Jeffiey Epstein +2. +3. +4. L72 MALE +5./ 70e4 +6. DAViA MULLEN +7. +8. +9. +10.- +11. +12. - +13.- +COMMENTS +Pilots: +Dave Rodgers, Leny Visakl +• Tom Vy +5. Neonber +1809 +FROM IdeaAlier Defoed +CYPEZERBORQ +Stata or Comaty .... MA$. +TD Identifier Detined +CN MARThAS ViNEXARO +State or Comity +'MA +Nautical Mit 207 +Statute Miles +238 +• Gallms 400 +Poreds — +3514.983.2.7 +Flight Tune +_+3% +Akitade FL_ +EL210 78.33.3 +TAKE-OFF POWER +Night, +Mex Tako-Of. +Min Tasso-de +Approuch +g*d +6888LL40+E +TE:ET S00Z LZ 2NE +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000306 + + +P. 003/042 +Туре: G-11598 +DATE: 8282005 FROM MVY +Tinte +De 4:18. 800 +Antivai +• Tine 7:23 +PASSENGERS +1. Jefficy Epstein +2 +3. +A DAVIR MULLEN +s. AMALE. +=./ FEZMALE +7. +8. +9. +10. +1k. +12- +13._ +COMMENTS +Pilots: Dave Rodgers, Larry Visoald +, то- +TiST +1810 +FROM Iden +inter Defined +cy MARthAs VI +stato or corry MA. +TO Ideafiler Defined +City. +ST.ThomAs +Nautical Mile +142% +Stalute Miles +1639 +Gulo 2300 +AIRERAMME +Pounds 12198 98333 +Figh Time 3+05. +3L +Aliado _ FL45098367 +TAKE-OFF POWER +Flex Taks-Of_ +Min Tako-OB +I 210 +Appranch +6888LL40+E +#E:EI S002 L2 9ny +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000307 + + +P. 004/042 +Registration Number: N909J# Type: C-1159B +8.27 +2005 +Time +гр 3: 48 +FROM TIST : +6.10 +PASSENGERS +Pilots: Dave Rodgers, Larry Visoski +_ To PBI. +Number 1811 +FROM Identifier Defined +ci. ST. THOMAS +State or Country_ USVI +TO Identifier Delined +Cy WEST PALM BEACH +State or Counry. : FL +Nautical Miles +Stamnte Miles +9. +10. +11. +12. +13. +COMMENTS +WINDSHREND HEAS REPADA +Galons_ 1300 +Pounds 9939 +98364 +Fight Time 2.21 +24 +Altitude FL. 380 +98388 +TAKE OFF POWER +Night. +Flex Tabo-OM 2.15. m. - +Min Take-OfF__ +IMC — +Condition —— — +NO PASSENGERS +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000308 + + +09/14/2005 14:16 FAX +P. 005/042 +40006 +B.II Hammonl +PIos: DiveRodgers, Larry Vsoski +7:360 +TO +Trip +Number +TIST +1812 +Regiscation Number: N90SUE Type: G-1159B +DATE: 8 -2,2005 FROM_P/S/ +Diman 5: 13 +Time +Arrival +Time +PASSENGERS +1. Jeffrey-Epstein +NO AASSENGERO +3. +10. +11. +12 +13. +COMMENTS +FROM Identiber Defined +CHy INesT Peca BecoL +State or Coxatry PL +TO Ideatißier Defined +Cry St Thamme +State or Country _ +ÜskL +Nautical Milles +285 +Statute Miles _ +1333 +Gallons / 6.50 +Pounds 9988 +Flight Time_ 2+23 +Altitade FL 92 0 +• TAKE-OFF POWER +Flex Take-Of_.— +Min Tais-OBl +98388 +24 +9841. 2 +Night 1.0 +IMC / +Approach_ P +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000309 + + +0W/14/2005 +14:16 FAX +P. 006/042 +2005. +DATE: 2 - 3,2005 +Departure +Time +11:48 +PASSENGERS +1. Jeffrey Epstein +2 PArIs mulleN +3. +Туре: G-1159฿ +Pilots: +Ba 11 He Lay rade +FROM. +TIST +TO KPAI +Arrival +Time +2:1200 +Trip +Number +1813 +7. +8. +9. +10. +11. +12. +13. +COMMENTS +FROM Identifier Defined +CY ST THEMAS +State or Country ...US V1 +TO Ideatifier Detined +C WEST Pauso BenEA +State or Country FL +Nautical Miles +985 +Statute Miles +113 г +Gallons +1300 +Pounds +Flight Tinc_2+23 +Attrade FL Y3.02 +TAKE-OFF POWER +98412 +24 +9843.6 +Flex Tako-OF__ +Min Take-Off +Coodition. +Approsch. +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000310 + + +09/14/2005 14:16 FAI +P. 007/042 +44004 +Registration Number, N909JE +. Type: G-1159B +DATE: 2. 10,2005 +FROM 2BI +Dea 3.59 +Arrival +6. 11 +PASSENGERS +I. Jetfity Epsicin +2 GOSLANE +MAXWSAL +Bit Hammond, DAVE Rusoons +Pilots: -Đave-Rodgers, Leng Wiseski +_ TO TEB +Trip +5 Member 1814 +IROM Identifier Defined +3. Female +7. +8. +9. +10. +11. +12. +13. +COMMENTS +State or Country FL +TO Identifier Delived +Co TETERBORO +State or Country NT +Nautical Miles 95% +Statute Miles / 0 9.7 +Gallons 1425 +Pounds 9477 +Fight Timc_ 2+// +Attitude FL +410 +TAKE-OFF POWER +Flex Take-Off_ +Min Tokc-Off_ +Condition, +_9843. la +22 +2845. 8 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000311 + + +P. 008/042 +Registration Nutber; Nº09JE( +DATE: 9..9.2005 +T 10: 00 +PASSENGERS +1. Jeffiey Epsicin +2 +Type: G-1159B +Plons: Dat age, Larry Vote +FROM TER +TO PB1 +Arrival +12:22 +Tamber 1875 +9. +10. +IL +12. +13. +COMMENTS +FROM Identifier Defined +Cy TeTERBORo +State or Country... +N5 • +TO Identifier Defined +Go WesT Palm BEn2 +State or Country_. FL +Nautical Miles... +1025 +Statute Miles +1179 +Gallons 1150 +Pounds 9,590 +Fright Time 2+22 +• Altitode EL +450 +TAKE-OFFPOWER +98458 +23 +98481 +Night 2.3 +Flex Take-Olt_— +Min Take-Off __ +MC — +Approsch ... +P +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000312 + + +AUG-14-2006 (MON) 15:08 +P. 009/042 +2/002 +Rogistration Number: N909JE +Type: G-1159฿ +DATE: 9-1 2005 FROM POT +No 2: 06 +Arrival +Tithe +Tithe +4:30 +Sal-Cantoned +Pilots: Dave Rodgerz, Larry Viseski +- то. +Trip +3) Number, +TAST +1816 +PASSENGERS +Toffer Footin +8. +9. +10. +IL +12. +13. +COMMENTS +FROM Identifier Defined +ETY WEST PALM BEACh +Stale or Country_ FL : +TO Identifier Defined +cy St. Thomas +Stale ot Country _ +USVI +Mantical Miles 985 +Strate Miles 1032 +Gallons 13.00 +AIRERAME +Pounds 9532 9848. L +Fligh Time 2. 123. +23 +'Alinder Fi450 98504 +TAKE-OFF POWER +Night... +Flex Take-Off_i- +Min Take-OfF_ +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000313 + + +RUG-1-42205 042115 PAS +P. 010/042 +2001 +Registration Number: Nº09JE ' Type: G-1159B +DATA: 9-13 2005 FROM TIST +1 653 +Am 10.30 +Time +PASSENGERS +1, Teliney Enstein +Bil Hammoad. +Plots: Nave Rodgers, 1 +_ то TEB +Number_ +1817: +6, +7. +8. +9. +10. +1L. +12.. +13. +COMMENTS +FROM Identifier Delined +Ciy ST. THOMAS +State or County _ USVI: +TO Identifier Defed +CiL TETERBERO +State or Copatry +NJ +Nautical Miles. +1427 +Statnie Miles_ +164) +Gallons_ 2200 +Pounds |5224 +Righe Tino 3,36 +9850.4 +3.6 +9854.0 +TAKE-OFF POWER +Night_ +Flex Tais-OE_ +Min Taker-Off +MC +Appronch +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000314 + + +AU6-14-2006(MON) 15:40 +P. 001/004 +Bil Ermmont +Registration Nupber: N909JE +Type: G-1159฿ +Pilots: Dave Rodgers, Labng Viruske +DATE: 2.14.2005 FROM TEL +- то- +BED +Pati 1:33 +Time +nina 12:12. +A Ter 1818 +PASSENGERS +1. Jefficy Epstein +2, +mi +vi +9. +10. +13. +COMMENTS +FROM Identifier Delined +State or Country NT. +TO Identifier Defined +City_ +BEDFORS +State or Country MA +Nautical Miles +125 +Statate Miles_ +201 +Gallons_. 900 +98540 +Plight Time _0+38 +Altitude EL L59 +TAKE-OFF POWER +Flex Take-Off_ +Min Toke-Off +Condition, +9854 6 +Night. +I/L +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000315 + + +AUG-14-2006 (MON) 15:40 +P. 002/004 +Type: G-1159B +FROMBED +Anival +Time +Plots: Dare Roger, Laryllenti +_ TO MEN +AM +Trip +Number +1869 +Registration Number: N909J7 +DATE: 2.14.2005 +Bet 6: 30 M +PASSENGERS +1. Jeffrey Enstein +3. +• LARry SummERS +5. Guest +6. +7. +8. +9. +10. +11. +12. +13. +COMMENTS +FROM Identifier Defined +State or Coutry: MA +TO Identifier Defined +cia white PlaINs +State or Country ALY +Nautical Milles. +150 +Statute Viles... +Galtons 300 +Pouses 3559. +98546 +Flight Time_0+36 +Altitudo FL 16000 +TAKE-OFF POWER +98652 +Night... 2 +Flex Take-Of. +Min Take-Off, +Condition, +IMC_ +Approacte P +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000316 + + +AUG-14-2006(MON) 15:40 +P. 003/004 +DATE: 9-182005 +Time +PASSENGERS +Jefficy Ensein +Type: G-1159B +FROM +_HPN +Arrival +Time +936 +BEl Bamboad +Plots: Demelodges, Larry Visoski +TO_ +_PRI +Trip +Number +1820 +6. +7. +8. +9. +10. +11. +12. +13. +COMMENTS +FROM Identifier Defined +Cy WHiTE PRAINS +state or County ... ANY. +TO Ideottfier Deflood +CiY QUEST PALM BCH +State or Country __ EL +Nanical Males 949. +Statute Miles_/ 09/ +Gallons 13.00 +Pounda_ 9014 +9855.2 +Flighe Time 217 +22 +Alinde F1 E6430 9857 4 +TAKE-OFF POWER +Night L.5 +Flex Take-Off —_ +тл. _ l +Min Take-Off_ +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000317 + + +AU6-14-2006(MON) 15:40 +P. 004/004 +DATE: 920 +. 2005 +Dimentor 8 16 +Time +PASSENGERS +1. Jeltrey Epstein +«JIMMY +Type: G-1159B +Pilots: Dave Rodgers, Larry Visesid +FROM PBI +_ No TIST +Time +THE 10 30$ +Timbe 182) +7. +8. +9. +10. +11. +12 +13. +COMMENTS +FROM Identifler Defined +Co WEST PALM BEACH +State or Country FL +TO Identifier Defined +cly ST. THOMAS +State or Country_ U SVI +Nautical Miles. +Statute Miles +Gallons 1300 +Pounds 9327 +9857.4 +Flight Time 2-19 +23 +Altitude FL 410 +9859. +TAKE-OFF POWER +Night 2.0 +Min Take-Of 2 4) +Condidon W/S +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000318 + + +AUG-14-2006 (HON) 15:08 +P. 011/042 +PASSENGER MANIFEST ' +Type: G-1159B +• DATE: 2-242005 eROM TIST +TIE 2:05 +ilots: Dare Rodgers, Larry Visosl +то ТЕВ +Ter 1822 +PASSENGERS +1 Jeffrey Epstrin +3. +1. ALER RESNIK +S. +SANDy +BErsEr +6, +8. +9. +10. +11, +12. +13. +COMMENTS +FROM Identifier Defined +as ST. Thomats. +State or Country_ US.VI +TO Identitier Delined +City. +-TetoniBoro +State or Coutrity _ +Mantical Miles 1427 +State Miles 16441 +Gallons 2250 +Pounds 14497 +9859.7 +Flight Time 3+32 +3.5 +Attend Is F2430 9863.7 +TAKE-OVE POWER +Night. +Flex Tako-Offm..- +Min Taks-f.. +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000319 + + +AUG-14-2006 (MON) 15:08 +P. 012/042 +• Registration Number: Nº09JE +DATE: 9.25-2005 +10 51 +PASSENGERS +I. Jeffrey Epstein +Type: G-1159฿ +Pilois: Dava Rodgery, Larry Visoski +BROM TEB +_ To CMH +At 12024 Mi 1823 +• PAUL HALADA +5. LMALE +• 1 MALE +7. I FEMALE +8: +9. +10. +1l. +12 +COMMENTS +FROM Identifier Defined +CiN TETERBOR 0 +State or Country.... NJ +TO Identifier Defined +City COLUMBUS +State or Courty ... +OH +Nautical Miles +Statute Miles _ +Gallons 1000 +Pounds _ +5899 +Flight Time_L+11 +Altitude FL... +400 +TAKE-OFF POWER +Flex Take-OF 215 TiL +Min Take-Off +9863.2 +12 +9864.4 +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000320 + + +P. 013/042 +Regisration Number: N909JE Type: G-11598 +Pilots: Dave Rodgers, Larry Visoski +DATE: 9.25.2005 FROM CMH +10 TEB +De ≤ 09 AM +Arrival +Time +6.21 0 TiE 1824 +PASSENGERS +1, Jeffrey Erstein +• PAUL HALARA += 1 MALE +6. I MALE +1. 1 FEMALE +8. +9. +10. +12 +13. +COMMENTS +PROM Ideatifier Deliaed +ay_ COLUMBUS. +State or Country _ +oH +TO Idcutifier Defined +CIN TETERBARO +State or Country - +NT +Nautical Miles +• Statate Miles +Galons 500 +AIRERAME +Prund_ 6383- 9864.4 +Flie Tir_1+12 +1.2 +Attitude FT. 370 +9865.6 +TAKE-OFE POWER +Night_ +Mextake-oF Z17 Te i! +Min Take-Off... +IMC m +5 +Approsch VOK +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000321 + + +AUG-14-2006(MON) 15:09 +P. 014/042 +BiB Hammond +Registration Number: N909JE Type: G-1159B +Pilots: Dave Rodgers, Larry Visoshi +DATE: 9 277.2005 • FRON TEB +_ то BED +Дерапше +Tice +4:28 99 +Am 12:05 M i 1825 +PASSENGERS +I. Jefticy Epstein +2. +3. +8. +9. +10. +11. +12 +13. +COMMENTS +FROM Identificr Delited +cly TETEBORO +Stato or Country NJ. +TO Identifier Delped +City +BEDFORD +State or Country_... MA +Mantical Miles /52 +Statute Miles +Galtons 1100 +AIRERAME +Pounds 3300 +4865.% +Flight rime _. +38 +AttiTude Ft EUSO +TAKE-OFF POWER +Flex Taks-OE_- +Min Take-OfF +98bb.z +Night_ +.T/l. +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000322 + + +AUG-14-2006(MON) 15:09 +P. 015/042 +Registration Nutiber: Nº09JE +DATE: 9.27.2005 +mar 5:53 +Time +PASSENGERS +1. Jeffrey Epstein +2 +Type: G-11598 +TROM BED +I0_ +Atrival +Time +6:390 Tentor. +BIll Hammond +Pilots: Dave Rodgers, Larry Visosto +TER +1826 +FROM Ideotifer Defined +state or Country MA: +TO Identifier Defined +7. +8. +9. +10. +11. +12 +13.. +COMMENTS +State or Country .. +NJ +Nautical Miles 15€ +Statute Miles +AIRERAME +pounds 418678662 +Flight Time_ +Mitados F416098669 +TAKE-OFF POWER +Nightt_ +Min Take-Off _. +Coudition. +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000323 + + +AUG-14-2006(NON) 15:09 +P. 016/042 +Type: G-1159B +FROM. TER +Arrival +Time +- то. +Registration Number: Nº09JE +DATE: 929.2005 +Departure +Time +8:56 +PASSENGERS +I. Jeffrey Epsicin +2. +Bil Hammond +Pilors: Dare Togers, Larry Visostai +PBI +1827 +LEEMALE +5. +б. +7. +8. +9. +10.. +I1. +12. +13. +COMMENTS +FROM Identifier Defined +Ci_TE/ERBORO +Suals or Coumtry_Nita +TO Identifier Defined +Stare or Country _EL. +Nautical Miles +1025 +statore Miles 1/79 +callons 1500; +Pouads_ 9/53 +AIRPRAME +_ 98664 +Fligir Time 2+Ila +22 +Aliode 1. 1650.9862+ +TAKE-OFF POWER +Nigh z. +Flex Take-O#_- +The fit +Min Take-Off +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000324 + + +AU6-14-2006 (MON) 15:09 +P. 017/042 +Regisuntion Number. N909JE +Type: G-1159# +DATE: 10.4 2005 FROM PB1 +Arrivel +Time +Z:11 +Bul Hambond +Pilots: Damalladeats, Larry Visesti +- TO TEB +N Taber 18.28 +PASSENGERS +1. Jefficy Epstein +3. +8. +9. +10. +11._. +COMMENTS +BROM Identifier Defined +ci WEST Pano Beach +State or Combry EL +TO Identifier Defed +ais Teronson +State or Coutitry _ +Nautal Miles. 1925. +Statute Miles._ +_479 +• Gallons 1470. +Pounds +Flight Time_ 2+24 +• Atitude 1l 452 +AIRERAME +98491 +2.5 +9871.6 +TAKE-OFF POWER. +Flex Take-Off _- +The bil +Min TakoOH_- IMC __ +Approaca +1. +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000325 + + +P. 018/042 +ЗіН Пакод +Registration Number: N909NE Typc: G-1159฿ +DATE: 10.Se 2005 FROM TEB +Atrival +Tino +1.484 Me +1829 +PASSENGERS +L. Jeffrey Epstein +6, +7. +8. +9. +10, +11. +12. +13. +COMMENTS +YROM Ideatifier Delistd +CiNTEtERDORO +sude or Country N. Sh +TO Identifier Befined +City +MiAMi +State or Contry _.. Elue +Nanical Miles 9,54 +StateMElo 1096 +Gallons 1200 +pounds 12222 9821 6 +Fligh Tic 2+26 +-25 +Atirador EL450 98.74.1 +TAKE-OFF POWER +Night m +Flex TakcOll. +Min Tako-Oft" +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000326 + + +.P. P.019/042 +Registration Number: N902JE +Type: G-1159B +DATE 10-6 2005 FROM MiA +B 7:34 +Arzival +Time 10:00 +PASSENGERS +1. Jefficy Epstein +2. +3: +4. +5. +6. +7. +8. +9. . +10. +11... +Bil Hampeond +Pilots: Danowedon, Larry Visorki +_ то_ +T.15.7 +1830 +13.- +COMMENTS +FROM Identifier Deflaed +Cy MiAMI +IO Identtler Defined +Cy ST. ThomAs. +State or County. USKI +Nautical Miles_ 962 +SAnte Mites 1106 +Gallons 1300 +Pounds. 994798741 +Flight Tim 2+25 +- 2.5 +win. E245098766 +TAKE-OFF POWER +Night 2.0 +Mex Taka-OR +Min Tako-Of= +Condition. +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000327 + + +P. 020/042 +Registration Number: Nº09JE Type: G-1159# +і Harmon +ilos: Dave Redgers, Larry Visos! +DATE: 10-1L.2005 FROM TLST. +4: +- TO TEB +A T 1831 +"PASSENGERS +I. Jellinar Enstein +2. +3. +FROM Identifier Defined +5. +6. +7. +8. +9. +10. +11.- +12. +13. +COMMENTS +State or Corney LSKI +TO Identifler Defined +ain_T.ETERBORO +State or Coumuy_ NJ +Nautical Miles_ 15,0k +Statute Miles /7.31 +Gallons 7040. +Ponds: 14597_98766 +Flight Time 3+40 +37 +Alitude it 43,2 +9880 3 +TAKE-OFF POWER +Night_ +Mex Take +Min Take-Off +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000328 + + +AUG-14-2005(MON) 15: 09 +P. 021/042 +Registration Number: N909JE Type: 6-12595 +DATE: 1D-23.2005 +FRONTER +a /0:11 +Am 10:55 +Time +al Harrond +Pilots: Dave Rodgers, Larry Visoski +TO +BED +Number +1832 +PASSENGERS +I Jafficy Ensacin +2. +3. +S. +6. +7. +8. +9. +10. +1l., +IZ. +13. +COMMENTS +FROM Identifier Defined +si TEAER BORD +Stacor County N.D:. +TO Identifier Defined +City- +BEDFORD +State or Contry. MA +Nautical Milles 158 +Stature Miles 20/ +Gallons 1000. +Pounds 4157 +98803 +sier Tino 44 +8 +TAKE-OFF POWER +Flex Tak-.... +Min Taka-Off_ +Condition, +Night_ +Il — +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000329 + + +P. 022/042 +Bill Bammos +Type: G-1159B +Jots: Dare Rodgers, Larry Ylsost +DATE: /0-23.2005 FROM_ BED +_ то ТЕВ +Arrival +Time. +6:18 () Tumber_ /833. +PASSENGERS +1. Jeffrey Epstein +5. +6. +7. +8. +9. +I0. +IL. +12. +13. +COMMENTS +FROM Identifier Defined +CiE-BEDFORD +State or Country. +MA +TO Identifier Befted +Ci TETERBORO +State or Country .. +Nautical Miles _ +158 +Stature Miles_ 20/ +Galons 300 +powd_ 4644 988L1 +Eniger Time +54 +9 +Aid0 71. E2160 9882.0 +TAKE-OFF POWER +Flex Takc-OC. +Min Take-OLF +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000330 + + +AUG-14-2006 (NON) 15:10 +P. 023/042 +Registation Number: NUE Type: G-1159B +DATE: 10-262005 +PROM TEB +Poen 11:14 +Antal 11:52 +PASSENGERS +1. Jettey Epsteln +Bill Hammond +Pilots: Nam-Flødyers, Jarry Viroski +_ TO BED +M Thip +Number _ +1834 +6. +7. +8, +9. +10. +11. +12. +13.. +COMMENTS +FROM Identifier Defined +CYTeTERBONO +State oT Conntr.. N5 +TO Identifier Delined +City. +BEDFORD +State or Conntry. +MA. +Nautical Miles _ +229 +Statuto Miles_ +264 +Gallons / 000 +Pouds 3798 +AIRERAME +98820 +Fiştr Tins Q+38 +Attitade El 150 +TAKE-OFF POWER +Flex Take-Off_. +Min Take-OFF_ +98826 +Night_ +The _laf +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000331 + + +P. 024/042 +DATE: 1D-2 le. 2005 +- 8:37 AN +PASSENGERS +1. Jelticy Enstein +Bill Hammoed +Pilos: Derp Rodgers, terry Visoski +Type: G-1159B +FROM BED +Anival +Thre +9.23€ +So Muabe_. 1 835 +5.. +6. +T. +8. +9. +10. +IL. +12 +13. +COMMENTS +FROM Identifier Defioed +CIE PEDFORD +Sante of Country Me +TO Idartifier Defined +CI TETERBORO +State or Couttry .... +NT +Nautical Miles +230 +Statute Miles +Z45 +Gallons 200 +Founds. +9882 6 +Pligh Time 2+45 +Aläude r bere 2883. +TAKE-OFF POWER +Night_ +Flex Tako-Off +I/L +Min Take-OfF. +Approst_P +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000332 + + +P. 025/042 +Registration Number: N9O9JE Type: G-1159B +DATE: IL-Z 2005 FROM TEB +pрa10 21 +Artival +Time +1L00 +Pilots: Deve Rodgers, Larry Visoski +- TO BED +Number +183฿ +PASSENGERS +1. Jeffrey Epstein +FROM Identificr Defiaed += ShishaiNe MAXWELL +9. +10. +1. +12, +13. +COMMENTS +State or Country _ +Nel +TO Identifier Defined +ciy_ BEDFORD +State or Country... +MA +Nautical Mitos_ 279 +Sante Miles 2-644 +Gallors 1000 +Pounds 4092 +28833 +Flight Time _ +38 +Altitude FL FL./:70 +TAKE-OFF POWER +Flex Take-Off _- +Min Take-Off +9883 +T/. +Approech__ +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000333 + + +P. 026/042 +Registration Number: N909JE| +DATE: 11-22005 +Time +PASSENGERS +Type: G-1159m +FROM BED +Pilots: Dave Rodgers, Jarry Yboski +- то 0Q4 +Number +1837 +3 Shistaiet MAKNElLe +7. +8. +9. +10. +11. +12. +13. +COMMENTS +FROM Identifier Defined +Cy BEDFORD +State or Comtry +MA +TO Ideatiller Defued +cir_ QUONSET +Stute or Country ... +RI +Netical Miles_ 5Q +Stanto Miles_ 58 +Gallona do +Pounds 1800 +{8839 +Flight Tone 17 +- 3 +Altitude FL £60 +98842 +TAKE-OFF POWER +Night, +Plex Tak-OFf TR +Min Take-Off_ +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000334 + + +AU6-14-2006 (MON) 15:10 +P. 027/042 +PASSENGER MANIFEST | +Registation Number: N909E Type: G-1159B +Pilots; Deve Rodgers, Larry Visoski +DATE: 11-2a 2003 FROM DQU +- то... +BED +3 09 8 +Trip +Time +1) Number +1838 +PASSENGERS +~ GhIsLAINE MAXWELL +9. +10, +11.- +1- +13. +COMMENTS +FROM Ideatifier Defined +City. +_QUONSET +sente o Conty. REL. +_RI +TO Ideatifier Dellned +CiNBEDFORD +State or Country.. +MA +Mentical Miles 50 +Statute Miles 50 +Galions d +Pousas 1840 +98842 +Fite Time +17. +3 +Altitudo Pr F2030 98845 +TAKE-OFF POWER +Flex Take-Off +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000335 + + +AUG-14-2006 (MON) 15:10 +P. 028/042 +Registration Number: Nº69JE +Typc: 6-1159B +DATE: 4:2a2005 FROM BED +Dele 7.35 +Ai 8 25. +• Time +PASSENGERS +1, Jeffrey Epstein +•EohIsLAINE AMAXNELL +Bill Hemmond +Pilots: Dave Rodgers, Larry Visoski +- I0 TEB +Trip +D Number. +18.39 +6. +5. +9. +10.-. +12. +12. +13.. +COMMENTS +FROM. Identifier trefined +aBEDZORD +state or comery MA +.TO Identifler Delised +O TETERETORO +Mentiul Miles_ 209 +Smmite Miles_ +264 +Gattons 200 +Pounds 4315 +Altitodo E A170 +TAKE-OFF POWER +Flax Tak-Off...- +Min Taks-Off +98845 +2885.43 +Night, +.L.L +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000336 +EFT A00066851 + +AUG-14-2006(HON) 15:10 +P. 029/042 +BBI Hoomond +• Registration Number: Nº09JE +Typc: 6-115913 +Pilots Dare Rodgers, M +DATE: 11-122005 KROM TER +_ x0 TIST. +Deat 5:20 +Arrival +Time +9:350 +My Number 1840 +PASSENGERS +I. Jedney Epstein +1 IGOR ZINDVIEW += VALDSON COTREN += MARK TAYFa +7. +3. +9. +10. +11. +12.- +13. +COMMENTS +FROM Ideatifier Defined +Cy TETERBORO +.TO Ilentiller Deftoed +city_ST. THOMAS +state or Comery USVI +Macial MARCS 1879 +Statute. Milles +Gallons 22,00 +AIRERAME +9885.3 +Piste Time 3 +14 +3.2 +ANANA RE 410 9888.5 +TAKE-OFF POWER +Night_ 3.2 +Plex Tato OF 215 In 11 +Mia Taks-00_ +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000337 + + +P. 030/042 +Registration Namber: N909JE +DATE: AL. Ila. 2005 +so 6: 549 +PASSENGERS +L. Jeliney Epstein +PASSENGER MANIFEST : +Type: 6-11595 +Plot: Dare Rode, Larry Verdi +FROM TIST +Io TEB. +Air 9 44€ +MD Trip +Time +: 2291 +- MARK TAPSAA (hEF) +00 +9. +10. +12,. +12. +13, +COMMENTS +FROM Identitier Delined +cix 3T. ThomAs +state or Country US.V VI. +.TO Identifier Delived +State or Country +Nest +Nantipal Males 1819 +Statute Miles +Gallons 18.00 +Parat 14450 +08885 +Per o 3+47 +3.8 +AlinG T EL470 98923 +TAKE-OFF POWER +Night._ +Flex Take-Off_ +Min Take-OfF. +IMC - +Condition. +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000338 + + +P. 031/042 +Registration Number, N909JZ +DATE: 11-17.2005 +Дра 9:41 0 +PASSENGERS +1. Jelfter Epeteio +2. +3. +4. +5. +6. +T. +8. +9. +10. +11. +12. +13. +COMMENTS +Тур: 6-11598 +FROM TEE +Arrival +TiNG 10:27 +Bill Hammond +Pilots; Dave Rodgers, Luerry Visoshi +- то- +D Trip +Nutber. +BED +1842 +FROM Identifier Detived +IN TETERBORO +State or County _ N.de +.TO Identifier Defined +City _ +BEDFORD +Sunto or Country. M.A. +Nautical Miles 229. +Statito Mais 264 +Galtons L000 +Powats_ 3348 +98923 +Flight Time _ ++35 +Altino / EL120 9892 9 +TAKE-OEF POWER +Night_ +Flex Tako-OFF, +TIL +Min Taks-OHI_ +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000339 + + +RUG-14-2006 (HON) 15:11 +P. 032/042 +Registration Number: N99JE +DATE: 1L 2005 +at 2:29 € +PASSENGERS +11 += ALAN DERshoWitz +3. +4. +S. +6. +7. +8. +9. +10. +11.. +12. +13. +COMMENTS +Type: G-1159B +FROM BED +Arrival +Time +3:11 +Pilots: Dave Rodgers, Larry Visoste +1 Tier 1243 +FROM Identifier Deltaed +CYBEDFORD +State or Country MA +"TO Identifler Deflaed +Clty. +MONTREAL +State or Country +_CANADA +Nautical Miles 220. +Serbie Miles 266/ +Gallons 400 +Pounds 4045 +98929 +Flight Titte m ++92 +7 +Alindor. F62909893 la +TAKE-OFF POWER +Flex Tabo-OfF +TAL. +Min Taks-OH, +Condition, +Approacta +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000340 + + +P. 033/042 +AUG-14-2005(NON) 15:11 +Registration Nurober: N909JE +Type: 6-11598 +DATE: J1-12_2005 FROM CYUL +Arrival +ime 10.26 +Bill Hamassond +Pilots: Dave Rodgers, Xarry Visoski +To BED +Trip +Namber, +1844 +PASSENGERS +~ ALAN DERshaNitz +3. +6. +7. +8. +9. +10. +II._ +12, +13. +COMMENIS +FROM Idestifier Defined +. auMONtREAL +State or County__ CANADA +IO Identifler Defined +a BEDFORD +State or Contry MA +Matical Miles 220 +Statute Miles_266/ +Galtons 3425L +Pocads 3766 +9893.6 +Pighe Tins 37 +Miton. E2280. 9894.3 +TAKE-OFF POWER +Night. +Flex Tako-Off_ +TAL +Min Taks-Off_ +Condition. +Approath. +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000341 + + +RUG-14-2006(MON) 15:11 +P. 034/042 +PASSENGER MANIFEST i +Registration Number: Nº09JE +Typc: G-11598 +DATE: 11-17,2005 +PRON BED +/ 0: 48 +Aria 12 31 +PASSENGERS +1. Jellicy Epstein +2. +ALAN DERsheWitz +3. +lots: Dave Rodgers, Larry Visox +TO +TEB +Tor_ 1845 +7. +9. +10. +11._ +12. - +13. +COMMENTS +FROM Identitler Delined +CIs BEDFORD +State or Country MA +TO Ideatifier Defined +City +TEtERBIRO +State or Country. +N.N. +Nautical Miles 2.29 +Statue Miles_ 264 +Gallons +Flight Timo +43 +Altade Tr.E2260 98950 +TAKE-OFF POWER +Min Take-OB +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000342 + + +AUG -14-2006 (NON) 15:1] +Dec. 12. 2005 10:09PM +P. 035/042 +No.1657 .P. 8 +DATE: /1 -30.2005 +Time +PASSENGERS +1. Jeffrey Epstein +2. +3. +4 Esmale +5. +6. +7. +5. +9. +10. +11. +• I2 _ +13. +COMMENTS +Type: 6-11595 +BIl Hautmond +Pilots: Dave Rodgers, Ienig femele +FROMT.EB +_ TO BER +Antival +Time +1:2 :24e +M Number: +1846 +TROM Identiter Detined +City TETERGIRO +State or Country _ +NI +,TD Identifier Defined +cily_ +BEDFORD +State or Country . MM A +Neuzical MElES - +229 +Stanne Miles +2,64 +Callas 1020 +Founds3716e.. +Flight Time 2 + 33 +Attitude Tl. 150 +TAKE-OFF POWER +Flex Tat-OFF_ +Mia Tako-OF.- +AIRERAME +9895. 0 +ite +SEPE le +IMC :2 +Approad_ P +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000343 + + +RUG-14-2006 (HON) 15:11 +Dec. 12. 2005 10:09PM +P. 036/042 +No. 1657 P. 8 +PASSENGER MANIFEST : +Registrasion Number: N909JE Type: G-11595 +DATE: /1:30.2005 TROMBED +at 8:33 0 +Anival +Time +RASSENGERS +1. Jeffrey Epstein +Bill Hanmond +Pilots, Dare Rogers, Larry Wisenti +2:20 64 Miner: 1847 +4. +5. +б. +FEmAle +9. +10... +11. +12. +13. +COMMENTS +FROM Ideatifer Defined +City_ +BEDFORO +State or Country MEl. +TO Identifler Defined +CY TETERBORO +State or Country _N$ +Nantical Miles, +229. +Stamte Miles +264 +Gallons 220 +Pounds_ 4383 +Fligh Tüx_0+47 +Altime IL 149 +TAKE-OFF POWER +Fics Take-OFF_ +Min Teko-Of_ +Condition. +9895.6 +28964 +. TIL +2 +Approach... +P +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000344 + + +AUG-14-2005(40 2 5 U 09/M +10-1857 Р. 6 P.037/082 +Type: G-11598 +BEl BArrond +Pilot: annüadghs, Larry Visoskt +DATE: 12- 2.2005 FROM TEB. +- то- +.TIST +F : 160 10400 1848 +PASSENGERS +1. Toffer Ensteit +5. IGOR += MARC IAFOYa +7, +8. +• 9. +10. +1L +12, +13. +COMMENTS +FROM Identiter Delael +TETERBORO +seai or Country AL.d, +,TO Identifier Defed +City.- +SKIHEMAS +State or Country. +usta +Nautical Miles +1879 +z 16/ +Stettite Miles, +Gattous 2000 +AIRERAME +pund: 1407998964 +Pligt Timo 3 27 +Alitalo Fl. 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Jefiney Enstein +2. +PASSENGER MANIFEST ' +Typc: G-1159B +TOM TER +Aia 11 :39 +Time +Bill Harmond +Pilots: BretoWergere Larry Visoski +- T0_ +BED +Trip +Nacabe 1,850 +• • +7. +8, +9. +11. +12. +13. +COMDENIS +FROM Identifier Delined +City +TETERBORO +Stato or Contry N. S +.TO Identifier Delined +a BEDFORD +State ar Conotty - +MA +Nutical Miles 229 +Statute Miles_ 264 +Callows 800 +AIRERAME +Rons 3325. 9903.6 +AlindoT 61709904.4 +TAKE-OFF POWER +Flex Take-Off. +TIL +Min Tak-Off. +Consition +Approacte, +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000347 + + +AUG-14-2006(MON) 15:12 +Dec-12- 2005 10:08PM +P. 040/042 +No. 1657 P. 1 +Registration Number: NOSTE +DANTE: 12 1622005 +Diarro 8 2l +PASSENGERS +Jeffrey Enstein +•HYPERION AIR, INC. +PASSENGER MANIFEST i +Type: 6-125933 +FRON. 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J. +Nantical Mies 227 +Stanto Miles 264 +Gatous_ 600 +Boiants_ 4120 +ATRERAME +9904· +Flight Tins _ +Atitude ir EL160 99052 +TAKE-OFFPOWER +Night_. +Flex Tako-Off +Min Tassion +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000348 + + +P. 041/042 +AUG-14-2006 (MON) 15:12 +Repistration Natober: N909JE +DATE: 12 21 2005 +TaIN 5 24 +Time +PASSENGERS +2 GHISLAINE MAXWELL +3. +4. +5. +6. +.7. +8. +9. +10. +1l. +12. +13.. +COMMENTS +:: +Турс: G-1159฿ +THOM TES +Arrival +Time +603 +Pilots: Dave Rodgers, Larry Visaski +- то BED +1 Timb: 1852 +FROM Idcatifier Defined +Ciy TETERBORO +Btate or Country. +NJ +„ED Identifier Defined +City. +BEDFORD +State of Country +MA +Nautical Miles. +Statute Miles +Gallons +2400 +Poinds 4154 +Flight Time +-+39. +Altitudo I 130 +TAKE-OFF POWER +9905.2 +6 +9905.8 +• Night... +6 +Min Ta. +2 •d +6800-4LL (0/E) +MM16-31E-MM-108062-GJ-1A SEC 001 SER 1A1-1A5-000349 + + +AU6-14-2006(MON) 15:12 +P. 042/042 +Typc: G-11503 +Pilots: Dave Rodgers, Larry Visoski +PROM BEO +xo TIST +A 10.58 +Time +mr_ 1853 +DATE: 12 21.2005 +Fa 6 24 AN +PASSENGERS +LI +z. 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Group the inmates according to their respective housing units. This form is to be used only as an +Out-Count. No other form will be accepted in lieu of the Out-Count Form. + + +NYMDK 530*05* +INMATE ROSTER + +CATEGORY: OCT +ASSIGNMENT: HOSP +OPER CATG ASSIGNMENT +OPER +CATG ASSIGNMENT +NUM ASSIGNMENT REG NO +NAME +0001 HOSP +89673-053 MERSEY +* +07-25-2019 +19:59:19 +GROUP CODE: +FACILITY: NYM +OPER CATG ASSIGNMENT +OCT DATE +OTR +07-25-2019 E12-592U +WRK +ES PM +SUICIDE OR +GO000* +TRANSACTION SUCCESSFULLY +COMPLETED + + +Unit: +Count: +Signature: +Signature +Metropolitan Correctional Center +Official Count Slip +IN +_ Date _ +7/25/2019 +92 +Time: 1000 fos. +C. Washingten +I Manate +C. Tone, +Ce +Unit: +HA +Count: +Metropolitan Correctional Center +Official Count Slip +_ Date _ +7/25/19 +Time: 10:00pm +Signature: +B-Lame +Signature_ +Unit: ES +Count: +Metropolitan Correctional Center +Official Count Slip +Date: 07-25-19 +85 +Time: 1000 pre +mos +Signature: +Signature: +RichARaser +Metropolitan Correctional Center +Official Count Slip +Unit:_ +CA +_ Date +7/25/19 +Count: _ +10 +Time: 10008m +A Baptiste +Signature: +Baptiste +whit? +Signature +Metropolitan Correctional Center +Official Count Slip +Unit: +KN +Count: +90 +Date +7/25/17 +_Time: 10:00 PM +J. RICKENBACKER +Signature: +Signature. +Marcus +.. 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Ghislaine Maxwell, 20 Cr. 330 (AJN) -- Renewed Bail Motion and Exhibits (to be +Filed Under Seal) +Date: Tue, 08 Dec 2020 22:26:12 +0000 +Attachments: Memorandum_re_Second_Bail_Application_Final_Redacted.PDF; +Exhibit A Redacted par, Exhibit Redacted pi, Exhibil C. Redacted pal; +Inline-Images: image001.gif; image004.jpg +Dear Judge Nathan - +Attached please find the following documents submitted to the Court and all counsel under seal pursuant to the Court's +order (Dkt. 89): +1. Renewed bail motion (redacted) +2. Accompanying exhibits A-E (redacted) +Regards, +Christian R Everdell +COHEN & GRESSER LLP +New York NY 10022 +view bio +www.cohengresser.com +New York | Paris | Washington DC | London +CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only +the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient, you are hereby notified that any +review, dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error, please immediately notify +the sender by telephone and permanently delete this e-mail. Thank you. +PRIVACY: A complete copy of our privacy policy can be viewed at: https://www.cohengresser.com/privacy-policy diff --git a/vision-fixhub/ds9-parsed-01/23bc1edab5beac82489f6a36cad9510447a2af30ea5899a35ad4f4639e1b4a18.receipt.json b/vision-fixhub/ds9-parsed-01/23bc1edab5beac82489f6a36cad9510447a2af30ea5899a35ad4f4639e1b4a18.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..d31e1788ccfab39694dd9e5cb36853ea94a15034 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/23bc1edab5beac82489f6a36cad9510447a2af30ea5899a35ad4f4639e1b4a18.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "23bc1edab5beac82489f6a36cad9510447a2af30ea5899a35ad4f4639e1b4a18", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "e8a6409c25b4693d1061dd4e699b3a796c8c9720fac4ef2eb72328658741c808", + "output_sha256": "670a2b5453d6a355f3139afff5178f8f51056be307f9053172ab2eb2f07fb0d4", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/23e34ff97e33a6c8a6722df9816da37d5e30138eb3cfafd464b0606e1a289d8e.md b/vision-fixhub/ds9-parsed-01/23e34ff97e33a6c8a6722df9816da37d5e30138eb3cfafd464b0606e1a289d8e.md new file mode 100644 index 0000000000000000000000000000000000000000..7d26bf24f8e293167ec08fcbd686792dbf661ba5 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/23e34ff97e33a6c8a6722df9816da37d5e30138eb3cfafd464b0606e1a289d8e.md @@ -0,0 +1,768 @@ +Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 1 of 26 +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +UNITED STATES OF AMERICA, +20 Cr. 330 (AJN) +V. +GHISLAINE MAXWELL, +Defendant. +-X +IN OPPOSITION TO COVER HE OTION FOR DETENTION +Mark S. Cohen +Christian R. Everdell +COHEN & GRESSER LLP +800 Third Avenue +New York, NY 10022 +Phone: 212-957-7600 +Jeffrey S. Pagliuca +(pro hac vice admission pending) +Laura A. Menninger +HADDON, MORGAN & FORMAN P.C. +150 East 10th Avenue +Denver, Colorado 80203 +Phone: 303-831-7364 +Attorneys for Ghislaine Maxwell + + +Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 2 of 26 +TABLE OF CONTENTS +PRELIMINARY STATEMENT +ARGUMENT +I. +The Conditions Created by the COVID-19 Pandemic Mandate the Release of +Ms. Maxwell. +II. +The Government Has Not Carried Its Burden Under 18 U.S.C. § 3142. +A. Applicable Law +B. Ms. Maxwell Has Rebutted the Presumption That She Poses a Flight +Con indion or Condions Can Be Imposed Reasombly Assure Her +Presence In Court +Ms. Maxwell's Personal History and Characteristics +Demonstrate That She Is Not a Flight Risk. +The Nature and Circumstances of the Charges and the Weight of +the Evidence Militate in Favor of Bail. +The Proposed Bail Package Is More Than Adequate to Secure +Ms. Maxwell's Presence +Page +1 +..5 +5 +..9 +9 +CONCLUSION +11 +12 +17 +. 20 +22 + + +Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 3 of 26 +TABLE OF AUTHORITIES +Page(s) +Cases +Hung v. United States, +439 U.S. 1326 (1978).. +United States v. Abdellatif El Mokadem, +No. 19-CR-646 (AJN), 2020 WL 3440515 (S.D.N.Y. June 23, 2020). +United States v. Alindato-Perez, +627 F. Supp. 2d 58 (D.P.R. 2009)... +United States v. Bodmer, +No. 03-cr-947(SAS), 2004 WL 169790 (S.D.N.Y. Jan. 28. 2004). +United States v. Boustani, +932 F.3d 79 (2d Cir. 2019). +United States v. Carrillo-Villa, +20-MJ-3073 (SLC)... +United States v. Chandler, 19-CR-867 (PAC), +2020 WL 1528120 (S.D.N.Y. Mar. 31, 2020) . +United States v. Conway, +No. 4-11-70756 MAG(DMR), 2011 WL 3421321 (N.D. Cal. Aug. 3, 2011) .. +United States v. Crowell, +No. 06-CR-291E(F), 2006 WL 3541736 (W.D.N.Y. Dec. 7, 2006) +United States v. Deutsch, +No. 18-CR-502 (FB), 2020 WL 3577398 (E.D.N.Y. July 1, 2020) +United States v. DiGiacomo, +746 F. Supp. 1176 (D. Mass. 1990). +United States v. Dominguez, +783 F.2d 702 (7th Cir. 1986) +United States v. Dreier, +596 F. Supp. 2d 831 (S.D.N.Y. 2009)... +United States v. English, +629 F.3d 311 (2d Cir. 2011). +.. 16 +17 +18 +16 +8 +8,9 +10,18 +11 +11,18 +.. 14 +.. 10 +..21 +10,11 +ii + + +Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 4 of 26 +United States v. Epstein, +425 F. Supp. 3d 306 (S.D.N.Y. 2019) +United States v. Esposito, +309 F. Supp. 3d 24 (S.D.N.Y. 2018).. +United States v. Friedman, +837 F.2d 48 (2d Cir. 1988). +United States v. Hansen, +108 F. App'x 331 (6th Cir. 2004). +United States v. Hanson, +613 F. Supp. 2d 85 (D.D.C. 2009) +United States v. Karni, +298 F. Supp. 2d 129 (D.D.C. 2004). +United States v. Kashoggi, +717 F. Supp. 1048 (S.D.N.Y. 1989).. +United States v. Mattis, +No. 20-1713, 2020 WL 3536277 (2d Cir. June 30, 2020) +United States v. Moscaritolo, +No. 10 Cr. 4 (JL), 2010 WL 309679 (D.N.H. Jan. 26, 2010) +United States v. Sabhnani, +493 F.3d 63 (2d Cir. 2007). +United States v. Salerno, +481 U.S. 739 (1987). +United States v. Stephens, 15-CR-95 (AJN), +2020 WL 1295155 (S.D.N.Y. Mar. 19, 2020) +United States v. Veres, +No. 3:20-CR-18-J-32JBT, 2020 WL 1042051 (M.D. Fla. Mar. 4, 2020) +United States v. Williams-Bethea, +No. 18-CR-78 (AJN), 2020 WL 2848098 (S.D.N.Y. June 2, 2020). +Statutes +18 U.S.C. § 3142 +17 +..21 +13,18 +16 +16 +16 +16 +.. 10 +18 +9,10, 16, 18 +9 +• 5, 6,7,8 +18 +6 +- passim +ili + + +Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 5 of 26 +PRELIMINARY STATEMENT +Ghislaine Maxwell respectfully submits this Memorandum in Opposition to the +government's July 2, 2020 Memorandum in Support of Detention ("Gov. Mem."). +It is difficult to recall a recent case that has garnered more public attention than the +government's prosecution of Jeffrey Epstein ("Epstein"). In July 2019, Epstein was indicted for +offenses relating to sexual misconduct, amid overwhelming media attention focused on the +nature of the charges and Epstein's wealth and lifestyle. On August 10, 2019, Epstein died in +federal custody, and the media focus quickly shifted to our client—wrongly trying to substitute +her for Epstein even though she'd had no contact with Epstein for more than a decade, had +never been charged with a crime or been found liable in any civil litigation, and has always +denied any allegations of claimed misconduct. Many of these stories and online posts were +threatening and harassing to our client and those close to her. +But sometimes the simplest point is the most critical one: Ghislaine Maxwell is not +Jeffrey Epstein. She was not named in the government's indictment of Epstein in 2019, despite +the fact that the government has been investigating this case for years. Instead, the current +indictment is based on allegations of conduct that allegedly occurred roughly twenty-five years +ago. Ms. Maxwell vigorously denies the charges, intends to fight them, and is entitled to the +presumption of innocence. Far from "hiding," she has lived in the United States since 1991, has +litigated civil cases arising from her supposed ties to Epstein, and has not left the country even +once since Epstein's arrest a year ago, even though she was aware of the pending, and highly +publicized, criminal investigation. She should be treated like any other defendant who comes +before this Court, including as to bail. Under the Bail Reform Act, case law in this Circuit and +other circuits, as well as decisions of this Court, Ms. Maxwell should be released on bail, subject +to the strict conditions proposed below. + + +Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 6 of 26 +Background. Ms. Maxwell, 58, is a naturalized U.S. citizen who has resided in the +United States since 1991. She is also a citizen of France, where she was born, and of the United +Kingdom, where she was educated and spent her childhood and formative years. Ms. Maxwell +graduated from Oxford University. She moved to the United States in 1991, and has lived in this +country ever since that time. Ms. Maxwell has maintained extremely close relationships with her +six siblings and her nephews and nieces. They all stood by her in the aftermath of the July 2019 +indictment of Epstein and continue to stand by her now. She is especially close to two of her +sisters and their children, all of whom reside in the United States. Ms. Maxwell also has +numerous friends in the United States who themselves have children, and she is a godmother to +many of them. Ms. Maxwell's family and friends have remained committed to her because they +do not believe the allegations against her, which do not match the person they have known for +decades. +The Government's Position. The government has the burden of persuasion in showing +that detention is warranted, and that there are no conditions or combination of conditions that +will secure a defendant's appearance in court. In seeking to carry this burden, the government +relies on the presumption of detention in 18 U.S.C. § 3142(e)(3)(E), and argues that Ms. +Maxwell poses a flight risk because she supposedly lacks ties to the United States; is a citizen of +the United Kingdom and France, as well as a citizen of the United States, and has passports for +each country; has traveled internationally in the past; and has financial means. And echoing +recent media stories, the government speculates that Ms. Maxwell was "hiding" from law +enforcement during the pendency of the investigation, even though she has been in regular +contact with the government, through counsel, since Epstein's arrest. Finally, the government +argues that the nature and circumstances of the offense and the weight of the evidence warrant +2 + + +Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 7 of 26 +detention. Importantly, in contrast with the bail position it took with Epstein, the government +does not and cannot assert that Ms. Maxwell presents a danger to the community under Section +3142(g)(4). +Ms. Maxwell's Response. The Court should exercise its discretion to grant bail to Ms. +Maxwell, on the strict conditions proposed below (or as modified by the Court), for two +compelling reasons. +First, the COVID-19 crisis and its impact on detained defendants warrants release. As +this Court has noted, the COVID-19 pandemic represents an unprecedented health risk to +incarcerated individuals, and COVID-19-related restrictions on attorney communications with +pretrial detainees significantly impair a defendant's ability to prepare her defense. Simply put, +under these circumstances, if Ms. Maxwell continues to be detained, her health will be at serious +risk and she will not be able to receive a fair trial. (See infra Section I, pages 5 to 9). +Second, the Court should grant bail because the government has not met its burden under +the Bail Reform Act and controlling case law. The presumption relied on by the government +may be rebutted, and is so here. Ms. Maxwell has strong ties to the community: she is a U.S. +citizen and has lived in this country for almost 30 years; she ran a non-profit company based in +the United States until the recent media frenzy about this case forced her to wind it down to +protect her professional colleagues and their organizations; and she has very close ties with +family members and friends in New York and the rest of the country. Nor does her conduct +indicate that she is a flight risk: she has no prior criminal record; has spent years contesting civil +litigation arising from her supposed ties to Epstein; and has remained in the United States from +the time of Epstein's arrest until the present, with her counsel in regular contact with the +government. She did not flee, but rather left the public eye, for the entirely understandable +3 + + +Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 8 of 26 +purpose of protecting herself and those close to her from the crush of media and online attention +and its very real harms-those close to her have suffered the loss of jobs, work opportunities, +and reputational damage simply for knowing her. The government's remaining arguments +about Ms. Maxwell's passports, citizenship, travel and financial means — also fail because they +would require that every defendant with multiple citizenship and financial means be denied bail, +which is simply not the law. Finally, as discussed below, the government's position regarding +the nature and circumstances of the offense and weight of its evidence, which relates to alleged +conduct that is roughly twenty-five years old, is not persuasive and does not alter the bail +analysis. (See infra Section II, pages 9 to 21). +Proposed Bail Conditions. In light of the above, we propose the following bail +conditions, which are consistent with those that courts in this Circuit have imposed in analogous +situations: (i) a $5 million personal recognizance bond, co-signed by six financially responsible +people, all of whom have strong ties to Ms. Maxwell, and secured by real property in the United +Kingdom worth over $3.75 million; (ii) travel restricted to the Southern and Eastern Districts of +New York; (iii) surrender of all travel documents with no new applications; (iv) strict +supervision by Pretrial Services; (v) home confinement at a residence in the Southern District of +New York with electronic GPS monitoring: (vi) visitors limited to Ms. Maxwell's immediate +family, close friends and counsel; (vii) travel limited to Court appearances and to counsel's +office, except upon application to Pretrial Services and the government; and (vili) such other +terms as the Court may deem appropriate under Section 3142. +The Bail Reform Act does not discard the presumption of innocence; Ms. Maxwell is +entitled to that presumption here, as she is in all aspects of this case. See 18 U.S.C. § 3142() +("Nothing in this section [3142] shall be construed as modifying or limiting the presumption of +4 + + +Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 9 of 26 +innocence."). The government has failed to meet its burden of establishing that Ms. Maxwell +presents an "actual risk of flight" and must be detained under Section 3142. The strict bail +conditions outlined above are appropriate under the circumstances and are the "least restrictive" +set of conditions that will "reasonably assure" Ms. Maxwell's appearance in Court, without the +health and access to counsel risks inherent in the government's request that Ms. Maxwell be +detained pending trial. See 18 U.S.C. § 3142 (c)(1)(B). Under the controlling legal standards, +Ms. Maxwell should be released on bail. +ARGUMENT +There are two compelling reasons why the Court should order Ms. Maxwell's release +on bail pursuant to the strict conditions she has proposed: +First, Ms. Maxwell will be at significant risk of contracting COVID-19 if she is detained, +and she will not be able to meaningfully participate in the preparation of her defense due to the +restrictions that have been placed on attorney visits and phone calls in light of the pandemic. +Second, the government has failed to carry its burden under 18 U.S.C. § 3142 that no +combination of conditions can be imposed that will reasonably assure Ms. Maxwell's presence in +court. +1. +The Conditions Created by the COVID-19 Pandemic Mandate the Release of +Ms. Maxwell. +Impact of COVID-19 on the Prison Population. We submit that the conditions created by +the COVID-19 pandemic compel Ms. Maxwell's release pursuant to appropriate bail conditions. +Four months ago, this Court held in United States v. Stephens, 15-CR-95 (AJN), 2020 WL +1295155 (S.D.N.Y. Mar. 19, 2020), that COVID-19 is an "unprecedented and extraordinarily +dangerous" threat that justifies release on bail. Id. at *2. In that case, the defendant, who had no +underlying medical conditions, filed an emergency motion for reconsideration of the Court's +5 + + +Case 1:20-Cr-00330-AJN Document 18 Filed 07/10/20 Page 10 of 26 +prior detention order based in part on the risks brought on by COVID-19. At the time, COVID- +19 had only begun to take its devastating toll on New York, and there was no known outbreak in +the prison population. Nevertheless, the Court noted that "inmates may be at a heightened risk of +contracting COVID-19 should an outbreak develop," and, based in part on this changed +circumstance, ordered the defendant released. Id. +Since the Court issued its opinion in Stephens, the COVID-19 risks to inmates have +increased dramatically, as there have been significant outbreaks of COVID-19 in correctional +facilities. In the last month alone, the number of prison inmates known to have COVID-19 has +doubled to 68,000, and prison deaths tied to COVID-19 have increased by 73 percent.' Indeed, +as of July 2, 2020, nine of the ten largest known clusters of the coronavirus in the United States +are in federal prisons and county jails.? As this Court noted last month, "the "inability [of] +individuals to socially distance, shared communal spaces, and limited access to hygiene +products' [in correctional facilities] make community spread all but unavoidable." United States +v. Williams-Bethea, No. 18-CR-78 (AJN), 2020 WL 2848098, at *5 (S.D.N.Y. June 2, 2020) +(citation and internal quotation marks omitted). The risks are further enhanced by the possibility +of a second wave of coronavirus cases. 3 +In particular, COVID-19 has begun to spread through the Metropolitan Detention Center +(MDC), where Ms. Maxwell has been housed since the Bureau of Prisons (BOP) transferred her +there on July 6, 2020. According to the MDC's statistics, as of April 3, 2020, two inmates and +' Timothy Williams, et al., Coronavirus Cases Rise Sharply in Prisons Even as They Plateau Nationwide, N.Y. +Times, available at https://www.nytimes.com/2020/06/16/us/coronavirus-inmates-prisons-jails.html (last updated +June 30, 2020). +* Coronavirus in the U.S: Latest Map and Case Count, N.Y. Times, available at +https://www.nytimes.com/interactive/2020/us/coronavirus-us-cases.html#clusters (last updated July 2, 2020). +" See, eg., Audrey Cher, WHO's Chief Scientist Says There's a "Very Real Risk" of a Second Wave of Coronavirus +As Economies Reopen, CNBC, June 9, 2020, available at https://www.cnbc.com/2020/06/10/who-says-theres-realrisk-of-second-coronavirus-wave-as-cconomies-reopen.html. +6 + + +Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 11 of 26 +five staff had tested positive; by June 30, 2020, those numbers had risen to 14 and 41, +respectively.* The increased spread among prisons means that the COVID-19 risks that were +present in the Stephens case four months ago are far more serious for Ms. Maxwell now and +mandate her release. +Impact of COVID-19 on the Ability to Prepare the Defense. The Stephens opinion +provides yet another independent basis that, we submit, requires Ms. Maxwell's release: if she is +detained, her ability to meet with her attorneys and prepare for her defense will be significantly +impaired and she will not be able to meaningfully participate in the preparation of her defense. +In Stephens, the Court found that this factor required the defendant's release under 18 +U.S.C. § 3142(i), which provides for temporary release based on a determination that such +release is "necessary for preparation of the person's defense." Stephens, 2020 WL 1295155 at +*3. The Court noted that the spread of COVID-19 had compelled the BOP to suspend all inperson visits, including legal visits, except as allowed on a case-by-case basis. Id. at *3. That +suspension persists to this day. In a case such as this, which will require assessing evidence +relating to events that occurred approximately twenty-five years ago, including documents and +personal recollections, numerous in-person meetings between counsel and Ms. Maxwell will be +critical to the preparation of the defense. The recent resurgence of the pandemic calls into +question whether these meetings will ever be able to happen in advance of her trial. As in +* See April 3, 2020 Report from the BOP regarding the Metropolitan Detention Center and Metropolitan +Correctional Center ("MDC and MCC Report"), available at +https://img.nyed.uscourts.gov/files/reports/bop/20200403_BOP_Report.pdf; and June 30, 2020 MDC and MCC +Report, available at https://www.nyed.uscourts.gov/pub/bop/MDC_MCC_20200630_071147.pdf. +5 See BOP COVID-19 Modified Operations Plan, available at https://www.bop.gov/coronavirus/covid19 _status.jsp. +7 + + +Case 1:20-Cr-00330-AJN Document 18 Filed 07/10/20 Page 12 of 26 +Stephens, Ms. Maxwell's inability to meet with her attorneys while this policy is in effect +constitutes a "compelling reason" requiring her release. Stephens, 2020 WL 1295155 at *3.° +Even speaking by phone with Ms. Maxwell presents daunting challenges due to COVID- +19-related protocols requiring at least 72 hours' notice to schedule a call, unless it is urgent, in +which case counsel can email a request to the MDC. As counsel learned this past week, +however, even an urgent call request does not mean the call will take place in the time required. +At approximately 5:30 p.m. on July 6, 2020, the Court ordered us to confer with Ms. Maxwell +about waiving her physical presence at the arraignment, initial appearance, and bail hearing, and +ordered counsel for both sides to jointly report back by 9:00 p.m. that night with a proposed date +and time for these proceedings. We promptly emailed the MDC to request an urgent call, +making specific reference to the Court's Order, but were not connected with Ms. Maxwell until +9:00 p.m. There will no doubt be other orders of the Court with no guarantees we will be able to +reach our client in time if she is detained.? In addition, during this past week, Ms. Maxwell has +not been able to physically review documents and has had limited access to writing materials. +The prohibition on in-person visits means we must read to her any documents requiring her +review, and she has virtually no ability to take notes. The age of the allegations in this case +compound these problems. Under the current circumstances, Ms. Maxwell cannot review +"Since the Court issued its opinion in Stephens, numerous other courts in this District have ordered defendants +released on bail, over the government's objection, due to the pandemic and its impact on the defendant's ability to +prepare for trial. See, e.g., United States v. Carrillo-Villa, 20-MJ-3073 (SLC) (S.D.N.Y. Apr. 6, 2020) (releasing +undocumented defendant in drug conspiracy case because of inability to meaningfully communicate with lawyer and +risk of COVID-19); United States v. Hudson, 19-CR-496 (CM) (S.D.N.Y. Mar. 19, 2020) (releasing defendant in +drug conspiracy, loansharking, and extortion case, whose two prior, pre-COVID-19 bail applications were denied, +because of inability to prepare for upcoming trial and risk of COVID-19); United States v. Chandler, 19-CR-867 +(PAC), 2020 WL 1528120, at *1 (S.D.N.Y. Mar. 31, 2020) (releasing defendant on felon in possession case, with +prior manslaughter conviction, due to inability to prepare for trial due to COVID-19 restrictions). +'The government has recently worked with the BOP to set up a standing call between counsel and Ms. Maxwell +each morning until the initial appearance to facilitate attorney-client communications. While we greatly appreciate +these efforts, they are a short-term patch to a persistent problem that shows no signs of abating. Nor would it be +appropriate, on an ongoing basis, for the prosecutors to be involved in and dictate the date and time of our +communications with our client in connection with the preparation of our defense. +8 + + +Case 1:20-Cr-00330-AJN Document 18 Filed 07/10/20 Page 13 of 26 +documents and other evidence from approximately twenty-five years ago and meaningfully assist +in the preparation of her defense. These restrictions are additional "compelling reasons" +justifying her release. See id. +II. +The Government Has Not Carried Its Burden Under 18 U.S.C. § 3142. +The grave concerns raised by the current COVID-19 crisis notwithstanding, Ms. Maxwell +must be released because she has met her limited burden of production showing that she does not +pose a flight risk, and the government has entirely failed to demonstrate that no release condition +or combination of conditions exist that will reasonably assure Ms. Maxwell's presence in court. +A. Applicable Law +As the Supreme Court has recognized, "Ti]n our society liberty is the norm, and detention +prior to trial or without trial is the carefully limited exception." United States v. Salerno, 481 +U.S. 739, 755 (1987). Pretrial detention is appropriate only where "no condition or combination +of conditions will reasonably assure the appearance of the [defendant]." United States v. +Sabhnani, 493 F.3d 63, 75 (2d Cir. 2007) (quoting 18 U.S.C. § 3142(e)). The Bail Reform Act +provides that a court "shall order the pretrial release" of the defendant (18 U.S.C. § 3142(b)) +(emphasis added), but may impose bail conditions if "such release will not reasonably assure the +appearance" of the defendant in court. 18 U.S.C. § 3142(c). Where conditions are necessary, +such release shall be "subject to the least restrictive ... set of conditions that [the court] +determines will reasonably assure the appearance of the person as required." 18 U.S.C. § +3142(c)(1)(B) (emphasis added). Consequently, "[u]nder this statutory scheme, 'it is only a +limited group of offenders who should be denied bail pending trial.'" Sabhnani, 493 F.3d at 75 +(citation and internal quotation marks omitted). +9 + + +Case 1:20-Cr-00330-AJN Document 18 Filed 07/10/20 Page 14 of 26 +The government bears a dual burden in seeking pre-trial detention. First, the government +must show "by a preponderance of the evidence that the defendant ... presents an actual risk of +flight." Sabhnani, 493 F.3d at 75 (emphasis added). If the government is able to satisfy this +burden, it must then "demonstrate by a preponderance of the evidence that no condition or +combination of conditions could be imposed on the defendant that would reasonably assure his +presence in court." Id. +In determining whether there are conditions of release that will reasonably assure the +appearance of the defendant, the court must consider (1) the nature and circumstances of the +offense charged; (2) the weight of the evidence against the person; (3) the history and +characteristics of the person; and (4) the nature and seriousness of the danger to any person or +the community that would be posed by the person's release. 18 U.S.C. § 3142(g). +In this case, unlike in the Epstein case, the government does not contend that Ms. +Maxwell poses any danger to the community, and therefore the fourth factor does not apply. +The Bail Reform Act contains a rebuttable presumption, applicable based on certain of +the crimes charged here, that no conditions will reasonably assure against flight. See 18 U.S.C. § +3142(e)(3)(E). In cases where this presumption applies, the "defendant bears a limited burden of +production not a burden of persuasion to rebut that presumption by coming forward with +evidence that [she] does not pose ... a risk of flight." See United States v. English, 629 F.3d +311, 319 (2d Cir. 2011) (quotation omitted). This rebuttable presumption can be readily +satisfied, United States v. Conway, No. 4-11-70756 MAG (DMR), 2011 WL 3421321, at *2 +(N.D. Cal. Aug. 3, 2011), and "[a]ny evidence favorable to a defendant that comes within a +category listed in § 3142(g) can affect the operation" of the presumption. United States v. +Dominguez, 783 F.2d 702, 707 (7th Cir. 1986); see also United States v. Mattis, No. 20-1713, +10 + + +Case 1:20-Cr-00330-AJN Document 18 Filed 07/10/20 Page 15 of 26 +2020 WL 3536277, at *4-5 (2d Cir. June 30, 2020). Although the presumption "remains a factor +to be considered" even after the defendant has met her burden of production, "[a]t all times ... +the government retains the ultimate burden of persuasion by ... a preponderance of the +evidence" that the defendant poses a flight risk that cannot be addressed by any bail conditions. +English, 629 F.3d at 319 (citation and internal quotation marks omitted); see also United States +v. Deutsch, No. 18-CR-502 (FB), 2020 WL 3577398, at *5 (E.D.N.Y. July 1, 2020). And +regardless of the presence of the presumption or the nature of the charges alleged, "InJothing in +this section [3142] shall be construed as modifying or limiting the presumption of innocence." +18 U.S.C. § 3142(); see also United States v. Crowell, No. 06-CR-291E(F), 2006 WL 3541736, +at *3 (W.D.N.Y. Dec. 7, 2006) (those charged with crimes involving minors "continue to enjoy +the presumption of innocence in setting conditions of release."). +B. +Ms. Maxwell Has Rebutted the Presumption That She Poses a Flight +Risk, and the Government Has Not Carried Its Burden That No +Combination of Conditions Can Be Imposed To Reasonably Assure Her +Presence In Court +The government has not carried its burden of establishing that no set of conditions +will reasonably assure Ms. Maxwell's appearance in court. As set forth below, Ms. +Maxwell's personal history, her family and other ties to this country, and her conduct prior +to her arrest easily rebut the presumption that she presents a risk of flight. For these same +reasons, the government cannot establish that the strict bail conditions she proposes, which +are consistent with a number of cases in this Circuit in which courts have ordered release, +will not "reasonably assure" her presence in court. Accordingly, the Court should order Ms. +Maxwell released pursuant to her proposed conditions. + + +Case 1:20-Cr-00330-AJN Document 18 Filed 07/10/20 Page 16 of 26 +Ms. Maxwell's Personal History and Characteristies +Demonstrate That She Is Not a Flight Risk +a. +Ms. Maxwell Has No Prior Criminal Record, and Has +Significant Ties to the United States and the New York Region +Ms. Maxwell's history and characteristics do not "strongly support detention," as the +government contends (Gov. Mem. at 6), but instead demonstrate that she is firmly rooted in +this country and that her appearance can be reasonably assured with appropriate bail +conditions. Ms. Maxwell has no criminal record, which includes the approximately twentyfive-year period from the time the conduct alleged in the indictment took place to the +present. Ms. Maxwell also has significant ties to the United States. She has lived in this +country for almost 30 years and became a naturalized U.S. citizen in 2002. Ms. Maxwell +also has strong family ties to this country. Two of her sisters, who have agreed to co-sign +her bond, live in the United States, and they have several children who are U.S.-born +citizens. Ms. Maxwell is very close with her sisters and maintains regular contact with +them, as well as with her nieces and nephews. Ms. Maxwell also has numerous close +friends and professional colleagues who reside in this country. In sum, the United States has +been Ms. Maxwell's home for decades. +b. +Ms. Maxwell Has Actively Litigated Civil Cases in this District +and Has Not Left the United States Since Epstein's 2019 Arrest +Ms. Maxwell has never once attempted to "hide" from the government or her +accusers, and has never shown any intent to leave the country. To the contrary, Ms. +Maxwell has always vehemently denied that she was involved in illegal or improper conduct +related to Epstein, and her conduct has been entirely consistent with someone who fully +intends to remain in this country and fight any allegations brought against her. For example, +since 2015, and continuing through today, Ms. Maxwell has actively litigated several civil + + +Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 17 of 26 +cases related to Epstein in the Southern District of New York and has sat for depositions in +those cases. Similarly, throughout the course of the criminal investigation of this case, +which has been publicly reported on for nearly a year, Ms. Maxwell has remained in the +United States. Indeed, on July 7, 2019, the day after Epstein's arrest, Ms. Maxwell reached +out to the prosecutors in the Southern District of New York, through counsel, and +maintained regular contact with them right up to the point of her arrest. +The government's broad assertion that Ms. Maxwell has engaged in "frequent +international travel" in the last three years (Gov. Mem. at 6) obscures the critical point: she +has not left the country even once since Epstein's arrest. Ms. Maxwell's decision to remain +in the United States after Epstein's arrest and subsequent death in August 2019 is +particularly significant because any incentive she may have had to flee would have been +even more acute at that time. Within days of Epstein's death, a steady stream of press +articles began turning the public's attention to Ms. Maxwell—wrongly substituting her for +Epstein and speculating that she had become the prime target of the government's +investigation.? Adding even more fuel to this fire, several of the women claiming to be +victims of Epstein's abuse began publicly calling for her immediate arrest and prosecution. +Despite the increasing risk of being criminally charged, and the media firestorm that was +redirected toward her after Epstein's death, and despite having ample opportunity to leave +the country, Ms. Maxwell stayed in the United States for almost an entire year until she was +arrested. These actions weigh heavily in favor of release. See United States v. Friedman, +"See, e.g., Spotlight turns on Jeffrey Epstein's British socialite 'fixer' Ghislaine Maxwell after his suicide - but will +she be prosecuted?, Daily Mail (Aug. 10, 2019), https://www.dailymail.co.uk/news/article-7344765/Spotlight-turns- +Jeffrey-Epsteins-fixer-Ghislaine-Maxwell-suicide.html; Ghislaine Maxwell: the woman accused of helping Jeffrey +Epstein groom girls, The Guardian (Aug. 12, 2019), https://www.theguardian.com/us-news/2019/aug/12/ghislainemaxwell-woman-accused-jeffiey-epstein-groom-girls; British socialite Ghislaine Maxwell in spotlight after +Epstein's apparent suicide, NBC News (Aug. 12, 2019), https://www.nbcnews.com/news/us-news/british-socialiteghislaine-maxwell-spotlight-after-epstein-s-apparent-suicide-n1041111. +13 + + +Case 1:20-Cr-00330-AJN Document 18 Filed 07/10/20 Page 18 of 26 +837 F.2d 48, 49-50 (2d Cir. 1988) (overturning district court's decision that defendant posed +a flight risk based in part on the ground that the defendant took "no steps" to flee +jurisdiction in three-week period between execution of search warrant at home and arrest); +United States v. DiGiacomo, 746 F. Supp. 1176, 1179-80 (D. Mass. 1990) (concluding +defendants did not present a flight risk because each of them "for three years knew there +was substantial evidence of the likely charges against them and did not attempt to flee +before indictment"). +Indeed, the absence of any allegation by the government that Ms. Maxwell was +taking steps to leave the country at the time of her arrest is conspicuous. The government +has offered no proof that she was making plans to leave the country. In fact, had the +government alerted her counsel that she was about to be arrested, we would have arranged +for Ms. Maxwell's prompt, voluntary surrender. Instead, the government arrested Ms. +Maxwell without warning on the day before the July 4* holiday, thus ensuring that she +would be in federal custody on the one-year anniversary of Epstein's arrest. +c. +Ms. Maxwell's Actions to Protect Herself From Intrusive Media +Coverage and Death Threats Do Not Demonstrate an Intent to +Furthermore, the steps Ms. Maxwell took to leave the public eye after Epstein's +arrest are not indicative of a risk of flight. The government notes that Ms. Maxwell dropped +out of public view after Epstein's arrest, which the government seeks to portray as "hiding" +from the law. The government further argues that she has taken several steps to avoid +detection, including moving residences and switching her phone and email address. (Gov. +Mem. at 8). But Ms. Maxwell did not take these steps to hide from law enforcement or +evade prosecution. Instead, they were necessary measures that Ms. Maxwell was forced to +14 + + +Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 19 of 26 +take to protect herself, her family members, her friends and colleagues, and their children, +from unrelenting and intrusive media coverage, threats, and irreparable reputational harm. +Ever since Epstein's arrest, Ms. Maxwell has been at the center of a crushing +onslaught of press articles, television specials, and social media posts painting her in the +most damning light possible and prejudging her guilt. The sheer volume of media reporting +mentioning Ms. Maxwell is staggering. Since Epstein's arrest, she has been mentioned in +literally thousands of media publications, news reports, and other online content. The media +attention also spawned a carnival-like atmosphere of speculation about her whereabouts. In +November 2019, the British tabloid, The Sun, even offered a £10,000 bounty for information +about Ms. Maxwell's location. A headline reminiscent of a Wild West wanted poster read: +"WANTED: The Sun is offering a £10,000 reward for information on Jeffrey Epstein pal +Ghislaine Maxwell."'' And in the days leading up to her arrest, there was a deluge of media +reports (all untrue) claiming that Ms. Maxwell was hiding out in an apartment in Paris to avoid +questioning by the FBI." She has seen helicopters flying over her home and reporters hiding in +the bushes. Indeed, since Ms. Maxwell's arrest on July 2, 2020, her counsel has been flooded +with hundreds of media inquiries and solicitations from members of the public. +The "open season" declared on Ms. Maxwell after Epstein's death has come with an +even darker cost - she has been the target of alarming physical threats, even death threats, and +has had to hire security guards to ensure her safety. The media feeding frenzy, which has only +intensified in recent months, has also deeply affected her family and friends. Some of Ms. +Maxwell's closest friends who had nothing whatsoever to do with Epstein have lost their jobs or +' See https://www.the-sun.com/news/74018/the-sun-is-offering-a-10000-reward-for-information-on-jeffrey-epsteinpal-ghislaine-maxwell/. +" See, e.g., https://www.dailymail.co.uk/news/article-8444137/Jeffrey-Epsteins-fugitive-madam-Ghislaine- +Maxwell-hiding-luxury-Paris.html. +15 + + +Case 1:20-Cr-00330-AJN Document 18 Filed 07/10/20 Page 20 of 26 +suffered severe professional and reputational damage simply by being associated with her. Ms. +Maxwell therefore did what any responsible person would do - she separated herself from +everyone she cares about and removed herself from the public eye in order to keep herself and +her friends out of harm's way.'? +Lacking any evidence required under the governing standard that Ms. Maxwell +presents an "actual risk of flight," Sabhnani, 493 F.3d at 75, the government's flight risk +argument is reduced to the following: Ms. Maxwell is a woman of means who has foreign +citizenship and has traveled internationally in the past, and who now faces serious charges. +But if that were sufficient, then virtually every defendant with a foreign passport and any +meaningful amount of funds would need to be detained as a flight risk. See Hung v. United +States 439 U.S. 1326, 1329 (1978) (to detain based on risk of flight, government must show +more than "opportunities for flight," and instead must establish an "inclination on the part of +[the defendant] to flee"). That is not what the Bail Reform Act requires. Indeed, courts in +this Circuit and elsewhere commonly find that bail conditions can adequately address risk of +flight, even where individuals have foreign citizenship and passports or otherwise substantial +foreign connections, and financial means. See, e.g., Sabhnani, 493 F.3d at 66; United States v. +Hansen, 108 F. App'x 331 (6th Cir. 2004); United States v. Hanson, 613 F. Supp. 2d 85 (D.D.C. +2009); United States v. Bodmer, No. 03-cr-947(SAS), 2004 WL 169790, at *2-3 (S.D.N.Y. +Jan. 28. 2004); United States v. Karni, 298 F. Supp. 2d 129 (D.D.C. 2004); United States v. +Kashoggi, 717 F. Supp. 1048, 1050-52 (S.D.N.Y. 1989). +Finally, the ongoing travel restrictions caused by the COVID-19 pandemic would +pose a significant hurdle to Ms. Maxwell's ability to flee the United States, particularly to +fire media police has led ur or perpet, kav claim to a rare Makel, aer. Or surpro have had +even given numerous television interviews on news shows in the United Kingdom. +16 + + +Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 21 of 26 +France and the United Kingdom." Notably, two weeks ago, this Court recognized in United +States v. Abdellatif El Mokadem, No. 19-CR-646 (AJN), 2020 WL 3440515 (S.D.N.Y. June +23, 2020) that "concerns regarding risk of flight are mitigated by the ongoing [COVID-19] +pandemic, which has understandably curtailed travel across the country, and, indeed, around +the world." Id. at *1. In that case, despite finding detention to be warranted on two prior +occasions, the Court concluded that the government could no longer establish flight risk and +ordered the defendant released pending sentencing. Id. ("Taking account of the COVID-19 +pandemic, which had not yet reached this country when the Court last considered +Defendant's custody status, the balance now clearly and convincingly tips in Defendant's +favor…..."). Consideration of this factor weighs heavily in favor of release on the proposed +bail conditions here. +2. +The Nature and Circumstances of the Charges and the +Weight of the Evidence Militate in Favor of Bail +The Defense Has Rebutted the Presumption Relating to Certain of the Charges. The +government relies on the statutory presumption of detention applicable to offenses involving +minor victims. (Gov. Mem. at 4-5.) But unlike the position it took with Epstein, the +government does not contend that Ms. Maxwell poses any danger to the community, or that +she suffers from compulsive or addictive sexual proclivities. See United States v. Epstein, +425 F. Supp. 3d 306, 314-15 (S.D.N.Y. 2019). Even according to the indictment, Ms. +Maxwell's alleged participation in offenses involving minors ended in 1997. Here, the only +" See, e.g., E.U. Formalizes Reopening, Barring Travelers From U.S., N.Y. Times, (June 30, 2020), available at +https://www.nytimes.com/2020/06/30/world/europe/eu-reopening-blocks-us-travelers.html (confirming that the +European Union will not open its borders to travelers from the United States, and "[t]ravelers' country of residence, +not their nationality, will be the determining factor for their ability to travel to countries in the European Union"); +England Drops Its Quarantine for Most Visitors, but Not Those From the U.S., N.Y. Times (July 3, 2020), available +at https://www.nytimes.com/2020/07/03/world/europe/britain-quarantine-us-coronavirus.html (confirming that +England will leave mandatory 14-day quarantine restrictions in place for travelers coming from the United States). +17 + + +Case 1:20-Cr-00330-AJN Document 18 Filed 07/10/20 Page 22 of 26 +applicable presumption relates to risk of flight, and, as noted, Ms. Maxwell has rebutted that +presumption based on her ties to the United States, her decision to remain in this country +after Epstein's arrest, and all of the other reasons discussed above. This Court should follow +other courts in this Circuit and elsewhere that have found that defendants rebutted the +presumption and imposed appropriately strict bail conditions in cases involving alleged +offenses against minors. See Deutsch, 2020 WL 3577398, at *5-6; United States v. Veres, +No. 3:20-CR-18-J-32JBT, 2020 WL 1042051, at *3-4 (M.D. Fla. Mar. 4, 2020); Conway, +2011 WL 3421321, at *4-5. +The Impact of the Potential Penalties Is Overstated. The government asserts that +detention is warranted because of the potential for a long sentence in this case. (Gov. Mem. +at 4-5.) This oversimplifies the governing standard. Although the severity of potential +punishment is a relevant consideration, the Second Circuit "require[s] more than evidence of +the commission of a serious crime and the fact of a potentially long sentence to support a +finding of risk of flight." Friedman, 837 F.2d at 49-50 (district court's finding that +defendant posed a risk of flight was clearly erroneous, despite potential for "long sentence +of incarceration"); see also Sabhnani, 493 F.3d at 65, 76-77 (reversing detention order +where defendants agreed to significant physical and financial restrictions, despite the fact +that they faced a "lengthy term of incarceration"). Accordingly, the asserted potential for a +long sentence does not meet the government's burden of persuasion. 4 +14 The government relies on United States v. Alindato-Perez, 627 F. Supp. 2d 58, 66 (D.P.R. 2009), cited +approvingly by United States v. Moscaritolo, No. 10 Cr. 4 (JL), 2010 WL 309679, at *2 (D.N.H. Jan. 26, 2010) for +the proposition that "[t)he steeper the potential sentence, the more probable the flight risk is, especially considering +the strong case of the government ..." (Gov. Mem. at 5.) But Alindato-Perez is easily distinguished on its facts +from Ms. Maxwell's case. Alindato-Perez was a narcotics case that did not involve 20-year old conduct as here, but +instead involved a conspiracy that "continu[ed] until the date of the indictment." 627 F. Supp. 2d at 60-61. The +evidence included eleven "clearly incriminating video tapes" and testimony from various cooperating witnesses, and +the defendant faced a 10-year mandatory minimum sentence. Id. at 61-64. These factors are not present in this case. +18 + + +Case 1:20-Cr-00330-AJN Document 18 Filed 07/10/20 Page 23 of 26 +Moreover, the government overstates the potential for Ms. Maxwell to spend +"decades in prison" if she is convicted. (Gov. Mem. at 5.) In fact, her likely total exposure +even if she were convicted on all counts is 10 years, assuming the Court were to follow the +traditional practice in this District and impose concurrent sentences. Although a 10-year +sentence would be significant, it is a far cry from the government's forecast, further +demonstrating that the government has not met its burden of showing Ms. Maxwell is an +actual risk of flight. +The Government's Case Is Subject to Significant Challenges. In evaluating the +strength of the government's case, we note that Ms. Maxwell intends to mount several legal +challenges to the indictment, including that: (i) this prosecution is barred by Epstein's +September 24, 2007 non-prosecution agreement with the Department of Justice, which +covers "any potential co-conspirators of Epstein"; (ii) the conspiracy, enticement of minors, +and transporting of minors charges are time-barred and otherwise legally flawed; and (ili) +the two perjury charges are subject to dismissal on several legal grounds. ' In addition, as +we understand from the face of the indictment, the government's case is based primarily on +the testimony of three individuals about events that allegedly occurred roughly 25 years ago +between 1994 and 1997. It is inherently more difficult to prosecute cases relating to +decades-old conduct. These issues further call into question the strength of the government's +case, and provide an independent basis justifying release on bail. +15 The defense is also considering whether the government's comments in connection with this case conform to +Local Criminal Rule 23.1, and whether to seek appropriate relief from the Court. +19 + + +Case 1:20-Cr-00330-AJN Document 18 Filed 07/10/20 Page 24 of 26 +The Proposed Bail Package Is More Than +Adequate to Secure Ms. Maxwell's Presence +For the reasons stated above, the Court should release Ms. Maxwell because the +circumstances created by the COVID-19 pandemic will greatly increase her personal risk +and prevent her from meaningfully participating in her defense, and because the government +has not carried its burden under 18 U.S.C. § 3142. We respectfully submit that the proposed +bail package represents the "least restrictive" set of conditions that will reasonably ensure Ms. +Maxwell's presence in court. 18 U.S.C. § 3142 (c)(1)(B). +The package includes six co-signers +—Ms. Maxwell's siblings, relatives and +friendsmany of whom reside in the United States, and all of whom continue to support her +despite the unrelenting media attacks that Ms. Maxwell and they, themselves, have suffered +as a result of this case. Each of them has voluntarily agreed to assume responsibility for an +extremely large bond amount of $5 million, in order to secure her appearance. The bond is +also to be secured by real property in the United Kingdom worth roughly $3.75 million. +The package also includes stringent travel and physical restrictions, including surrendering +all passports and no new travel applications, travel restricted to the Southern and Eastern +Districts of New York, and home detention with electronic GPS monitoring. Ms. Maxwell, +for personal reasons, will continue to need security guards to protect her upon release. +Under the circumstances, if the Court requires it, the security guards could report to Pretrial +Services." +1* In United States v. Boustani, 932 F.3d 79 (2d Cir. 2019), the Second Circuit curtailed the circumstances under +which a court can grant pretrial release to a defendant on the condition that the defendant pays for private armed +security guards. Boustani, nevertheless, held that a defendant may be released on such a condition if the defendant +*is deemed to be a flight risk primarily because of his wealth. In other words, a defendant may be released on such a +condition only where, but for his wealth, he would not have been detained." Id. (emphasis in original). We submit +that a similarly situated defendant who, like Ms. Maxwell, had no prior criminal record, significant ties to the United +States, and a demonstrated lack of intent to flee the country, as well as numerous, supportive co-signers, but who did +20 + + +Case 1:20-Cr-00330-AJN Document 18 Filed 07/10/20 Page 25 of 26 +Ms. Maxwell has a number of other family members and friends who, under normal +circumstances, would also co-sign and secure her bond. She is not relying on them in +connection with this bail application in an effort to safeguard their privacy and protect them +and their families from harm. +The proposed bail conditions are consistent with those approved by courts in this +Circuit in other high-profile cases, and should be approved here. See, e.g., United States v. +Esposito, 309 F. Supp. 3d 24, 32 (S.D.N.Y. 2018) (alleged leader of Genovese crime family +who was charged with racketeering and extortion granted release subject to conditions), +aff'd, 749 F. App'x 20 (2d Cir. 2018); United States v. Dreier, 596 F. Supp. 2d 831, 832 +(S.D.N. Y. 2009) (Mare Dreier, accused of "colossal criminality" and alleged to be a "high +flight risk," granted release subject to conditions); United States v. Madoff, 586 F. Supp. 2d +240, 243 (S.D.N. Y. 2009) (Bernie Madoff, charged with "largest Ponzi scheme ever" and +alleged to be a "serious risk of flight," granted release subject to conditions). +not have Ms. Maxwell's means, would be released on bail conditions. Accordingly, if the Court deems it necessary, +it may impose private security guards as a condition of release. +21 + + +Case 1:20-Cr-00330-AJN Document 18 Filed 07/10/20 Page 26 of 26 +CONCLUSION +For the foregoing reasons, Ms. Maxwell respectfully requests that the Court order her +release on bail pursuant to the conditions she has proposed. +Dated: July 10, 2020 +Respectfully submitted, +/s/ Mark S. Cohen +Mark S. Cohen +Christian R. Everdell +COHEN & GRESSER LLP +800 Third Avenue +New York, NY 10022 +Phone: 212-957-7600 +Jeffrey S. Pagliuca +(pro hac vice admission pending) +Laura A. Menninger +HADDON, MORGAN & FORMAN P.C. +150 East 10th Avenue +Denver, Colorado 80203 +Phone: 303-831-7364 +Attorneys for Ghislaine Maxwell +22 diff --git a/vision-fixhub/ds9-parsed-01/23e34ff97e33a6c8a6722df9816da37d5e30138eb3cfafd464b0606e1a289d8e.receipt.json b/vision-fixhub/ds9-parsed-01/23e34ff97e33a6c8a6722df9816da37d5e30138eb3cfafd464b0606e1a289d8e.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..6507ea23c34472668a7c9acd11752895abc0f427 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/23e34ff97e33a6c8a6722df9816da37d5e30138eb3cfafd464b0606e1a289d8e.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -324, + "dataset": "marble-joined", + "doc_id": "23e34ff97e33a6c8a6722df9816da37d5e30138eb3cfafd464b0606e1a289d8e", + "engine": "marble-apple-vision", + "event_count": 32, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "1d6c5c4a10210e489e4e91ab69995e28f275860cbfe2d8e2944874b771f226ab", + "output_sha256": "ec33c3ba7265bfd0b18a9eae753667de155fa0e3fb53c71a9df2094891af147d", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/23f4d1b9dafe181a7ccae8801cdb5f25aa716bdf3a68a883391f8c4543b203d3.md b/vision-fixhub/ds9-parsed-01/23f4d1b9dafe181a7ccae8801cdb5f25aa716bdf3a68a883391f8c4543b203d3.md new file mode 100644 index 0000000000000000000000000000000000000000..f7a31b99e55b4cdc06616a142561dc1f5f8066fc --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/23f4d1b9dafe181a7ccae8801cdb5f25aa716bdf3a68a883391f8c4543b203d3.md @@ -0,0 +1,6 @@ +Inmate Epstein #76318-054 is being taken off of Psych Observation and needs to be housed with an appropriate cellmate. +Suicide Watch +None +Psych Observation +None +Thank you, diff --git a/vision-fixhub/ds9-parsed-01/23f4d1b9dafe181a7ccae8801cdb5f25aa716bdf3a68a883391f8c4543b203d3.receipt.json b/vision-fixhub/ds9-parsed-01/23f4d1b9dafe181a7ccae8801cdb5f25aa716bdf3a68a883391f8c4543b203d3.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..8e170bf8f71e6362327d2cfcce4da8dcecc4fab1 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/23f4d1b9dafe181a7ccae8801cdb5f25aa716bdf3a68a883391f8c4543b203d3.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "23f4d1b9dafe181a7ccae8801cdb5f25aa716bdf3a68a883391f8c4543b203d3", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "c2628c428d47d9e7539bd85b8368bf7d5a8f640b78125f657fc04ce115ca33f5", + "output_sha256": "329228a8d7764ea35cec2e8d7d00f61f5b262027ae7ebee1b3cb2b6761a60696", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/23f905bf95751403e29e6f4cfd6483a3c44ddd97b7d594f0950e3cfeace57146.md b/vision-fixhub/ds9-parsed-01/23f905bf95751403e29e6f4cfd6483a3c44ddd97b7d594f0950e3cfeace57146.md new file mode 100644 index 0000000000000000000000000000000000000000..b22f9d043d36a9c79b2ee97add20f4e57fef250e --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/23f905bf95751403e29e6f4cfd6483a3c44ddd97b7d594f0950e3cfeace57146.md @@ -0,0 +1,25 @@ +Precedence: ROUTINE +Date: +08/29/2011 +To: +Miami +Attn: PB-2 +From: Miami +Squad PB-2 +Contact: +SA +Approved By: +Drafted By: +Case ID #: 72-MM-113327 +(Pending) +Title: +ALFREDO RODRIGUEZ; +OBSTRUCTION OF JUSTICE +Synopsis: Request administrative closure of captioned case. +All investigative +and prosecutorial issues have been +resolved in captioned case. +It is requested +that captioned +be closed. +** diff --git a/vision-fixhub/ds9-parsed-01/23f905bf95751403e29e6f4cfd6483a3c44ddd97b7d594f0950e3cfeace57146.receipt.json b/vision-fixhub/ds9-parsed-01/23f905bf95751403e29e6f4cfd6483a3c44ddd97b7d594f0950e3cfeace57146.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..150322fd15404928eb3458355f304f7ea2c47bf4 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/23f905bf95751403e29e6f4cfd6483a3c44ddd97b7d594f0950e3cfeace57146.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "23f905bf95751403e29e6f4cfd6483a3c44ddd97b7d594f0950e3cfeace57146", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "535b5d53c40cf5e9591e344f695c1071ce5277cf7cf429da65a07cb85e7c2a2d", + "output_sha256": "a0419a20431042016bfc293f2b53ab2b1aab4446c33936716b80076b71d1af78", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2410f1cfc98d63cb66ff614a684c5ef371a3bb0fe9a95b40b0410b2192fc4a35.md b/vision-fixhub/ds9-parsed-01/2410f1cfc98d63cb66ff614a684c5ef371a3bb0fe9a95b40b0410b2192fc4a35.md new file mode 100644 index 0000000000000000000000000000000000000000..f67b6beaed40a2fa0a3db792649b3601262df8d3 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2410f1cfc98d63cb66ff614a684c5ef371a3bb0fe9a95b40b0410b2192fc4a35.md @@ -0,0 +1,114 @@ +FD-302 (Rev. 5-8-10) +- 1 of 2- +FEDERAL BUREAU OF INVESTIGATION +OFFICIAL RECORD +Cramerica come hagals sel +Date of entry +04/23/2020 +, date of birth (DOB) +I, was interviewed at +455 Madison Avenue, +New York, New York. +Present for the interview was +attorney +•, along with AUSA +AUSA +• Detective +• and Special Agent +1. After being advised of the identity of the above listed individuals +and the nature of the interview, +provided the following +information: +has lived back and forth between Europe and New York. +has worked in real estate for six year and has her own jewelry design +company, +• for the past three years. +grew up in Italy +outside Venice, where she attended school. When +was between 22 to +24 years old, she came to New York to learn English and studied fashion. +started modeling and casting work for a good agency. Her booker, +ANDREW INU, was casting for Victoria's Secret. +Her booker recommended her +to a man to go to a casting. +went to JEFFREY EPSTEIN's house with +her book. +saw many girls living there at the house. A woman, who +thought may have been a sister but was not sure, told her, "oh you +have to be nice to him; he's going to help you a lot". EPSTEIN's house was +on the Upper East Side on maybe 72nd street; it was a big house. This was +maybe in the winter/March of 2004. +_ described a woman as having +short dark hair and thought this to be GHISLAINE MAXWELL. This woman +introduced +to EPSTEIN and told her, "Be nice, he's important". +This woman +walked her up the stairs. Once there when it was just the two of +them, +and EPSTEIN talked. +did not remember what the two +of them talked about. EPSTEIN made +realize she was not there for a +casting. +said, "It was a sexual thing; it was harassment.". +did +not remember EPSTEIN +saying much, but remembered him being +aggressive with her. EPSTEIN pushed +to the door, came up to her, +touched her face and touched her all over, her vagina in particular. +Investigation on +09/12/2019 +File # +5OD-NY-3027571 +at New York, New York, United States (In Person) +Date drafted 03/17/2020 +This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your agency; it and its contents are not +to be distributed outside your agency. + + +FD-302a (Rev. 5-8-10) +50D-NY-3027571 +Continuation of FD-302 of (U) Interview of +., On +09/12/2019 +_, Page +2 of 2 +recalled there being a massage table in the room. EPSTEIN offered +money, but she was not sure why she was offered the money. +told EPSTEIN this was not going to happen and left. +was +scared, so she left. +thought that the same girl that told her to be nice to EPSTEIN +asked her where she was going and why she was leaving. This girl told +that this guy could help her out. +described the room she was in as dark brown with books and a +desk and a massage table to the left. When +met EPSTEIN, he asked +her if she wanted to work as a model. EPSTEIN told her that he could help +her work with Victoria's Secret. When +started to push EPSTEIN +away, he started to touch her genitals. +saw his sex toys in his +office; they looked like a "massage thing", like a vibrator/massager. The +vibrator/massager was long. +did not have any more contact with EPSTEIN. The woman who +out of the home told her she would not be working with +escorted +them. +booker told her how important EPSTEIN was before she went. +did not talk to her booker after she went to EPSTEIN's home. +When +went into the room, EPSTEIN introduced himself and +told him where she was from. EPSTEIN had a robe on and started to take it +off. EPSTEIN touched her face and touched her all over and pushed her to +the door. +tried to push him away. The massage table was near the +desk and the massager/vibrator was there. +EPSTEIN tried to give her money +but she told him no and that she did not do that. +threw the +vibrator at him. +spoke to the press in July after EPSTEIN' s arrest. +in the New York Post article, but her name was not published. +was diff --git a/vision-fixhub/ds9-parsed-01/2410f1cfc98d63cb66ff614a684c5ef371a3bb0fe9a95b40b0410b2192fc4a35.receipt.json b/vision-fixhub/ds9-parsed-01/2410f1cfc98d63cb66ff614a684c5ef371a3bb0fe9a95b40b0410b2192fc4a35.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..d7f6affd110ce63b5e5f9ee1701af902badf3f52 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2410f1cfc98d63cb66ff614a684c5ef371a3bb0fe9a95b40b0410b2192fc4a35.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "2410f1cfc98d63cb66ff614a684c5ef371a3bb0fe9a95b40b0410b2192fc4a35", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "1af34eab271e9863d73543591ed8c51606d629bf97afb9aaba84c62689bdacf9", + "output_sha256": "61c2ffff4c88e1cfa67dad76372e1d4b6f59cee08618f6e32c1457b59c8c2a60", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/24513efcd1e4a29b782ff8a3c8b258ba1efa7581708a5c3b1d74fe012247dacd.md b/vision-fixhub/ds9-parsed-01/24513efcd1e4a29b782ff8a3c8b258ba1efa7581708a5c3b1d74fe012247dacd.md new file mode 100644 index 0000000000000000000000000000000000000000..ee0f683c037c0f77253cc4945a858ed5d11f5a10 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/24513efcd1e4a29b782ff8a3c8b258ba1efa7581708a5c3b1d74fe012247dacd.md @@ -0,0 +1,3010 @@ +To: + + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +Date: Fri, 11 Jun 2021 11:59:38 +0000 +Attachments: KCG_ +_Appendix_3-20_13_penultimate.docx; KCG_TCR_3-20-13-penultimate _draft.pdf; +KCG_TCR_3-20-13-penultimate +draft.docx; KCG_Appendix 3-20_13 _penultimate.pdf; +kcglq2015.pdf +SDNY,NY Supreme Court, NJ Judges et al +to say the SEC is a grossly corrupt, criminal enterprise ACTIVELY facilitating multiple, massive, ongoing frauds on +the public to the benefit of the criminals who own them while screwing the whistleblower who caught them: +me. The real world implications of this irrefutable FACT are staggering. REAL lives changed/ruined. Staggering +losses for "main street investors" as Clayton referred to them. Because, for ANYONE spending more than an +hour or 2 on a trading desk: Gordon Gekko was right: "It's a zero sum game. Somebody wins, somebody loses". +The Grossly corrupt SEC has rigged the game in favor of the criminals over the public it is mandated to protect. +Mr Paley, did your Micro Cap Fraud Task Force actually accomplish ANYTHING? How did 4+ +TRILLION shares of OTCM money laundering shells trade in 1Q, 2021? Are prolific Bag Men like Kramer and +Honig etc etc etc actually "out of business"? +HELL NO! +Mr Gensler, Chair Waters/Congress made repealing the grossly corrupt Clayton, Peirce, Roisman Rule in the +summer of 2020 that exempts 90% of current 13 F filers a priority. Will you execute the stated will of Congress? +As the Corrupt POS Paley et al know: NONE OF THESE CRIMINALS are out of business in 2021. In Fact, business +is BOOMING +SEC. gov | SEC Proposes Amendments to Update Form 13F for Institutional Investment Managers; Amend +Reporting Threshold to Reflect Today's Equities Markets +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. +Speaking of Prolific Bag Man Honig: As you are all aware, I made the connection between Honig, Russian +entities,Signature Bank: SBNY, and the criminal law firm of Sichenzia Ross. Mr Gottschall: Have you been able +to locate Castle Rock on a map yet? +Here are just a few of the recently filed RIOT Blockchain filings with the SEC +Detailing a few "transactions" + + +With the likes of The Bejing China Bitcoin mining company Bitmain where RIOT bought the "mining machines" +at the Rockdale Texas Igigt "HPC" data center. It doesn't look like Bitmain has much of a future in China. But +Rockdale Texas is a growth market for sure. +https://www.sec.gov/Archives/edgar/data/1167419/000107997321000272/ex99x1.htm +SEC.gov|HOME +Hash Rate Growth . By Q4 2022, Riot expects a total hash rate capacity of 7.7 EH/s with a fleet of +approximately 81,146 Antminers, 95% of which will be the latest generation S19 series model. +Another "transaction" involves the RIOT acquisition of a Data Center in Rockdale Texas owned by a German +entity called Northern Data/Northern Bitcoin/Whinstone +Northern Data AG successfully closed the sale of its Texas data center to Riot Blockchain, Inc. - Northern Data +AG +Northern Data AG successfully closed the sale of its Texas data center to +Riot Blockchain, Inc. - Northern Data AG +Frankfurt am Main - May 27, 2021 - Northern Data AG (XETRA: NB2, ISIN: DE000AOSMU87) a leading +infrastructure supplier for Bitcoin mining and other HPC infrastructure solutions, successfully completed the +sale of its U.S. subsidiary Whinstone US, Inc., which operates a high-performance data center facility based +in Rockdale, Texas, to Riot Blockchain, Inc. (NASDAQ: "RIOT"). The .... +northerndata.de +Northern Data is a publicly traded company with ADR's trading OTCM Pinks. +US Jurisdiction established +Half-Year-Report_2019.pdf (northerndata.de) +HALF-YEAR REPORT 2019 - Northern Data +PAGE 4 NORTHERN BITCOIN AG | HALF YEAR REPORT 2019 BITCOIN IS CHANGING THE WORLD Bitcoin is a +digital finance system that cannot be manipulated. +northerndata.de +Investor Relations - Northern Data AG + + +Investor Relations - Northern Data AG +Northern Data AG develops and operates global infrastructure +solutions in the field of High-Performance Computing (HPC). +With its customer-specific solutions, the company provides the +infrastructure for various HPC applications in areas such as bitcoin +mining, blockchain, artificial intelligence, big data analytics, IoT or +northerndata.de +OTC Markets| NDTAF | Company Profile | OTC Markets +Northern Data is now a 12% holder of RIOT +Inline XBRL Viewer (sec.gov) +EDGAR Filing Documents for 0001140361-21-019019 (sec.gov). +Northern Data/Bitcoin Frankfurt came into existence in 2015. +The founder is a guy named Mathis Schultz. Mr Schultz previously was a Private Banker at Julius Baer, LGT, +and Elan Capital Management +Mining Like a Viking: How the Fjords of Norway Offer a Greener Alternative - Bitcoin Magazine: Bitcoin +News, Articles, Charts, and Guides +Mining Like a Viking: How the Fjords of +Norway Offer a Greener Alternative - Bitcoin +Magazine: Bitcoin News, Articles, Charts, and +Guides +Northern Bitcoin's energy costs are lowered still by the climate +control measures Lefdal mine features by design. As if the +Norwegian climate wasn't cool enough, the data center is +situated some 656 feet below ground, so it maintains a constant +temperature of 55 degrees Fahrenheit (~12.5 degrees Celsius). +bitcoinmagazine.com +Schultz picked a very interesting nobody from New Orleans to build his 1Gig+ "HPC" data center in Rockdale +Texas: Chad Everett Harris +qualifications? +The Year of Chad Everett Harris - Chad Everett Harris + + +The Year of Chad Everett Harris - Chad Everett +Harris +2020 will be the Year of Chad Everett Harris. This will be the year +that the last 1642 days of work pays off and things get back to +my normal chaotic life that I love. This year will be filled with +achievement, challenges, and excitement. It will also be a year of +living in the [...] +www.chadeverettharris.com +Chad Everett Harris | Meet New Orleans Entrepreneur +Chad Everett Harris | Meet New Orleans +Entrepreneur +Chad Everett Harris realized his passion for entrepreneurship very +early on in his childhood. Born in Palos Verdes, California in 1969, +he spent much of his young life moving between cities across the +US.In his early years alone, he spent considerable time in Georgia, +Michigan, and Louisiana. +www.chadeverettharris.com +Chad Everett Harris Archives - Page 2 of 4 - Chad Everett Harris +Northern Data/ Northern Bitcoin bought Whinstone in 2019. +Whinstone was building its Rockdale Texas 1 gigt "HPC" data center in 2020 supervised by Chad Everett Harris +Northern Data/ Northern Bitcoin sells Whinstone Texas "Data center" in April 2021 +Northern Data founded in 2015 by former Private Banker Mathis Schultz +RIOT has no office at SEC filings address. +RIOT is Honig/Russian money laundering shell +RIOT does "offering" with SBNY as escrow agent and the criminal law firm Sichenzia Ross. +Northern Data trades OTCM Pinks: no info +Northern Data now owns 12% of RIOT +RIOT is a "customer" of Beijing based Bitmain which has been effectively shut down by the PRC +Bitmain filed a "secret ipo" with Clayton/SEC +RIOT is a National security risk and ONGOING fraud on the public kept up and running by the grossly corrupt +SEC: Gottschall et al +Bitmain +funny. +Mr Gottschall: And to think ALL of this is happening 15 from my home in Castle Rock Colorado. Too fucking + + +Sent: Tuesday, June 1, 2021 6:31 AM + + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +SDNY, NY Supreme Courts/NJ Courts grossly corrupt SEC et al, +Let's break down VIRT CEO Dougie "Mr Transparency" Cifu comments to Sell Side analists on the NITE/VIRT 10. +2021 earnings call in May 2021: +Per below: +"Yes, Dan, obviously you look at the same metrics I do, just to give you a little commentary on them,l mean +April volumes were a hair under 10 billion shares per day which is down 32 odd percent from the first +quarter....." +Meaning: 1Q, 2021 equity market making volumes at NITE were roughly 13 billion shares per day. +Let's compare the last KCG stand alone quarter: 102017 (below) where total equity market making share +volumes were "a hair OVER 10 billion shares per day": 10.082 billion shares per day to be exact. +KCG 1Q2017: 154 mil trading revenue +93.589 mil commissions/fees +eps .05/ 67 mil shares outstanding +Since Dougie "Mr Transparency" Cifu won't actually disclose 102021 metrics, let's do some simple math and +solve for "X" shall we? +NITE/VIRT COMBINED 1Q2021 +Remember: "April volumes were down approximately 32% from 1Q, 2021 volumes " +April volumes were a "Hair under 10 billion shares pe day" +Therefore: Cifu says to Sell Side analysts on May4 2021 earnings call: 102021 share volumes were roughly 13 +billion shares per day +The 1q2021 NITE/VIRT combined SEC reviewed 10Q. +Document (sec.gov) +trading income: 812.743 mil +net commissions: 191.64 mil +eps 1.91/sh on 123.4 mil shares out +Again: 1Q, 2017 OTCM Pink money laundering shell volumes: 90%+ of total equity MM volumes +OVERALL OTCM Volumes: 100-300 billion shares/month +in 102021 OVERALL OTCM Money laundering share volumes were 4+ TRILLION shares +a 10-30x+ INCREASE 2021 vs 2017 in OTCM Money laundering shell volumes +YET TOTAL equity market making share volumes were up just 30+% 102021 vs KCG stand alone 1020177??? +How much market share did NITE/VIRT LOSE since 2017: 90+%???? +NITE/VIRT 1Q2021 share volumes were MULTIPLES of 13 billion shares/day. Cifu is KNOWINGLY LYING +Further: +Recall: ANOTHER example of SEC corruption: the KCG 1Q2014 "astronomical" OTCM share volume metrics +expunged by McKessy, Norberg, Pasquinelli, et al from the 102014 10Q: +The KCG stand alone 1Q2014 10Q: the basis of my March 2014 letter to McKessy with Berger Montague : I have +attached the KCG 1Q2015 SEC reviewed 10Q, above +Year over year numbers: The corrupt SEC failed to expunge +Pg 53 +1Q2014 KCG STAND ALONE OTCM share volumes +14.045 BILLION shares/day (My Letter to McKessy) + + +NYSE/NASDAQ volumes: 862 MILLION shares/day +So according to Dougie "Mr Transparency" Cifu" +1Q,2021 average daily share volumes were roughly 13 billion shares per day: This number is LESS than KCG stand +alone 102014 share volumes of almost 15 billion shares/day: 7 FUCKING YEARS AGO +In 1Q2014 KCG trading revenue was 254.6 million and eps was .30/share +This is blatant, egregious Cifu/SEC facilitated fraud on the public the SEC is mandated to protect. +WHY is Cifu hiding this from the investing public and as important: WHY is the grossly corrupt SEC letting him? +Read my TCR. In furtherance of the conspiracy: the CORE business at Knight/KCG/VIRT: NITE is and always has +been Illegal naked shorting OTCM shells to facilitate money laundering. +Further: Clayton et all CORRUPTLY gave NITE and CDEL their own exchange: MEMX: in 2020 for this EXACT +reason +The FINRA OTCM share volume discrepancies explained: NITE/VIRT is NOT reporting the vast amount of illegal +naked shorting OTCM share volumes. Recall my correspondence to the grossly corrupt SEC when MEMX was +announced: "Just between us criminals" +Once again, my allegations are irrefutably accurate. The SEC has AGAIN doubled down and taken the side of the +criminal entity NITE. As a result: the SEC ACTIVELY facilitates multiple, ongoing frauds on the public to the +benefit of the criminals who own them while screwing the whistleblower who caught them: ME. +Whistleblower extraordinaire +Sent: Friday, Mo 28, 2021 8:58 AM + + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +SDNY/NY Supreme Court/NJ judges: My apologies. I think I typed too fast for many on this email. Let me state +plainly what | allege: For that, I turn directly to UBS Sell Side Analyst Alex Kramm who had quite the exchange +with Cifu on the 1Q, 2021 earnings call earlier this month. +Mr Kramm: based on my analysis below, tell everyone WHY you think Cifu chose to be "Less transparent" with +regards to 1Q, 2021 share volumes? +l'll type slower this time: +1Q, 2021 OTCM total reported share volumes: 4+ TRILLION +Cifu on the call! have electronic version should you prefer) +"Yes Dan (Jefferies analyst Fannon), obviously, you look at the same metrics I do, just to give you a little +commentary on them (without actually disclosing them), I mean April volumes were a hair under 10 billion +shares per day......' +Mr Kramm: this is a knowingly, blatantly false and misleading statement. Accurately: a bald face lie. This is why +Cifu won't disclose the actual share volumes. +Per below: in 1Q, 2017: the last stand alone KCG quarter: OTCM share volumes were reported in SEC reviewed +10Q at 9+ billion shares/day. Back when OTCM TOTAL SHARE VOLUMES were reported in the 100-300 billion +shares per month. +Yet, in 1Q 2021 when total reported OTCM share volumes were more than 1 TRILLION shares per month, hitting +almost 2 TRILLION shares in Feb 2021, Cifu would have us believe NITE Equity market making share volumes +were a "hair under 10 billion shares per day". +A blatant LIE. The SEC knows EXACTLY what the NITE equity share volumes were in 102021. And it was a LOT +MORE than "a hair under 10 billion shares/day". Driven of course by OTCM Money laundering shells Trading +profits: illegal naked shorting. Exploding balance sheet. Insolvent still/again. +Once again, the SEC facilitating/covering up a MASSIVE ongoing fraud on the public to the benefit of the +criminals who own them while screwing the whistleblower who caught them: ME + + +Have a GREAT long weekend! +Whistleblower Extraordinaire +From: Chris Dilorio «| +Sent: Friday, May 28, 2021 7:25 AM +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +Ms Pasqinelli, + + +There have been 3 (THREE) SEC actions CLEARLY based on my information that also CLEARLY qualify for OWB +Award eligibility. +Sason/Keener/Salviola et al: NewLead +Joshua Sason, et al. (Release No. LR-24403; Feb. 15, 2019) (sec.gov). +Joshua Sason, et al. (Release No. LR-24403; Feb. 15, 2019) +SEC Files Charges in Elaborate Microcap Stock Fraud Litigation Release No. 24403 / February 15, 2019 +Securities and Exchange Commission v. Joshua Sason, et al. +John Fife +John M. Fife, Chicago Venture Partners, L.P., Iliad Research and Trading, St. George Investments LLC, Tonaquint, +Inc., and Typenex Co-Investment, LLC (Release No. LR-24886; Sep. 3, 2020) (sec.gov) +John M. Fife, Chicago Venture Partners, L.P., Iliad Research and Trading, St. +George Investments LLC, Tonaquint, Inc., and Typenex Co-Investment, LLC +(Release No. LR-24886; Sep. 3, 2020) - SEC.gov +The Securities and Exchange Commission today filed charges against John M. Fife of Chicago and +companies he controls for acquiring and selling more than 21 billion shares of penny stock without +registering as a securities dealer with the SEC. +Justin Keener/JMJ +Justin W. Keener d/b/a JMJ Financial (Release No. LR-24779; Mar. 24, 2020) (sec.gov). +Justin W. Keener d/b/a JMJ Financial (Release No. LR-24779; Mar. 24, 2020) +- SEC.gov | HOME +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) +ALL: My information. +Yet NONE of these actions have been posted to the OWB Award Eligible website +SEC.gov | Office of the Whistleblower +SEC.gov | Office of the Whistleblower + + +NOTICE: Until further notice, any Whistleblower Award Applications submitted by mail should be sent to +the following address due to the mandatory telework posture at the SEC's Washington, DC headquarters: +14420 Albemarle Point Place, Suite 102, Chantilly, VA 20151-1750. +SEC IG Hoecker: HOW IS THIS REMOTELY PLAUSIBLE?? +There is only 1 explanation: SEC criminal obstruction and corruption. +Like the Dick Best/FINRA BBH complaint: also my information. No mention of executing broker dealers/MM's. +OR as the SEC would like us to believe: "Penny stock trading fairies" +NO! +The SEC in ALL of these actions is protecting the criminal enterprise which has been bailed out on multiple +ocassions: Knight/KCG/VIRT:NITE +Automatically placing this criminal enterprise on the SEC "Do not investigate list". +As a result, the SEC has KNOWINGLY, ACTIVELY facilitated countless, ongoing frauds on the public it is mandated +to protect. ALL of the ilegal activity I have detailed is ongoing in May 2021. NITE is again/still insolvent. Cifu in +the latest attempt to conceal this massive ilegal activity has once again limited transparency for the investing +public. The NITE Q1 earnings call: May 4, 2021 +Virtu Financial Inc (VIRT) Q1 2021 Earnings Call Transcript | The Motley Fool +Virtu Financial Inc (VIRT) Q1 2021 Earnings +Call Transcript | The Motley Fool +Virtu Financial Inc (NASDAQ:VIRT) Q1 2021 Earnings Call May 4, +2021, 8:30 a.m. ET. Contents: Prepared Remarks; Questions and +Answers; Call Participants; Prepared Remarks: Operator. Good day, +and... +www.fool.com +Cifu: "April volumes were a hair under 10 billion shares per day…...." +So, the last 10Q, filed by KCG/Knight as a stand alone company was 10, 2017. The VIRT acquisition closed on July +31, 2017. Cifu won't disclose and the SEC let him KCG 2Q2017 financials. BLATANT fraud. Cifu/ the SEC wrote +down more than $4 billion in fails. +The 1Q2017 KCG 10Q +Document (sec.gov) +Market Making stats. Cifu no longer discloses in SEC reviewed filings +Avg daily OTC BB and OTC Market shares traded (millions) 9,096 +Avg daily NYSE AND NASDAQ shares traded (millions) 986 +Per my consistent correspondence with the SEC: Knight/KCG:NITE derived 80-90%+ of their equity Market +making share volumes from OTCM. This is why VIRT acquired KCG/Knight. This is and always has been the core +business at NITE. This is what Cifu conceals from the investing public. In May 2021. + + +As I have also detailed over the last several years: FINRA share stats data is complete fraud. This ALSO continues +in May 2021 +Market Statistics - Equity Trading Data Monthly_(finra.org). +At the top of the page: "Last month statistics: April-2021 Share volume 44+BILLION shares" +Yet below that under April share volumes:TOTAL SHARES: 928+BILLION +The Knight/KCG/VIRT: NITE balance sheet in 10, 2021 filed with the SEC in May 2021 +The balance sheet is AGAIN exploding +Inline XBRL Viewer (sec.gov). +NOT HFT related where holding time is seconds +Tangible book after properly classifying naked short fails: booked as an asset: receivable due to self clearing: +insolvent. By a VERY wide margin. +ALL as a direct result of ONGOING SEC criminal obstruction and corruption. +So, Ms Pasquinelli: who was the executing BD/MM converting all of these fraud notes into worthless certs and +dumped on the investing public where they are converted to real money? WHY would ANY BD/MM execute +these trades? HOW do OTCM money laundering shells trade to trip zeroes? More buyers than sellers? NOPE: +ilegal naked shorting to facilitate money laundering. That is why none of these actions have been posted to the +OWB website. Even though they CLEARLY are eligible actions: My information. +Sent: Thursday, May 27, 2021 5:49 AM + + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +More Honig/Stetson et al SEC facilitated ONGOING fraud on the public +David Urban: Trump PA Campaign Manager and NITE Not So Independent Board Member and his own money +laundering shell: FSD Pharma: HUGE with Pakistani's +Had a BINDING LOI to acquire Israeli Therapix. +FSD Pharma Responds to Therapix Termination of Binding LOL | Business Wire +Not so binding. I caught them. Plan B +Therapix: An Israeli money laundering shell where Stetson was "investor" +EDGAR Filing Documents for 0001493152-17-003810 (sec.gov) +and never shut down by the SEC as is typical of many Honig money laundering shells +Today, Therapix is now Sci Sparc Ltd +SEC approved offerings done By Aegis +SEC FORM D +Yes: that Aegis: also very much up and running in May 2021. New York: SDNY jurisdiction +We don't need no stinkin' SAR's. Aegis prolific OTCM/NASDAQ shell money launderer +Aegis Capital Corporation (sec.gov) +UNITED STATES OF AMERICA Before the SECURITIES AND EXCHANGE +COMMISSION ADMINISTRATIVE PROCEEDING File No. 3-18412 ORDER +INSTITUTING ADMINISTRATIVE PURSUANT TO SECTIONS 15(b) AND 21C + + +OF THE SECURITIES EXCHANGE ACT OF 1934 AND SECTION 203(e) OF +THE INVESTMENT ADVISERS ACT OF 1940, - SEC.gov | HOME +3 As a result of the foregoing, Aegis willfully 2 violated Exchange Act Section 17(a) and Rule 17a-8 +thereunder. RESPONDENT Aegis is a dually-registered investment adviser and broker-dealer with multiple +branches +Well known to the SEC/FINRA: WHO were the customers? +Who were the executing BD/MM's? MORE SEC "penny stock trading fairies" of course. NOPE: NITE. +WHY are all entities once again UN Named? +Robert_Eide.pdf (finra.org). +FINANCIAL INDUSTRY REGULATORY AUTHORITY OFFICE OF HEARING +OFFICERS - FINRA.org +FINANCIAL INDUSTRY REGULATORY AUTHORITY OFFICE OF HEARING OFFICERS DISCIPLINARY +PROCEEDING NO. 2011026386002 HEARING OFFICER: MJD ORDER ACCEPTING OFFER OF SETTLEMENT +August 3, 2015 INTRODUCTION Disciplinary Proceeding No. 2011026386002 was filed on October 21, +2014, by the +www.finra.org +Orders Accepting Offers of Settlement - Aegis Capital Corp., Charles Smulevitz, Kevin McKenna (finra.org) +Complainant, Hearing Officer Rochelle S. Hall Department ofEnforcement, +Disciplinary Proceeding ORDER ACCEPTING OFFER OF OFFICE OF +HEARING OFFICERS INDUSTRY REGULATORY AUTHORITY FINANCIAL +Aegis Capital Corp. SETTLEMENT Date: August 3, 2015 Respondents. +INTRODUCTION - FINRA.org +another F11"4RA member and registered with FINRA, through the firm, in several capacities, including as a +GSR and GSP. Under Article V ofthe FINRA By-Laws,FINRA possesses +www.finra.org +Kevin Mckenna and Robert Eide (sec.gov) +Kevin Mckenna and Robert Eide - SEC.gov | HOME +3 As a result of the foregoing, McKenna willfully 2 aided and abetted and caused Aegis' violations of +Exchange Act Section 17(a) and Rule 17a-8 thereunder and Eide was a cause of Aegis' violations. + + +Stetson: Honig side kick. Therapix now SciSparc. Still Israel +Beginning on pg 10 of the SciSparc SEC approved and reviewed registration +https://www.sec.gov/Archives/edgar/data/1611746/000121390021022427/ea139707- +f1_scisparcltd.htm#a_009 +20 Raul Wallenberg Street, Tower A, Tel Aviv 6971916, Israel. Tel: (+972) (3) 610-3100 : Puglisi & Associates. +850 Library Ave., Suite 204. Newark, DE 19711 +Sellers include: +Aegis CEO Robert Eide Pension Plan: NOW that is f'n funny +Hoboken restraunteur Rohit Bawa +NYC Restaurateur Revamping Former Liberty Bar Site | Jersey Digs +NYC Restaurateur Revamping Former Liberty +Bar Site | Jersey Digs +The building itself was designed by Minervini Vandermark and +will be four stories of concrete construction. The residential +component will consist of three separate 3-bedroom, 2-bathroom +units, each occupying one floor. +jerseydigs.com +Connecticuit distributor Michael Bozzuto +Contact | Bozzutos.com +Contact Bozzutos.com +Connect With One of Our Teams. We value your feedback. Let us know what's on your mind and how we +can serve you better. Please select a department on the left to send a message directly to the team you +would like to reach. +www.bozzutos.com +and, prolific Bag Man Michael Bigger +Bigger Capital +AND many more +More on New York based Bigger Capital coming +Of course, Aegis has a BOOMING wealth Management business + + +How many related party transactions in this SEC reviewed Therapix F1? +https://www.sec.gov/Archives/edgar/data/1611746/000121390016017994/ff12016_therapixbio.htm#a_017 +Next up: SciSparc +Aegis "Investment banking" has ties to Israeli military +Isaac Livni-EIDE: related? +Investment Banking Team - Aegis Capital Corp. (aegiscapcorp.com). +Aegis just did an SEC approved offering for Meten Edtech Education Group +China +Brought to the US public/NASDAQ, by the same Bag Man who brought Hwang/Archegos money laundering shell +GSX to the US/NASDAQ +Puglisi and Associates:Delaware +https://www.sec.gov/Archives/edgar/data/1796514/000121390020018525/ea124386-f1_metenedtech.htm +Form F-1 (sec.gov) +Some reports I've read suggest the SEC won't investigate Archegos/Hwang because it lacks "jurisdiction". +Perhaps Ms Hodgman/Strzok can clarify for us. +Recall: Honig, Stetson/Frost/Alpha Cap (my TCR). As | REPEATEDLY told the SEC: multi BILLIONAIRE Frost didn't +risk it all to make a few million. He/they were laundering +8 (EIGHT) YEARS after submitting my NITE/UBS TCR with the SEC, Alpha Capital Anstalt is very much up and +running in 2021 +For His part: Frost bought Ladenberg from Icahn/Lorber/ et al: Vector/New Valley AFTER Ladenberg had bought +Icahn's former firm Gruntal. Gruntal: SAC,Sater,Feinberg, Icahn: MILKEN +Archegos and Greensill: Credit Suisse. +Credit Suisse is controlled by Milken flunkies. Including the Risk Officer who quietly stepped down. +Greensill: Jim Justice: Magna/Sason/Saviola/Sichenzia: SDNY/NY Supreme Court +I suspect there will be no SEC investigation of Credit Suisse. Ms Hodgman Strzok is an expert at criminal +obstruction. +Pretty good, eh? +It's a gift really +Whistleblower Extraordinaire + + +Sent: Monday, May 24, 2021 5:47 AM +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +Judge Engelmayer: +Simply put: RIOT exists in SEC filings only. Multiple Honig money laundering shells: Aspenbio/Venaxis/Bioptix +involving Russian Government entity: Rusnano +RIOT world HQ in Castle Rock is 15 minutes from my home. Apparently Mr Gottschall can't seem to find Castle +Rock on a map. There is no RIOT at SEC filling address. +An ISP: Clear Connect and a Pakistani BPO entity: NASDAQ traded IBEX. +Who did Mr Gottschall deliver his "no further investigation" letter to exactly? It sure as hell wasn't RIOT. +BTW: as a result of said Gottschall letter/determination as result of his incredibly THOROUGH investigation, the +SEC chose not to review a RIOT offering in December 2020 +Riot Blockchain, Inc. S-3 Letter.pdf (sec.gov) +UNITED STATES SECURITIES AND EXCHANGE COMMISSION +WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE - +SEC.gov +United States securities and exchange commission logo December 11, 2020 Jeffrey McGonegal Chief +Executive Officer Riot Blockchain, Inc. 202 6th Street, Suite 401 +and resulted in Susquehanna/CVI pump and dump +EDGAR Filing Documents for 0001104659-21-023563 (sec.gov) + + +EDGAR Filing Documents for 0001104659-21-023563 +Riot Blockchain, Inc. (Subject) CIK: 0001167419 (see all company filings) IRS No.: 841553387 | State of +Incorp.:NV | Fiscal Year End: 1231 Type: SC 13G | Act: 34.. +Judge Engelmayer, other SDNY/NY Supreme Court Judges: I implore you to send me a subpoena +Sent: Tuesday, May 18, 2021 6:07 AM + + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +Well well well. Mr Gottschall ended his "thorough investigation" into RIOT/Honig et al on 1/29/2020 +Riot Blockchain SEC Ends Investigation Letter 1.29.20 | U.S. Securities And Exchange Commission | Common +Law (scribd.com) +Riot Blockchain SEC Ends Investigation Letter +1.29.20 | U.S. Securities And Exchange +Commission | Common Law | Free 30-day +Trial | Scribd +Riot Blockchain SEC Ends Investigation Letter 1.29.20 - Free +download as PDF File (.pdf), Text File (.txt) or read online for free. +Included a letter from the Denver office of the SEC telling Riot +Blockchain that the investigation by the securities regulator is +over and at this time no enforcement action is recommended. +www.scribd.com +without EVER visiting the RIOT world HQ in Castle Rock. SHOCKING! +Curious Mr Gottschall: who recieved/signed for your "termination of investigation" into RIOT: The ISP +ClearConnect or the Pakistani BPO entity IBEX? +Judge Ramos, other SDNY judges, NY Supreme Court, and NJ Judge Quraishi: you have been played for fools +once again by the grossly corrupt SEC. ALL of your courts have jurisdiction over the SEC NY. +Let's give NJ Judge Quraishi a primer on prolific Bag Man Barry Honig shall we? +As detailed by me in my extensive correspondence: the record. +ANOTHER Honig money laundering shell: Inergetics fka Millenium Biotech +Based in Newark NJ +Is everyone familiar with Healthcare fraud felon Brian Colleran? +Three Companies and Their Executives Pay $19.5 Million to Resolve False Claims Act Allegations Pertaining to +Rehabilitation Therapy and Hospice Services | OPA | Department of Justice +Three Companies and Their Executives Pay $19.5 +Million to Resolve False Claims Act Allegations +Pertaining to Rehabilitation Therapy and Hospice +Services | OPA | Department of Justice +Ohio based Foundations Health Solutions Inc. (FHS), Olympia Therapy Inc. +(Olympia), and Tridia Hospice Care Inc. (Tridia), and their executives, Brian + + +Colleran (Colleran) and Daniel Parker (Parker), have agreed to pay +approximately $19.5 million to resolve allegations pertaining to the submission +www.justice.gov +Somehow, the DoJ didn't believe this was a criminal case. The "prosecutor" on the case was Chad Readler. Now: +JUDGE Chad Readler. Made so by Trump. +Colleran entered into a fraud $20 million purchase order with Millenium Biotech in 2007 +Millennium Biotechnologies, Inc. Signs Five Year $20,000,000 Purchase Agreement with Provider Services Inc. I. +BioSpace +Millennium Biotechnologies, Inc. Signs Five Year $20,000,000 Purchase +Agreement with Provider Services Inc. - BioSpace +Millennium Biotechnologies, Inc. Signs Five Year $20,000,000 Purchase Agreement with Provider Services +Inc. - read this article along with other careers information, tips and advice on BioSpace +www.biospace.com +Colleran then became a large shareholder in Millenium +EDGAR Filing Documents for 0001144204-08-023159 (sec.gov) +Guess who controlled the money laundering shell Millenium/Inergetics? +Prolific Bag Man Barry Honig +EDGAR Filing Documents for 0001144204-10-011488 (sec.gov) +But, it gets better still: Somehow, some way Prolific Bag Man Josh Sason/Hanover/Magna: MULTIPLE TCR's filed +by me and a massive SEC fraud on the SDNY and NY Supreme Courts: NewLead/FreeSeas et al: showed up as a +very large holder of Millenium successor Inergetics +EDGAR Filing Documents for 0001144204-15-034843 (sec.gov) +https://www.sec.gov/Archives/edgar/data/72170/000114420414046310/v385056_s1.htm#s1_007 +The SEC revoked the Inergetics/Millenium registration only AFTER this massive fraud on the public was +committed +I can't seem to find any reference to this money laundering shell in the DoJ/Readler CIVIL not criminal +complaint. You won't find any SEC complaint implicating Colleran/ Honig /Sason either +Millenium/Inergetics: New Jersey: SEC NY +OTHER Sason entities list offices at 40 Wall Street: Trump +So, Judge Ramos: HOW did prolific Bag Man Honig become involved in the Honig money laundering shell MGT +Capital which ALSO did a "pivot" to crypto mining? +EDGAR Search Results (sec.gov). + + +Venaxis/Aspenbio/Bioptix: now RIOT. Which only exists in SEC filings. Thanks in large part to the well +orchestrated SEC NY/ SEC Denver criminal obstruction/corruption. +EDGAR Filing Documents for 0001493152-16-013083 (sec.gov) +That was 1 thorough "investigation Mr Gottschall. I see great things at the SEC for you +AND guess who ELSE was involved in MGT in 2019 just before the SEC revoked the registration: +Chicago Bag Man Fife/Iliad +6 years after I filed my TCR with the grossly corrupt SEC +EDGAR Filing Documents for 0001567619-19-008772 (sec.gov) +AND the Scumbags at Sichenzia Ross:MULTIPLE frauds on SDNY/NY Supreme Courts with Sason et al +https://www.sec.gov/Archives/edgar/data/1001601/000114420415063432/v423506_s-1.htm +The interconnectedness of my claims on display yet again. OR: The record +to be continued... +From: Chris Dilorio I +Sent: Monday, May 17, 2021 5:28 AM + + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +Oh, +But it gets MUCH better Mr Gottschall et al: +Ibex Digital: +Bermuda based/Pakistani controlled Ibex Ltd +NASDAQ: IBEX +EDGAR Search Results (sec.gov). +60+% controlled by Pakastani entities: The Resource Group: TRGI +and TRG Pakastan Ltd: TRGP +BPO takes on a WHOLE different meaning. +Which explains the co location with Local ISP ClearConnect. +Riot Blockchain is just a front. +RIOT crypto mining contract with Massena NY Coinmint +New York Crypto Mining Farm Coinmint Set to Dissolve? - MinerUpdate +New York Crypto Mining Farm Coinmint Set to +Dissolve? - MinerUpdate +An ongoing dispute between the two partners who hold equal +shares in multi-cryptocurrency mining company Coinmint has +resulted in one of the partners filing to dissolve the company. +www.minerupdate.com +is on verge of dissolution +RIOT/Aspenbio/Bioptix/Venaxis is and always has been a Prolific Bag Man Honig money laundering shell. +Because: say it with me: the only difference between a NASDAQ money laundering shell and an OTCM money +laundering shell is the amount being laundered. +I've read that somewhere before. Hey, I'm the 1 who said it. +Give me a call Mr Gottschall. After I help you find Castle Rock on a map, lIl walk you through it. I'Il type/talk +slowly for you. Because, if you can't find Castle Rock on a map you don't have a chance in hell of finding + + +Pakistan on a map. And, after you're able to find Castle Rock on a map, I'Il take you to Vista Gold :VGZ "world +HQ" all +Littleton CO +The money laundering shell cited in my TCR and kept up and running by the grossly corrupt SEC for the last 8+ +years and with SEC approved offering after offering. +From: Chris Dilorio d +Sent: Friday, May 14, 2021 6:34 AM +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +In addition to NeoPhotonix and Bioptix +BiOptix Diagnostics, Inc. - Portfolio company - RUSNANO Group + + +BiOptix Diagnostics, Inc. - Portfolio company - +RUSNANO Group +RUSNANO was founded in March 2011 as an open joint stock +company through reorganization of state corporation Russian +Corporation of Nanotechnologies. RUSNANO's mission is to +develop the Russian nanotechnology industry through coinvestment in nanotechnology projects with substantial economic +en.rusnano.com +Rusanano/Akhanov invested in Quantenna +Now On Semiconductor which supplies chips to Apple +EDGAR Filing Documents for 0001628280-17-001249 (sec.gov) +as well as chip company Aquantia +EDGAR Filing Documents for 0001387131-18-000659 (sec.gov) +Aquantia was acquired by giant chip company Marvell +Company - Newsroom - Marvell Completes Acquisition of Aquantia - Marvell +Company - Newsroom - Marvell Completes +Acquisition of Aquantia - Marvell +Marvell Completes Acquisition of Aquantia Accelerating Multi- +Gig Ethernet Technology Leadership. Santa Clara, California +(September 19, 2019) - Marvell (NASDAQ: MRVL) today +announced that it has completed its acquisition of Aquantia, +Corp. (NYSE: AQ).. Aquantia pioneered Multi-Gig technology - +www.marvell.com +The SEC massive frauds on the SNY and NY Supreme Courts continues +Sichenzia Ross: Sason/Crede/ Jim Justice et al NewLead and FreaSeas +As well as WNW and others. +Now RiotBlockchain. +So, Sichenzia facilitated a fraud "acquisition" of certain Futures Commission Broker now Introducing Broker +trading platform from Mark B Fisher of "Miami" +https://www.sec.gov/Archives/edgar/data/1167419/000107997318000207/riot_8k-03272018.htm + + +SEC.gov | HOME +Check the appropriate box below if the Form 8-K filing is intended to simultaneously satisfy the filing +obligation of the registrant under any of the following provisions (see General Instruction A.2. below): +Mark B Fisher has owned MBF Clearing +MBF Clearing Corp (mbfcc.com) +MBF Clearing Corp. +Welcome to MBF Clearing Corp website About MBF Clearing Corp Founded in 1987, MBF Clearing Corp. is +widely-recognized for our preeminent role within the global futures markets. +www.mbfcc.com +As well as MBF Capital +mbf online | management (mbfcapital.com). +mbf online | management +Mark Fisher is the President of MBF Capital Corporation, Inc. He is a founder of Vela Pharmaceuticals, +Inc., ExSAR Corporation, and Kimeragen, Inc., which merged into Valigen, Inc. Prior to the formation of +MBF, Mr. Fisher was a Principal of Alex Brown where he was employed from 1990-1996. +www.mbfcapital.com +for quite some time. BOTH New York based. +Not even sure if there is a Miami Office for eithe Fisher entities. So WHY "Miami"? +Part of that question can be answered by ANYONE receiving my extensive and irrefutable evidence of SEC +criminal obstruction and corruption: +Miami SEC Director Eric Bustilloe. A grossly corrupt Piece of Shit on par with Gottschall and Best. Did Fisher +have outside investors in his firmS based in Miami? +MBF /Fisher CLEARLY fall under SDNY/NY Supreme Courts jurisdiction. As does Sichenzia Ross +As I have said repeatedly: the national security implications of these massive, multiple SEC facilitated frauds are +staggering. + + +From: Chris Dilorio «| +Sent: Thursday, May 13, 2021 9:49 AM +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +"Mr Dilorio, do you have any MORE irrefutable evidence of SEC gross criminal obstruction and corruption while +screwing you the whistleblower who caught them?" +Yes SDNY/NY Supreme Courts, SEC IG Hoecker, Audrey Strauss, FBI, IRS CI etc etc etc: It just so happens I took a +field trip to try and find the longstanding address of the Castle Rock CO money laundering shell +Riot Blockchain fka Aspen Bio, Venaxis, Bioptix +EDGAR Search Results (sec.gov). +Enlightening! Kept up and running by the grossly corrupt SEC and pumped by Najarian(NetElement) on CNBC, +Riot Blockchain is a Honig/Grousman/Stetson/GRQ et al money laundering shell which somehow escaped +(along with many others) the SEC scrutiny in its Honig/Stetson/Frost/Jaclin/Alpha Cap et al complaint +https://www.sec.gov/Archives/edgar/data/1167419/000107997317000238/bioptix_s3.htm +But WAIT. There's MORE! +The Honig/Stetson Bioptix money laundering shell is ALSO a Colorado entity: Boulder + + +Bioptix was just a vehicle to get Honig/Stetson et al into RIOT. Gee, I wonder what they saw in Bioptix that +caused them to "invest" when it was around less than 2 years before "pivoting" to blockchain/crypto???? +let's ask the scumbags at Sichenzia Ross who advised on the Bioptix money laundering offering which gave +Honig et al ownership in RIOT +https://www.sec.gov/Archives/edgar/data/1167419/000107997317000154/ex10x5.htm +SEC +WHEREAS, subject to the terms and conditions set forth in this Agreement and pursuant to Section 4(a)(2) +of the Securities Act of 1933, as amended (the "Securities Act"), and Rule 506 promulgated thereunder, the +Company desires to issue and sell to each Purchaser, and each Purchaser, severally and not jointly, desires +to purchase from the Company, securities of the Company as more fully .... +Then, we can ask the Bioptix offering Escrow agent: New York licensed Signature Bank:SBNY. You know the 1: +the once and always Private Banking arm of Hapoalim where Strauss/Berman criminally obstructed a thorough +investigation of Hapoalim tax evasion and money laundering. The same SBNY which boasted Ivanka Trump as a +Board memberand was a "go to lender" for Trump/Kushner and where ALL SEC filings have disappeared. AND +where Chairman Scott Shay is on BoD of CardWorks (Berman) which was go to processor for Net Element: +Merrick Bank UT. Etc etc etc. YES, that SBNY +https://www.sec.gov/Archives/edgar/data/1167419/000107997317000154/ex10x3.htm +SEC.gov| HOME +WHEREAS, pursuant to the terms of the Purchase Agreement the Company desires to sell (the "Offering") a +minimum of $2,000,000 (the "Minimum Amount") and a maximum of $2,250,000 (the "Maximum Amount") +of units of its securities (the "Units")."). Each Unit is being sold at a price of $2.50 per Unit. Each Unit +consists of one (1) share of the Company's common stock, no par value per share (the .... +How much SEC et al criminal obstruction and corruption are we up to so far Mr Gottschall et al? +Wait, there's more! +In 2015, just prior to Honig/Stetson/SBNY/Sichenzia et al fraud offering, Boulder Based Bioptix FKA Alphasniffer +did an SEC approved D offering +SEC FORM D/A +SEC FORM D/A +In submitting this notice, each issuer named above is: Notifying the SEC and/or each State in which this +notice is filed of the offering of securities described and undertaking to furnish them, upon written request, +in the accordance with applicable law, the information furnished to offerees.* + + +Guess who shows up as A Bioptix/Alphasniffer insider? +Dimitry Akhanov +WTAF is Rusnano USA????? AND head of the Russian Federal Energy Agency???? +WHY is he involved in Bioptix now RIOT??? +Dmitry Akhanov, CEO of Rusnano USA, Inc., RUSNANO (topionetworks.com). +Dmitry Akhanov, CEO of Rusnano USA, Inc., RUSNANO +Curated profile of Dmitry Akhanov, CEO of Rusnano USA, Inc., RUSNANO +www.topionetworks.com +Akhanov is also involved in NYSE listed Neophotonics +NeoPhotonics Names Dmitry Akhanov to Board of Directors President and CEO of Rusnano USA Joins +NeoPhotonics Board_| NeoPhotonics Corporation +Neophotonics supplies optical chips to some of the biggest optical switching companies in the world like US +based Cisco and Ciena +Recall: Honeg/Stetson/Frost/Alpha Cap +Alpha Cap: my 2013 TCR +Honig/Stetson: Jaclin: Farkas: BLNK. Also CFO New: NETE: Crede/SBNY/CardWorks/ESQ, etc +Honig also Trump fundraiser: Cleveland: Colleran. DoJ "prosecutor" on Colleran massive healthcare fraud: Chad +Readler. Trump made Readler a Federal judge. +SEC left dozens of Jaclin money laundering shells up and running. Including Blink/New Image Concepts, +Intercloud with Sason etc. As well as OZ/Maso/Sculptor NJ deli Hometown International: HWIN. NONE of this is +by accident. SEC gross criminal obstruction and corruption. +Now Honig/Stetson: Bioptix now crypto RIOT. +Right here. 15 minutes from my home. Like CGFIA and VGZ. As well as prolific shell CPA firm BF Borgers. +Give me a call Mr Gottschall. I'Il point out Castle Rock to you on a map you grossly corrupt piece of shit! +From: Chris Dilorio +Sent: Sunday, May 9, 2021 5:06 PM +P; + + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +Per below: +Judge Cote's sentencing of Dan Kamensky is a gross miscarriage of justice. The SDNY, NY Supreme Court, Audrey +Strauss, Mr Kamensky's counsel, FBI, other DoJ attorneys are in possession of information which clearly +indicates a long standing and grossly corrupt relationship between the SEC and Handler/Jefferies. Further, as is +material in the "ongoing" Joshua Sason investigations of massive fraud committed on the SDNY/NY Supreme +Courts and directly related to my multiple claims: AQR and Sason: MI Acquisition with known felon Tom Priore: +ICP: also SDNY and now a direct lending client of Ares Management: Ressler: Drexel with Handler: also Neiman +Marcus. In short: Handler/Ressler set up Mr Kamensky for fucking with their deal. Had Kamensky won his bid, +Ares/Ressler would have been left with a much less valuable asset. AND put them further under water. +AresNeiman.pdf (pecloserlook.org) +Sticker Shock: Can Ares Management Sell Neiman Marcus? + + +2 Ares' Neiman Marcus Gamble In September 2013, Ares Management purchased luxury retailer Neiman +Marcus in a joint venture of Ares Corporate Opportunities Funds III and IV and the Canadian Pension Plan +Investment +www.pecloserlook.org +The SDNY Courts had this information. Kamensky's counsel had this information. Judge Cote should have +declared a mistrial rather than sentence Kamensky. A gross miscarriage of justice. +Now, let's turn to another example where the grossly corrupt SEC is ACTIVELY facilitating multiple frauds on the +investing public while screwing the whistleblower who caught them: ME. +Recall ANOTHER completely fraudulent denial of award : UBS AML. Where Norberg/OWB invoked the ILLEGALLY +enacted Summary Disposition Rule aka Christopher J Dilorio rule. Where the SEC own SEC website clearly +states: ALL tips received are THOROUGHLY reviewed by Enforcement Staff. Meaning: The Summary Disposition +Rule: SEC Staff never saw the information: is a KNOWN fraud. +Follow up for Mr Searles/Banerjee et al: SEC LA where multiple frauds left up and running. Ares also LA and NY. +Milken: Beverly Hills +Recall: UBS San Diego: K2. Where FINRA,FINCEN, and the SEC all confirmed UBS cross border business was +never shut down per the terms of the DoJ dropping it's DPA in 2010. Further, clearly obstructed by SEC IG +Hoecker when I filed a complaint with his office in 2015 after receiving another denial for Award related to the +UBS Reg Sho complaint. ALSO according to the SEC OWB FAQ: Enforcement staff notifies investigating staff of +related tips received AND Whistleblowers are ALSO entitled to awards based on new lines of inquiry. The +Mckessy/Norberg/Hoecker criminal obstruction led to the UBS cross border business never being shut down. +The UBS AML complaint acknowledges this irrefutable fact. +UBS K2: NO individuals were censured/fined by SEC/FINRA. ALL correspondence to UBS Weehawken. SEC +LA:Searles/Banerjee et al had ZERO jurisdiction. +Searles: Anton Chia and related fraud and money laundering. As I have also irrefutably proven: MULTIPLE frauds +Up and running today. +It is no coincidence the SEC LA/ UBS San Diego multiple money laundering frauds. Searles et al are PROTECTING +UBS San Diego. That's why none of these frauds have been shut down. The UBS cross border business is very +much up and running TODAY +MORE.... +Who is San Diego resident Jason Sunstein? CFO of several Once/still SEC reporting money laundering shells +trading OTCM Pinks and no doubt well known to Searles, Banerjee et al in SEC LA. +Viper Networks fka +Tinglefoot Mining +Baja Pacific International +Taig Ventures +EDGAR Search Results (sec.gov). +Microsoft Word - VPER - OTC PInkGuidelines Annual 12.31.20(Feb21 vers)v.3_nowcfo changes - Apollo Smart +Lights-3.docx (otcmarkets.com) +VPER - OTC PInkGuidelines Annual 12.31.20(Feb21 vers)v.3 nowcto changes +- Apollo Smart Lights-3 +27& Odunhwv *urxs ,qf 27& 3lqn %dvlf 'Ivforvxuh *xIgholqhv y )heuxdu\ 3djh ri i wklv Ivvxhu ru da\ ri lwv +suhghfhwvruv kdyh ehhq wkh vxemhfw ri vxfk surfhhglqjv sohdh surylgh dggiwIrqdo ghwdlov lq wkh + + +backend.otcmarkets.com +Santeon Group +fka Air-Q +Air Rover +Covenant Financial +Homegate Corp +Spartan Oil +ubroadcast +Santeon and Viper: African/Egyptian entities/Individuals +Santeon CEO : Ashraf Rofail +International Land Alliance +A San Diego virtual office well known to the SEC in its correspondence +Virtual Office in DiamondView Tower | Regus RU +Virtual Office in DiamondView Tower | Regus RU +Renting a Virtual Office in DiamondView Tower is affordable and easy. Choose a virtual office option and +pay one simple price. Get a quote today. +www.regus.ru +filenamel.pdf (sec.gov) +filename1.pdf (sec.gov) +International Land Alliance +A little California pot +a little "Mexico vacation properties" +Mexico Vacation Property Investment | Baja Mexico Real Estate Investment | International Land Alliance +(ila.company) +Mexico Vacation Property Investment | Baja +Mexico Real Estate Investment - Baja Mexico +Real Estate Investment | International Land +Alliance + + +International Land Alliance is a Mexico vacation property +investment firm based in San Diego, California. The company was +formed for the purpose of developing and selling residential +communities for home buyers, vacation/second home, +retirement, and investors. +ila.company +As of 2017, ILA is a Wyoming LLc +SEC FORM D +SEC FORM D +In submitting this notice, each issuer named above is: Notifying the SEC and/or each State in which this +notice is filed of the offering of securities described and undertaking to furnish them, upon written request, +in the accordance with applicable law, the information furnished to offerees.* +Of course: as has been well documented by ME: ILA currency of choice for these "beautiful Mexico land +ventures" is common stock. +In April 2021 +International Land Alliance Inc. (Form: 8-K, Received: 04/05/2021 14:00:05)_(otcmarkets.com) +OMID Holdings +fka New York Based Avl Group +content (otcmarkets.com) +Disclosure Statement Pursuant to the Pink Basic Disclosure Guidelines - +OTC Markets Group +OTC Markets Group Inc. OTC Pink Basic Disclosure Guidelines (v2.1 December 2019) Page 1 of 23 . +Disclosure Statement Pursuant to the Pink Basic Disclosure Guidelines +backend.otcmarkets.com +Back in 2010, AV1 Group New York was controlled by a Moussa Traore +SEC FORM D +Who happens to have the same name as former Mali Dictator. +Of Course, Jason Sunstein ONLY experience on Linked In is his ILA tenure. ALL of these other ventures have been +ommitted. Gee, I wonder why. +Jason Sunstein - Co-Founder and Vice President - International Land Alliance, Inc. (OTCQB: ILAL)_| Linkedin + + +Jason Sunstein - Co-Founder and Vice President - +International Land Alliance, Inc. (OTCQB: ILAL) | +Linkedin +Jason Sunstein Co-Founder and Vice President at International Land Alliance, +Inc. San Diego, California 500+ connections +www.linkedin.com +Mr Searles, Banerjee, SEC LA have been criminally obstructing a REAL investigation into Sunstein et al. Right +there in San Diego/UBS K2 back yard. So: No individual UBS San Diego K2 complaints, multiple money +laundering shells up and running. +For MANY reasons IG Hoecker: ALL SEC OWB Denials of my award applications are complete fraud. ALL of the +activity continues TODAY as a direct result of your criminal obstruction and corruption. +AND: NITE and CDEL trading all of them. +In furtherance of the conspiracy...... +Sent: Friday, May 7, 2021 4:01 PM +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +Judge Cote, +Your 6 month prison sentence for Dan Kamensky is a gross miscarriage of justice. Your Courts, Ms Strauss, and +Mr Kamensky's counsel are in posession of information that clearly indicates a long standing and corrupt +relationship between the SEC and Handler/Jefferies. Kamensky was set up. I will be contacting Mr Kamensky +directly as his counsel has committed gross negligence in his representation. +Sent: Friday, May 7, 2021 6:28 AM + + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +SDNY/NY Supreme Court Judges et al: +The interconnectedness of my claims on display AGAIN +Per my 2013 TCR criminally obstructed by McKessy/Norberg et al: WHY do $50 billion Swiss banks trade OTCM +Pink penny and fractional penny stocks? The record is irrefutable: FINRA/SEC/FINCEN using my information: +these publicly traded shells are the perfect money laundering vehicle. Absolutely IRREFUTABLE. WHY do firms +like NITE and CDEL trade the same OTCM Pink shells? Abusive, illegal naked shorting to facilitate this illegal +activity. Virtually riskless. VERY profitable. NONE of this happens without a willing executing criminal BD like +NITE converting worthless certs to real money and dumped on the investing public the SEC is MANDATED to +protect. ACTIVELY facilitated and perpetuated by the grossly corrupt SEC: reverse splits, no CAT, Obligation +Warehouse: circumvent close outs of Rule 204, rarely revoked registrations, outsourcing the entire OTCM to the +BD SRO FINRA, etc etc etc. I made the link between the money laundering and the illegal, abusive naked +shorting. This is and always has been the core business at Knight/KCG/VIRT:NITE. ALL money laundering can be +reverse engineered from the executing BD/MM level. The cash register. +What we are seeing in GME is a rounding error compared to the fails and illegal naked shorting in the OTCM. + + +As I have also repeatedly said: the only difference between a money laundering OTCM Pink shell and a NASDAQ +SPAC is the amount of money being laundered. Also on display real time as I have detailed. As with Swiss banks +and penny/fractional penny stocks: WHY do giant Quant Hedge Funds like AQR facilitate so many fraud blank +check shell transactions? CERTAINLY does not fit the investment thesis of a firm run by Phd's. +WHY does giant PE/Real Estate firm Apollo play Fisker SPAC? WHY did Goldman,JPM, Jefferies et al bail out NITE +more than once? WHY has the SEC repeatedly bailed out criminal NITE? +The most recent Earnings call for NITE was remarkable: SELL SIDE is actually doing what it's supposed to do and +questioning NITE/Cifu lack of transparency particularly in the last few years. This has been going on for some +time detailed by me and blessed by the SEC. This lack of transparency is designed to conceal from the public the +true nature of the core NITE business: illegal, abusive naked shorting OTCM publicly traded shells to facilitate +money laundering. Until now, the Sell Side turned a blind eye/ also intentionally misled the public by omitting +these share volumes from their models. These share volumes have been the subject of other SEC/FINRA +actions. But, somehow NITE has avoided such actions. INEXPLICABLE. The SEC/FINRA have done everything in +their power to protect NITE. WHY? Because they bailed out a known criminal entity in 2012 and have been +criminally and corruptly covering up this irrefutable fact ever since. As a result: The illegal activity has continued +un abated. Then in 10,2021, the activity hit a level not even dreamt of. It has been a well orchestrated and +massive SEC facilitated fraud on the public the SEC is mandated to protect. A key player in this massive fraud is +the corrupt SEC IG Carl Hoecker who not only has criminally and corruptly obstructed an investigation of my +extremely serious allegations, Hoecker has also criminally obstructed Congress from executing its oversight of +the SEC. +These corrupt, criminal, ongoing frauds have also found their way into the SDNY and NY Supreme Courts as I +have detailed. Mr Kamensky is most definitely NOT on the SEC/DoJ "Do not investigate list". This can also be +observed in real time. Per my correspondence: MI Acquisition: Magna/Sason: 40 Wall St with AQR/"payment +processing" and felon Tommy Priore: ICP:SDNY. +There is a straight and direct line between ICP/Priore and the Degenerate Milken as well as the corrupt +SEC/SDNY Kamensky "sting" that goes beyond the degenerate Milken flunkie Handler/Jefferies. Where Audrey +Strauss Praised the work of the SEC. As I have previously detailed: Ares Management: Neiman Marcus: Tony +Ressler: Milken/ Drexel degenerate flunkie has built quite the monstrosity. A little PE. A little Real estate. But +the 800lb gorilla at Ares: Credit. Ressler's sister is married to Fat Leon Black. Close knit bunch for sure. +Ares: +Massive CLO manager/originator. 1 stop shop. Because as I detailed previously: now a direct lender to fraud +money laundering entities like Priore/Sason/AQR et al: PRTH. +Because securitization drives the lending and is not a biproduct of sound credit analysis: Junk is junk REAL +TIME. +I applaud Chair Waters and her efforts to reign in illegal trading practices detailed in my extensive record. +However: non bank lenders like the massive Ares pose a systemic risk to the US financial system. CLO's are a +massive fraud on the public developed by the Milken degenerates like the sub prime and S&L's. The SEC actually +brought a complaint recently: IIG which described using CLO's as a money laundering vehicle. The Caymans +have recently cracked down also. Greensill: Credit Suisse: Milken: is another example of securitization as money +laundering vehicle in sub prime factoring: Jim Justice. SBNY is also a securitization fraud: SBA. +Chair Waters and her Committees see the Credit Ratings Agency/SEC fraud I have also detailed. +My Coronavirus/repo virus: CLO correspondence: The SEC corruptly didn't downgrade massive CLO debt in +2020. The result: issuance exploded in 2021. Non bank lenders like Ares as well as Apollo,Jefferies, Ted Virtue +etc etc have reaped tens of millions in management fees. Who told the SEC to obstruct the proper role of the + + +Credit Agencies to downgrade massive CLO's in 2020? Mr Clements knows. His garbage CLO "report" late in +2020 set the stage for the "all clear" to the SEC. +Oh Mr Kamensky! I only hope you sue these corrupt scumbags who ruined your life while they are treated with +ZERO implications for their illegal activity by the grossly corrupt SEC/DoJ. +Sent: Tuesday, May 4, 2021 7:15 PM + + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +Mr "Not so Transparent" Dougie Cifu got a little testy on the 102021 earnings call and it abruptly ended. +2 Sell Side Analists: Fannon/Jefferies and Kramm/UBS pressed @dougielarge on his lack of transparency. What +is Dougie Cifu hiding? Something about "what percentage of those 4+ trillion shares of OTCM money laundering +shells did NITE trade?" made Dougie squirm like the snake most already know he is. +Love the parting shot to Kramm/UBS: +"your firm would love to have our business" +Virtu Financial Inc (VIRT) Q1 2021 Earnings Call Transcript | The Motley Fool +Virtu Financial Inc (VIRT) Q1 2021 Earnings +Call Transcript | The Motley Fool +Virtu Financial Inc (NASDAQ:VIRT) Q1 2021 Earnings Call May 4, +2021, 8:30 a.m. ET. Contents: Prepared Remarks; Questions and +Answers; Call Participants; Prepared Remarks: Operator. Good day, +and ... +www.fool.com +I fell off my chair laughing. +Still no questions on the balooning/insolvent balance sheet. But, hey it's a start. +Ms Mehraban, Mr Williams: your former Paul Weiss colleague Dougie Cifu is feeling some heat. I know you will +be gentle with him +Mr Gensler: in case you missed it: Dougie sends his best +Sent: Monday, May 3, 2021 2:03 PM + + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +SDNY/NY Supreme Court Judges. +I once challenge the best and brightest the SEC/DoJ/FBI/IRS CI/FINCEN have to offer. Tear me to shreds. Make +an example. I haven't been wrong about 1 single thing. NOT EVEN 1. +The record is simply irrefutable: +The latest edition of "The SEC is a grossly corrupt, criminal organization actively facilitating +multiple, massive, ongoing frauds on the public it is mandated to protect to the benefit of the criminals who own +them while screwing the whistleblower who caught them:ME" +I refer you to the SEC Office of the Whistleblower FAQ +Of course, I have multiple forms copied should you prefer +SEC.gov | Office of the Whistleblower +SEC.gov | Office of the Whistleblower +3. What information can I submit to the SEC? The SEC conducts investigations into possible violations of +the federal securities laws. In general, the more specific, credible, and timely a whistleblower tip, the more +likely it is that the tip will be forwarded to investigative staff for further follow-up or investigation. + + +AGAIN AGAIN AGAIN IG Hoecker et al: the "summary disposition" aka Christopher J Dilorio rule corruptly +enacted by Norberg/Clayton et al was/is COMPLETE FRAUD +per FAQ #12 from the grossly corrupt SEC/OWB website: +"ALL TIPS, complaints, and referrals received by the SEC are FULLY REVIEWED BY OUR ENFORCEMENT +STAFF........" +FURTHER +"Complaints that relate to an EXISTING INVESTIGATION are FORWARDED TO the STAFF WORKING ON THE +MATTER." +New line of inquiry. +I don't see how it could be ANY MORE CLEAR IG Hoecker et al. +In addition to annual reports to Congress ACKNOWLEDGING the OWB as the primary contact for whistleblowers +to the Commission at large, this is damning. The summary disposition rule aka Christopher J Dilorio Rule: "SEC +staff never saw Mr Dilorio's information" is complete and total FRAUD. Designed to use my information to both +bring and obstruct thorough investigations while screwing me out of rightfull compensation. +IG Hoecker, I'm still looking forward to our first interview given the 3 (THREE) complaints I have filed with your +office. The UBS Reg SHO Denial was complete fraud. The UBS FINRA/FINCEN, SEC AML Denial was complete +fraud. The Opco Denial was complete fraud. ALL must be reversed. The Summary Disposition Rule/aka +Christopher J Dilorio rule must be nullified RETROACTIVE to its passage as it is clearly contrary to the SEC Rules +ITSELF. +| look forward to speaking with you Carl +Sent: Thursday, April 22, 2021 5:57 AM +To: +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +so sorry for incorrect e mail +Sent: Thursday, April 22, 2021 5:44 AM + + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +Judge Buchwald, +I hope your colleagues in the SDNY and NY Supreme Court have forwarded my information. Like your +colleagues, you are the victim of another SEC fraud on the SDNY court. I am an irrefutable expert on SEC +criminal obstruction and corruption. Jay Clayton was NEVER "shocked" by the widespread fraud in the OTCM +and crypto markets. +Widespread Fraud in ICOs and Penny Stocks Shocked SEC's Jay Clayton - Bloomberg +Widespread Fraud in ICOs and Penny Stocks +Shocked SEC's Jay Clayton - Bloomberg +The former Wall Street deals lawyer who leads the U.S. Securities +and Exchange Commission said one of the biggest surprises of +his first year heading the agency has been learning about the +levels ... +www.bloomberg.com +Clayton's firm Sullivan Cromwell/Jared Fishman/Rodgin Cohen et al are EXPERTS on penny stock fraud having +bailed out the criminal enterprise Knight/KCG/VIRT:NITE on more than 1 occassion. OTCM shells and crypto are +complimentary money laundering vehicles. +Clayton and the SEC have obstructed a thorough investigation of my very serious allegations for years. Including +the 2017 merger of Virtu and KCG: NITE. As a direct result multiple, massive SEC facilitated frauds on the public +the SEC is mandated to protect are very much ongoing. In 1Q 2021, more than 4 TRILION shares of OTCM +money laundering shells were traded. Money laundering shells like SEC reporting HWIN and hundreds just like +it. Bitcoin continues to be mined in China, Russia, and Belarus. Bitcoin claims to have a limited supply. But, can +that actually be verified? On his way out the door, Clayton bought the Ripple action. As you have stated: +extremely flawed SEC argument that Ripple IS a security but somehow Bitcoin ISN'T. +In fact: either ALL crypto are securities OR NONE are. The IRS for its part treats cryptos as a capital asset. +Subject to capital gains and losses for tax purposes. As your colleagues can attest, the interconnectedness of my +information is irrefutable. Several entities including Signature Bank/Greenbox are just 1 example of my +"Derivative" information. +Seems to me that Clayton,Hinman, crypto pumper Peirce ALL had KNOWN settled precedent to regulate Bitcoin +and ALL crypto as securities: SEC V SG Ltd. Where appeals Court got it right and where Howey was applied: +Securities & Exchange Commission v. SG Ltd., 265 F.3d 42 | Casetext Search + Citator +Securities & Exchange Commission v. SG Ltd., 265 F.3d 42 | Casetext Search ++ Citator + + +Read Securities & Exchange Commission v. SG Ltd., 265 F.3d 42, see flags on bad law, and search Casetext's +comprehensive legal database +casetext.com +The inconsistency in the SEC approach to regulating ALL crypto as securities has caused great confusion in the +marketplace and has opened the door wide to fraud. +This is just another example of SEC corruption. +Now, the SEC corruption has reached your Courtroom as well +Sent: Tuesday, April 20, 2021 11:39 AM + + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +Several typos omissions corrected below +Judge Ramos: SEC 1 Off's +Sec. & Exch. Comm'n v. Honig, 18 Civ. 8175 (ER) | Casetext Search + Citator +Sec. & Exch. Comm'n v. Honig, 18 Civ. 8175 (ER) | Casetext Search + Citator +Read Sec. &. Exch. Comm'n v. Honig, 18 Civ. 8175 (ER), see flags on bad law, and search Casetext's +comprehensive legal database +casetext.com +SEC settled quickly with Honig et al. Also Alpha Capital Anstalt: Liechtenstein: IMDS: Bag Man Schlaff: Bawag: +Refco:Rhino: Sedona: Scan Graphics: Shaye Hirsch: Karfunkel: Kushners: Nordlicht: Englander: et al: Judge Swain +Derivatives. +These SEC 1 off's guarantee the activity continues. It does. +Below: Tri-Mark: Sytner +last 10K filed with the SEC:2010 +form10k5to1holding123110.htm (sec.gov). +Pg 46 Honig owned 2,514,786 shares or 7% +That's STATED control +When did the SEC waive 13D/G filings simply because it was disclosed in an audited/SEC reviewed 10K? +Not 1 off's: guarantee activity continues +Judge Ramos, did you put an end to Honig? +NOPE +Barry_C. Honig, et al. (Release No. LR-24262; Sep. 7, 2018) (sec.gov). +Barry C. Honig, et al. (Release No. LR-24262; Sep. 7, 2018) +The Securities and Exchange Commission today charged a group of ten individuals and ten associated +entities for their participation in long-running fraudulent schemes that generated over $27 million from +unlawful stock sales and caused significant harm to retail investors who were left holding virtually worthless +stock. +And, as I proved below: Jaclin/Honig STILL up and running in April 2021 + + +SDNY Judges/NY Supreme Court: The SEC CONTINUES to play you for fools while ACTIVELY facilitating massive, +ongoing frauds on the public it is mandated to protect while screwing the whistleblower who caught them: ME +As I have stated repeatedly in my correspondence: the record +Multi billionaire Frost wasn't trying to MAKE a few million. Frost et al were LAUNDERING. +Frost: bought Ladenburg from Icahn/LeBow/Lorber: Vector /New Valley. AFTER Icahn rolled his former +employer: Gruntal: Sater,Feinberg, SAC et al: MILKEN: into Ladenburg. As MY record also clearly shows: Honig +also Colleran: Trump felon fundraiser. AND: Vector/New Valley also Trump/Russia. +"1 off's"! +Too f'n funny +Sent: Monday, April 19, 2021 4:10 PM + + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +Welcome to Episode number: I lost track: of SEC criminal obstruction/corruption while screwing the public it is +mandated to protect and screwing the whistleblower who caught them: ME. +Give me a call Mr Gensler. Love to catch up. Saw where you did a OTCM esque reverse split in the massive USO +fraud on the public. +SDNY Judges et al, when you read about something as absurd and ridiculous as Hometown International with a +Deli front and New Jersey and entities in Hong Kong and Macau, you're probably thinking what I was thinking +10 years ago when I began researching NITE and the OTCM shells they traded. But, these are NOT 1 offs. This is +VHY the OTCM exists: abusive naked shorting OTCM shells to facilitate money laundering is and always ha +een the core business at NITE et al. This is WHY NITE has been bailed out multiple times by other crimina +entities. There is no such thing as just 1 cock roach. HWIN is no different. It is part of a MUCH MUCH bigger and +well orchestrated scheme. +More on Hometown International: +Hey look, there's a Senegal/Ivory Coast individual named Ibrahima Thiam with a Macau address +OTCQB-Certification.pdf (sec.report) +If the name Thiam is familiar, it should be: Tidjane Thiam the former CEO of Milken controlled Credit Suisse: Jim +Justice: Greensill. +The resemblance is striking. Don't you think? +Ibrahima Thiam - Wetlands International +Ibrahima Thiam - Wetlands International +P.O. Box 471 6700 AL Wageningen The Netherlands. Tel. +31 (0) +318 660 910 E-mail: [email protected] RSIN Number: 806703726 +Reg No: 09099028 +www.wetlands.org +You know the 1 I'm talking about Judge Silver: NITE top traded/multiple SEC/FINRA reverse splits/Jim Justice: 5 +Mile: Perian Salviola/Josh Sason/Sichenzia : NewLead fame? AND sister fraud "Greek Shipper" FreeSeas: also NY +Supreme Court. Also Sason/Sichenzia. But with other Milken flunkie Terren Peizer. Crede. Along with Deutsche +Bank and Credit Suisse. Peizer/Crede also Net Element. Net Element former CFO New: also Blink Charging: with +JMJ/Keener AND Prolific Bag Man Michael Farkas. MORE derivatives + + +More on Farkas later in the e mail. Read on +And, not to get too graphic +But another Hong Kong/Macau HWIN "investor" is Swiss "model" Nathalie Pasyawon +Nathalie Pasyawon - Boobpedia - Encyclopedia of big boobs +Interconnectedness defined. OR as I like to say MORE DERIVATIVES +The 2020 SEC reviewed HWIN 10K filed March 26, 2021 +https://www.sec.gov/Archives/edgar/data/1632081/000121390021018020/f10k2020_hometowninter.htm +UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 . FORM 10-K (Mark +One) IX ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF +1934 For the fiscal year ended: December 31, 2020 or • TRANSITION REPORT PURSUANT TO SECTION 13 +OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934 For the transition period from . +Guess who has been the HWIN auditor since 2015? +Fined/censured by PCAOB Liggett and Webb +James Liggett/Martin Webb +Microsoft Word - 105-2020-010-L.docx (azureedge.net) +Not the ONLY money laundering shells L/W CPA are involved in either +Directory - Service Provider Directory_| OTC Markets +OTC Markets | Official site of OTCQX, OTCQB and Pink Markets +Get Stock &. Bond Quotes, Trade Prices, Charts, Financials and Company News & Information for OTCQX, +OTCQB and Pink Securities. +www.otcmarkets.com +Several SEC reporting +AND a few more with up and running TODAY +NASDAQ listed Orbital Energy Group OEG +Aqua Power Systems APSI. That's Aqa Power systems fka NC Solar: a Jaclin money laundering shell +https://www.sec.gov/Archives/edgar/data/1553264/000114420412044855/v321146_s1.htm + + +Bang Holdings Corp BXNG: VERY appropriate Name. Read on. Also Jaclin. Also Zenith. AND Platinum +Brownies Marine Group BWMG +CZE Energy Inc OOGI FKA Odyssey Oil and Gas: through 2020: a NY HQ company +https://www.sec.gov/Archives/edgar/data/1160798/000121390021020286/f10k2020_c2eenergyinc.htm +The Company intended to expand the making of bio fuels from algae to other large mining Companies in +South Africa. On May 26, 2009, the Company acquired 51% of H-Power (Pty) Ltd. H-Power (Pty) Limited, a +South African registered company, which owns an exclusive license to develop and market batteries based +on patented Hybrid Battery Technology worldwide. However, on August 27, 2009, the ... +Enviro Technologies US Inc EVTN +Hometown International HWIN +See Below +Ocean Thermal Energy Corp CPWR +Point Of Care Nano-Technology Inc PCNT fka Alternative Energy and Environmental Solutions: Also Jaclin +ts10511_altenergy.htm (sec.gov). +Second Street Capital CTON +content (otcmarkets.com). +Vynleads Inc VYND +PuraDyn Filter Technologies PFTI +A New York Liggett/Webb money laundering shell is CZE Energy Inc +1185 Avenue of the Americas + + +Began as an "exercise equipment " shell controlled by Curtis Olschansky +Everyone remember the Better Buns machine? +https://www.sec.gov/Archives/edgar/data/1160798/000114420407015535/v069715_10ksb.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. +Here's ANOTHER lesson in derivatives for the slow on the uptake +New York C2E Energy Inc is now controlled by PROLIFIC Bag Man David Lazar/Zenith Partners/International +/Equity Holdings LLd's and Custodian Ventures. +https://www.sec.gov/Archives/edgar/data/1160798/000121390021020286/f10k2020_c2eenergyinc.htm +The Company intended to expand the making of bio fuels from algae to other large mining Companies in +South Africa. On May 26, 2009, the Company acquired 51% of H-Power (Pty) Ltd. H-Power (Pty) Limited, a +South African registered company, which owns an exclusive license to develop and market batteries based +on patented Hybrid Battery Technology worldwide. However, on August 27, 2009, the ... +Lazar/Zenith following money laundering shells: +Mediashift MSHF +Melt Inc MELT +XXStream XMET +FinotecGroup FTGI +Enabling Asia Inc EAIN +Goff Corp GOFF +NYSE listed SyntheticBiologics SYN +Exobox EXBX +just to name a few +Lazar NY address: 3445 Lawrence Ave +Oceanside, NY +Also SEC NY +Lazar partner in Zenith is Los Angeles/Beverly Hills/Santa Monica based Barry Sytner +also home to Mogilevich Bag Man Milken/Dexel/Boyd Jefferies et al +Sytner was himself in control of Tri - Mark Mfg Inc with guess who? Barry Honig + + +and another money laundering shell up and running today: Chinese S$ laundering shell Worry Free Holdings +Teed up and ready to go with Rent A CFO: CFO NOW +Worry Free is FKA SEC reporting iVoiceldeas Inc +Microsoft Word - WYCC 30 SEPT 2018 OTC FILING.FILED VERSION (otcmarkets.com). +Worry Free not the only Lazar China S$ laundering shell +Hong Kong Winalite Group +Not revoked by the grossly corrupt SEC after 10 years of no financial disclosures. Rather: voluntarily suspended +by Lazar to be re used at a later date. Per my record with the SEC et al: money laundering shells go dark AFTER +the fraud is committed. SEC does nothing to PREVENT the fraud from happening in the first place +https://www.sec.gov/Archives/edgar/data/1059885/000121390020001328/f1515d0120_hongkongwinalite.ht +m +Anyone keeping track of the Jaclin/Honig related money laundering shells we're up to so far? +Again: the Lazar/Sytner/Zenith/Custodian Ventures/Liggett/Webb list is not exhaustive +But in excess of 20 money laundering shells up and running today should be a good start. Don't you think Mr +Gensler? +Of course, the money laundering shell that ties all of these ongoing frauds together is Bang Holdings: BXNG +https://www.sec.gov/Archives/edgar/data/1632323/000161577415000921/s101040_s1.htm#INTEREST +SEC.gov | HOME +(1) This Registration Statement covers the resale by our selling shareholders up to (1) 1,857,050 shares of +common stock previously issued to such selling shareholders and (2) 1,500,000 shares of common stock +issuable upon exercise of outstanding warrants ("Warrants") at an exercise price of $0.35 per share, that +were issued in connection with a Securities Purchase Agreement by and between ... +A Colorado incorporated/Miami based/Jaclin money laundering shell where Liggett/Webb are auditor with +Farkas/Platinum/Zenith Equity Holdings/Michael Bernstein et al +EDGAR Search Results (sec. gov) +Vast majority: SEC reporting. Several Jaclin. BXNG: Farkas/Jaclin. Several with Chinese Nationals. +Zenith/Lazar/Sytner: Jaclin 2.0 like Honig. ABSOLUTELY NOTHING random about this as I have stated repeatedly: +MASSIVE in scope/Brazen/Egregious/ongoing/SEC facilitated/SEC IG complicit frauds on the public the grossly +corrupt SEC is mandated to protect while screwing the whistleblower who caught them: ME. AND NONE OF IT +HAPPENS without well known criminal entities like executing BD/MM's NITE et al. NOT the "penny stock trading +fairies" + + +No, SDNY/NY Supreme Court Judges: Hometown International is NOT a 1 off that slipped through the cracks. At +ALL times Jaclin has been under the jurisdiction of the SEC NY. At ALL times SEC NY ALSO under the jurisdiction +of the SDNY. +Sent: Saturday, April 17, 2021 10:31 AM + + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +SDNY Judges and SEC IG, +I would like to Re admit the following which is part of my extensive record with the grossly corrupt SEC: Jaclin +Money laundering shells: Honig et al. AND prolific Bag Man Michael Farkas: BLNK,ICLD etc etc +Have you been watching the story about this Deli in New Jersey with a $100 million dollar market cap? +US Financial Markets Have Become A Giant Mirage Built On A Foundation Of Fraud_| ZeroHedge +US Financial Markets Have Become A Giant +Mirage Built On A Foundation Of Fraud +ZeroHedge - On a long enough timeline, the survival rate for +everyone drops to zero +www.zerohedge.com +SDNY judges/ SEC IG: This is what I have been telling the grossly corrupt SEC for more than 8 f'n years now. +ALL of this activity is up and running TODAY: April 2021 thanks to SEC criminal obstruction and corruption. +The SEC is a criminal enterprise ACTIVELY facilitating multiple, ongoing frauds on the public it is mandated to +protect to the benefit of the criminals who own them while screwing the whistleblower who caught them: ME +Say Hi to the OTCM Pink money laundering shell Hometown International +EDGAR Search Results (sec.gov). +pg 22 and following of Selling Shareholders in this 2020 SEC approved S1 +https://www.sec.gov/Archives/edgar/data/1632081/000121390020014269/ea122720-s1_hometown.htm#j_015 +SEC.gov|HOME +(1) Pursuant to Rule 416(a) under the Securities Act of 1933, as amended (the "Securities Act"), there are +also being registered hereby an additional indeterminate number of shares of the Registrant's Common +Stock, $0.0001 par value (the "Common Stock") as may become issuable to the selling stockholders as a +result of stock splits, stock dividends and similar transactions, and, in … +New Jersey Deli with "investors" in Macau, Hong Kong etc +Welcome to my world in dealing with the grossly corrupt SEC +Of course, Hometown International was ANOTHER Jaclin money laundering shell kept up and running by the +grossly corrupt SEC +https://www.sec.gov/Archives/edgar/data/1632081/000114420415059929/v422176_s1.htm +SEC.gov| HOME + + +25 E. Grant Street. Woodstown, NJ 08098 (856)759-9034 (Address, including zip code, and telephone +number, Including area code, of registrant's principal executive offices) +What I have been telling the grossly corrupt SEC for YEARS: This is WHY the OTCM exists. AND, in Q1 2021, more +than 4 TRILLION shares of money laundering shells like Hometown International were traded by NITE, CDEL et +Market Statistics - Equity Trading Data Monthly_(finra.org). +ABSOLUTELY nothing has changed in the last 8 years. Infact, as the grossly corrupt SEC, DoJ et al have been in +possession of my information, this illegal activity has EXPLODED. +SEC IG: DO YOUR FUCKING JOB!!!!! +Hometown International: Woodstown NJ: SEC NY: SDNY jurisdiction +Sent: Monday, April 5, 2021 5:29 AM + + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +Judge Swain: still ANOTHER version of A Stroll Down the ABSOLUTELY NOTHING HAS CHANGED Avenue. +This is another version of my extensive correspondence as I wait on the SEC Final Determination. Below, I +detailed the $765 million fraud DFC/taxpayer loan to almost insolvent Kodak to transition from +film/cameras(buggy whips) to hydroxychloriquine. The DFC was run by Jared Kushner's college roommate. +Massive fraud from the outset. The SEC of course never investigated the massive pump and dump related to +this fraud. AND, thanks to the SEC egregious obstruction of Congress: there is STILL no CAT. Of Course the DFC +first appointed IG Zakel (Sep 6 2020) concluded 2 months later that Jared's roommate didn't break any laws. +Further: The Akin Gump internal investigation is ripped to shreds by yours truly below. AGAIN:There was no +Clayton et al/SEC OR DoJ investigation into the egregious Insider Pump and Dump that took place in KODK +related to the fraud DFC taxpayer loan. +The interconnectdness of my claims on display yet again. +Some Interesting entities involved with Blackstone/Schwarzman/New in the almost insolvent at the time/still: +KODK. +Recall from a version I sent last week Judge Swain: +Sedona/Scan Graphics: 1998 +Kushners/Nordlicht/Englander AND +The Karfunkel Family Trust +https://www.sec.gov/Archives/edgar/data/764843/0000943396-98-000012.txt +KODK got some attention when GEORGE KARFUNKEL made a generous donation to a "synagogue" in Brooklyn +called Congregation Chemdas Yisroel +https://www.sec.gov/Archives/edgar/data/31235/000121390020020114/ea124950sc13da2karfunkel_eas.htm +SEC.gov |HOME +This Amendment No. 2 to Schedule 13D ("Amendment No. 2") relates to the common stock, $0.01 par +value per share (the "Common Stock"), of Eastman Kodak Company, a New Jersey corporation (the +"Issuer"), and amends and supplements the initial statement on Schedule 13D filed on May 18, 2017, as +amended and supplemented by the Schedule 13D/A filed on December 6, 2019 (the "Schedule ... +Chemdas Yisroel address: + + +This EXACT address is the home of Roth CPA's etc +Which also has offices in Israel +Roth&Co - We understand that your business is your life's work (rothcocpa.com). +Roth&Co - We understand that your business is your life's work +NEW YORK. 1428 36th Street, Suite 200 Brooklyn, NY 11218 Phone: 718-236-1600 Fax: 718-236-4849 +rothcocpa.com +Important to note here that George Karfunkel founded 1 of the largest Stock transfer companies: American +Stock Transfer. Did I mention there was no Jay Clayton et al/SEC/DoJ Insider trading/P&D investigation into +KODK? +I digress. +See, back in 2004, Barry F'n Honig had a shop called GRQ Consultants +GRQ was involved in 2 money laundering Shells: +Amplidyne yada yada +EDGAR Filing Documents for 0001170022-05-000036 (sec.gov) +AND +Cell Power Technologies +EDGAR Filing Documents for 0001144204-04-007936 (sec.gov) +Everyone catch the address of this Cell Boost "technology" Cell Power? +The SAME address as Chemdas Yisroel and Roth CPA's +but just down the hall: Suite 205 +This is priceless. +An SEC approved offering from 2005 for Cell Power +https://www.sec.gov/Archives/edgar/data/1202034/000114420405030051/v026245_424b3.txt +Who was the law firm on this money laundering shell in 2005??? +Sichenzia Ross. The same law firm responsible for NewLead and FreeSeas: 2 massive frauds perpetrated on the +SDNY Courts as well as NY Supreme Court. Brought to you by the grossly corrupt SEC. +Gets better still.... +The SEC revoked Cell Power Technologies in 2010 +EDGAR Search Results (sec.gov). +Barry Honig/Jaclin: also Blink Charging with prolific Bag Man Michael Farkas, JMJ, Drexel Alum Director, +Jonathan New: NETE CFO up and running in 2021. +And Barry Honig: Frost/Stetson/Colleran/ Alpha Capital et al +Recall the record Janey: "multi billionaire Frost wasn't trying to MAKE a few million. Frost was laundering" +Frost: bought Ladenburg from Icahn/Vector after Ladenburg bought Gruntal: Milken, SAC, Feinberg et al +Colleran: Trump felon fundraiser +Alpha Cap: Schlaff: Bawag/Refco/Sedona/Judge Swain: also my Knight/KCG/VIRT:NITE TCR +2020. TEN YEARS AFTER the SEC revoked the Honig/Sichenzia money laundering shell down the hall from +Chemdas Yisroel/Roth CPA: Garfunkel: Cell Power Technologies + + +Garfunkel: 1998 Sedona/Scan Graphics w/Kushners et al +Karfunkel/Chemdas Yisroel/Roth CPA's weren't the only ones to "get the look" (for those of you with ZERO +trading experience charged with enforcing Securities Laws like insider trading, this is the term used for insider +trading) +Moses Marx also "got the look" +EDGAR Filing Documents for 0001104659-20-089495 (sec.gov) +EDGAR Filing Documents for 0001104659-20-089495 +EASTMAN KODAK CO (Subject) CIK: 0000031235 (see all company filings) IRS No.: 160417150 | State of +Incorp.:NJ | Fiscal Year End: 1231 Type: SC 13D/A | Act: 34 | File … +Marx and Karfunkel go way back and are still in business together +Does United Equities/Commodities ring any bells? +How about Berkshire Bancorp? ANOTHER New York licensed Bank +EDGAR Search Results (sec.gov). +Karfunkel/Marx moved BERK from the NASDAQ to the OTCM Pinks around 2013 +WHY? Less disclosure stupid. +Microsoft Word - (D634DCBC-639A-4A58-8504-3EDC20157A89) (otcmarkets.com) +hey look! Marx, Karfunkel:BERK has the same auditor as Trump: Mazars. Prly just ANOTHER coincidence. For +those of you incapable of following along: The probability that ALL of the Karfunkel illgotten gains in the +SEC/Trump/Kushner/Blackstone/DFC et al facilitated P&D/Insider trading went to Congregation Chemdas +Yisroel is virtually ZERO. +Have I mentioned there was NO :zero,zilch, nada Jay Clayton et al/SEC/DoJ insider trading investigation into +KODK? +OK, good. Got it covered +Maybe, just maybe had the grossly corrupt SEC thoroughly investigated my irrefutably accurate allegations: +Blackstone/Schwarzman: NITE, the massive pump and dump fraud:Blackstone et al: KODK wouldn't have +happened. Which is why there has NEVER been a thorough investigation of my irrefutably accurate allegations. +In fact, the grossly corrupt SEC has criminally obstructed a thorough investigation of my claims SO THAT frauds +like KODK can continue. The SEC is bought and paid for by criminals while actively facilitating MULTIPLE frauds +on the public it is mandated to protect WHILE screwing the whistleblower who caught them:ME. the record +Janey is IRREFUTABLE. +Finally Ms Wing/Strauss: will you be keeping your DoJ e mail address up and running months after you land a +new gig like Geoffrey Berman has? Almost like he never left. +So Judge Swain: What has changed since your Sedona/Badian/Hirsch/Refco/Bawag decision? +ABSOLUTELY NOTHING! +Yes: Blackstone/Schwarzman/Marx/Karfunkel/Kushner/Trump et al are most definitely on the SEC/DoJ "Do not +investigate List" + + +Sent: Wednesday, September 23, 2020 7:18 PM +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +Judges Cave and Nathan, +If there was ANY question as to the veracity of my extremely serious allegations, the SEC put it to rest today +with its "clarification" and new rules governing the Whistleblower program: +My preliminary denial in June for the Opco Award application which was 5 years in the waiting: "SEC staff never +saw Mr Dilorio's information" +I refer you to the ONLY new rule in the "clarifications" in the interest of "transparency" +https://www.sec.gov/rules/final/2020/34-89963.pdf +SECURITIES AND EXCHANGE COMMISSION 17 CFR Parts 240 and 249 RIN +3235-AM11 ACTION SUMMARY +SECURITIES AND EXCHANGE COMMISSION . 17 CFR Parts 240 and 249 [Release No. 34-89963; File No. S7- +16-18] RIN 3235-AM11. Whistleblower Program Rules +New Rule 240.21F-18 Summary Disposition +(3) The information you submitted was never provided to or used by the staff handling the covered action or the +underlying investigation (or examination), and the staff members otherwise had no contact with you. +AKA the Christopher J Dilorio Rule. Created to deny awards of rightful compensation. Per my appeal: a whistleblower CAN +NOT know who at the SEC he/she should contact as investigations are done in strict confidentiality. Further, the OWB itself +is the CENTRAL contact for whistleblowers. It is the EXPLCIT and EXCLUSIVE responsibility of the OWB to distribute +whistleblower information within the SEC. This "rule" is FURTHER overwhelming evidence of SEC corruption and +obstruction. +Judges Cave and Nathan: ALL information presented to your Courts must be treated with extreme skepticism if not +outright disdain. IF the SEC is willing to commit massive fraud on whistleblowers who expose their corruption and criminal +activity just imagine the evidence it is willing to fabricate to bring a case like they are in Kamensky. An immediate STAY in +Kamensky is warranted until an independent thorough investigation of my claims can be executed. ALL evidence +presented to your courts by the SEC must be questioned in light of the overwhelming evidence I have provided. Again: this +corruption goes straight to Jay Clayton himself. His former colleague Jared Fishman has played a key role in this massive +fraud. Clayton NEVER disclosed these conflicts. In addition, your Honors are in possession of other Clayton/Sull +Crom/AQR/Girsky facilitated fraud: Nikola. This is what it has come to when you blow the whistle on the grossly corrupt +SEC: They create a completely arbitrary and fraudulent rule to silence you. +Rule 204-21F summary disposition aka Screw the whistleblowers exposing SEC corruption Rule OR + + +The Christopher J Dilorio Rule +Regards, +FROM:Chris Dilorio< +Sent: Wednesday, September 23, 2020 5:27 AM +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +Judges Cave and Nathan, +My allegations are chock full of members of the SEC "Do Not investigate Club". Per my TCR: Key to the Aug 2012 +"glitch/Bailout: Blackstone/Schwarzman. Blackstone had done extensive Due Diligence on Knight prior to the +"glitch" and had considered buying them north of $14/sh. Somehow/some way Blackstone decided not to go +ahead with buying Knight not too long before the "glitch" which took the stock to $3. The ultimate bailout deal +was NOT collateral based. Rather a convert with a %50 discount to $3: $1.50/share. "WHEW". Per my TCR: ALL +2012 "glitch" bailout participants including Blackstone knew EXACTLY the fraud on the Knight balance sheet. +Because of SEC corruption/criminal obstruction, NITE is insolvent TODAY. Absolutely nothing has changed. A +massive ongoing fraud on the public. +As a direct result of the SEC "Do not investigate Club", The KODK/Blackstone fraud on US Taxpayers (see below) +was perpetrated on the public. +Steve Schwarzman/Blackstone are near the top of the SEC "Do not investigate List". +Obviously, Mr Kamensky is not in the Club. +As you can clearly see from my appeal to the OWB: The SEC intended to run out the clock. 5 years in the waiting +in their Preliminary Determination Opco Award Denial for " Investigators never saw my information". Yet, SEC +actions based on my information include: Hanover/Magna, JMJ/Keener, Fife, Southridge/Hicks, Opco, and +UBSS. Missing somehow: NITE, Handler/Jefferies, Blackstone/Schwarzman etc etc. +The last overt act of this massive conspiracy has not yet occurred. +Mr Kamensky and I are BOTH victims of a longstanding and corrupt relationship between the SEC and +Handler/Jefferies et al. Also victim of this corruption: the investing public the SEC is mandated to protect and +the US Taxpayer. +Regards, + + +Sent: Wednesday, September 16, 2020 6:25 AM +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +Janey, +Schwarzman must be pretty close to the top of the SEC's "do not investigate" list. +The latest Schwarzman/Blackstone orchestrated fraud and cover up: KODK +Today, the KODK Board Member Jason New: Blackstone "independent" outside inquiry by the law firm Akin +Gump is in +https://www.kodak.com/content/products-brochures/Company/Report-to-the-Special-Committee- +09.15.2020.pdf +"gaps" indeed +The flowery New/BX cover up is chock FULL of gaps. +"Introduction to Phlow" +Phlow: the VA consortium receiving $350 mil in Government Covid funding to provide Trump pushed Covid +Cure: hydroxychloroquine +https://www.prnewswire.com/news-releases/phlow-corporation-awarded-354-million-hhsasprbarda-contractto-manufacture-essential-medicines-in-shortage-301061648.html +Phlow Corporation Awarded $354 Million HHS/ASPR/BARDA Contract to +Manufacture Essential Medicines in Shortage - PR Newswire +RICHMOND, Va., May 19, 2020 /PRNewswire/ -- Phlow, a U.S.-based, public benefit drug manufacturing +corporation, has received federal government funding of $354 million for advanced manufacturing … +www.prnewswire.com +Phlow already has/had a long standing relationship with Ampac Fine Chemicals +https://www.phlow-usa.com/about-us/ +About Us | Phlow Corporation +Robert Mooney is a tireless champion of creativity and business +acumen. As an entrepreneur and co-founder of New Richmond +Ventures (NRV), Bob counseled startups and early stage +companies on accounting and financial reporting, capital + + +strategies, equity raising, project financing, milestones, business +www.phlow-usa.com +In May 2020, Phlow was re starting/building a mfg facility/warehouse with partner Ampac (AFC) to fulfill its +Government contract +https://richmondbizsense.com/2020/05/20/new-richmond-based-pharma-startup-with-350m-in-funding-eyesfacility-in-petersburgL +New Richmond-based pharma startup with +$350M in funding eyes facility in Petersburg - +Richmond Bizsense +Earlier this month BizSense first reported Phlow's initial +government contract for $6 million, but details on the company's +plans remained unclear at the time... Gupton said in an interview +Tuesday the company's plans have been in the works for about 18 +months, well before COVID-19 hit. +richmondbizsense.com +Per the KODK/New/BX/Akin Gump cover up: pg 20 +"On June 15 2020,Kodak signed a Letter of Intent with Phlow in furtherance of its application to the DFC to +show it had a CUSTOMER for its future API's" +Most definitely "DEFINITIVE AND MATERIAL" +So, where is the SEC reviewed/required 8k for this agreement? +https://www.sec.gov/cgi-bin/browse-edgar?CIK=31235 +Meaning: the DFC application was a FRAUD. Fraud on the government. Fraud on American taxpayers. +Further: WHY would the DFC consider "loaning" $765 million to KODK with NO EXISTING API capability when it +already granted LESS money to Phlow/Ampac with proven capabilities? Answer: KODK liquidity issues are +SEVERE +Like Milken: Insider trading is NOT the real issue here. The latest BX orchestrated "glitch": KODK. +I know this information may be more than the SEC/DoJ are capable of comprehending. +Call me and I'll walk you through it SLOWLY. + + +From: Chris Dilorio ‹| +Sent: Tuesday, September 1, 2020 7:40 AM +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +Janey, +MORE on the Blackstone/Trump/Kushner KODK P&D grift. +Again, BX helped orchestrate the Knight "glitch" and bailout. No doubt, the "luckiest" f'ers on the Street. VERY +high on the SEC do not investigate list. So, they can continue to facilitate criminal activity. +See below: Jason New: KODK BoD: BX. In charge of the KODK "internal investigation". Now we read where DE +Shaw has taken a 5% stake in KODK. guess who DE Shaw largest investor is: Blackstone. Corruption cover up. For +the record Janey +https://www.thetrustedinsight.com/investment-news/de-shaw-blackstone-20190325420/ +Sent: Thursday, August 20, 2020 12:04 PM + + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +Mr Best, +Congratulations on your new position as Director of SECNY. +No doubt you have earned the promotion. For those of you who don't know Dick Best from his FINRA days, this +masterpiece is what got him his job at the SEC Atlanta office +https://www.finra.org/media-center/news-releases/2014/finra-fines-brown-brothers-harriman-record-8- +million-substantial-anti +The BBH AML complaint. Truly, fantastic work. +ALL of the entities in the complaint are un named. WHY? +This is my information. +Swiss Banks, FFI's, and of course: penny stock trading fairies aka executing BD's/MM's that made it all possible. +Per Dick's complaint: BBH delivered 80%+ of the trades to executing BD's/MM's. Did Dick Best criminally +obstruct an investigation into my claims? Per my extensive correspondence with Robin Traxler at FINRA AND the +fact that the SEC had my Knight Capital TCR in its possession for almost a year when Dick brought his BBH +complaint. So, did Dick's complaint implicate entities in my TCR and that's why ALL of the entities in Dick's +complaint are un named? Most certainly YES. +Recall, this scheme generated $850 MILLION in proceeds. Dick's $8 mil fine was not a deterrent. Intentionally +SO. +So Congrats Dick on your new position as Director at SECNY. Janey, Hoecker, Dick, the record is extensive of my +correspondence including Dick Best at the Atlanta Office. No doubt he will be recusing himself related to +matters involving the un named entities in his FINRA BBH complaint. OR will he do what is expected at the SEC: +Criminally obstruct investigations while screwing whistleblowers like me? +Sent: Wednesday, August 19, 2020 6:53 AM + + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +Further: +Janey, Hoecker, Jay, Mehraban et al +Let me help narrow down the SEC facilitated, ongoing accounting fraud at NITE as I know none of you have ever +spent a day on a trading desk: +IF the avg holding period for VIRT HFT is a matter of seconds AND VIRT goes home flat every night, then what is +the receivable/fails related to? With the core Virtu HFT business eliminated, what that does that leave? The +CASH OTCM business maybe? Should I draw a picture in crayon for you Ms Mehraban? +NITE: 3 different CFO's in the last year. Ms Mehraban, How much is your former Paul Weiss colleague/boss +Dougie Cifu paying you to criminally obstruct an investigation of my allegations? +Janey, Hoecker, Mehraban et al: When it comes to trading fraud/accounting fraud cover ups, SEC attorneys are +CLEARLY not qualified. +The record there is ALSO IRREFUTABLE. +Here glitchy glitchy. +Sent: Tuesday, August 18, 2020 6:37 PM +V + + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +Janey, Hoecker, Mehraban, Jay et al, +The massive SEC facilitated fraud on the public known as Knight/KCG/VIRT: NITE is reaching epic proportions in +August 2020. For the new "accounting" hires at the SEC: +In 102020, the receivable at NITE was up 90% or $1.2 BILLION from Dec 2019 to $2.562,721 billion +Per the extensive record Janey: fails: because of self clearing are booked as a receivable. FRAUD. no intention of +delivering. More accurately a liability. AND per my 2013 TCR: a large portion: structural liability as a result of an +open naked short fail position WHEN not if a reverse split is approved by the grossly corrupt SEC/FINRA. There +are some new "buckets" Malusso, loffe, Dougie large have created within the Receivable as well. Creative. The +accounting shell game: moving fraud (abusive naked shorts) from bucket to bucket. +The 1Q2020 10Q +https://www.sec.gov/ix?doc=/Archives/edgar/data/1592386/000159238620000006/virtufinancial03- +31x20.htm +Inline XBRL Viewer - SEC +The Inline XBRL Viewer allows a user to quickly and easily review details of the tagged information in an +Inline document by automatically placing a top and bottom highlight border around each tagged numeric +fact and left and right border for each block tagged fact. +Pg 23. +Buckets total $2.562,721 BILLION +the 2Q2020 10Q +https://www.sec.gov/ix?doc=/Archives/edgar/data/1592386/000159238620000009/virt-20200630.htm +pg 24 +Buckets total $2.441,283 BILLION +The FRAUD (please see the record Janey). +ALL of the receivable items are related to SETTLEMENT. +Certain items within the receivable: buckets: would zero out within days IF VIRT was in compliance with the +Securities LAWS: Close out requirements of Rule 204. So, isn't it beyond amazing THAT: although there was + + +some change in certain buckets AND that the amounts were zeroed out within days of March 31, 2020 ONLY to +end the quarter June 30, 2020 a mere $121.438 MILLION difference from the March 31, 2020 ending +balance?????? +That is absolutely f'n amazing: $2.562,721 BILLION zeroed out from March 30, 2020 THEN a $2.441.283 balance +at June 30,2020. Well, the SEC does believe in "penny stock trading fairies" too. +Nope. Not penny stock trading fairies. AND VIRT didn't zero out :FAILED to SETTLE BILLIONS S$ in transactions. +This massive fraud is due to NEVER closing/covering as is mandated by LAW. SEC, ongoing, massive fraud on the +public. Classic bucket shell game. A la FCM and Reverse mortgages. +NOTHING has changed thanks to SEC corruption and obstruction while screwing whistleblowers like me. +The massive NITE accounting fraud facilitated by the SEC that facilitates the ongoing fraud on the public the SEC +is mandated to protect. +CLEARLY, IRREFUTABLY: NITE is and always has been a criminal entity. ILLEGAL NAKED SHORTING drives trading +profits at NITE. ALWAYS has. Janey, please post Jay Clayton AND Ms Mehraban NITE conflict disclosures. No +doubt, Dougie large will see this e mail the same way the grossly corrupt SEC has disclosed my information to +NITE for the last 10 years. NITE is GROSSLY insolvent TODAY August 18,2020. +From: Chris Dilorio d +Sent: Tuesday, August 11, 2020 6:53 AM +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight TCR & Appendix +Janey, Hoecker et al +SEC criminal obstruction virtually real time. + + +https://www.sec.gov/news/press-release/2020-178 +SEC.gov | SEC Charges Interactive Brokers With Repeatedly Failing to File +Suspicious Activity Reports +The Securities and Exchange Commission today announced that Interactive Brokers LLC will pay an $11.5 +million penalty to settle charges it repeatedly failed to file Suspicious Activity Reports (SARs) for U.S. +microcap securities trades it executed on behalf of its customers. +SECNY: Lara Shalov Mehraban. Ms Mehraban, I've asked this before: Was Dougie "Large" Cifu your boss at Paul +Weiss? The IBKR "complaint" is getting very close to your former boss/colleague isn't it? +Questions Ms Mehraban doesn't want the public to see: +Her former boss/colleague Dougie "Large" Cifu hired Alex loffe as VIRT CFO in 2019. From 2003-2019 loffe was +CFO at IBKR. INCLUDING the period covered in Ms Mehraban's complaint. +Not filing SAR's, Microcap securities, AML red flags. No kidding. WHY are the securities un named? WHO was +ultimate executing BD/MM? +As self clearing Ms Mehraban, isn't Knight/KCG/VIRT (Cifu): NITE the LARGEST clearing agent of microcap +securities? How many SAR's coming out of your former boss executing BD/MM? +Per my TCR: NONE. ZILCH. NADA. How do I know that? +When would the criminal enterprise NITE which is run by Ms Mehraban's former Paul Weiss boss/colleague Cifu +file a SAR: +BEFORE +AFTER trading billions of shares? +Did NITE Compliance rely on IBKR/loffe compliance? That would be a violation wouldn't it? +Ms Mehraban is the poster child of SEC corruption and criminal obstruction while screwing whistleblowers like +me. Virtually real time in August 2020. Very much an ONGOING and massive fraud on the investing public. +Ms Mehraban, please pass along my warmest regards to your former Paul Weiss boss/colleague Dougie "Large". +No doubt you "chat" often. +The record is overwhelming AND irrefutable. +From: Chris Dilorio <| +Sent: Monday, August 10, 2020 8:32 AM + + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight TCR & Appendix +Janey, Hoecker et al +speaking of NO 8K, recall the extensive record for the criminal/insolvent/fraud on the public +Knight/KCG/VIRT:NITE +The record Janey: Clayton/Sull Crom/Fishman "sale" of FCM business to other criminal firm Wedbush with NO +8K +3Q2014 10Q +https://www.sec.gov/Archives/edgar/data/1569391/000156939114000013/kcg2014093010-q.htm +KCG then CFO Bisgay resigned with 2 weeks left in the quarter and didn't certify the financials. WHO certified +along with Coleman? Sean P GALVIN. +Cifu, Viola, Urban, Hutchins et al getting the fraud band back together +https://finance.yahoo.com/news/virtu-financial-announces-changes-finance-105100941.html +WHY would "Cutting edge technology firm" VIRT want to go with a guy who knows how to run the books at low +as low tech gets OTCM cash trading firm Knight/KCG? The core business at Knight/KCG/VIRT: NITE is and always +has been: abusive naked shorting OTCM (and other) publicly traded shells to facilitate money laundering +Here glitchy glitchy +Sent: Friday, August 7, 2020 6:20 AM + + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight TCR & Appendix +The SEC facilitated fraud on the public continues unabated. MORE irrefutable evidence of SEC criminal +obstruction while screwing whistleblowers like me. +A direct result of this ongoing massive fraud on the public. +After NITE reported its 1Q2020 results | again again, again, like the last 10 years, alerted the grossly corrupt SEC +to the massive accounting fraud at NITE as a direct result of abusive naked shorting. +Per my 2013 TCR Janey, Hoecker, Jay et al: +NITE is in a constant state of insolvency as a result of illegal, criminal, abusive naked shorting OTCM money +laundering shells. This illegal activity drives trading revenue at NITE. This illegal activity is and ALWAYS has been +the core business at NITE. This very profitable albeit illegal activity is WHY Sull Crom client KCG was bought by +Virtu. This illegal activity is WHY NITE has been repeatedly bailed out by GS,B,JEF, JPM and the SEC +The receivable is where NITE books naked short fails as a result of self clearing. NITE has no intention of closing/ +can't close these naked short positions. NOT a legit asset. Further, the receivable isn't a legit asset NITE can +convert to cash for its own use. There are prior commitments on these "assets": SETTLEMENT +In 1Q,2020, the NITE receivable grew to $2.5 BILLION. UP 90% from December 2019 +https://www.sec.gov/Archives/edgar/data/1592386/000110465920057660/tm2018404d1_ex99-1.htm +SEC.gov | HOME +Exhibit 99.1 . Virtu Announces First Quarter 2020 Results . NEW YORK, NY, May 7, 2020 - Virtu Financial, Inc. +(NASDAQ: VIRT), a leading provider of financial services and products that leverages cutting edge +technology to deliver innovative, transparent trading solutions to its clients and liquidity to the global +markets, today reported results for the first quarter ended March 31, 2020. +Per the SEC reviewed 8k filing this am Aug 7, 2020 NITE reported 202020 earnings. showing the receivable +roughly flat with 1Q2020 at 2.44 BILLION +https://www.sec.gov/Archives/edgar/data/1592386/000110465920091707/tm2026789d1_ex99-1.htm +These are NOT "assets". More accurately, these are LIABILITIES. Massive accounting fraud. After moving these +fraud "assets" to the appropriate liability classification, NITE tangible book value is GROSSLY insolvent. The SEC +has obstructed my allegations for several years while allowing NITE to write down this structural liability on + + +more than 1 occasion. Further, sell side analists at the guidance of Cifu et al never question these EGREGIOUS +balance sheet issues. AND, with the grossly corrupt SEC blessing, Cifu et al never disclose insolvency in any SEC +filing OR investor presentation. +After dismal April/May REPORTED OTCM volumes on the FINRA now controlled website, June saw a dramatic +spike in share volumes. +The Top 25 OTCM money laundering shells by share volume in June 2020 and share price +PLYZ .00015 +PVDG .0008 +RTON .00015 +GRST .001 +RNVA .76 (rev split) +OZSC .0049 +EWLL .0002 +VSYM .0012 +OPTI .14755 +AFOM .0001 +SIML .00025 +IGEN +0084 +XMET .0002 +GTEH .0001 +ABCE .0003 +TSOI .007 +NTRR +.0014 +GFTX .0005 +LVXI .0003 +SGMD 0024 +INQD .002765 +RBNW .0005 +TLSS .0238 +TPTW .07215 +HYSR +.0328 +Combined price approximately $1 +How do stocks trade to trip zeroes? More buyers than sellers? +Covering/closing out naked short fails shouldn't be an issue. ONLY explanation: abusive naked shorting: +MANIPULATION. NOT Bona Fide market making. +As a direct result of this massive, ongoing SEC facilitated fraud on the public, ABSOLUTELY NOTHING HAS +CHANGED. +The record is irrefutable: SEC criminal obstruction while screwing whistleblowers like me to facilitae a +MASSIVE, ongoing fraud on the public. Key facilitator: Jay Clayton/Jared Fishman: Sull Crom + + +From: Chris Dilorio «| +Sent: Thursday, July 30, 2020 9:31 AM +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight TCR & Appendix +MORE SEC corruption/obstruction/screwing whistleblowers like me. +Per my 2013 TCR attached Janey, we know that Schwarzman/Blackstone has played a key role in perpetuating +the criminal entity Knight, KCG,VIRT:NITEthe Sull Crom client. +We also know Trump and Schwarzy are BFF's. Schwarzy is also connected to Kushner and Epstein. +Schwarzy is most definitely on the SEC's "Do not investigate List" +A stroll down the record Janey: Around the same time as the SEC/BX/JEF/GS et al August 1 2012 NITE "trading +glitch", Schwarzy/BX were key advisers to bondholders of Eastman Kodak and to the company also. Jason New: +Blackstone was re elected to the KODK BoD in May 2020. +https://www.sec.gov/Archives/edgar/data/31235/000156459020027039/kodk-8k_20200520.htm +Then the Pumper/Grifter in Chief Trump goes out wide and far with this absolutely incredible news: +The camera/film company Eastman Kodak is now going to be the US savior in pharma ingredients supply chain. +This is a page out of the penny stock grifter playbook. This is what happens when we have a WH full of money +laundering shell grifters. So, what has been the result of this incredible pump/transformation? KODK has gone +from 2 to 90 back to 40. +As is typical Trump/grifters/ and his criminal Clayton led SEC: the public hasn't seen a 8K filed by KODK to detail +this incredible "transformation". The SEC has given its blessing to yet ANOTHER Trump/Grifter/Bag Men P&D. in +KODK, FBO Trump BFF and Sull Crom client: Knight "savior" Schwarzy/BX. Had the grossly corrupt SEC +investigated my claims instead of obstructing them and screwing me, MAYBE Schwarzy/BX would have thought +twice about their latest grift: KODK. We know that Schwarzy is also a prolific GOP donor. +F'n criminals + + +From: Chris Dilorio wrote: +Is this case currently being prosecuted In the United States Attorney's Office Southern District of New York. +If the case is in SDNY please tell me the case name/defendants name. +If the case is being investigated please tell me what agency is investigating the case. +Victim Witness Coordinator +United States Attorney's Office + + +Southern District of New York +1 St. Andrews Plaza +New York, New York 10007 +Tel. +From: +Sent: Monday, May 3, 2021 3:32 PM +To: | +I (USANYS) < +Subject: Victim services request +Victim/Witness Coordinator +United States Attorney's Office +One St. Andrew's Plaza +New York, New York 10007 +Dear +My name in +Tand and I received your contact information from the United States Department of Justice website as a +resource for victims of child sex abuse and sex trafficking cases that being prosecuted. +I have spoken to law enforcement representatives and mandatory reporters regarding the crimes of which other people +and | are victims and would like request assistance and participate in the investigation. +My contact phone number is +Thank you for your consideration. +Sincerely, diff --git a/vision-fixhub/ds9-parsed-01/24f89ba112796ac8522e0639995c19662aade069b342bd27b05c746863ed1d7b.receipt.json b/vision-fixhub/ds9-parsed-01/24f89ba112796ac8522e0639995c19662aade069b342bd27b05c746863ed1d7b.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..af6958610c11faeb075e258eb7f7d9bb0e3fc9da --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/24f89ba112796ac8522e0639995c19662aade069b342bd27b05c746863ed1d7b.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "24f89ba112796ac8522e0639995c19662aade069b342bd27b05c746863ed1d7b", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "9f57536a5ca9c5b2539b1301a71a92aedec6bbbba611a91f1cb223f1532d62a0", + "output_sha256": "ac14c7aeb1c59a0a8c770be97ee4813d8437095a4fec6bf251b9942f908a1771", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/252ec7a61e26c4145d02cb710c248944d5900c2b46d878e3abed05db7e179e4d.md b/vision-fixhub/ds9-parsed-01/252ec7a61e26c4145d02cb710c248944d5900c2b46d878e3abed05db7e179e4d.md new file mode 100644 index 0000000000000000000000000000000000000000..1eeff25f45791d14e8fee0e6ba322242b486b665 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/252ec7a61e26c4145d02cb710c248944d5900c2b46d878e3abed05db7e179e4d.md @@ -0,0 +1,32 @@ +FD-302 (Rev. 5-8-10) +- 1 of 1- +FEDERAL BUREAU OF INVESTIGATION +OFFICIAL RECORD +Cramerica come hagals sel +cared FRi intornarica ayatara. +Date of entry +01/10/2020 +NATALIE M. JOSEPH, date of birth +telephone numberl +was +interviewed +on the island of Little St. James. After being advised +of the identities of the interviewing Agents and the nature of the +interview, JOSEPH provided the following information: +JOSEPH was born and raised on St. Thomas. JOSEPH was hired for security +for Little St. James. JOSEPH had heard of this job from a friend that worked +with MICHAEL TURNBALL. JOSEPH's friend told her to call TURNBALL and see if +there were any openings. JOSEPH called TURNBALL on Thursday, August 8 or +Friday, August 9. August 12°h was JOSEPH's first day working on Little St. +James; she started at 7:00AM. Her job entailed securing the docks. +Tourists can pass through the waters near the island and stay on the +boat, but cannot come onto the island. JOSEPH had never met JEFFREY EPSTEIN +nor had she seen him on St. Thomas. +Prior to working security on Little St. James, JOSEPH worked for Port +Authority and saw boats come and go from Little St. James. +Investigation on 08/12/2019 at Little St. James, Virgin Islands, United States (In Person) +File # 31E-NY-3027571 +Date drafted 12/23/2019 +by +This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your agency; it and its contents are not +to be distributed outside your agency. diff --git a/vision-fixhub/ds9-parsed-01/252ec7a61e26c4145d02cb710c248944d5900c2b46d878e3abed05db7e179e4d.receipt.json b/vision-fixhub/ds9-parsed-01/252ec7a61e26c4145d02cb710c248944d5900c2b46d878e3abed05db7e179e4d.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..da386dbc59dcd34a834fefea65842a4f563864a8 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/252ec7a61e26c4145d02cb710c248944d5900c2b46d878e3abed05db7e179e4d.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "252ec7a61e26c4145d02cb710c248944d5900c2b46d878e3abed05db7e179e4d", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "62bccf8c8b857dfd79d3232579a882291cb9bb590cb62441b75d1f5b66a7dd73", + "output_sha256": "e7ee246fb140389e8210f67fa36ed2f06331524c179b676faa22ba8a5fb8f1be", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2530cf082140c888209ffd3827783152878f96a0f252207655f4ba15c1d09ce9.md b/vision-fixhub/ds9-parsed-01/2530cf082140c888209ffd3827783152878f96a0f252207655f4ba15c1d09ce9.md new file mode 100644 index 0000000000000000000000000000000000000000..e50067291dd55ca35a33bf8e6888d7d034fb8808 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2530cf082140c888209ffd3827783152878f96a0f252207655f4ba15c1d09ce9.md @@ -0,0 +1,1277 @@ +From: Chris Dilorio ‹ +To: +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & +Appendix +Date: Wed, 14 Oct 2020 15:00:47 +0000 +Attachments: KCG_Appendix_3-20_13_penultimate.docx; KCG_TCR_3-20-13-penultimate_draft.pdf; +KCG_TCR_3-20-13-penultimate_draft.doex; KCG_Appendix_3-20_13_penultimate.pdf; +Cifu.jpg; Blostein.jpg; KCGMarch2017 jpg +The corrupt, criminal relationship with Handler/Jefferies as I have stated is NOT the only corrupt, criminal +relationship the SEC/SDNY have with members of their respective "do not investigate lists". AQR, Blackstone as +well as Jay Clayton good fried Glenn Hutchins. Hutchins also worked at Blackstone with Schwarzman prior to +founding Silver Lake. Hutchins bought SunGard. Then sold it to FIS. This transaction was the basis of the +formation of North Island with former NASDAQ CEO Greifeld. North Island is a top shareholder of the criminal +enterprise NITE/VIRT. More context: Greifeld was a Director UK/NJ company called Automated Securities +Clearance Ltd +https://find-and-update.company-information.service.gov.uk/company/03385409/officers +AUTOMATED SECURITIES CLEARANCE (EUROPE) LIMITED - Officers (free +information from Companies House) + + +AUTOMATED SECURITIES CLEARANCE (EUROPE) LIMITED - Free company information from Companies +House including registered office address, filing history, accounts, annual return, officers, charges, business +activity +find-and-update.company-information.service.gov.uk +Sold to SunGard. Greifeld then became CEO at SunGard. He wasn't at SunGard very long. Then made the jump +to CEO of NASDAQ. Curious to say the least. Shortly after becoming NASDAQ CEO, NASDAQ bought the BRUT +ECN from SunGard. Self dealing? MUCH WORSE +http://ir.nasdaq.com/static-files/6b1ca278-75f0-4259-9372-5b3351126a8b +ir.nasdaq.com +121e<2h"'21e<16$8;1<76=23 $ 54-*2((1-&22 +ir.nasdaq.com +As you can see, current NASDAQ CEO Adena Friedman signed off on this transaction. +SunGard was then sold to FIS. AFTER it had developed a very interesting product converting Russian Rubles to +dollars in real time. +https://www.finextra.com/pressarticle/49357/otkritie-capital-taps-sungard-for-automated-ruble-conversion +Otkritie Capital taps SunGard for automated +Ruble conversion +Otkritie Capital (Otkritie), one of the leading financial services +providers in Russia, has selected SunGard to help launch a new +direct market access (DMA) service allowing for automatic real … +www.finextra.com +I'II say that again: FROM Russian rubles TO dollars in real time. Providing DMA to WHICH markets???? +So, the marriage of Blackstone Alum Hutchins and Greifeld to form N Island and become a top investor in the +criminal enterprise NITE was a natural fit. Money laundering on a MASSIVE scale. Algos and OTCM shells are +very complimentary money laundering vehicles. Not to mention: Russian Mirror trades: RU ADR's trade OTCM +Pinks as well. The KCG 1Q2014 astronomical increase in OTCM volumes. Expunged from SEC reviewed +filings. Attached on previous emails as part of the OWB record. NASDAQ is also the repository of the vast AQR + + +blank check money laundering shells. FULLY SEC reporting for credibility. As with many OTCM shells. The +only real difference between a NASDAQ/AQR blank check shell and an OTCM shell is the amount of money +being laundered. Clayton should have been investigated and barred from SEC business pending a full and +thorough investigation. So, that precludes the corrupt SEC IG Hoecker from any involvement. +Cheers! +Christopher J Dilorio +Sent: Thursday, September 17, 2020 5:56 PM +To: +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix +Judge Nathan, +I applaud your reproof of the SDNY. +Now, I urge you to look at the Dan Kamensky case. I have never met Kamensky. When I saw the joint SEC/SDNY +complaint I became physically ill. I am an SEC whistleblower. The SEC/SDNY have actively and continuously +obstructed a thorough investigation of my extremely serious allegations. In favor of Rich Handler/Jefferies. The +IB in the Kamensky case. Based on my experience with the SEC/SDNY I believe they both are withholding +exculpatory evidence which impeaches the credibility of the SEC/SDNY/Handler/Jefferies. A corrupt relationship +exists between the SEC/SDNY and Handler/Jefferies. In addition to others in my claims. I have contacted Judge +Cave as well as Kamensky counsel. Disclosure of this corrupt relationship puts the Neiman Marcus "sting" in a +whole different context. The motives of which should be investigated. +Respectfully, +Christopher J Dilorio +From: Chris Dilorio ‹ +P +Sent: Thursday, September 17, 2020 9:17 AM +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix +Please see the new photos attached: + + +Mr Blostein's Eureka moment and Cifu admission that the NITE/VIRT revenue model is driven by the "retail +participation" rate: +Cifu: "The retail segment of what we do is a SIGNIFICANT portion of our overall American equity segment..." +So, are institutions trading 0001 OTCM money laundering shells? Mr Blostein: what are you modeling for +NITE/VIRT OTCM share volumes when you KNOW and Cifu admits the importance of these share volumes on +the NITE/VIRT revenue model? Does ANY Sell side analyst model this NITE/VIRT revenue driver? WHY doesn't +Cifu disclose these share volumes in SEC filings? He used to. Knight/KCG used to as well. See photo. So why did +he stop? Did NITE exit OTCM trading? ABSOLUTELY NOT. So the Goldman Analist Blostein KNOWS these share +volumes drive revenue at NITE. Blostein doesn't disclose these volumes in his model. Fraud is also an OMISSION +of material fact. Time to ask Cifu WHY he doesn't tell you to model OTCM share volumes fellas. This is WHY the +SEC/Handler/Jefferies/VIRT/KCG acquisition took place. As Cifu admits: Retail:OTCM drives NITE/VIRT earnings. +Cheers! +Christopher J Dilorio +From: Chris Dilorio ‹ +Sent: Wednesday, September 16, 2020 3:01 PM +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix +First Sell Sider, SEC, DoJ who can get me a current NITE/VIRT tangible book value calculation wins a prize: Mr +Kamensky's freedom. That's BEFORE properly classification of Naked short fails NITE/VIRT KNOWINGLY books as +fraud assets: receivable. +Mr Blostein, I remember a NITE/VIRT earnings call not to long ago where you made a direct correlation +between NITE OTCM share volumes and NITE trading profits. Remember the 1? I have hard copies of that too. +Did Cifu threaten you if you bring it up again? Please forward your model including these share volumes so we +can compare notes. Who else has been threatened with retaliation by Cifu/Handler? Who has been promised +business? Mr Repetto/Fannon? Who has BUY ratings on NITE/VIRT currently? +Cheers! +Christopher J Dilorio +Sent: Wednesday, September 16, 2020 9:20 AM +To: + + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix +Judge Cave, +The criminal, corrupt relationship between the SEC/Handler/NITE goes further. +Doesn't it Mr Repetto? +For the Sell Siders on this e mail: +Please tell Judge Cave, The SEC/DoJ, Mr Kamensky's counsel the following: +1) how many red flags in NITE 3 CFO's in a year? +2) What you're modeling for NITE OTCM share volumes +3) WHY none of you question the once again ballooning balance sheet on earnings calls +The other questions below can be answered by Mr Repetto and Jefferies Mr Fannon +Cheers! +Christopher J Dilorio +Sent: Monday, September 14, 2020 9:22 AM +To +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix +| look forward to speaking with you +Regards, +Chris +From: Chris Dilorio « +Sent: Monday, September 14, 2020 6:02 AM +P +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix +Judge Jones, Judge Cave +Straight forward, irrefutable proof of SEC corrupt relationship with Handler Jefferies: + + +KCG was engaged in abusive naked shorting in months leading up to the SEC/Handler/Jefferies VIRT acquisition +closing 7/31/2017 +SEC/Handler/Jefferies KNEW the core business at KCG is and always has been abusive naked shorting OTCM and +other shells to facilitate money laundering. +SEC/Handler/Jefferies knew KCG was insolvent in 2012 as well as 2017 as a direct result of this illegal activity +Handler/Jefferies were the largest shareholder of KCG in 2017 when the SEC/Handler/Jefferies/Cifu +orchestrated VIRT/KCG merger was consumated +https://www.clearygottlieb.com/news-and-insights/news-listing/14-billion-merger-of-kcg-holdings-and-virtufinancial +$1.4 Billion Merger of KCG Holdings and Virtu Financial | Cleary Gottlieb +Cleary Gottlieb is representing Goldman, Sachs & Co., as financial advisor to KCG Holdings in its sale to +Virtu Financial in an all-cash transaction valued at $1.4 billion. +www.clearygottlieb.com +SEC/Handler/Jefferies/Cifu used known fraud "assets" on the KCG balance sheet to determine the grossly +inflated tangible book value calculation used to value the KCG acquisition price. +Immediately prior to the transaction closing on 7/31/2017 the SEC/Cifu wrote down more than $4 billion in +leverage from the KCG balance sheet. INCLUDING fraud assets used to calculate the grossly inflated acquisition +price of KCG. +SEC/Handler/Jefferies KNEW KCG was insolvent in 2012 AND July 2017 +The SEC has known about the Knight/KCG/VIRT accounting fraud and securities fraud for years. I TOLD THEM. +The SEC has engaged in a massive criminal obstruction scheme that is ongoing to protect NITE/VIRT. +As a direct result of this corrupt, criminal scheme the investing public is put at risk, NITE/VIRT is insolvent +again/always, Handler/Jefferies benefit, my rights as a whistleblower have been egregiously abused, +Kamensky's life is ruined. +The SEC/SDNY is making a mockery of your respective courts. Worse: the SEC and SDNY are committing a +massive and well known FRAUD on your respective courts. +The true character of Handler/ Jefferies as well as the corrupt relationship the SEC has with Handler/Jefferies +must be disclosed to Mr Kamensky. Any verdict without these disclosures is a known miscarriage of justice. +https://www.lexology.com/library/detail.aspx?g=9e2b4e49-5ee2-48f6-b8c7-03d39d02b5ca +SEC ordered to produce Brady and Giglio +materials due to joint investigation with U.S. +Attorney's office - Lexology +A district court ordered the SEC to produce material solely in its +possession to a defendant in a parallel criminal prosecution by +the U.S. Attorney... +www.lexology.com +Mr Kamensky WILL have my information. Mr Kamensky WILL have justice. The SEC/Handler/Jefferies/Cifu +corrupt criminal relationship and ongoing frauds on the public will be exposed and ENDED. + + +Regards, +Christopher J Dilorio +From: Chris Dilorio ‹ +P +Sent: Saturday, September 12, 2020 8:23 AM +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix +Judges Cave and Jones, +The SEC corruption goes well beyond just Handler/Jefferies/NITE. +My research: I developed a template. I would search NITE top traded OTCM shells. From there: Derivatives. I +have filed several separate but related TCR's based on that information. +The SEC has brought several actions related to my 2013 Knight TCR with Berger: Hanover/Magna, JMJ, Keener, +Hicks, Fife, UBSS, and FINRA's NITE Nov 2016 Rule 204 complaint. ALL my information. In addition: FINRA +brought a complaint against Brown Brothers Harriman AFTER the SEC was in possession of my information for +almost a year. That complaint IS also my information. New SEC NY Richard Best brought that FINRA complaint. +ALL of the entities are un named. WHY? Per the complaint: BBH delivered 80%+ of the trades to executing +BD's/MM's. NITE as the #1 trader in the space would most certainly have executed BBH trades converting +worthless certs to real money. The BBH complaint also cites un named Swiss Banks and FFl's. As a result of +exposing these frauds the SEC/FINRA no longer allow searches of OTCM share volume by Market Maker. +Further, Cifu, Handler,the SEC have allowed the post VIRT/KCG: NITE to no longer disclose these share volumes +in any SEC filings NOR SEC reviewed investor presentations. Has NITE exited this business? ABSOLUTELY not. It is +and always has been the DRIVER of NITE trading profits. Virtually riskless albeit illegal. The investing public is +intentionally misled as to the true, core business of NITE +The August 1 2012 "glitch" proved my allegations that Knight was insolvent. Knight had to raise virtually the +entire "glitch" loss despite claiming to have a "highly liquid balance sheet". The accounting fraud is a result of +the illegal naked shorting. The SEC, Handler, Jefferies et al "glitch" and bailout wasn't JUST a cover up of a +massive SEC failure to protect the investing public however. The 2012 "glitch" was the first of many cover ups so +that this massive fraud on the public can continue. Per previous correspondence and the extensive record with +the SEC: As with the "glitch" ALL participants KNEW exactly the NITE core business and accounting fraud at NITE +in 2017 had not changed. As the record clearly shows: NITE was engaged in abusive naked shorting OTCM (and +other) money laundering shells immediately prior to the VIRT/KCG merger closing. Many of the same players in +the 2017 "glitch" as the 2012 "glitch". JPM,GS,JEF/Handler, and Jay Clayton Sull Crom colleague Jared Fishman. +How did the VIRT/KCG merger get approved in the face of the overwhelming evidence I provided? The same +way the 2013 Knight/Getco reverse merger got approved: SEC criminal obstruction. +In 2017 the SEC, Cifu, Handler wrote down 4 billion+ Naked short fails immediately prior to the VIRT/KCG deal +closing. These fraud "assets" were sitting on the KCG balance sheet and used to calculate the grossly inflated +tangible book value used in the KCG acquisition price. KCG was grossly insolvent. ALL participants and the SEC +knew this. The primary beneficiary of this fraud: Handler/Jefferies. + + +In 1Q2020 | alerted the SEC that absolutely nothing had changed. NITE reported a receivable of 2.5 BILLION+. +This was up 90% sequentially. HUGE red flags. No investigation. In 2Q,2020 the receivable had fallen by just $100 +mil from 1Q. Meaning: The 1Q receivable would have zeroed out within days of March 31 2020 as is required: +settlement Then, the receivable at June 30 was within 100 mil of the March 31 balance. Inconceivable. The +March 31 receivable was NEVER zeroed out as is required by law. Further, the fails listed as "assets" are a fraud. +More accurately: liability. AND there is nothing in the receivable that can be converted into cash for company +use. There are prior commitments: settlement. Combine this with the THIRD CFO in a year and you have the +makings of ANOTHER "glitch" +As I've told the SEC: HFT holdings:seconds. No receivable there. DMM? KCG sold theirs in 2016. So that leaves +the VIRT DMM. Even AFTER the massive 202017 Cifu/Handler/SEC write down, the receivable is up more than +6X from the last VIRT stand alone 2Q2017. AGAIN the effects of the core NITE illegal activity. +So, what has changed since August 1 2012? Absolutely nothing. This is an ongoing, massive fraud perpetrated +on the American people. Well orchestrated by the SEC, Handler/Jefferies, Sull Crom et al. +Did Clayton recuse himself from my Award denial? Did Clayton recuse himself from the VIRT/KCG approval? Did +Clayton EVER disclose his Sull Crom NITE conflicts? +The answer can be found in the very carefully structured complaints against several entities in my 2013 and +derivative TCR's: NONE of the activity in these SEC/FINRA complaints takes place without a willing, executing +BD/MM converting worthless certs into real money. The #1 trader in the space: NITE. Yet, you won't find NITE in +ANY of these complaints. As far as the SEC is concerned: : "penny stock trading fairies". The corrupt, criminal +SEC/Handler/Jefferies relationship explained. +I offer AGAIN to fly to SEC DC HQ or NY Office on my own dime to have the best and brightest at the SEC rip me +apart and refute my extremely serious allegations 1 by 1. Bring the SDNY too. Better yet: RE forward my +information to Handler,Cifu et al. I know they have already seen it from the SEC. I still have yet to be sued by +ANYONE related to my information. The Opco Denial Award is also further evidence of SEC criminal obstruction. +A gross mishandling of my information to both bring strategic complaints while protecting the criminal entity +NITE. Ms Norberg has created some of the most extraordinary reasons for denying my award. The best so far: +"SEC investigators never saw my information". An acknowledgement of SEC criminal Obstruction. It is the job of +the OWB exclusively and explicitly to distribute whistleblower information within the SEC. A whistleblower has +no way of knowing WHO at the SEC is working on a case. Further, despite my request for Norberg to produce +the entirety of my extensive record with the SEC, she failed to do so. +What was the denial in Opco based on? The SEC, Clayton, Handler, Jefferies, NITE et al ongoing massive fraud +on the public must continue. So it does. +Mr Kamensky must have my information. +This massive fraud on the public MUST end. ALL of it +Per the extensive record and my derivative TCR's: It isn't just NITE, Cifu, Handler, Jefferies et al the SEC is +protecting. Is it Jane? +Regards, +Christopher J Dilorio +From: Chris Dilorio 4 +Sent: Tuesday, July Z, 2020 6:09 AM + + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix +Janey, +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 +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. +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. O. 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#.XwRXGuWSnIV +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. 0). 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: | 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 +Not just irony but a massive fraud on the +From: Chris Dilorio « +Sent: Tuesday, June 30, 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, Hoecker, 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 +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-antimoney-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 +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_0_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 .... + + +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 +12345678910 11 1213 14 15 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 ... +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 +https://www.sec.gov/cgi-bin/browse-edgar? +action=getcompany&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 HQ'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/Ir24779.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) +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 +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 2Q2014 that were expunged from KCG 10Q SEC filings. Not 202014 and 302014 SEC +reviewed 100's as I previously stated +corrected below +Chris + + +From: Chris Dilorio «I +Sent: Tuesday, June 23, 2020 9:48 AM +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 AMP) where the ultimate +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 +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. +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 +"OU'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:Icahn/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 5&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. +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: +$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 2Q2017 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 I 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. +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 +Sent: Wednesday, June 10, 2020 2:30 PM +To: +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 +Sent: Mondav. 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 +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 +Sent: Tuesday, May 12, 2020 8:54 AM +To: +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: +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 +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 + + +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_10g.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. +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 +he SEC KNEW who the "third partv BD" +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 +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 +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. +https://www.sec.gov/Archives/edgar/data/1322587/000114420413065095/v361773_sc13g.htm +(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. +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 + + +Sent: Tuesdav, 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 +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 --O-- 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’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! +Christopher J Dilorio +From: Chris Dilorio 4 +Sent Sundav April 26 20209-36 AM. +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix +Sent: Friday, 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 +(asComplaint 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 +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. GfiRALTAR 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 +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? +The judge in the Gibraltar case said "the SEC's requested amount CLEARLY UNDERESTIMATES the defendants illgotten 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 +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 +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 +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 ... + + +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. +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 +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. +1 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 +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) +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. +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 +Mr Peirce, +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 obstructing an investigation, they are aiding and abetting the activity. These are not far flung +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 +SEC +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 I contacted Kevin Goodman Dir OCIE for Broker Dealrsat 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 +obstruet. 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 \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/2530cf082140c888209ffd3827783152878f96a0f252207655f4ba15c1d09ce9.receipt.json b/vision-fixhub/ds9-parsed-01/2530cf082140c888209ffd3827783152878f96a0f252207655f4ba15c1d09ce9.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..269e12f41f949d1b2a07e40e85dde1c227e51c49 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2530cf082140c888209ffd3827783152878f96a0f252207655f4ba15c1d09ce9.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -1083, + "dataset": "marble-joined", + "doc_id": "2530cf082140c888209ffd3827783152878f96a0f252207655f4ba15c1d09ce9", + "engine": "marble-apple-vision", + "event_count": 40, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "ff0dbd0eaa840865510fbca8ee945bd7e818670f2d39144f44f7e704836ddbef", + "output_sha256": "154831b52967b902f98d4bf94b6a2c845b0a5986418ff341e38128c4f965c5d5", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2539c1cc1c0250c7e657aded0bb76f3194e7958c1b788b3964a57e52221639d8.md b/vision-fixhub/ds9-parsed-01/2539c1cc1c0250c7e657aded0bb76f3194e7958c1b788b3964a57e52221639d8.md new file mode 100644 index 0000000000000000000000000000000000000000..de7680baf12e15543ceb217ee5cdbc9c17eb5d82 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2539c1cc1c0250c7e657aded0bb76f3194e7958c1b788b3964a57e52221639d8.md @@ -0,0 +1,14 @@ +From: +To: "1 +(USANYS)" < +Cc: " +(USANYS)". +Subject: Epstein +Date: Wed, 23 Jan 2019 23:24:34 +0000 +Importance: Normal +Any progress in getting the scanned docs from the trip? Particularly interested in seeing the draft indictment and defense +submissions. +Deputy Chief, Public Corruption Unit +U.S. Attorney's Office for the +Southern District of New York +Tel. (I diff --git a/vision-fixhub/ds9-parsed-01/2539c1cc1c0250c7e657aded0bb76f3194e7958c1b788b3964a57e52221639d8.receipt.json b/vision-fixhub/ds9-parsed-01/2539c1cc1c0250c7e657aded0bb76f3194e7958c1b788b3964a57e52221639d8.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..d7dfe20ed1709ab48a6df076976794d6de05229b --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2539c1cc1c0250c7e657aded0bb76f3194e7958c1b788b3964a57e52221639d8.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "2539c1cc1c0250c7e657aded0bb76f3194e7958c1b788b3964a57e52221639d8", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "f20a0d3bec40a0b72af42d187f2c8042d7c925a63f4f6dfee6c5b0e8437b1cea", + "output_sha256": "3518dddfccd5a67fec40c300e71b528d131f8dcaddb51201ea6d908195cf3014", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2562cf0ad087d9dd0578517a02af1252bc6f4bc9cb50948017d8651329f3b2a1.md b/vision-fixhub/ds9-parsed-01/2562cf0ad087d9dd0578517a02af1252bc6f4bc9cb50948017d8651329f3b2a1.md new file mode 100644 index 0000000000000000000000000000000000000000..bf3bfe9da55b14cbeed247670cd8f79d6572cc0d --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2562cf0ad087d9dd0578517a02af1252bc6f4bc9cb50948017d8651329f3b2a1.md @@ -0,0 +1,15 @@ +From: +To: " +Ce +Subject: +(USANYS)" ≤ +Date: Tue, 13 Aug 2019 15:36:10 +0000 +(USANYS) +A reporter is working a story about what appears to be an unregistered ambulance operating out of the Epstein +compound, shown in the link. They inquired with the local USVI gov't who said they're "conducting their own +investigation into it." +He speculates that getting the ambulance on the island would require help from customs and/or some other gov't +entities. *Some of the drone footage in the linked video(s) actually shows the raids taking place yesterday. +Public Affairs +United States Department of Justice +U.S. Attorney's Office Southern District of New York. diff --git a/vision-fixhub/ds9-parsed-01/2562cf0ad087d9dd0578517a02af1252bc6f4bc9cb50948017d8651329f3b2a1.receipt.json b/vision-fixhub/ds9-parsed-01/2562cf0ad087d9dd0578517a02af1252bc6f4bc9cb50948017d8651329f3b2a1.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..ec86c8f895b32f0d083e1fbbfdfc3907436bf83b --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2562cf0ad087d9dd0578517a02af1252bc6f4bc9cb50948017d8651329f3b2a1.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "2562cf0ad087d9dd0578517a02af1252bc6f4bc9cb50948017d8651329f3b2a1", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "2495bf904cc83ecb8134d8929ca867b402cf7477f761437c4940a18276b9cde1", + "output_sha256": "f4b097a592da09aa41e31f7f57cde0bf2896bbe18b8096fade14f440588b360e", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/25c691060de39ab590a341543e0c98be4c4363a374802f40007599042ca02c1c.md b/vision-fixhub/ds9-parsed-01/25c691060de39ab590a341543e0c98be4c4363a374802f40007599042ca02c1c.md new file mode 100644 index 0000000000000000000000000000000000000000..032b0c213cd870d67d55617b26acbcaca24b6f5d --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/25c691060de39ab590a341543e0c98be4c4363a374802f40007599042ca02c1c.md @@ -0,0 +1,374 @@ +From: +To: +Subject: United States v. Ghislaine Maxwell- victim compliant of crime and request for justice and +monetory compensation +Date: Wed, 22 Jul 2020 03:17:40 +0000 +Attachments: 186-15_(1).pdf;| +_ comments_on_April_23_pdf; +court_comments_on_non_confirming_documents_.pdf; 60879166_(1).tif; +BP 96272880 SP22617782 26737793 24607693-24607694- +24607695 1576904400(1).pdf; +correction +_of marriage _certificate_ (3).png +pdf; +Inline-Images: correction_marriage_certificate_png +Hello +I would like to forward this email to the District Attorney Audrey Strauss, Acting United States Attorney for the +Southern District of New York, and to the Attorney General for victim human rights and the Investigation +division of the office of the inspection general office. +I would like to open with a clear statement: I have been going through pain and loss of life and joy all those +years where the corrupted system was used to take the life of innocent children and the disadvantaged. Nothing +will be a proper compensation to all the suffering and emotional and mental abuse that me and My children +were going all those years since 2002 up till now. I have been used sexually as well as my children ( in different +times and episodes that not all is brought to light) by a group of powerful corrupted USA judges, social services +and attorneys (Jeff Berke Esq tell +and Nick Donovan Esq) . +My story has just begun and I am sure it will get an international audience It's a shame that for 15 years I have +been dragging myself and my children in countries and cities in order to save my children from being sexually +trafficked by the Epstien / +group. The pain is very difficult to carry and for hearing the news lately +I have decided to take the risk and come forward with my story. I guess I am being brave . I am fortunate to be +educated and to be an attorney who set nights and days to carry this life story and the unjust ice of the judicial +system in the united state. +would fre to renort muself as a mictim of a mand crime that was done aminst me +D and my 3 children +attempt to inflict badly harms against me, medical Faud, id, tith vei, coed, payer a and emorion hammest +unlawfully by providing flash documents, medical reports, in order to conceal thief identity. attempt to murder +my brother in Israel and attempt to cause me badly harm, stealling of heritage rights, stealing money and +properties, fraud of marriages and Human trafficking of children and fraud in medical and pregnancy reports +while commeting crime against me in order to gain personal financial gain and unjust ice enrichment by +breaching the fiduciary duty and my human rights. +In December 2019 I saw Ghisaine Maxwell in my building ( +Dspeeding out after getting out of the +elevator. I remember her face because she turned around and gave me and my Husband +D) a strong look +. It was published that she bought a new house with cash and a Ile that was created. After reading in the news I +saw on the Internet that the name : +is connected to the heritage of Mr. Espstien I believe from his father's +side. It was strang all the coincidence around this . +- what was an obstacle was the letter S +and not C. ( + + +Also in the2015 case of Martha Bursios esq - that was a case of fiduciary stealing from a sister that was +declared unfit by two brothers - this case was from 2015 at the DA OF QUEENS . and she got 5 years. She was +released in 2019 and hopes to immediately continue stealing . I saw her in December following me to Chase +Bank - 1 sat with a person named Sandra Baichoo/ Jose Severino: from Chase Bank 1025 Madison Av. I was +referred to them by an employee of Safra Bank - sigi (israeli) on 5 av. I was looking to find my account In the +Bank they took my driving Id and I believe that they have changed the name +with +. I believe that this change was done +illegally by Allan Lassarus - the attorney of Albert Nasser ( israeli citizen ) and Jeff Bereke office and Nick +Donovan. The attorney / Bruce Gottsman +, was introduce to me by the notary who notarize the +marriage certificate Gianluca Croce +ONLY NOW I can understand the way they have acted. ( They - Maxawell Kardedien family and martha +Borisus,and the sex trafficking ring) .)now after 15 years of suffering and filling all reports to save my +daugthers life and my son - who had paid in his health and was hospitalized few times during 2012 till now with +broken nose - and uncounses- retilliation of his father +The distress, the pain, the lost of life and +all those years who will compensate me and my children? +the corruption of the judges Goldstien from the family court in NEW YORK CITY and the Nassau court family +Judge Cipotolla - who foret me to leave the country in order to protect +from sexual abuse and +rom cruelty abuse for years. I just wonder where the money for the briabcome from ? I personally saw Jeff +Bereke going and talking with Cipoltolla - Nassau family court - to convince her to have a order against me in +2015 - just because I wanted to save +and I was waiting for him in the street knowing that he is being +abused brutally (I had reports from the health insurance that I paid or him ) +I have compliant and gave the name of my x husband - +long time ago +to court and the police and the FBI. ( since 2006) and indicated that this is sexual abuse and trafficing of me and +my children. I gave the attorney general in New York city - stating that there is a ring of Pedophiles. +Instead the Judge in Nassau - Cipotolla wanted to arrest me and take +so this woman( Maxawell) and +her partners will be able to use them while concealed the thief identity against me and the activity of human +trafficking. +I was looking for explanation how this is going so many years ? and I wrote to FOIA in 2014 to see if there is +another social security number that is being used by others under my name. The answer was negative and I +didn't get another social security number. Today after research and the aggregation of documents and fraud in +my New York state Id and all fraud in city -social services and health insurance files in the governmental offices +that done by others against me I have concluded that and now understand and believe that that somewhere in +the History of the united state ( new York) there is a report of a missing baby -I believe this baby is me. me.1 +believe that I was kidnapped /or missing ( taken by a family member to Israel). My memory in Israel is from +age 4. +I am the love child of two big Sicilan families and my mother is +- I believe I was born before +her marriage to +. I dont have my birth certificate but I am sure that my DNA will match to the ones +that the FBI and CIA has in the DNA bank and L am willing to prove it with forensic genetic test. +My parents are Sicilian and 1 am in +- from mother side and +from father side ( my father +- from +. I believe that the name that was given me at birth +I believe that +Maxwell Knew the connection - Israeli -Italian - Epstien and the money of my heritage /beneficiary of shares and +took the steps to control my life and to defraud the Authorities using my Identity • (Therefore Maxwell stated: its +not my money :. I understand that she enjoys a close relationship with Kardashian sisters who helped her to use +my identity ( and there are rumors of using my eggs for conceiving . (need to do DNA test I but I don't know if +that's is correct, need to check the las Vegas family court and all annulment filled +Land the jpo +not to move step daughter from the state, when I asked why the judge wrote this on the order and why the +annulment has the correction of the judge assistant on the decree " LCD " I got stupied answer that -she add her +letters on the annulment / and the children is a mistake in the order - I don't buy this explanation and I believe +that there is trafficking of children in this file. One of + + +I believe that when he died she wanted to clean all me from all my rights and therefore created the condition of +thief identity and change name This was taken speed after Epstien had died. The mind is Maxwell who has +personal knowledge of me. I never met her or any member of the kardashian and Jener sisters. ( This point need +to be checked in documents of the financial enterprise of this family,) +As you can learn from the documents - Every time they ( her group ) wanted to use or traffic one of my children - +they have created the" fake love condition "of marriage so they can move my children around with the help of +corrunted indue and corrupted police officer and corrupted attorney - Nick Donovan esq and Linda Donovan esq +tel +who I believe used my confidential information and personal relationship, all this years +facilitated Epstien and Maxwell financial transaction on my behalf without my knowledge or consent and to +have a bad report on my character to gain financial gain unlawfully in since 2008 and in 2015 court proceeding +Nassau Surrogate court , and currently prior to Maxwell arrest. He helped them to have conceal my Identity in +Social security and IRS. By doing so with the intention to keep his law office successful he took my funds and +diverted them to the wrong account including the receiving of child support payments from me as the custodian +parents ( +the case worker that open the compliance in tax offset unit is IRINA SVETNIKOVA +Land Alla Pirogovskaya +PAID 26.000 DOLLARS On January 8 2020 after losing +the appeal in first appellate division +). Since that payment all my financial and +banking were in irregulatory and fraud in the transaction. Everytime that I didn't a transaction it was +doublicated with a different account. I used to transfer money between my accounts because I had limited funds +and my limit debit card was 30 Odollar and my credit is secure up to 1500 dollar. after marriage to +and +around the end of January - February - they have empty my accounts. I had no money to buy food. +In 2010 I have filed with the family court in New York city petition to protect my daughter +2010)from her father sexual harassment. There was the interview with the DA in new york city +and +she referred us to Nassau where the intake and interview was don with an officer in Nassau without me present +and it was a male. No one continue with the process and judge Goldstien in Family court gave him Visitation- +"two hours on Sunday - Upper East side ) what kind of a judge wanted to incarcerate me the mother who +protecting her little daughter and send the kids back to the sexual and Physical abuse with the evidence that this +happened. since than i believe the sexual abuse of my children continue. My self was sexual harassment by +Nasser who told me : " that I am not paid because I don't let him feel like a man " he stole from me the building +I bought it for " Nasser Group " under the name Hilla Capital from Jhonatan +Schults tell +which was the receiver of Bank of America and leona Hemsely estate. I never got my +fee or my rights from him +. Just in December 2019 my daughter came home crying from her father home but didn't say a word and I have +a feeling that it was connected to the visit of Maxwell in my building at the same time. - I don't know who +Maxawell was meeting but I know that there is someone in my building . Also my mail was stolen from my +apartment ( letter to court las vegas and letter to bank with name change and copy of my passport to Safra Bank . +Constantly there is is stealing of my rent pavments from the building tenant account /and registration of transfer +of funds to the owner of my building on +( attached letter from the +attorney - I have asked to speak with the owner but they don't let me I wanted to check how my rights are +registered. (maybe I am not a tenant Maybe some ownership is under my name and that's why they steal the +money from the account ) +Regarding the Identity thief I would like to share my thoughts For years I am complaining that someone using +my identity. They have used my registration to +department of +private and commercial law (matricolla number +The Documents clearly show - my grandfther name +so closed tol +. Therefore the change of name was done from +- to +by +fraud. The change of name after my marriage to +(November 21,2019 ) was from +. My x husband +and his +accomplice in Las Vegas have done fraud on my papers in las Vegas county Clark and change it from +And I have saw irregularity in my banks immediately after Maxwell visit in my +building . Why they did it? after sawing the news I think I got it - She signed the name Jane Mechella on the last + + +purchase of home with LLC adhok and after visiting my building. Starting September 2019 ( when I met my x +husband +and till her arrest there was distribution of few Big Financial Transaction such as : Cory inccosmetics company purchase of Kylie jenner Kardashian control 6000,000 million, ( got from the news) Real +estate - Corcoran Group - had my Broker license working on project among new development - trump tower on +57 and, vodka license -scott Diskin ( again kardashian) agreements with Bar Refaeli and kkr ( kim and Robert - +) and finally Epstien estate - or +| I am keep looking and to myself very similar +to +as askenze jew origin in Germany can be spelled different in Hebrew its only one +spelling). I believe and base on my research and some input that I got from comments that my x husband blurte +that that a person sign on my documents for the purpose of transfer rights especially in the virgin island court +regarding the heritage and with the last distribution of Cory cosmetics 600 million take over control - and in +vodka deals of diskin scott (from long island) and real estate deals under corcoran group In all this both +Maxwell and Nick Donovan attorney and Jeff Berke attorney and his son Berke Facilitating the fraud and the +human trafficking of me and my children. There are few ways of human trafficking and I am a victim of +Espstien , +, Maxwell. I was told that the Kardasian sisters (kim and all the rest ) used my name +and funds to promote their businesses. I don't have documents to back this claim and therefore I am leaving this +to the law investigation and social services in LA. The account number in Bank of America is under my x +husband name +Additionally there is fraud in IRS tax reports. In 2008 my x husband +filled " joint tax return as +married to +I believe he did the green card application with her)in his +immigration file he filed IRS report At that time I was married to him . We got divorce in March 2009 - ( all +court documents and full transcript were filed with the appellate division first department +(especial attention for the +- who insiste to leave me without child support if I don't bring my +daugther to physically be sexual abu.And Strange at the same time Martha Bursiuos was appealing in the same +court asking for less of punishment - I saw here in December - coming after me to Chase Bank on 44 st-and 5 +av - I believe they have change the name +a. and as I have heard Maxawell +used the name Jane Mechella - when she purchase the new home in December 2019 - ( the new lIc) +I have never signed the affidavits for change name - As I have got the response from the court ( attached) with +that still someone in the clark court did the change and fraud my signature and with that changed my name as a +heir and beneficiary of the trust and also limited my children rights. +I have sent a letter to Safra Bank in Geneva and asked to see who moved the money to purchase the building +I have noticed that the affidavit with the letter from the ceo of the bank +to send a copy of my passport disappeared. I believe that Sara bank - legal department in Basel will be able to +show what happened and how Maxwell did the fraud and who is the attorney that helped her to notarize the +signature - is it the accountant Joram Rados from forest hill or Nick Donovan esq +_jor Michael +Rosenblaum +who is located in Florida and was the first mentor of mine and peter delman esq tel: +his past partner who mentor me as well and signed my immigration papers and Barry Silbergberg +) who was my immigration attorney in 2002-2009. Deborah kelly esq from Nassau was the +fiduciary attorney of my separation agreement. +Additionally, my companies : +1, I was filling as a +corporation. I was told by an accountant back in 2015 that there are different tax reports with my name. +Including the mentioned +was registered in florida +He (florida )20201 +,2006 - all need to be checked the financial reports since I believe the financial reports are different +from what I was filling . This is a thief Identity .Fraud in financial documents - IPO that I have done with Nick +Donovan esq for H& S equities which was owned by Serge Hoyda from Great Neck. the properties are located +in the lower east side of manhattan - with an offshore shell company in Cyprus - I believe Maxwell and another +woman - Michal from Miami - (who is known to be the madam of tiger wood )did fraud with the intention to +defraud my legal rights and monetary compensation. +I have been told that they are stealing the funds involved in this deal with the Kardashian family and that the +sisters are involved in using my name (I have been told that Khloe and Kendall had special interest in my +marriages and change of name ) to mention. i have never met any of them personally or had contact with them +,In this regards I have sent revocation to the attorney Gottman Bruce in order to eliminate damages while this is +being investigated + + +This group of individuals are including the business man Serge Hoyda and Yair Levi (all Israelis ) and Frank +Calabresse - I was working in each place 1 year or less at the years 2006-2009 . All were in a business +relationship with my x husband +For years I was trying to get my son out of their hands. I have no doubt that my son who had to go through a +liver transplant at the age of 25 was abused mentally physically and emotionally by this group. Rosario and +Morgan the magistrate where laughing in my face one time Morgan told my x husband " that he is getting 21 +and what will be with the money …/" They had a plan to make him entitled to disabilities - I never understood - +why a father would like the doctor to make him disabled - now I think that there was big sum of insurance +money and also pension and disabilities rights in the" other file " +I never knew why I am hitting walls when it so obvious that he is being extremely abuse. This +Maxawell woman wanted my son - and I am just wondering who was the one that was abusing him - my son +filed reports and the police told him that he will be in Jail if he reports. My son never talks anymore about this +and it is still going on. The person that sold my son was his father and the Averbuch and Maxawell. My +marriage to +made my son's situation even worse .. +(On another note the name kim Kardasien was mentioned by lorida julie who was tiger wood mistress and I +have wrote a book about in 2010 )as the one who is in competition with me over my name identity and children - +I thought its a joke !! now after the exit of 600,000 million in the cosmetic company Cory inc and the fraud in +my marriage and all the pregnancy surrogate I am not sure its a joke ). she mentioned horrible things +happening in the Island and including dead body of a girl that " had mask and was tied to a tree." She siad "that +the one from London was very mean and also the one from Miami ." also that the man " in the mention was +making her fucking black guys and he liked to wach it, she was young -high school student in ocean side long +Island) she also said that her friend Ashely Massarow (who died in 2019 - the wwe) got pregnant in high school +they both worked for Maxwell and Mechella from Miami Florida. +Moreover ,since I believe that in the social security there are two files. In 2014- 2015 I filed a complaint with +the social security in main office i new york city - nothing was done to protect me. The opposite, they didn't +believe me. I believe that in California ( where I was living with my ex husband +there is one file with +the name +and that woman pretanded to be me +In New +York - the file is +and that's me. In the Irs I am sure that the trust/ corporation connected to +the social security like +I have filed numerous complaints with the FBI in 2010 and in 2014 and in 2015. I have mailed the homeland +security to check if there is another person with my name. Now I understand that there is another social security +with a missing person and I dont know when the identification was made but it is wrong . +I would like to check the 2008 tax report to the IRS that my x +filed as married to +Maybe +used also the name / +) she worked in Brooklyn and I met me at corcoran later +socialized with me and I think it was just in order to use my identity -" all his wifes") and the daughter +I believe that in Israel there is a person that has the power, money and connection to organize this big scam. The +prime minister Netanyu is familiar with my case. He was having me and my Israeli father in his house for his +boy's birthday celebration in 2001. Sara Netanyahu knows my x husband L +( sometimes spelled +D personally and they met in New York with me in 2007-2006 .. Bib Netanyahu and his wife Sara +- know me personally . and I have been told that Sara Netanyahu was acting as my " girl friends " and I am sure +there is a report in the prime minister office about my identity and using BIBI cousin as my attorney was a big +mistake of my Israeli father who passed away in January 2009 from liver cancer. I have done the Israeli Army +and I am sure that there is a file of me . +Currently the most acute situation is that my brother is being extorted and placed in the hospital when the +COVID spread . I believe that the fraud action will continue in Israel were the doctors asking me to be a donor to +my brother +who is not my biological sibling and by doing the medical fraud actually will kill him with my +blood.- this is the final stage of the scam. + + +It is important to understand that my brother will die if Maxwell and +plan will succeed. If no one +believes me then by forcing me to donate bone Marrow to my Brother (who is not my biological brother ) and +forcing me to hide my origin and Identity my Brother will die because of a bad blood transplant. The doctors in +Israel gave me a letter stating that I am 100 mach as a sibling > ) They want to kill him for gaining financial +rights. I have approached the Israeli Police and my PCP and the cancer center in Mount Sinai. +In summary: +1. I am asking to file a complaint against Maxwell and her accomplices in this crime against me and my +family members. And would like to release my son from the holding of this group I would like to get my son +freedom from the brutal abuse and trafficking that was done against him by of his father ( +who donor in the liver operation -which I claim is a cover up to the brotality my son went at the time in his father +house and till now, and by others . +/ Maxwell ring and to disconnect any +transfer of his rights to anyone else including his human rights and liberty to be granted to him back by a court +order, return of all his rights that was violated all this time till and while I was married to the +(my 3 x +husband) Additionally I would like to get compensation for all the stealing of rights and monies from Epstien +and Maxawell actions .AND to stope all procedures in the virgin Island regarding the execution of the estate and +transfer the money to a trust. I would like to reserve my rights /heritage /beneficary in the estate and to reverse +any fraud on my legal rights as a victim of sexual trafficking by my husband and the sexual abuse of years of +myself, my daugthers and my Son +2. I would like to restore my original identity and to know what happened with my heritage and me when I was +a baby +3. I would like to know if there was a use of frozen eggs or and / Embrio and if there were children who were +conceived with the use of my eggs/ ivf. without my knowledge or consent or any legal rights. I have fraud in my +NYS health insurance and my policy has changed ID number three times since 2020. That's three different files. +I had hackers on my computers and emails and while i was in Israel from June 15-July 8, someone brook to the +place that I was in Isolation for 14 day (be Covide and I had to see my brother in the hospital ) and the used this +to do fraud in my account in Bank of America new york and IA. Account number and tax reports of the +company +tax was filed by my x +in the court in Los +Angeles +with +who used to continue with her relationship with him prior and after +marriage I believed she also used my identity in corporate papers and tax reports. +4. I believe that on the flight to Austria on January 10 202 and on the flight from London to New York on March +16 2020 , there was a "woman " who used my identity to transfer rights in Austria. +5. I would like that all the procedures in the virgin Island - Epstien estate will be held under scrutiny of the US +attorney general office in regards to my identity, proven DNA and Francis evidence of the bone and medical +records. +7. I would like to receive all marriage certificate and transfer of name and assets done by Gianluca Croc'e-esq +D who notarized our mariage certificate and mailed it to Italy Millano (not sure in Milano or +Roma), and the attorney Baruch Gottsman Esq who was referred to me by X husband +annulment, and for the transaction involving my rights and children rights including step daughter as mentioned +in the Vegas court order. +6. The Doctor Professor shimoni tel Hashomer +who is responsible in Israel +for the fraud of finding the mach of the Bone Marrow transplant between me and my brother which is basically +attempt to murder - knowingly that we are not biologic sibling and inflicting on me badly harm. My brother was +hospitalized on March 17 , 2020. ( with my return from Austria) He was not sick before . +7. I am reserving my rights of the US Constitution (it's not in court setting now ) to protect against self +incrimination in this correspondence and the Six amendment right to be presented by an attorney in any witness +situation and while being asked to provide any additional information / questions by government Authorities. +I am willing to answer any questions and provide any documents that I will be asked for by the USA attorney +office I would like that My son +be protect and moved to my house for me to take care of all his needs and +My brother in Isreal in +to be protected from wrongfull death + + +Thank you for taking the time to review and consider my email. +join in lawful wer +tate/Country of +of. +date of birth diff --git a/vision-fixhub/ds9-parsed-01/25c691060de39ab590a341543e0c98be4c4363a374802f40007599042ca02c1c.receipt.json b/vision-fixhub/ds9-parsed-01/25c691060de39ab590a341543e0c98be4c4363a374802f40007599042ca02c1c.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..e52d3364c01666b99c4378d634d150fb9e512f87 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/25c691060de39ab590a341543e0c98be4c4363a374802f40007599042ca02c1c.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -86, + "dataset": "marble-joined", + "doc_id": "25c691060de39ab590a341543e0c98be4c4363a374802f40007599042ca02c1c", + "engine": "marble-apple-vision", + "event_count": 8, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "798e99cf6bceec0668eed4ef36e5d2af2e1f12cfbc67929621400959236c3aac", + "output_sha256": "597f1cc641ce6d0c3a1702601ee5a25c0b4ba298d0da9503fdc583ac5d63527a", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/260250071859a8c48a3f8dee03863a6fa8680fabf0d6ac9d0365928bf3aaae85.md b/vision-fixhub/ds9-parsed-01/260250071859a8c48a3f8dee03863a6fa8680fabf0d6ac9d0365928bf3aaae85.md new file mode 100644 index 0000000000000000000000000000000000000000..3a147c4491216a4e5b141818df3a8662a91005bd --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/260250071859a8c48a3f8dee03863a6fa8680fabf0d6ac9d0365928bf3aaae85.md @@ -0,0 +1,12 @@ +From: +To: Sigrid McCawley +Ce: +Subject: bail +Date: Mon, 01 Mar 2021 18:10:40 +0000 +Hi Sigrid, +We wanted to let you know that Ghislaine Maxwell has submitted a third motion for bail. We currently anticipate that +this motion will be resolved on the papers, but we will let you know if a hearing is scheduled. +Best, +Assistant United States Attorney +Southern District of New York +New York, NY 10007 diff --git a/vision-fixhub/ds9-parsed-01/260250071859a8c48a3f8dee03863a6fa8680fabf0d6ac9d0365928bf3aaae85.receipt.json b/vision-fixhub/ds9-parsed-01/260250071859a8c48a3f8dee03863a6fa8680fabf0d6ac9d0365928bf3aaae85.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..8f4516c8efced4a06b58587ebca0f4ab0bef1702 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/260250071859a8c48a3f8dee03863a6fa8680fabf0d6ac9d0365928bf3aaae85.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "260250071859a8c48a3f8dee03863a6fa8680fabf0d6ac9d0365928bf3aaae85", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "fd42b21beaaa7368dcc6b7a7d113e09e863d6c751a34641234f1901dc2f8cbec", + "output_sha256": "7149c04e8516edaa0a296dfa65bbfe348ca91bdb0a110fe3aa97f3e1c794f7cf", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/262e0b8aa15a99d914aefe62cd3bd4aed94327fa08241bbe3c763e9871bdf2bd.md b/vision-fixhub/ds9-parsed-01/262e0b8aa15a99d914aefe62cd3bd4aed94327fa08241bbe3c763e9871bdf2bd.md new file mode 100644 index 0000000000000000000000000000000000000000..5292aef56fcb035b96574fccd258ee8bf5581e79 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/262e0b8aa15a99d914aefe62cd3bd4aed94327fa08241bbe3c763e9871bdf2bd.md @@ -0,0 +1,109 @@ +Service Request #24975 +Raid just crashed +9-2-41 +HAD +Customer: +FBOP MCC New York MS0109 (130104.001) +Contact: +Status: FBOP Assigned +Priority: +P3 (Next Day) +Type: +Service Contract +Assigned To: +Date Created: +Next Appt.: +Aug 8, 2019 +Service Location: Main Location +150 PARK ROW +NEW YORK, NY 10007 +Bill To: FBOP MCC New York MS0109 (130104.001) +150 PARK ROW +NEW YORK, NY 10007 +PO#: +Additional Information & Custom Fields: +Is this a emergency request: Yes. You must call 844-802-0188 +Is the system in question under +any warranty: +What is the system in question: +When was the problem first +discovered: +Today +PO Number: +Who reported the problem initally: +Is this a consistent problem or +intermittent: +CONSISTENT +Is this problem effecting all users: YES +Is there power to the device in +YES +question: +Do you have a spare device on +Unknown +site: +Can you send a picture of the NO +device: +Has any work been done in the +NO +area involved: +Can you describe what is or is not +happening: +Material Required For Request: +recording +PHONE SUPPORT +Who Requested the service call : +Detailed Description: +Raid is showing 2 "S"s on the display. +is going to get new drives from computer services for the raid and replace them in the morning. +Schedule + + +When +Aug 8 - 16, 2019, allday +Assigned To +Comment +will be working on this. Get a case started with Qognify. +Equipment - No Equipment +Comments +Comment +by +on Aug 14, 2019. 8:02 PM +(PRIVATE] +called us on Thursday August 8th stating that he had 2 bad drives on his raid unit of the NICE Vision Pro Unit NVR. We advised +him to get replacement drives. Once they are replaced they should start to initialize to become available for the raid array. +did not have +drives readily available. He checked with his local CSM to see if they had any spare replacement drives. Once he located replacement drives on +Friday August 9th, he did not have access to the DVR room to replace them. He called Signet for phone support on Saturday August 10th when +he gained access to the DVR room. He attempted to replace the drives and they started to rebuild. During the rebuild process of the drives, the +drives were required to be taken out of the raid on DVR 2. Once the drives are removed without proper shutdown of the recorder, the video +database becomes corrupted. Typically, any time the raid on a raid 5 configuration loses 2 drives, the raid needs to be rebuilt and all data is +wiped from the raid. +Comment +by +on Aug 8, 2019, 3:38 PM +[PRIVATE) +Unable to locate anything official. The basic steps are as following: 1. Set the raid level to none, and save. It will restarted with all drives +being "J." (Replace any faulty drives] 2. Set the raid level to 5 and save. It will restart and being an initialization. The password is 1111 (if I recall +correctly). Once the raid is created, you'll need to restart windows and create the proper partitions, I'll keep looking but that should get you going. +Best regards, +Senior Support Engineer (T) +I (M) +www.qognify.com +CUSTOMER SUPPORT CONTACTS USA Toll Free +1-866-8954607 USA +1-201-377-3408 UK +44-203-1501-393 UK Toll Free +44-800- +0488305 Israel +972-73-394-7900 France +33-170-70-0066 support@Qognify.com Germany +49-3419-288-035 Singapore +65-3163-3144 +India +91-117-1279-047 Hong Kong +852-5808-6118 China +86-10-5357-3270 From: +Sent: Tuesday, February 26, 2019 14:35 To: Support < Support@gognify.com> Subiect: RE: PRO UNIT RAID REBUILD DOCUMENTATION +REQUEST Anything you have on Pro Unit documentation would be appreciated +I Senior Customer Support Technician SigNet +Technologies | Convergint Federal Solutions 12300 Kiin Ct Suite E, Beltsville, MD 20705 Office: +| Mobile +Direct: +Assignment Created +by +on Aug 8, 2019, 3:36 PM +The assignment on Aug 8 - 16, all-day for Justin Houston, +[ [PRIVATEl +and +has been created. +will be working on this. Get a case started with Qognify. +Details - No Detail Items diff --git a/vision-fixhub/ds9-parsed-01/262e0b8aa15a99d914aefe62cd3bd4aed94327fa08241bbe3c763e9871bdf2bd.receipt.json b/vision-fixhub/ds9-parsed-01/262e0b8aa15a99d914aefe62cd3bd4aed94327fa08241bbe3c763e9871bdf2bd.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..16082049ffaa9c1da488d5dcbb82c1ace22c0b12 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/262e0b8aa15a99d914aefe62cd3bd4aed94327fa08241bbe3c763e9871bdf2bd.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -26, + "dataset": "marble-joined", + "doc_id": "262e0b8aa15a99d914aefe62cd3bd4aed94327fa08241bbe3c763e9871bdf2bd", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "af1e653c719642f4536c186a800157e67bbf75f687d23321a725142bfadd32f6", + "output_sha256": "70d64a54d26ea1800fa8bb58bd8294837289dcd57fd71c3964591e0f7abe9267", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2649897bfcc35a4e22a848d18469b2487231f923950cf556353cd47ea1137077.md b/vision-fixhub/ds9-parsed-01/2649897bfcc35a4e22a848d18469b2487231f923950cf556353cd47ea1137077.md new file mode 100644 index 0000000000000000000000000000000000000000..a54528c4871eeb075dbff4e7385709f914ec24db --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2649897bfcc35a4e22a848d18469b2487231f923950cf556353cd47ea1137077.md @@ -0,0 +1,68 @@ +From: +To: +Subject: +Date: +Attachments: +Epstein, Reg. No. 76318-054 +Saturday, August 10, 2019 6:14:05 PM +TEXT. htm +2019 OR 10 18 17 55 pdf +Фори +Psych Ops discontinued on 7/30/18 at 8:15 am +Associate Warden +MCC New York +150 Park Row +New York. NY 10007 +Componon heg + + +Epstein 76318-054 +7-30-19 +5:00 +am +5: am +iS am +S. +30 +am +5:42 +00 +bi am +6:15. +6:30 +6:45 +inmäte Epstein is sleeping +=JF6 +Inmate Epstein is cuake sitting on bed-JFG +immate epstein is seeping +Inmate fostein is skeping- +- Jf6 +inmate Cöstein is sleeping= +5f6 +Inmate epstein s seeping. +566 +incite töstein is sleeping +JfG +Inmate tostein b awake. +566 +inmete böstein is talking to me abet +sail life- +JFG +Fan +7:00 +cem +AM +7300 +inmate fipsten its cating breaktast- +End of shift +Start & new shit Richard MartiNer 277580502 +I Epstein is hapúng breakant Cereal andrick in +Sle kaling setting onlo +2/39/19 u M. → 1ar +7:30 AM +30 AM The If gire the Fi breakast the brow long R +7:45AM +F/m Epstein is setting down on his bed RM +315Am +Spatrin +Prr.h alanation is being disentand diff --git a/vision-fixhub/ds9-parsed-01/2649897bfcc35a4e22a848d18469b2487231f923950cf556353cd47ea1137077.receipt.json b/vision-fixhub/ds9-parsed-01/2649897bfcc35a4e22a848d18469b2487231f923950cf556353cd47ea1137077.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..c5fb7c74e2f27c4ea70b747d40676dcfdffbd9d9 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2649897bfcc35a4e22a848d18469b2487231f923950cf556353cd47ea1137077.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "2649897bfcc35a4e22a848d18469b2487231f923950cf556353cd47ea1137077", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "57cb3c929f6f96c17eb4bb59a9e38d65822a5ee3a34d753a58c55857f734ae01", + "output_sha256": "48a0a165a62ca793970c7268262c3761df79671597362c10ef060083b7f33c3a", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/26736b3ff93ba70d8bbf8976c0765759e436cd489c0bd345d7bddea073bb6a07.md b/vision-fixhub/ds9-parsed-01/26736b3ff93ba70d8bbf8976c0765759e436cd489c0bd345d7bddea073bb6a07.md new file mode 100644 index 0000000000000000000000000000000000000000..249121a8b8306b6562de02377a4a114a66e76a76 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/26736b3ff93ba70d8bbf8976c0765759e436cd489c0bd345d7bddea073bb6a07.md @@ -0,0 +1,47 @@ +Sent from my Verizon, Samsung Galaxy smartphone +Original message - +From: +Date: 8/1/19 9:24 AM (GMT-05:00) +To: +Subject: Re: Epstein +>>>' +Here are his notes. +, Psy.D. +Chief Psychologist +08/01/2019 09:24>>> +150 Park Row +New York, New York 10007 +Office: +Fax: +E-mail: +23> +NERO. Please I need this asap. +> 8/1/2019 9:10 AM >>> +Sent from my Verizon, Samsung Galaxy smartphone +• Original message -- +From: +Date: 8/1/19 7:47 AM (GMT-05:00) +To: +Subject: Re: Epstein +>>> +" 08/01/2019 07:47 >>> +For who? We need a HIPPA. +I, Psy. D. +Chief Psychologist +U.S. Department of Justice/ +Federal Bureau of Prisons +Metropolitan Correctional Center +150 Park Row +New York, New York 10007 +Office: +Fax: +E-mail: +> 7/31/2019 4:48 PM >>> + +SDNY_00009999 + +Dr. +Can you send me notes on Epstein on his suicide attempt. +Sent from my Verizon, Samsung Galaxy smartphone + +SDNY_00010000 \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/26736b3ff93ba70d8bbf8976c0765759e436cd489c0bd345d7bddea073bb6a07.receipt.json b/vision-fixhub/ds9-parsed-01/26736b3ff93ba70d8bbf8976c0765759e436cd489c0bd345d7bddea073bb6a07.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..3164c11aec7e379c324c7171b5fd484b6941f5e2 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/26736b3ff93ba70d8bbf8976c0765759e436cd489c0bd345d7bddea073bb6a07.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -57, + "dataset": "marble-joined", + "doc_id": "26736b3ff93ba70d8bbf8976c0765759e436cd489c0bd345d7bddea073bb6a07", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.stamp-stripping.confidential\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "976d9f99f27180c8d678479ea2cece3bd3188bb37b48a7d63d44437f6d6df4e3", + "output_sha256": "26f1e27c888e7b7a8eec202992bf17e73ec55751951454bdc55a6a04efe126cd", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2682681127d5ac068b118ae61f43b119fb1d6acce1381757aeb0759d0830a93c.md b/vision-fixhub/ds9-parsed-01/2682681127d5ac068b118ae61f43b119fb1d6acce1381757aeb0759d0830a93c.md new file mode 100644 index 0000000000000000000000000000000000000000..486600cb03eced8348a736d779bd34e65382f884 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2682681127d5ac068b118ae61f43b119fb1d6acce1381757aeb0759d0830a93c.md @@ -0,0 +1,58 @@ +From: +To: +Subject: +Date: +Attachments: +Justin Houston +[EXTERNAL] FW: IP submittals +Friday, October 1, 2021 1:57:37 PM +image001.jpg +image002.png +convergintfederallogorey1 189c4fc5-8f29-4ea7-9d0d-c27372e28fb4 png +MCC New York IP submittal.xisx +Email traffic for new gear. +Justin Houston +Program Manager FBOP Contracts +Convergint Federal | SigNet Technologies +12300 Kiln Ct Suite E, Beltsville, MD 20705 +This e-mail and any attachments to it are intended only for the identified recipients. It may contain proprietary or otherwise legally +protected information of SigNet Technologies, Inc d.b.a. Convergint Federal. Any unauthorized use or disclosure of this +communication is strictly prohibited. If you have received this communication in error, please notify the sender and delete or otherwise +destroy the e-mail and all attachments immediately. +From: Justin Houston < +Sent: Tuesday, November 27, 2018 9:43 AM +To: +Subject: RE: IP submittals +Hey +You will just need one IP address and one port for each device on the excel. +Justin Houston | Program Manager FBOP Contracts +SigNet Technologies | Convergint Federal Solutions +12300 Kiln Ct Suite E, Beltsville, MD 20705 +This e-mail and any attachments to it are intended only for the identified recipients. It may contain proprietary or otherwise legally +protected information of SigNet Technologies, Inc. Any unauthorized use or disclosure of this communication is strictly prohibited. If +you have received this communication in error, please notify the sender and delete or otherwise destroy the e-mail and all +attachments immediately. +From: +[mailto: +Sent: Tuesday, November 27, 2018 5:53 AM +To: Justin Houston < +Subject: Re: IP submittals +How man ports do you need with IP addresses ? +H.Daniel +Communication Technician + + +US Department of Justice +MCC-New York +150 Park Row +New York, NY 10007-1704 +>> > Justin Houston < +> 11/1/2018 2:21 PM >>> +Can you please send this over to computer services for the IP submittals. I will need this in order to move +forward with programing the AMS server. +Thanks +Justin Houston +Program Manager FBOP Contracts +SigNet Technologies +12300 Kiln Ct Suite E +Beltsville, MD 20705 diff --git a/vision-fixhub/ds9-parsed-01/2682681127d5ac068b118ae61f43b119fb1d6acce1381757aeb0759d0830a93c.receipt.json b/vision-fixhub/ds9-parsed-01/2682681127d5ac068b118ae61f43b119fb1d6acce1381757aeb0759d0830a93c.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..514eca6134cc34d97d94d965493b64d60c6e3332 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2682681127d5ac068b118ae61f43b119fb1d6acce1381757aeb0759d0830a93c.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "2682681127d5ac068b118ae61f43b119fb1d6acce1381757aeb0759d0830a93c", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "be67c6ff4d152cc67bff69022c88a63aae9d011f094e966334c0bd10022b4829", + "output_sha256": "208847a9e833168b15f948019ca67a50a3a94fab9604f0696e46ac981c4e6d9c", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/26a98b75eb76228610dc223094756b7fa0ac6c9deb130d93ce3ca160ec9b7595.md b/vision-fixhub/ds9-parsed-01/26a98b75eb76228610dc223094756b7fa0ac6c9deb130d93ce3ca160ec9b7595.md new file mode 100644 index 0000000000000000000000000000000000000000..8f8778df2296abfe0b51ac26daaa4535e01ce191 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/26a98b75eb76228610dc223094756b7fa0ac6c9deb130d93ce3ca160ec9b7595.md @@ -0,0 +1,1797 @@ +From: +To +Subject: TEXTERNAL EMAIL] - FBI Public Affairs News Brieling Priday, November 13, 2020 +Importance: Normal +Priority: Normal +Sensitivity: None +Mobile version and searchable archives available at fbi.bulletinintelligence.com + +TO: THE DIRECTOR AND SENIOR STAFF +DATE: FRIDAY, NOVEMBER 13, 2020 6:30 AM EST +TODAY'S TABLE OF CONTENTS +Leading the News +• Agencies, Cybersecurity Experts Say Election Was Most Secure In US History. +Protests +• Attorneys Seek Bond Release For Accused In Arbery Case. +Counter-Terrorism +• Utah Man Pleads Guilty To Impersonating ISIS Leader In Attack Plot. +• FBI Analyst: Pittsburgh Is A "Hub" For White Supremacy. +• Massachusetts Man On Trial For Allegedly Trying To Firebomb Jewish Elder Care Facility. +• Accomplice Testifies Against Reputed Militia Leader In Minnesota Mosque Bombing Trial. +• Georgia Man Charged In 9/11 Bomb Threat. +• IS Claims Responsibility For Attack At Saudi WWI Ceremony. +• Iran Arrests Arab Separatist Leader Suspected To Be Behind 2018 Attack +• Gunman Opens Fire On Saudi Embassy In The Netherlands. +Counter-Intelligence +• "Growing Number" Of GOP Senators Call For Biden To Receive PDB. +• In Recording, Facebook CEO Defends Decision Not To Suspend Bannon. +• Opinion: "Stolen Election" Rhetoric Could Unleash Wave Of Violence. +• Wisconsin Official Says There Still Isn't Evidence Of Election Fraud. +• Former Ohio State Researcher Pleads Guilty To Lying About Chinese Ties. +• Cleveland Clinic Physician Charged With Taking Research To China. +• Chinese Professor Accused Of Stealing Trade Secrets For Huawei To Plead Guilty. +• House And Senate Poised To Extend Trump-Era Investigations. +• CNN: Internal White House Debate Over Fate Of Haspel +• Independent Investigation Finds Bonanza Media Is A Russian Disinformation Project. +• UC Global Spied On Assange For Ecuadorian Intelligence, Says Ex Manager. +Criminal Investigations +• US Charges South Carolina Inmate With Trying To Hire Hitman To Kill Prosecutor. +• Documents Show Alleged Whitmer Kidnapping Plot Ringleader Planned To Take Hostages At Capitol +Building. +• FBI Arrests California Man For Hate Crime Attack On Restaurant. +• Alaska Man Arrested With Large Amounts Of Drugs. +• Another Defendant Pleads Guilty In New Jersey Drug Trafficking Case. +• US Charges Four In Missouri Murder-For-Hire Plot. + + +• Pennsylvania Woman Gets 13 Months In Prison For Drug Trafficking. +• Marijuana-Related Search Warrant Operation Conducted In Arizona. +• FBI Ärrests Woman In Connection To Bank Robberies In Utah, Arizona. +• FBI Investigating Minnesota Robbery. +• North Carolina Jury Convicts Foreign National Of Sexual Abuse. +• Continuing Coverage: FBI Investigating Disappearance Of Missing Colorado Woman. +• FBI Search Colorado Home In Connection To 2016 Disappearance. +• New York Sex Offender Charged With Child Pornography Possession. +• Iowa Man Sentenced For Child Pornography. +Financial Crime & Corporate Scandals +• Attorney For Cincinnati Councilman Charged In Bribery Scheme To Hold Press Conference Today. +• US Arrests Nine Californians On Money Laundering Charges. +• US Charges California Man With Wire Fraud, Identity Theft. +• Former Philadelphia Officials, Contractor's Employee Charged With Embezzlement. +• Plea Hearing For Ex-Michigan Prosecutor Moved Again Due To Coronavirus. +• New Hampshire Attorney Pleads Guilty To Money Laundering, Wire Fraud. +Cyber Division +• Two DHS Officials Reportedly "Forced To Resign"; Krebs "Expects To Be Fired." +• Commerce Department Will Delay Enforcement Of TikTok Shutdown Order. +• Israeli Cybersecurity Firm Finds New Type Of Iranian Ransomware. +• Finland Prepares Change To Code Law After Hacking Case. +• NSA Grant To Help Two Indiana Campuses Expand Cybersecurity Programs. +Law Enforcement Services +• Springfield, Massachusetts Police Department Assigns Officer To FBI Gun Violence Task Force. +• WPost: Voters Usher In "New Phase Of Drug Policy." +Other FBI News +• DOJ Report: Acosta Engaged In No Misconduct When He Agreed To Epstein Plea Deal. +• Ramsey Tapped As New Portland, Oregon SAC. +Other Washington News +• Media Analyses: Trump Silent On Pandemic, "Largely Out Of Sight," As Election Challenges Continue. +• Agreement Reached With Pharmacies To Provide Free COVID Vaccinations. +• Fauci Says Working With Administration Has Been "Stressful." +• Fauci: Lockdown Can Be Avoided. +• Birx Urges Tighter Restrictions, Guidance Adherence. +• US COVID Infections Topped 150K Thursday; States See Surge In Hospitalizations. +• California Cities Reimpose Restrictions As State Reaches Millionth COVID Case. +• Upper Midwest, Plains States See COVID Cases Rising. +• Chicago Mayor Issues Stay-At-Home Advisory. +• NYC Schools Seen As Likely To Close Again Amid Resurgence Of COVID. +• Health Officials Encouraging Extra COVID Precautions For Holidays. +• Clinical Laboratories Warn COVID Testing May Be Delayed +• Lewandowski Tests Positive For COVID. +• Ivanka Trump, Kushner Withdrew Children From School After White House Outbreak. +• Alaska Congressman Tests Positive For COVID. +• WSJournal: Delaware COVID Settlement Allows Churches To Be Treated Neutrally. +• WSJournal: Biden's COVID Team Would Push For Lockdowns. +• Administration Leaving Stimulus Talks To McConnell As Pelosi, Schumer Signal No Compromise. +• Federal Judge Schedules Conference On Trump Defamation Suit. +• At Least Four Dead As Eta Moves Through Southeast. +• Appeals Court Upholds Harvard Affirmative Action Ruling. +• Deputy AG Rosen Reportedly Blocked Charges Against Zinke. +International News +• Chinese Government Stopping Taiwan's Participation In WHO Meeting. +• Prime Minister Says Japan Does Not Need To Declare COVID State Of Emergency. + + +• Germany, France See Slowing Of COVID Cases, But Hospitals Remain Crowded. +• South Africa Opens To Foreign Visitors. +• US Allies In Iraq Said To Fear Targeting By Iran. +• NY Times Analysis: Syrian Refugees Resist Return Under Current Leadership. +• NYTimes Analysis: Afghan Officials Do Not Expect Biden To Stop Trump's Troop Withdrawal. +• Five Americans, Two Others Killed In Crash Of Peacekeeping Force Helicopter In Sinai. +• Pompeo To Visit Golan Heights, West Bank Israeli Settlement. +• Wolf Planning To Visit Several Latin American Countries In Early December. +• Russian Military Operations Off Coast Of Alaska Impact Private US Ships. +• Hong Kong Legislature Opens Without Pro-Democracy Lawmakers. +• EU Plans Pro-LGBTQ Policies In Response To Hungary And Poland. +• Researchers Conclude World "Already Past A Point Of No Return For Global Warming." +• NYTimes Analysis: Nobel Peace Prize Repeatedly Awarded To Dubious Winners. +The Big Picture +• Headlines From Today's Front Pages. +Washington's Schedule +• Today's Events In Washington. +Leading the News +Agencies, Cybersecurity Experts Say Election Was Most Secure In US History. +The AP (11/12, Tucker, Bajak) reports, "A coalition of federal and state officials +said Thursday that they have no evidence that votes were compromised or altered in last week's presidential +election." Their comments reject "unsubstantiated claims of widespread fraud advanced by President Donald +Trump and many of his supporters." A statement distributed by a group led by CISA said, "While we know there +are many unfounded claims and opportunities for misinformation about the process of our elections, we can +assure you we have the utmost confidence in the security and integrity of our elections, and you should too." The +statement added, "When you have questions, turn to elections officials as trusted voices as they administer +elections." It "echoed repeated assertions by election experts and state officials over the last week that the +election unfolded smoothly without broad irregularities." +USA Today (11/12, Johnson, 10.31M) reports that the group of +agencies, which included the National Association of State Election Directors, "issued what appeared to be a +definitive coda to the 2020 vote." The statement "offered a decidedly different message than that delivered last +month" by DNI Ratcliffe, "who abruptly announced that that voter registration information had been obtained by +Iran and Russia in an attempt to undermine confidence in the 2020 election." Ratcliffe also "said that Russia has +obtained voter information just as the Kremlin had done in when it interfered in the 2016 election." +The New York Times (11/12, Sanger, Stevens, +Perroth, 18.61M) reports that the statement came "directly from one of Mr. Trump's own cabinet agencies." It +"also came as a previously unified Republican Party showed signs of cracking on the question of whether to +keep backing the president." Senate Republicans have "insisted that Mr. Biden should at least be given access to +the President's Daily Brief," their call amounting "to an acknowledgment that Mr. Biden will be declared the +victor in the election." Sen. Roy Blunt (R-MO) said, "I think they do need to know some things, and national +security would be one of them." +The Washington Post (11/12, Itkowitz, 14.2M) reports that the statement from security agencies "comes on the heels of +reporting earlier in the day by Reuters that Christopher Krebs, the head of the CISA, expected to be fired over his + + +efforts to debunk misinformation about voting fraud." Krebs has "retweeted an election law expert who called +out Trump for spreading misinformation." Center for Election Innovation & Research Executive Director David +Becker wrote, "Please don't retweet wild and baseless claims about voting machines, even if they're made by the +president. These fantasies have been debunked many times." +Axios +(11/12, Chen, 521K) reports that the Election Infrastructure Government Coordinating Council (GCC) Executive +Committee wrote, 'There is no evidence that any voting system deleted or lost votes, changed votes or was in +any way compromised." The statement "acknowledged 'opportunities for misinformation' and urged voters to +seek out election officials as 'trusted voices."" +Reuters (11/12) reports, "The groups, the Election Infrastructure +Government Coordinating Council Executive Committee (GCC) and the Election Infrastructure Sector +Coordinating Council (SCC), said the election was the most secure in U.S. history." CISA's "Rumor Control" +website "debunks misinformation about the election," and CISA Director Krebs "has told associates he expects +to be fired, sources familiar with the matter told Reuters." +The Washington Times (11/12, Lovelace, 492K) reports that among the parties issuing the statement are +"members such as CISA assistant director Bob Kolasky, U.S. Election Assistance Commission chair Benjamin +Hovland, and National Association of Secretaries of State president Maggie Toulouse Oliver, among several +others." +Also reporting are NBC News (11/12, 6.14M), the Daily Beast + and 2 ), Bloomberg (11/13, Sebenius, 4.73M), Axios + (11/12, 521K), NPR (11/12, +Wise, 3.12M), Federal Computer Week (11/12, 263K), and Newsweek (11/12, Grzeszczak, 1.53M). +Protests +Attorneys Seek Bond Release For Accused In Arbery Case. +On ABC World News Tonight + (11/12, story 7, +1:30, Muir, 6.57M), Adrienne Banker reported, "Tonight, attorneys for two of the men accused of murdering +Ahmaud Arbery seeking the release of the father and son on bond." Greg and Travis McMichael were "seen +chasing Arbery before Travis fatally shot the 25-year-old after spotting him running in their Brunswick, Georgia +neighborhood, in what they told police as an attempted citizen's arrest of a suspected burglar." Travis +McMichael's friends testified "that he is remorseful," with attorneys "citing his service in the Coast Guard" and +"saying this was no hate crime." Travis McMichael's attorney, Bob Rubin, said, "We have substantial evidence + + +that on the day in question, Mr. Arbery was not a jogger. He was there for nefarious purposes." The attorneys +"are asking the judge to reject the indictments" malice murder charge...saying it was written in such a way that it +actually charges two crimes in one count." The hearing resumes on Friday morning. +Counter-Terrorism +Utah Man Pleads Guilty To Impersonating ISIS Leader In Attack Plot. +The Salt Lake (UT) Tribune < https://www.sltrib.com/news/2020/11/12/utah-man-pleads-guilty/>(11/12, Pierce, +224K) reports, "A Utah man arrested in August 2019 has pleaded guilty to trying to help the Islamic State +terrorist organization carry out bomb attacks." Murat Suljovic, 23, of Salt Lake City, "pleaded guilty in U.S. +District Court to one count of attempting to provide material support to a designated foreign terrorist +organization. According to court documents, Suljovic admitted that in January 2019, while he was living in Utah, +he corresponded with two people he believed were members of the Islamic State, also known as ISIS, and that he +believed they were planning to carry out an attack. The two people were members of the FBI's Joint Terrorism +Task Force." +KUTV-TV Salt Lake City (11/12, Gardiner) reports, +"Documents state Suljovic provided advice about potential targets for a terrorist attack on how to plan an attack. +He also provided a bomb-making tutorial video to one individual who was then supposed to share it with another +person to be trained in carrying out an attack. By providing the bomb-making tutorial video, Suljovic admitted +he knowingly attempted to provide material support to ISIS, knowing that ISIS has engaged and does engage in +terrorism. Suljovic was charged with providing material support to a designated foreign terrorist organization in +a Felony Information filed in May. As part of his plea deal, Suljovic agreed to forfeit computer and electronic +equipment used to facilitate his criminal conduct or acquired from his conduct." +FBI Analyst: Pittsburgh Is A "Hub" For White Supremacy. +The Pittsburgh Post-Gazette (11/12, +Ove, 616K) reports, "Pittsburgh is a focal point for white supremacy and extremists, an FBI analyst said +Thursday at a symposium on domestic terrorism. 'Our area has become a hub. It's important to understand that it +is here,' said John Pulcastro, a supervisory analyst at the Pittsburgh FBI. In fact, he said the movement is as +strong here as any other place in the country he has studied in 20 years, including the Pacific Northwest, a hotbed +for supremacists." The Post-Gazette adds, "Extremist groups are active here in holding events and recruiting. As +an example, he said 100 members of a neo-Nazi group called the Patriot Front marched down the Boulevard of +the Allies on the weekend. Their motto, 'Conquer or Die,' makes their ideology clear, he said. Another catch- + + +phrase, 'Blood and Soil,' is aimed at making America a white country only, with refugees seen as invaders, Mr. +Pulcastro said." +Massachusetts Man On Trial For Allegedly Trying To Firebomb Jewish Elder Care Facility. +The Springfield (MA) Republican +(11/12, Barry, 395K) reports from Springfield, Massachusetts, "The plan was "simple, speedy and dangerous,' a +federal prosecutor said of John Rathbun's alleged attempt to set off a crudely made firebomb at a Jewish elder +care complex." According to the Republican, "Police and fire officials on the morning of April 2 found a +partially filled yellow gas container with a charred Christian church pamphlet in its spout. It was perched near a +tree on Converse Street in Longmeadow, just outside the campus, when the Longmeadow Fire Department +responded to a call for a 'suspicious package.' A grand jury indicted Rathbun, 36, of East Longmeadow, on two +charges connected to placing an explosive device to cause harm and destruction, plus lying to FBI agents. His +trial began Thursday in U.S. District Court in Springfield." +Accomplice Testifies Against Reputed Militia Leader In Minnesota Mosque Bombing Trial. +The Minneapolis Star Tribune (11/12, Mannix, 1.04M) reports, "The three men drove +through the night in a rented pickup truck with a bag full of automatic rifles in the back seat, and after 10 hours +on the road Michael Hari revealed the objective of their trip. 'We're going to go to Minnesota and we're going to +bomb a mosque,' Hari told them, according to Michael McWhorter's testimony in St. Paul's federal courthouse +on Thursday morning. It was about 4 a.m. on Aug. 5, 2017, and the three men were an hour away from Dar Al- +Farooq Islamic Center in Bloomington." McWhorter, "one of the passengers in the truck, is a star witness for the +prosecution in the domestic terrorism trial of Hari, which began Monday. McWhorter pleaded guilty in January +2019 to two federal charges related to the bombing of the mosque." +Georgia Man Charged In 9/11 Bomb Threat. +WTOC-TV Savannah, +GA (11/12, Bauman, 22K) reports from Savannah, Georgia, "A Vidalia man is facing charges after investigators +say he called in a bomb threat to a building at the Port of Savannah." Elliot Sherman, 32, "is charged with +Explosive Materials-Willfully Making a Threat. The indictment reports that Sherman is accused of calling the +California Cartage CFS 2 building on September 11. Sherman was assigned to the facility by his employer. +"Calling in a bomb threat, even as a hoax, wastes resources, disrupts commerce and terrifies potential threatened +victims, said Chris Hacker, Special Agent in Charge of FBI Atlanta. 'That's why the FBI takes them seriously +and the penalties are severe. +WTGS-TV Savannah, GA (11/12, Papadimas) reports from Savannah, "U.S Attorney for the Southern +District of Georgia, Bobby Christine, said the charge carries a possible penalty of up to 10 years in prison, +substantial penalties and a supervised release period. 'Bomb threats, whether real or hoax, are dangerous and +disruptive to work environments,' said U.S. Attorney Christine. 'This one was especially inexcusable as it was +made on the anniversary of the Sept. 11, 2001 terrorist attacks.'" WTGS-TV adds, "According to the indictment, +the DOJ said Sherman is accused of calling a bomb threat to the California Cartage CFS 2 building on Sept. 11, +2020. Officials said Sherman is assigned to the building by his employer." + + +IS Claims Responsibility For Attack At Saudi WWI Ceremony. +The AP (11/12) reports, "The Islamic State group claimed responsibility on Thursday for the explosion +the previous day at a cemetery in Saudi Arabia." IS "primarily targeted French diplomats attending the ceremony +in remembrance of the end of World War I." The attack in Jiddah "wounded three people, leaving them with light +to minor injuries." The terrorist group "primarily targeted the French consul attending the ceremony because of +his country's publication of caricatures of the Prophet Muhammad." IS's news agency, Aamaq, "said other +European countries at the ceremony were also considered targets because they are part of the international +coalition fighting Islamic State militants." +Iran Arrests Arab Separatist Leader Suspected To Be Behind 2018 Attack. +Reuters (11/12) reports, "Iran's intelligence ministry has arrested an +Iranian ethnic Arab separatist leader suspected of involvement" in a 2018 terrorist attack, according to state +television. The Ahvaz National Resistance "claimed responsibility for the attack that killed 25 people, almost +half of them members of Iran's elite Revolutionary Guards." Iranian state TV said, "Farajollah Chaab, the leader +of the separatist group, has been arrested by Iran's intelligence ministry agents." The report added, "Chaab has +planned several other major attacks in Tehran and Khuzestan province in recent years...he has recently been +planning to launch a new terrorist operation that failed with the efforts of the intelligence ministry agents." +Gunman Opens Fire On Saudi Embassy In The Netherlands. +The New York Times +(11/12, Erdbrink, 18.61M) reports that according to local police officials, at least one gunman opened fire at the +Saudi Embassy in The Hague, Netherlands at 6 a.m. on Thursday. No injuries were sustained in the "rare +attack...and it was not immediately clear whether the shooting was related to" the attack on a World War I +commemoration attended by European officials in Saudi Arabia the day prior. The Times says that Dutch Prime +Minister Mark Rutte "has voiced strong support for France in the aftermath of the beheading of a teacher by an +Islamist extremist," setting the two countries "apart from the United States and other Western democracies" and +stoking "anger in Muslim countries." +The Wall Street Journal (11/12, story 3, +2:55, Muir, 6.57M), Muir said a "growing number of Republican senators.. say it's time to start giving [Biden] + + +the intelligence briefings incoming presidents get to keep this country safe." ABC's Jonathan Karl: "There are +signs tonight Republican support for the President's give-no-ground posture is crumbling. While most +Republican senators have yet to acknowledge have yet to concede Joe Biden won the election, a growing number +are now saying it's time for Biden to receive the classified intelligence briefings normally given to a presidentelect." Sen. James Lankford (R-OK): "If that's not occurring by Friday, I will step in as well to be able to push +and to say this needs to occur so that regardless of the outcome of the election, whichever way that it goes, +people can be ready for that actual task." Karl: "All told, at least 10 Republican senators, including Trump +loyalist Lindsey Graham, said it's time for Biden to get those intel briefings." +Tracy reported on the CBS Evening News + (11/12, story 4, +0:25, Holt, 4.9M), Jackson similarly said Trump's "red wall of Republican support is showing some cracks. +More GOP lawmakers now say [Biden] should get access to classified information, briefings being blocked right +now by the Trump Administration." +The AP (11/11, Riechmann) reports Trump is not allowing Biden access to the +President's Daily Brief, the "ultra-secret daily brief of the nation's most sensitive intelligence," and "national +security and intelligence experts hope Trump changes his mind, citing the need for an incoming president to be +fully prepared to confront any national security issues on Day One." Politico + +(11/12, Levine, Desiderio, 4.29M) reports Lankford "noted that in 2000, then-President Bill Clinton allowed +George W. Bush to begin receiving presidential-level intelligence briefings during the recount in Florida." +According to Politico, Lankford "added that he plans to question the government agency responsible for jumpstarting the transition process if a certification is not made by Friday." The New York Daily News + (11/12, McAuliff, Sommerfeldt, 2.52M) reports Sen. John +Cornyn (R-TX) "echoed Lankford in saying that the president should break the logjam and allow Biden access to +national security briefings since he might "win in the end.'" +USA Today (11/12, King, 10.31M) reports "prominent and powerful +Republicans are signaling that Joe Biden should be treated as the next president," with senators saying "they see +no issue with Biden receiving the same daily intelligence briefings Trump is getting." Sen. Charles Grassley (R- +IA) "said he had 'no problem' letting Biden have access to the briefings," and several others, "including some of +the president's most ardent allies" like Graham and Sen. Josh Hawley (R-MO), "quickly followed suit." CNN + (11/12, Raju, Barrett, +83.16M) reports Acting SSCI Chair Marco Rubio (R-FL) said, "You don't lose any of your rights in court by +making available to a potential successor the information they would need if in fact it goes in that direction. In +all those domestic issues, you might have a few weeks or months. But on national security, our adversaries don't +wait for presidents to catch up." The New York Times (11/12, Sanger, Stevens, Perroth, 18.61M) quotes Sen. Roy Blunt (R-MO) as saying, "I don't think they +need to know everything. I think they do need to know some things, and national security would be one of +them." The Hill (11/12, Carney, 2.98M) reports that Sen. Mitt Romney (R-UT) said, "I think it is very +much in our national interest to have the president-elect receiving information." +The Washington Post (11/12, Sonmez, DeBonis, 14.2M) +also reports that "an increasing number of Senate Republicans" say Biden "should be granted access to classified +briefings during the presidential transition, an acknowledgment of the election results despite President Trump's +insistence that he will win." Senate Majority Whip Thune told CNN. "I think that it probably makes sense to +prepare for all contingencies. And as these election challenges play out in court, I don't have a problem with, and +I think it's important from a national security standpoint, continuity." +Asked on Fox News' Fox and Friends First (11/12, 483K) about whether the Administration is considering giving Biden access +to the President's Daily Brief, McEnany said, "All laws are being followed with regard to an expected transition, +though we expect to continue on as the Trump Administration. We will see how our litigation goes." +CBS News (11/12, +Quinn, 3.68M) reports that ODNI "said earlier this week it would not have contact with Mr. Biden's transition +team until notified by the head of the GSA, who ascertains the likely successful candidate in the election. But the +administrator of the GSA, Emily Murphy, has not yet determined Mr. Biden as the apparent next president, +leaving in limbo millions of federal dollars to support the transition, government resources and Mr. Biden's +access to high-level intelligence briefings." Still, Biden "has received lower-level intelligence briefings since +formally becoming the Democratic nominee in August." +However, ABC News (11/12, Bruggeman, 2.97M) reports that "experts said the intelligence +community is not beholden to the GSA 'ascertainment.' David Priess, a former intelligence briefer and author of +"The President's Book of Secrets: The Untold Story of Intelligence Briefings to America's Presidents,' said +briefings could begin "independent of the GSA decision' at the direction of the Director of National intelligence +or, of course, the president.'" Priess added, "The Presidential Transition Act of 1963 and its updates do not +mention the President's Daily Brief (PDB) or intelligence briefings for the president-elect. The custom of +allowing the president-elect to see the PDB is just that — a custom — and it's something the president can do, or +refuse to do, at his discretion." +Meanwhile, Politico (11/12, Bertrand, 4.29M) reports that "a group of more than 150 former national security officials who +served under [Trump] and other Republican and Democratic administrations is warning that the government's +delay in recognizing" Biden's victory "poses a 'serious risk to national security."" +Also reporting on the PDB issue are Axios (11/12, Arias, 521K), the Wall Street Journal + +(11/12, Peterson, Wise, Subscription Publication, 7.57M), Bloomberg + +(11/12, Cornwell, Chiacu, Lewis), the Washington Times + +(11/12, Sherfinski, Meier, 492K), and NPR +(11/12, Grisales, 3.12M), among others. +Meanwhile, according to the New York Times +(11/12, Sanger, Stevens, Perroth, 18.61M), "Deprived of access to secure government communications by the +Trump administration, Mr. Biden's team of more than 500 former officials and outside experts has embraced +workarounds, talking over encrypted apps like Signal to shield their conversations from the Chinese, meeting in +outdoor coffee shops with government officials they once worked alongside." The Times adds, The +conversations are circumspect, both because of rules on both sides limiting how much information Mr. Biden's + + +team can seek and how much executive branch officials are allowed to say." +In Recording, Facebook CEO Defends Decision Not To Suspend Bannon. +Reuters (11/12, Paul) reports Facebook CEO Mark +Zuckerberg "told an all-staff meeting on Thursday that former Trump White House adviser Steve Bannon had +not violated enough of the company's policies to justify his suspension when he urged beheading" Fauci and FBI +Director Wray, "according to a recording heard by Reuters." Zuckerberg said, "We have specific rules around +how many times you need to violate certain policies before we will deactivate your account completely. ... While +the offenses here, I think, came close to crossing that line, they clearly did not cross the line." Facebook +"removed the video but left up Bannon's page," while Twitter "banned Bannon last week over the same content." +BuzzFeed News (11/12, Mac, Silverman) reports, "Facebook CEO Mark Zuckerberg told employees on Thursday +that the Democratic nominee 'is going to be our next president."" Zuckerberg added, 'It's important that people +have confidence that the election was fundamentally fair, and that goes for the tens of millions of people that +voted for Trump." The CEO's comments "signify that he believes in the legitimacy of the result," and criticized +"people claiming that a Biden victory would be overturned." Zuckerberg said "it's...quite unhelpful that people +out there are raising expectations that there is going to be a different outcome than from what was projected." +Opinion: "Stolen Election" Rhetoric Could Unleash Wave Of Violence. +Albert Hunt, former executive editor of Bloomberg News, writes in an op-ed in The Hill + +(11/12, 2.98M) that white power expert Kathleen Belew "fears Donald Trump's refusal to accept the election +results may be inciting violence." The claim "that the presidential election was 'stolen' will likely become a +rallying cry for the Trump base." Belew, a history professor at the University of Chicago, "dismisses the notion +that this often is a 'lone wolf" problem." She told Hunt, "These militant fringe groups are much more directly +connected than is appreciated... They share a lot of ideas." FBI Director Wray "has said these white power +groups are a greater danger than the left-wing anarchists oft cited by President Trump and Attorney General +William Barr." Hunt concludes the claims of a "stolen election" not only undermine "confidence in our +Democratic system, but.….could also threaten to unleash a dangerous wave of violence." +Wisconsin Official Says There Still Isn't Evidence Of Election Fraud. +The Washington Post (11/12, Bauer, 14.2M) +reports, "There remained no evidence of any wrongdoing, fraud or irregularity in Wisconsin's presidential +election on Thursday," according to officials. Counties in the state are working "to wrap up the certification of +their votes and their estimates of how much it would cost to recount them." Wisconsin's top elections official, +Meagan Wolfe, said, "It's rare to see any sort of significant changes." She added, "There's always minor errors. +... We're certainly not seeing anything unusual." Discussing why the process may look different this year, Wolfe +cited the "counting of provisional ballots that came in after Election Day." +Former Ohio State Researcher Pleads Guilty To Lying About Chinese Ties. + + +Ohio State University - The Lantern (11/12) reports, "A former Ohio State researcher and +professor pleaded guilty in federal court Thursday for making false claims to federal authorities as part of an +investigation into his ties to China." Song Guo Zheng "was charged in July for using more than $4.1 million in +federal grants to funnel research back to China to help the country develop expertise in rheumatology and +immunology. He was also charged with making false statements about being employed in China at the same time +as he was employed at U.S. universities, including Ohio State, according to a press release from the U.S. +Southern District of Ohio Attorney General's Office." +Cleveland Clinic Physician Charged With Taking Research To China. +WEWS-TV Cleveland (11/12) reports, "An FBI +investigation into a former Cleveland Clinic doctor's ties to China includes a Chinese government program that +allegedly recruits professionals with access to foreign technology and intellectual property. 'We're opening up a +brand-new investigation every day,' says Cleveland FBI Special Agent in Charge Eric Smith." Dr. Qing Wang +"was arrested last May after the FBI filed a probable cause affidavit charging him with false claims and wire +fraud related to $3 million in compensation from a Chinese university that the FBI alleges Wang failed to +disclose while receiving $3.6 million in taxpayer-funded grants at the same time. A federal grand jury +investigation into Wang remains on hold while the COVID-19 outbreak has delayed the case from being +presented.* +Chinese Professor Aceused Of Stealing Trade Secrets For Huawei To Plead Guilty. +The Bloomberg +(11/12, Cheney, Desiderio, 4.29M) says President Trump "will be a private citizen in January. But Republicans +and Democrats on Capitol Hill are poised to carry on the investigations and legal battles that helped define his +presidency." Politico says that in the House, Democrats are "still in court fighting to obtain Trump's financial +records and testimony from his first White House counsel Don MeGahn, a key figure in the obstruction of justice +case against Trump." Meanwhile, in the Senate, Republicans are "plotting ways to expand and intensify their +investigations targeting the former Obama administration" and Joe and Hunter Biden, "with Senate Republicans +saying they will use the lame duck period to ramp up their probes." +Opinion: Prosecutors May Accelerate Hunter Biden Probe During Lame Duck Period. Jonathan Turley, the + + +Shapiro Professor of Public Interest Law at George Washington University, writes in an op-ed in The Hill + (11/12, 2.98M) that prosecutors involved in the Russia and Hunter Biden probes "may now face +pressure to move faster in the final two months of the administration." Former Vice President Biden has +"dismissed the probe as an "investigation of the investigators."' The Russia investigation "could result in new +evidence," and could "shed light on how the initial Russia investigation started and was sustained." +Investigations "could set the investigations into the amber of the lame duck as insurance against interference +from the next administration." +CNN: Internal White House Debate Over Fate Of Haspel. +CNN (11/12, Cohen, Collins, +Salama, 83.16M) reports that while some GOP lawmakers have "publicly defended" CIA Director Haspel, +"outside of Capitol Hill, there are conflicting views about whether Trump should follow through with his threat +to oust Haspel, and competing factions within the administration are lobbying the President accordingly." +National Security Adviser Robert O'Brien, among others, has urged the President not to dismiss Haspel, but +"several people inside the White House are pushing for her removal." A person "familiar with the situation" says +that some Trump advisers "believe Haspel has been "insubordinate' to both the President and" DNI Ratcliffe, +"arguing she routinely circumvents the chain of command to further her own agenda and that of the CIA." +Independent Investigation Finds Bonanza Media Is A Russian Disinformation Project. +A Bellingcat (UK) (11/12) investigation "has discovered evidence that Bonanza +Media" is a "disinformation project working in coordination with Russia's military intelligence." Bellingcat has +not yet "established conclusively whether" the GRU "was behind the initial launch and funding of the Bonanza +Media project." However, the investigative platform "established that shortly after it was launched, senior +members of the GRU entered into direct and regular communication with the project leader." The significance of +the findings is the "potential role of Bonanza Media as a source of evidence in the ongoing criminal trial over the +downing of flight MH17 in 2014." The outlets authenticated "emails from the mailboxes of two senior GRU +officers obtained by a Russian hacktivist group." It also reviewed "phone call logs of these two GRU officers +independently obtained by us from whistle-blowers with access to Russian telecoms data." +UC Global Spied On Assange For Ecuadorian Intelligence, Says Ex Manager. +Computer Weekly (11/12, Goodwin) reports that UC +Global, "the company accused of spying on WikiLeaks founder Julian Assange in the Embassy of Ecuador," +acted "on the orders of Ecuador's intelligence services." Michel Wallemacg, the firm's former head of +operations, gave "evidence to a Spanish court investigating claims the UC Global's founder David Morales +ordered video and audio surveillance of meetings between Julian Assange and visitors, including lawyers, +doctors and journalists." Two former UC Global staff members "have claimed in anonymous witness statements +that the company's founder supplied surveillance footage and audio recordings to "American friends", which +were passed on to the CIA." +Criminal Investigations + + +US Charges South Carolina Inmate With Trying To Hire Hitman To Kill Prosecutor. +The Columbia (SC) State < https://www.thestate.com/news/local/crime/article247142679.html> (11/12, Monk, +390K) reports from Columbia, South Carolina, "A plot by an inmate at the Edgefield County federal prison to +hire a hit man to kill a federal prosecutor has been foiled, a complaint made public Thursday charged." Richard +Gilbert, 49, "an inmate who was incarcerated at the Edgefield Federal Correctional Institute, a medium security +facility, tried to hire a contract killer to do away with a federal prosecutor and the key witness in a Kentucky drug +case in which Gilbert was convicted, the complaint said. Gilbert is charged with retaliating against an informant, +murder for hire and money laundering, the complaint said. Unknown to Gilbert, the 'hit man' he was talking with +was an undercover FBI agent, the complaint said." +The Greenwood (SC) Index-Journal (11/12, 35K) reports, +"Gilbert, who is currently confined in Edgefield Federal Correctional Institution, was indicted on counts of +murder for hire, retaliation against an informant and money laundering. Gilbert, 51, was arrested in 2017 after +selling methamphetamine to two undercover officers in Kentucky. Last year, he was sentenced to 130 months in +prison." The Index-Journal adds, "Last month, a confidential informant in the prison told authorities Gilbert +planned to have the informant associated with his 2017 arrest killed. Afterward, the affidavit said, Gilbert was +hoping to have someone kill an assistant U.S. attorney and perhaps a Bureau of Alcohol, Tobacco, Firearms and +Explosives agent who worked his case. The informant's notes included names of the individuals. At the Federal +Bureau of Investigation's direction, the informant arranged a number of phone conversations between Gilbert +and an undercover agent that included discussion of how to kill the target and how Gilbert would compensate +him. He even told the agent how to drive to the target's house while avoiding cameras." +The Spartanburg (SC) Herald-Journal (11/12, +Boyd, 134K) reports, "Following multiple recorded phone calls, Gilbert sent the undercover officer a $2,000 +check from his prison canteen account as a down payment for the retaliatory murder-for-hire, investigators say. +Masking the true purpose of this payment, Gilbert attempted to mislead prison officials by saying the payment +was for an 'investment firm,' investigators say. Gilbert drew maps of where he believed the witness from +Kentucky lived, and he provided directions on how to avoid detection by nearby surveillance cameras, +investigators say. Gilbert planned to use the income from two rental properties in Kentucky to facilitate the +attempted murder-for-hire and retaliation plot, according to investigators." Also reporting are WSPA-TV + +Greenville, SC (11/12, Coburn, 30K), WYFF-TV Greenville, SC (11/12, 398K), +WOLO-TV Columbia, SC (11/12, Olson), and WHNS-TV + Greenville, SC (11/12, Ablon, 157K). +Documents Show Alleged Whitmer Kidnapping Plot Ringleader Planned To Take Hostages At Capitol Building. +WXYZ-TV Detroit (11/12, 236K) reports, "According to +newly released court documents, the alleged plot to kidnap and kill Governor Gretchen Whitmer included +everyone watching it on TV, that it would take about a week and that no one was coming out alive." According to +WXYZ-TV, "The plot was allegedly made by Adam Fox who state and federal officials have called the alleged +ringleader. The documents spell out a Plan A that included recruiting 200 men, taking over the entire state +Capitol building, taking hostages, executing "tyrants" and have it televised. A secondary plan was to lock the door + + +and set the building on fire. Fourteen men have been charged by the state and the feds in related cases. These +documents were filed in Jackson County Court last month where Pete Musico was in tears while a judge +considered lowering bond from $1 million to $100,000." +The Detroit News (11/12, Dickson, 825K) reports, "The eight-page brief, filed in +October in a bid to block a bond reduction for defendant Pete Musico, 42, of Munith was obtained Thursday by +The Detroit News. The document sheds light on two plots the Wolverine Watchmen allegedly formed in June, +and how, according to authorities, the group's focus shifted from storming the Capitol building in Lansing to +kidnapping the state's chief executive. Plan A was revealed only after alleged participant Adam Fox checked the +backs and chests of Musico, Joe Morrison, Ty Garbin, Paul Bellar, Daniel Harris and Amanda Keller for wires. +The plan: Storm the Capitol building in Lansing, "take hostages, execute tyrants and have it televised.' Then +there was Plan B: Storm the Capitol while the Legislature was in session, lock every door, and burn down the +building with everyone inside." The Detroit Free Press + (11/12, 1.52M) also reports. +FBI Arrests California Man For Hate Crime Attack On Restaurant. +The Canyon (CA) News (11/12) reports from Beverly Hills, California, "William Stepanyan, 22, of Glendale was +arrested on Thursday, November 12, for attacking a restaurant in Beverly Hills in what authorities described as a +'hate crime.' The incident transpired on November 4 at around 8:30 p.m." The FBI, "along with the Los Angeles +County Probation Department, conducted an investigation into the case, which resulted in Stepanyan's arrest in +Glendale, the Beverly Hills Police Department noted in a news release. A probation violation hold has been +issued for Stepanyan, who is currently being held without bail at the Beverly Hills Police Department. +Authorities classified Stepanyan as one of the 'primary suspects' responsible for the incident. On November 4, a +group of between 6 and 8 suspects destroyed property and physically attacked the employees inside the Turkish +Café Istanbul restaurant on South Beverly Drive. 'The victims stated that the suspects made derogatory +comments during the incident, according to police." +Alaska Man Arrested With Large Amounts Of Drugs. +Alaska Native News (11/12) reports, "On Wednesday, Alaska State Troopers +announced that the Nome Office of the Western Alaska Alcohol and Narcotics Team, the Anchorage Airport +Interdiction Task Force, and the FBI Safe Streets Task Force, made another arrest in their continuing +investigation into drugs in the Nome area that seized approximately 54.2 grams (2 ounces) of methamphetamine +and approximately 452.6 grams (1 Ibs) of marijuana bud." According to ANN, "The task force stopped 59-yearold Robert Cahoon, who was traveling to Nome from Anchorage and found the drugs in his possession. The +value of the methamphetamine is estimated at $54,200 and the Marijuana at $11,350." +Another Defendant Pleads Guilty In New Jersey Drug Trafficking Case. +Tap Into New Jersey (11/12, Rodas) reports Jose Agron, who on Thursday pleaded +guilty "to conspiring to distribute heroin," is the 15th defendant to admit to being part of a drug trafficking +organization that was based in Camden, New Jersey. Tap Into News Jersey highlights that those 15 guilty pleas + + +are the result of an FBI-led investigation. +US Charges Four In Missouri Murder-For-Hire Plot. +KSDK-TV St. Louis (11/12, Cole, 493K) reports from St. Louis, "A federal +grand jury indicted four people in connection with the 2016 murder of Andre Montgomery." Montgomery "is the +grandson of Sweetie Pie's owner Robbie Montgomery. Montgomery was killed by gunfire at 3964 Natural +Bridge Avenue in the City of St. Louis on March 14, 2016 around 8 p.m. On Thursday, James Timothy Norman, +Terica Taneisha Ellis, Waiel Rebhi Yaghnam and Travell Anthony Hill were indieted." Norman, Ellis and Hill +"are charged with conspiracy to commit murder-for-hire and murder-for hire resulting in the death of +Montgomery, Norman and Yaghnam are charged with conspiracy to commit wire and mail fraud and Yaghnam is +charged with five counts of aggravated identity theft all in connection with Montgomery's murder-for-hire." +Pennsylvania Woman Gets 13 Months In Prison For Drug Trafficking. +The Pocono (PA) Record (11/12, McDonald, 51K) reports a federal judge has sentenced Pennsylvania +resident Jennifer Annette Bush to 13 months in prison "and a three-year term of supervised release for drug +trafficking." The case against Bush "was investigated by the FBI," the Pennsylvania State Police, and the Stroud +Area Regional Police Department. +Marijuana-Related Search Warrant Operation Conducted In Arizona. +The Navajo Times (AZ) +(11/12, Becenti, 66K) reports the DEA and the FBI were involved with an investigation that led to a recent +search warrant operation in Shiprock, Arizona. Operation Navajo Gold targeted "suspected illegal marijuana +farming on the Navajo Nation." +FBI Arrests Woman In Connection To Bank Robberies In Utah, Arizona. +Gephardt Daily (UT) (11/12) reports that the FBI Salt Lake Field Office announced Thursday the arrest of Maria +Azevedo, who was "wanted by the FBI in connection with multiple bank robberies" throughout Utah and +Arizona. The FBI's Violent Crimes Task Force "wanted to thank the Arizona agencies involved in the arrest." +FBI Investigating Minnesota Robbery. +The Brainerd (MN) Daily Dispatch (11/12) reports that the FBI +Headwaters Safe Trail Task Force is investigating an armed robbery in Minnesota, where an armed suspect +"made off with an undetermined amount of cash" from the M& W Convenience Store on Wednesday. + + +North Carolina Jury Convicts Foreign National Of Sexual Abuse. +WLOS-TV Asheville, NC (11/12, Whitehead, 103K) reports Siva K. Durbesula was sentenced Thursday +to two years in prison after he was convicted of abusive sexual contact. Court documents said that he "was a +passenger aboard Spirit Airlines Flight NK843 from Chicago O'Hare to Myrtle Beach International Airport on +June 23, 2019, when he sexually assaulted the 22-year-old woman seated next to him." He "was originally +indicted in the District of S.C. but the case was transferred to the Western District of N.C. for trial after he agreed +that the plane traveled over N.C. and venue was appropriate in that state." +Continuing Coverage: FBI Investigating Disappearance Of Missing Colorado Woman. +Fox News +(11/12, Wallace, 27.59M) reports that the FBI and local police have "renewed their appeal for information about +missing Colorado mom Suzanne Morphew on Tuesday, which marked the six-month anniversary of her +disappearance on Mother's Day earlier this year." Chaffee County Sheriff John A. Spezze "called on anyone who +may have engaged with Morphew on Facebook, Instagram, Voxer, FaceTime or WhatsApp to come forward if +they haven't already been interviewed, 'regardless of how insignificant you think the information may be, or +whether you think investigators are already aware of it."* +FBI Search Colorado Home In Connection To 2016 Disappearance. +The Denver Post (11/12, 720K) +reports that FBI agents and Aurora police officers searched Thursday a home in connection to the disappearance +of Lashaya Stine, who "went missing from the area in 2016 when she was 16 years old." +New York Sex Offender Charged With Child Pornography Possession. +WWNY-TV Watertown, NY (11/12, 6K) reports convicted sex offender Randell Adsit was arrested +Wednesday by the FBI on charges of possessing child pornography. The FBI says that he "used multiple +usernames on the social media app Kik Messenger to trade child pornography with other people over the +internet." +Iowa Man Sentenced For Child Pornography. +KWQC-TV Davenport, IA (11/12, 79K) reports from Des Moines, Iowa, "A man has been sentenced to 20 years in +prison on child pornography charges in Des Moines." KWQC-TV adds, "Officials say on Tuesday, Nov. 10, 33- +year-old Robert Joe Hennings, of Des Moines, was sentenced by the United States District Court to 240 months +in federal prison. Following this, he was sentenced to 20 years of federal court supervision. This is for the receipt +of child pornography. Additionally, Hennings was ordered to forfeit electronic media used in the offense, pay +$15,000 in restitution to victims and pay $100 to the Crime Victims' Fund." KWQC-TV adds, "According to the +record made at sentencing, officials say Hennings collected in excess of 550,000 images of child pornography +over the span of three years. This included material involving sexual assault on prepubescent minors, including + + +an infant according to officials." +Financial Crime & Corporate Scandals +Attorney For Cincinnati Councilman Charged In Bribery Scheme To Hold Press Conference Today. +The Cincinnati Enquirer (11/12, Coolidge, 223K) reports, "Councilman Jeff Pastor has hired +well-known attorney Ben Dusing to represent him against federal charges of bribery, money laundering, +attempted extortion and conspiracy in a pay-to-play scheme." According to the Enquirer, "Pastor has not spoken +since his arrest Tuesday; he skipped City Council Thursday. Dusing has scheduled an 11:30 a.m. press +conference at his Fort Wright office." The Enquirer adds, "The call for Pastor, a Republican, to resign has been +swift, both inside his party and from Democrats. Ohio Republican Party Chairwoman Jane Timken and Hamilton +County Republican Party Chairman Alex Triantafilou have called for Pastor to resign. Mayor John Cranley, a +Democrat and two mayoral hopefuls, Democrats David Mann and P.G. Sittenfeld also are seeking Pastor's +resignation. FBI agents arrested Pastor early Tuesday for leading what authorities describe as a brazen bribery +scheme involving payoffs for help with city development projects." +Cincinnati Blight Helped FBI Crack Bribery Case. WCPO-TV Cincinnati (11/12, 139K) reports from +Cincinnati, "Federal prosecutors described this week's arrest of Councilman Jeff Pastor as "indicative of a culture +of corruption' at City Hall. But the case also sheds new light on one of Cincinnati's most stubborn symbols of +blight." According to WCPO-TV, "Convention Place Mall, an eight-story office and retail complex that brought +squatters, drug users, mold and garbage to the corner of Fifth and Elm streets, has defied more than a decade of +effort by city officials to revive a key corner that's literally at the front door of the Tri-State's convention +industry. Prosecutors allege Pastor accepted bribes to help a former Cincinnati Bengal gain control of the site so +he could redevelop it. Chinedum Ndukwe, who became a real estate developer after leaving the NFL, worked as +a 'cooperating witness' for the FBI, US Attorney David DeVillers told reporters." +US Arrests Nine Californians On Money Laundering Charges. +My News LA (CA) (11/12) reports, "Federal authorities Thursday arrested nine defendants from the Los Angeles area, +most of whom were allegedly involved in a sophisticated money laundering scheme that moved tens of millions +of dollars derived from tax fraud and health care fraud schemes." According to My News LA, "Two indictments +unsealed in Los Angeles federal court allege that a total of 10 defendants participated in a large operation that +laundered more than $30 million in tax refunds that had been obtained from 7,000 fraudulent tax returns filed +using identities stolen from thousands of American taxpayers. Seven of the 10 defendants named in these two +indictments were arrested Thursday, and three were still being sought by authorities, according to the U.S. +Attorney's Office." +US Charges California Man With Wire Fraud, Identity Theft. +KGET-TV +Bakersfield, CA (11/12) reports, "Federal prosecutors say a grand jury has indicted a Bakersfield man on +multiple counts of fraud and identity theft that funneled nearly $1 million from banks and credit card +companies." According to KGET-TV, "The federal grand jury in Fresno indicted Nahed Mishmish, 46, on an 11- + + +count indictment. Prosecutors say Mishmish used stolen identification information to open numerous credit card +accounts to pay for a car and rent over five years between January 2015 and January 2020. He is alleged to have +used the phony credit accounts to purchase a large amount of cigarettes from Rite Aid stores, prosecutors say. +According to U.S. District Attorney in Fresno, a criminal complaint showed the FBI was tipped off to the scheme +after Mishmish allegedly purchased large amounts of cigarettes from a Rite Aid in McFarland. Federal agents +identified Mishmish and searched his home where they found 60 cellphones marked with names and other +personal identifying information." +Former Philadelphia Officials, Contractor's Employee Charged With Embezzlement. +WHYY-TV Philadelphia (11/12, 24K) reports, "Two former Philadelphia officials, and one former +employee of a city contractor, have been charged with fraud and embezzlement after joint investigations by the +city's Office of the Inspector General and the FBI." Leo Dignam, 61, of Philadelphia, "who once served as +director of the Mummers Parade and as assistant city managing director, is accused of wire fraud and embezzling +from a program that received federal funds. His brother, Paul Dignam, 58, also of Philadelphia, is facing charges +of mail fraud and similar embezzlement charges. Barbara Conway, 61, of Drexel Hill, has been charged with +alleged theft of funds from a federally funded program." +Plea Hearing For Ex-Michigan Prosecutor Moved Again Due To Coronavirus. +The Detroit News (11/12, Hicks, 825K) +reports, "A plea hearing in former Macomb County Prosecutor Eric Smith's corruption case has been +rescheduled a second time after he was diagnosed with COVID-19, officials said Thursday." Smith "had been set +to appear late last month but was forced into quarantine after his family was in contact with people who tested +positive for the coronavirus. The former prosecutor has agreed to plead guilty to obstructing a federal +investigation into whether he stole campaign funds." Smith "was expected to plead guilty at a new hearing +Friday. However, U.S. District Judge Linda Parker issued a order Thursday to move the date to Dec. 17 after +Smith was diagnosed and hospitalized this week. 'Defendant continues to exhibit severe symptoms of the virus,' +Parker wrote. 'Defendant is in quarantine at his home pursuant to the Centers for Disease Control and +Prevention's guidelines. +595 +New Hampshire Attorney Pleads Guilty To Money Laundering, Wire Fraud. +Manchester Ink Link (NH) (11/12, Fisher) reports from Concord, New Hampshire, "Former +Manchester attorney John Allen pleaded guilty Thursday to charges of money laundering and wire fraud for +taking $2.4 million from several clients." Allen, 63, of Bedford, "appeared in the United States District Court in +Concord on Thursday for the plea hearing. He allegedly took the money clients gave him for real estate +transactions of other uses, trusting him to dispose of it in the way they wanted. 'John Allen betrayed that trust, +took advantage of his clients, and stole their money,' said United States Attorney Scott Murry. "These are the +actions of a white-collar criminal rather than a dedicated counselor at law.*" Allen "was arraigned last week on +the charges, the culmination of an investigation that started when the New Hampshire Attorney Discipline Office +found red flags in the way he dealt with client monies." +Cyber Division + + +Two DHS Officials Reportedly "Forced To Resign"; Krebs "Expects To Be Fired." +CNN (11/12, +Marquardt, Sands, 83.16M) reports on its website that DHS Assistant Secretary for International Affairs Valerie +Boyd and DHS Cybersecurity and Infrastructure Security Agency Assistant Director for Cybersecurity Bryan +Ware "have been forced to resign by the White House, according to sources familiar with the resignations." CNN +says Ware's "farewell letter to staff indicates that he did not want to step down." +Reuters (11/12, Bing, Menn) reports that Christopher +Krebs, who heads the Cybersecurity and Infrastructure Security Agency, "has told associates he expects to be +fired by the White House." Krebs "drew the ire of the Trump White House over a website run by CISA dubbed +'Rumor Control' which debunks misinformation about the election, according to the three people familiar with +the matter." One CISA post rejected "a conspiracy theory that falsely claims an intelligence agency +supercomputer and program, purportedly named Hammer and Scorecard, could have flipped votes nationally." +Sen. Mark Warner (D-VA) tweeted, "Chris Krebs has done a great job protecting our elections. He is one of the +few people in this Administration respected by everyone on both sides of the aisle. There is no possible +justification to remove him from office." +Bloomberg (11/12, Courtney, Sebenius, 4.73M) reports that House Homeland Security Committee +Chairperson Bennie Thompson (D-MS) said, "There are rumors the president may be cleaning house at CISA, +with one high-level official reportedly asked to resign already. This is dangerous." Sen. Angus King (I-ME), cochair of the US Cyberspace Solarium Commission, "called Krebs" work with states on election security +'amazing' in a recent press briefing with reporters." King said, "The state infrastructure, the registration rolls, the +election rolls, voting machines, all of that, is much better, much stronger, much more resilient than it was four +years ago." +The Hill +(11/12, Chalfant, 2.98M) reports, "Krebs's potential ouster would leave a tremendous leadership vacuum at DHS +and would leave the top government cybersecurity role vacant at a critical moment." If he is "forced to step +down, his role would likely be filled by CISA Deputy Director Matthew Travis, who has served in the deputy +director position since 2018." Ware, as well as Valerie Boyd, another DHS official, "were forced to resign due to +pressure from the White House," according to reporting by CNN. +Politico (11/12, +Geller, Bertrand, 4.29M) reports that CISA "has been at the forefront of federal efforts to protect U.S. elections +from foreign hacking and interference, and his efforts have drawn praise from people in both parties." Krebs" +ouster "could make him the latest national security leader to lose his job amid a post-election purge that has +already forced out Defense Secretary Mark Esper and other top Pentagon officials." An unnamed official said the +White House "has wanted to fire Krebs for a while... From what I've heard from the [White House], they've +considered removing him before." +Also reporting are CyberScoop +(11/12, Lyngaas), The Hill (11/12, Miller, 2.98M), the Washington Times + +(11/12, Blake, 492K), and Federal News Network (11/12, Miller, 220). + + +Commerce Department Will Delay Enforcement Of TikTok Shutdown Order. +The Wall Street Journal (11/12, Maher, Subscription Publication, 7.57M) reports the Commerce +Department said Thursday it will not enforce an order that would have effectively shut down Tik Tok by +prohibiting US companies from offering it as a mobile app and offering web-hosting service for the company. +Citing a preliminary injunction against the shutdown last month from US District Judge Wendy Beetlestone in +Philadelphia, the Department said the order will not take effect "pending further legal developments." +The New York Times (11/12, McCabe, 18.61M) reports that the restrictions were +announced "in September under an executive order signed by President Trump targeting Tik Tok and WeChat." +App stores "would not have been able to offer TikTok, and American companies would have been forbidden +from hosting data for the service." The Commerce Department "had indicated that it would apply the restrictions +only to the app if ByteDance, TikTok's Chinese owner, were unable to sell its interest in the product." On +Tuesday, the agency "said that the order 'has been enjoined, and will not go into effect, pending further legal +developments.* +The Washington Post (11/12, Riley, 14.2M) reports that TikTok is "waiting on a +federal judge to grant a 30-day extension on the sale as it awaits a government green light on the deal it proposed +to set up a new company with investment from Oracle and Walmart." If a ruling is not issued, the "presidential +election results could leave the company with more options." +CNBC < https://www.cnbc.com/2020/11/12/tiktok-can-continue-to-operate-in-the-us-commerce-departmentsays.html> (11/12, Sherman, 3.62M) reports, "The Commerce Department order doesn't address the CFIUS +mandate demanding TikTok sell its U.S. assets," but "reaffirms TikTok can continue to operate in the U.S." The +company "continues to wait for more government guidance about how to proceed with its minority stake sale." +President Trump agreed to the sale of 20% of TikTok Global to Walmart and Oracle in August, but "the +transaction never got the approval of the Chinese government, and Trump administration officials have gone +silent on their demands in the weeks leading up to the election." +The Daily Caller (11/12, Lancaster, +716K) reports that TikTok would be "barred from using the web-hosting services of any U.S. based company, +like Amazon and Alphabet, making the app essentially useless." The company is "asking for an injunction from +U.S. District Judge Carl Nichols because they say different plaintiffs who have different interests are involved in +the Philadelphia case." If the preliminary junction "were lifted, it would be 'leaving Tik Tok's entire business in +jeopardy." +Also reporting is Bloomberg (11/12, Yaffe-Bellany, McLaughlin, 4.73M). +Israeli Cybersecurity Firm Finds New Type Of Iranian Ransomware. +Fox News +(11/12, Friling, 27.59M) reports, "Check Point revealed Thursday a new type of ransomware that is traced back +to Iran." The "Pay2Key" strain "targeted more than a dozen Israeli companies a few weeks ago," using the +"Remote Desktop Protocol (RDP) of employees who worked from home." According to the Israeli cybersecurity +company's investigation, "four Israeli victims of the attacks have decided to pay the ransom, which enabled its +experts to track the payment transfers between crypto wallets." Check Point's manager of threat intelligence, +Lotem Finkelstein, said, "Pay2Key is sophisticated and far more rapid compared to other ransomware strains. ... + + +The recent Pay2Key ransomware attacks indicate a new threat actor has joined the trend of targeted ransomware +attacks." +Finland Prepares Change To Code Law After Hacking Case. +The AP (11/12, Tanner) reports, "Finland said Thursday it was preparing legislation that would allow +citizens to change their personal identity codes in cases of gross data breaches that carry a high risk of identity +theft." The government's proposal "was designed primarily to assist thousands of people whose personal +information was stolen during a hacking of patient records at a private Finnish psychotherapy center." Citizens +"receive a personal identity code at birth to allow them to access most public and many private services," and the +"criteria for changing one's code are strict." The government is drafting legislation that "would make the process +slightly easier." +NSA Grant To Help Two Indiana Campuses Expand Cybersecurity Programs. +The Northwest Indiana Post-Tribune (11/13, Kiesling, 1.8M) reports, +thanks to a $5.9 million NSA grant, "two local campuses of Ivy Tech Community College plan to expand their +cybersecurity training partnerships in Northwest Indiana." The Lake County and Valparaiso campuses "are +included in a consortium of four higher ed institutions that has been awarded a two-year, $5.9 million NSA grant +to expand the pipeline for cybersecurity jobs both locally and nationally." Matthew Cloud, Information +Technology chair for Ivy Tech's Lake County campus, said, +, "The NSA grant will help us build and expand our +existing training program partnerships with the governor's office, financial institutions and law enforcement +agencies in Northwest Indiana to fill their needs." Cloud added, "The grant will help more than 425 law +enforcement personnel, military veterans, transitioning military, and other first responders obtain basic to +advanced cybersecurity training for free." +Law Enforcement Services +Springfield, Massachusetts Police Department Assigns Officer To FBI Gun Violence Task Force. +WWLP-TV Springfield, MA (11/12, Lannan, 81K) reports from Springfield, +Massachusetts, "A member of the Springfield Police Department has been assigned to the FBI's Western +Massachusetts Task Force to help combat gun violence." Springfield Police Department Commissioner "said on +Thursday that she and Mayor Domenic Sarno met with U.S. Attorney Andrew E. Lelling and the Special Agent +in charge of the FBI Boston Division, Joseph Bonavolonta, in the city on Tuesday to discuss and agree on the +officer's new assignment which will begin Monday, November 16, 2020. The FBI and Commissioner Clapprood +agreed that assigning a Springfield Police officer to their Task Force will improve intelligence sharing between +the two agencies. The goal is to crack down on illegal gun crimes and gun violence in the Springfield area." +WPost: Voters Usher In "New Phase Of Drug Policy." +In an editorial, the Washington Post (11/12, 14.2M) +says that Election Day votes to legalize recreational marijuana in New Jersey, Arizona, South Dakota, and +Montana, medical marijuana in Mississippi, and decriminalize "small quantities" of hard drugs in Oregon "mark +a welcome shift in decades of destructive drug policy" beginning with "the Reagan-era escalation of the war on +drugs." The Post says "severe criminal penalties have fueled a huge growth in the prison population" with an +outsized impact on many Black communities, while soaring opioid overdose deaths have underscored "just how +cruel and counterproductive it is to criminalize addiction." With new state legislation, The Post argues, +researchers will now "be able to closely observe these laboratories of democracy, hopefully ushering in a new +phase of drug policy based on evidence and the principles of public health." +Other FBI News +DOJ Report: Acosta Engaged In No Misconduct When He Agreed To Epstein Plea Deal. +The CBS Evening News (11/12, story 10, 0:25, O'Donnell, 4.06M) reported, 'This news today: The Justice Department said +the prosecutor who handled a 2008 case against Jeffrey Epstein showed poor judgment but did not engage in +professional misconduct. Alex Acosta, who later became President Trump's labor secretary, was under fire for +the generous plea deal that he entered into with Epstein, who was accused of abusing dozens of teenage girls. +Well, today, a lawyer for Epstein's victims called the DOJ report a cover-up." +The AP (11/12, +Balsamo, Tucker) says a report from the Justice Department's Office of Professional Responsibility has found +Acosta "exercised "poor judgment' in handling an investigation into wealthy financier Jeffrey Epstein when he +was a top federal prosecutor in Florida. " The report details Acosta's "handling of a secret plea deal with Epstein, +who had been accused of sexually abusing dozens of underage girls." According to the AP, the report "concludes +that none of the prosecutors committed misconduct in their interactions with the victims," which the AP says is +"likely to disappoint the victims, who have long hoped this would hold the Justice Department officials +accountable for actions they say allowed Epstein to escape justice." +Reuters (11/12) reports, "In a statement released on Thursday, the +Justice Department said that when Acosta let Epstein enter the non-prosecution agreement in 2008 that spared +him from federal sex trafficking charges, he 'failed to make certain that the state of Florida intended to and +would notify vietims identified through the federal investigation about the state plea hearing. ** Reuters also +reports that Sen. Ben Sasse (R-NE) denounced the report's conclusions, saying, "Letting a well-connected +billionaire get away with child rape and international sex trafficking isn't "poor judgment' - it is a disgusting +failure." +The New York Times (11/12, Goldstein, Benner, 18.61M) says that "the review was an attempt to close the door on an +embarrassing episode for the Justice Department that critics have said allowed Mr. Epstein to largely go +unscrutinized in the face of years of allegations that he sexually abused dozens of teenage girls." The Times says +despite the department's insistence "in its summary that it found no wrongdoing, it is clear from the full, nearly +350-page report that Mr. Epstein and his defense lawyers were in control of the negotiations from June 2007.' +The Washington Post < https://www.washingtonpost.com/national-security/jeffrey-epstein-alex-acosta-floridaplea-deal/2020/11/12/c960d078-243a-11eb-8672-c281c7a2c96e_story.html> (11/12, Zapotosky, Reinhard, +14.2M) reports that "lawyers for the victims criticized the report," as Adam Horowitz saying, "The mountain of +mistakes was not just poor judgment. It was reckless." Sasse also "called on the department to release its entire +report," saying, "We have an obligation to make sure this never happens again." A Justice Department + + +spokesperson "said the department could not release the entire report publicly, citing privacy law, but noted it +was being turned over to lawmakers." +Among the outlets also reporting on the review are the Wall Street Journal (11/12, Gurman, +Subscription Publication, 7.57M), the CNN (11/12, Scannell, 83.16M) website, and Axios (11/12, Chen, +521K). +Ramsey Tapped As New Portland, Oregon SAC. +Oregon Public Broadcasting (11/12, Wilson, 13K) reports, "The FBI confirmed Thursday it has named a new head of its Portland +field office. Section Chief Kieran Ramsey will take over for Special Agent In Charge Renn Cannon, who is set to +retire early next year after overseeing the office since January 2017." Ramsey, "who was officially named to the +post Nov. 4, spent time in Portland earlier this year during large, nightly racial justice protests that at times +turned violent. The protests in Portland were a particular focus for the Trump administration, as the president and +U.S. Attorney William Barr called for a harsher crackdown on demonstrators." +Other Washington News +Media Analyses: Trump Silent On Pandemic, "Largely Out Of Sight," As Election Challenges Continue. +While coverage of President Trump's challenges to vote counts in several states continues, media attention +shifted Thursday and early Friday to the President's near-total absence over the past week and his silence on +pressing matters. David Muir said on ABC World News Tonight +(11/12, story 3, +2:55, 6.57M) that Trump "has remained largely out of sight. He's not addressed the country's worsening +coronavirus situation, his tweets still largely on the election." Lester Holt said on NBC Nightly News +(11/12, story 3, +0:35, 4.9M), "As the COVID crisis deepens across the country, President Trump has said nothing about it +publicly since the election." NBC's Hallie Jackson: "The White House says the President is getting regular +updates and making sure local officials have what they need. The COVID task force did meet Monday, but it was +for only the second time in the last three and a half weeks. The President has not addressed the public in person +in a week." On ABC World News Tonight +(11/12, story 4, +0:40, Muir, 6.57M), Jonathan Karl said, "The President has been nowhere on this. He hasn't spoken about the +alarming increase in infections. He has not met with the coronavirus task force for months. He hasn't even +tweeted about it." +The AP (11/12, Madhani, Miller) says the President "has publicly disengaged +from the battle against the coronavirus at a moment when the disease is tearing across the United States at an +alarming pace." The AP says Trump "remains angry that an announcement about progress in developing a +vaccine for the disease came after Election Day. And aides say the president has shown little interest in the +growing crisis." The Los Angeles Times (11/12, Megerian, 4.64M) writes, "More than a week +after his stinging electoral defeat, President Trump spent another day secluded in the White House on Thursday + + +feverishly tweeting, watching television and telephoning allies - focused more on his own future than governing +the nation as it struggles with a worsening pandemie." +The Washington Post (11/12, A1, Nakamura, 14.2M) writes, "On Thursday, six American +service members were killed in a helicopter crash during a peacekeeping mission in Egypt. Tropical Storm Eta +made landfall in North Florida, contributing to severe flooding. The number of Americans infected with the +novel coronavirus continued at a record-setting pace, sending the stock market tumbling." But Trump "spent the +day as he has most others this week - sequestered from public view, tweeting grievances, falsehoods and +misinformation about the election results and about Fox News's coverage of him. Neither he nor his aides +briefed reporters on the news of the day." +Politico +(11/12, Forgey, 4.29M) reports that on Thursday, White House Press Secretary Kayleigh McEnany declined to +say when Trump "might end his conspicuous pause of post-election public appearances, telling Fox News that +Americans will 'be hearing from him at the right moment."" Politico says the President "has not appeared or +spoken publicly since a White House news conference last Thursday, when he repeated his attacks on the +country's electoral system and his baseless claims of widespread voter fraud." +Politico (11/12, Cook, Orr, +4.29M) additionally reports that Chief of Staff Meadows "gathered senior aides on a call" on Monday "to plot +the conservative policy moves they could push through in their final 10 weeks on immigration, trade, health care, +China and school choice." Staffers "have compiled a list of roughly 15 moves they could make through +executive orders, executive actions or finalizing agency rules that they plan to pursue in the coming days, +according to interviews with three administration officials," and aides say Trump "intends to start issuing the +orders as soon as possible." However, White House officials told the Wall Street Journal + +(11/12, Ballhaus, Restuccia, Subscription Publication, 7.57M) that Trump has not discussed what he wants to +achieve over the next two months, and one official said little formal planning is taking place. +The Washington Post (11/12, 14.2M) +editorializes, "The pandemic has reached runaway speed in the United States, and the president has vanished.... +On Wednesday, 1,549 people died from the virus in the United States. Would the leadership of the nation be on +high alert if, say, that many people were killed in three jumbo jet crashes? If a terrorist group or foreign attacker +drew such an awful toll on a single day? Yet there was not a word from President Trump, so self-absorbed with +his election defeat and the mirage of voter fraud that he seems unable and unwilling to deal with a supreme +national crisis." +Trump Campaign Continues To File Legal Challenges. Ben Tracy reported on the CBS Evening News + (11/12, Haberman, 18.61M) writes, "There is no grand strategy at play, according to interviews with +a half-dozen advisers and people close to the president." Trump is "simply trying to survive from one news cycle +to the next, seeing how far he can push his case against his defeat and ensure the continued support of his +Republican base. By dominating the story of his exit from the White House, he hopes to keep his millions of +supporters energized and engaged for whatever comes next." +The AP (11/12, Swenson, Seitz) reports the President on Thursday "falsely +claimed on Twitter that an election technology firm 'deleted' large numbers of his votes or 'switched' them to +count for Joe Biden." USA Today (11/12, Jackson, 10.31M) writes, "Intentionally +or not," Trump also "re-tweeted several items Thursday warning about the prospect of a Democratic-controlled +U.S. Senate - something that can only happen if Biden becomes president and Kamala Harris becomes vice +president." CNN (11/12, Bash, Borger, Klein, 83.16M) reports on its website that while Donald Trump Jr. and +Eric Trump "are gung-ho, leading the charge for the President to stay in the fight," Ivanka Trump "has emerged +as someone looking for a way for the President to save face as he considers his next steps." +The New York Times +(11/12, Feuer, 18.61M) reports, "Almost from the moment the election ended, President Trump and his allies +have relentlessly attacked the integrity of both the voting and vote counting, a narrative they have sought to +advance in nearly 20 lawsuits filed in the past eight days. While these suits have alleged systemic fraud in at +least five states, the evidence they have offered has been different. At least so far, it has been limited, narrow +and, according to several judges and experts, unlikely to affect - let alone to overturn - the outcome of the race." +The Wall Street Journal (11/12, Ramey, Randazzo, Subscription Publication, 7.57M) reports the +Trump campaign is pressing ahead with legal action in Georgia, Michigan, Pennsylvania, and Wisconsin, and on +Friday, a Pennsylvania judge is set to hear a challenge to more than 8,000 Philadelphia ballots with minor errors. +White House Press Secretary Kayleigh McEnany said on Fox News' The Story + (11/12), "Let's get to the bottom +of this in an effectual way, in a truthful way, and be very careful on the information we are putting forward, +which is what we've done." MeEnany said on Fox News' Hannity that new affidavits from Pennsylvania show +"one system for Democrat counties" and "another system for Republican counties," amounting "to tens of +thousands of ballots that were counted improperly." +The New York Post (11/12, Bowden, 4.57M) reports the Trump campaign "was handed a minor legal victory +on Thursday when a Pennsylvania judge ruled that a small number of ballots be tossed, from people who did not +provide ID by a Monday deadline." The state appellate court ruling "bars counties from including in their final +tally mail-in ballots from people who failed to validate their identification against state records by Nov. 9." The +Daily Caller (11/12, 716K) says "ballots for which proof of identity had been provided between +November 10 and 12 had been separated while the court decided what to do with them." The ruling "means that +the segregated ballots will not be counted." +The Philadelphia Inquirer (11/12, 347K) says "tens of thousands of Pennsylvanians +are still waiting to see if their vote will be counted as officials continue the tedious process of verifying what is +likely to be a record-breaking number of provisional ballots." And Reuters < https://www.reuters.com/article/ususa-election-jones-day/blowback-against-trump-campaign-law-firm-targets-clients-recruitingidUSKBN27S1M2> (11/12, Spiezio) reports that Jones Day, "the go-to law firm" for the Trump campaign, is +"under fire for representing Republicans in a lawsuit over Pennsylvania's extended deadline to receive mail-in +ballots, with law students threatening to boycott the firm and a prominent anti-Trump group targeting it online." +In Arizona, the Arizona Republic (11/12, 869K) reports, "all counties that have +conducted required hand-count audits of a sample of their ballots found no or minor discrepancies, county audit +reports submitted to the state show." In Georgia, the AP (11/12, Brumback) reports, counties are preparing "for a +hand tally of the presidential race." The New York Times + (11/12, Hakim, Fausset, +18.61M) reports Georgia's "159 counties were poised on Thursday to begin recounting nearly five million ballots +in the presidential election." The Atlanta Journal-Constitution < https://www.aje.com/polities/recount-teams- + + +assemble-for-manual-review-of-georgia-election-results/V22J6ZW66VESNHW77WJ2ZZ35WY/> (11/12, +895K) reports that "the recount is open to the public. Anyone can watch from an observation area. Official +monitors appointed by political parties will be able to get closer, but they're not allowed to talk to audit teams or +touch ballots." In Michigan, Townhall (11/12, McCarthy, 177K) reports, GOP state senators "are requesting a +full audit of the 2020 general election after allegations of election improprieties and irregularities." +USA Today (11/12, 10.31M) editorializes, "Two days after the election, +[Trump] stood in the White House claiming he was cheated out of victory. 'It's a corrupt system,' he told the +nation. 'We have so much evidence.' A week later, it's reasonable for Americans to ask: Where is it? The +increasingly obvious answer is that the evidence does not exist. There is no proof of any widespread voter fraud, +and surely not enough to overturn the results in a single state, much less the three or more states Trump would +need to reverse the outcome." +The Washington Post +(11/12, 14.2M) editorializes, "Trump is attempting to overturn the lawful results of a free election by spreading +lies and suborning local officials to abet his conspiracy. He is not likely to succeed, but the toxic effects on U.S. +democracy will not soon dissipate... Though conducted by partisan officials, the mechanisms of vote-counting +and election-certifying have until now been understood to be formalities based on actual vote counts. Vote +counting cannot depend on which party can more effectively manipulate the machinery of government." +Obama Says He Is "Troubled" By Republicans "Who Clearly Know Better" Supporting Trump's Claims. The +CBS Evening News (11/12, story 4, 1:05, O'Donnell, 4.06M), previewing a 60 Minutes interview with former President +Barack Obama, showed Obama saying, "The President doesn't like to lose, and never admits loss. I'm more +troubled by the fact that other Republican officials who clearly know better are going along with this, are +humoring him in this fashion. It is one more step in delegitimizing not just the incoming Biden Administration, +but democracy generally. And that's a dangerous path." +Adelson-Owned Newspaper Urges Trump To Cooperate With Biden Team. The Washington Post + (11/12, Izadi, +14.2M) reports, "In October 2016, the Las Vegas Review-Journal was the first major newspaper to endorse thencandidate Donald Trump for president.... Four years later, the Review-Journal - owned by Trump supporter and +Republican megadonor Sheldon Adelson - is advising Trump that he did indeed lose the 2020 presidential race +and that he should start cooperating with the Biden transition team." In a Thursday editorial +, the newspaper wrote, "It is too fitting that the Trump presidency concludes amid a babel +of bluster and bravado. But the president does a disservice to his more rabid supporters by insisting that he +would have won the Nov. 3 election absent voter fraud. That's simply false. " Politico + (11/12, +Niedzwiadek, 4.29M) and The Hill (11/12, 14.2M) column, Margaret +Sullivan looks at the challenges media organizations are facing in covering the post-election machinations. +Agreement Reached With Pharmacies To Provide Free COVID Vaccinations. +The AP (11/12, Alonso-Zaldivar) reports that "federal health officials have + + +reached an agreement with pharmacies across the U.S. to distribute free coronavirus vaccines after they are +approved and become available to the public." According to the AP, "Thursday's agreement with major chain +drug stores, grocery market pharmacies and other chains and networks covers about 3 in 5 pharmacies," and +"looks ahead to a time next spring when yet-to-be-approved vaccines will start to become available beyond +priority groups." HHS Secretary Azar is quoted as saying, "The vast majority of Americans live within five miles +of a pharmacy," and the deal is "a critical step toward making sure all Americans have access to safe and +effective COVID-19 vaccines when they are available." +State Health Officials Prepare For Vaccination Distribution Logistical Complexities. The AP + +(11/12, Choi, Smith) says, "With a COVID-19 vaccine drawing closer, public health officials across the country +are gearing up for the biggest vaccination effort in U.S. history - a monumental undertaking that must distribute +hundreds of millions of doses, prioritize who's first in line and ensure that people who get the initial shot return +for the necessary second one." According to the AP, "The push could begin as early as next month, when federal +officials say the first vaccine may be authorized for emergency use and immediately deployed to high-risk +groups, such as health care workers." The AP says state officials are "planning for the likelihood that the first +shipments will not be enough to cover everyone in high-priority groups." +Vaccination Distribution Requires Cooperation Between Governments, Drug Makers, Suppliers, Employees. The +New York Times +(11/12, Gelles, Robins, 18.61M) reports Pfizer, the US government, and "the public health community face a +new challenge: quickly making millions of doses of the vaccine and getting them to the hospitals, clinies and +pharmacies where they will be injected, two separate times, into people's arms." Before shipment, "federal and +state governments must tell it where to send how many doses," and medical supplier McKesson "will have to +provide hospitals and other distribution sites with the syringes, needles and other supplies necessary to +administer the vaccine." Employees "will need to be trained to store and administer the vaccine" and "ensure +that, four weeks after people get the vaccine, they return for a second dose." In addition, "millions of Americans +must be persuaded to get the shots in the first place." +Work On COVID Vaccine Began When Virus Was Spreading In Wuhan. On NBC Nightly News + (11/12, story 11, +1:45, Holt, 4.9M), Richard Engel said that when the novel coronavirus began to spread in Wuhan, China in +December 2019, "the Chinese government swooped in with all its authoritarian might, but China did something +else few noticed. It made a call for help, written in genetic code... Chinese researchers quickly cracked the code +and published it" online. Imperial College London COVID-19 Vaccination Lead Robin Shattock "fed it into a +computer and came up with a prototype vaccine within weeks. Nearly all the work since then has been testing." +Eli Lilly Antibody Treatment Aims To Speed Recovery Time For Vulnerable COVID Patients. ABC World News +Tonight(11/12, +story 2, 2:45, Muir, 6.57M) reported, "Ely Lilly's antibody treatment receiving FDA emergency use +authorization just this week, working to speed up the recovery in some of the most vulnerable patients." +Correspondent Alex Perez said researchers took "the most powerful antibody from one of the first survivors and +[are] using a synthetically-made version to fight the virus." However, "only certain patients are eligible. They +must be 12 years or older with mild to moderate symptoms and likely to develop severe illness, including many +with pre-existing conditions like diabetes and obesity. It's not for people already in the hospital. Availability is +limited. 88,000 doses ready now. 212,000 more expected by the end of the year." +Fauci Says Working With Administration Has Been "Stressful." +The Australian Broadcasting Corporation < https://www.abc.net.au/news/2020-11-11/anthony-fauci-coronavirusvaccine-donald-trump-joe-biden/12873046> (11/12, 99K) reports on its website that in an interview, NIAID +Director Fauci "said controlling America's worsening coronavirus outbreak was not impossible but becoming + + +more and more difficult." Fauci also said "working with the Trump administration on the coronavirus pandemic +had 'obviously been very stressful."" Fauci said, "When you have public figures like [former Trump advisor +Stephen] Bannon calling for your beheading, that's really kind of unusual. That's not the kind of thing you think +about when you're going through medical school to become a physician." +In Recording, Facebook CEO Defends Decision Not To Suspend Bannon. Reuters + (11/12, Paul) reports Facebook CEO Mark Zuckerberg +"told an all-staff meeting on Thursday that [Bannon] had not violated enough of the company's policies to justify +his suspension when he urged beheading" Fauci and FBI Director Wray, "according to a recording heard by +Reuters." Zuckerberg said, "We have specific rules around how many times you need to violate certain policies +before we will deactivate your account completely. ... While the offenses here, I think, came close to crossing +that line, they clearly did not cross the line." +Fauci: Lockdown Can Be Avoided. +The New York Times (11/12, Zraick, +Pérez-Peña, Grady, 18.61M) reports that on Thursday, NIAID Director Fauci "urged Americans...to "double +down' on basic precautions as coronavirus cases soared across the country and more Covid-19 patients were +hospitalized than ever before." However, in an appearance on ABC's Good Morning America, Fauci "reiterated +that a nationwide lockdown was unlikely, saying there was "no appetite for locking down in the American +public.' But he expressed confidence that virus cases could be reduced without such drastic measures - if +Americans 'double down' on basic preventive steps, like social distancing and masks." Fauci is quoted as saying, +"I believe that we can do it without a lockdown, I really do." +Azar: Facts "Do Not Support" Lockdown Of Country. HHS Secretary Azar said on Fox News' The Story + (11/12), "We +should be driven by science and data and the facts here, and they simply do not support the notion of locking +down the country, sheltering in place. You know, it's important the American people know the facts, and the +simple facts are that our colleges," K-12 schools, workplaces, air travel, and healthcare settings are not +mechanisms for major spread of the disease." Azar added that lack of protection during "indoor gatherings" is +"what's driving this" second wave. +Birx Urges Tighter Restrictions, Guidance Adherence. +WISC-TV Green Bay, WI +(11/12, 28K), Birx cited superspreader events and a number of asymptomatic cases as major drivers of the state's +spike. Birx said, "It's no one's fault. They don't know they're infected. I know it's difficult to comprehend that +there's a virus out there that can cause no symptoms in some and hospitalizations and deaths in others, and longterm consequences in others." She "says to flatten the curve, Wisconsin has to stop superspreader events +and..stay home." +US COVID Infections Topped 150K Thursday; States See Surge In Hospitalizations. +The CBS Evening News (11/12, lead story, +4:50, Muir, 6.57M) reported hospitalizations also nearly doubled "in just two weeks." +On NBC Nightly News (11/12, A1, Levitz, Ansari, Subscription Publication, 7.57M) reports the governors of New York, +Utah, Maryland, Iowa, and Minnesota, among other states, are imposing new measures aimed at curbing rising +COVID infection numbers. +CNBC < https://www.enbc.com/2020/11/12/average-covid-cases-and-hospitalizations-rise-in-nearly-every-stateacross-us.html> (11/12, Feuer, 3.62M) reports on its website that "average daily new cases are up by at least 5% +over the last week in at least 47 states and DC as of Wednesday, according to a CNBC analysis of data compiled +by Johns Hopkins University." +The New York Times (11/12, +Smith, 18.61M) reports, "Eight days after 100,000 US cases" of COVID infections "were found in a day for the +first time, the number topped 150,000 on Thursday." The pandemic "has risen to crisis levels in much of the +nation, especially the Midwest, as hospital executives warn of dwindling bed space and as coroners deploy +mobile morgues." Over "100,000 coronavirus cases have been announced nationwide every day since Nov. 4, +and six of the last nine days have broken the previous record." Hospitalizations "also set a record on Thursday, +climbing to 67,096, according to the Covid Tracking Project. It was the third straight day of record numbers, and +the figure has doubled in just five weeks." +Study Finds COVID Death Rate Down 30% Since April. The AP (11/12, Murphy) reports, "Deaths per day in the US +have soared more than 40 percent over the past two weeks, from an average of about 790 to more than 1,100 as +of Wednesday, the highest level in three months." This is "still well below the peak of about 2,200 deaths per day +in late April, in what may reflect the availability of better treatments and the increased share of cases among +young people, who are more likely than older ones to survive a bout with COVID-19." + + +Reuters (11/12, Beasley) reports, "The likelihood that a coronavirus infection will +prove fatal has dropped by nearly a third since April due to improved treatment, researchers at the University of +Washington's Institute for Health Metrics and Evaluation (IHME) said on Thursday." In the US, COVID-19 +"now kills about 0.6% of people infected with the virus, compared with around 0.9% early in the pandemic, +IHME Director Dr. Christopher Murray told Reuters." He "said statistics reflect that doctors have figured out +better ways to care for patients, including the use of blood thinners and oxygen support. Effective treatments, +such as the generic steroid dexamethasone, have also been identified." +Redfield: 1M New Cases Per Week Not "Unlikely." CDC Director Redfield said on WXYZ-TV +Detroit (11/12, +151K), "It's really important not to underestimate this virus. The threat is really real. A number of us were saying +back in September that we were on a course to get up from 30,000, 40,000 to 100,000, 150,000, maybe even +200,000 cases a day, and then see the increased hospitalizations a couple weeks later and then, unfortunately, +increased deaths. This is a very serious threat. I don't think it's unlikely in the next week or two that we won't be +having one million cases a week in this country. Clearly, we're likely to see significantly more deaths." +Experts Warn About Trajectory Of COVID Infections In US. The Washington Post + (11/12, lati, 14.2M) reports, +"Public health experts are sounding the alarm about the trajectory of the pandemic in the United States as the +coronavirus spreads through the country largely unabated and officials muse aloud about the possibility of fresh +lockdowns." The warnings "come amid widespread fatigue with restrictions, even as the virus is nowhere near +finished rampaging across the country. Although several states implemented new mitigation measures this week, +many people have been letting down their guards or, in some cases, vowing outright to ignore the rules." +California Cities Reimpose Restrictions As State Reaches Millionth COVID Case. +The AP (11/12, Melley, Taxin) reports California recorded its millionth known +case of COVID-19 case on Thursday, following Texas as the second state to reach the "grim milestone." +The New York Times +(11/12, Fuller, Arango, Hubler, 18.61M) reports, "Citing an alarming increase in cases, San Francisco this week +banned indoor dining at restaurants and paused a plan to reopen schools." In Los Angeles, "thousands of +residents have flocked in recent weeks to the parking lot of Dodger Stadium, one of the largest testing sites in the +nation." In Sacramento, "the number of people hospitalized with the virus has doubled to 158 in the past two +weeks." In San Diego, "where rising cases pushed the city to the most restrictive level of the state's guidelines, +indoor activities will be banned as of Saturday in churches, gyms, yoga studios and movie theaters." +The San Francisco Chronicle (11/12, Allday, 2.67M) says the "upward trend is especially concerning with multiple +threats on the horizon. People will naturally want to come together for the holidays, and the cold weather will +draw them indoors. Plus the flu season could further complicate the COVID-19 pandemic." The Los Angeles +Times (11/12, Money, 4.64M) reports Los Angeles Public Health Director Barbara Ferrer, during a +briefing on Thursday, "emphasized that LA County remains on a knife's edge and that everyone needs to do their +part to keep conditions from worsening." She said, "We all need to act now. ... The actions we take today, +tomorrow and next week have tremendous impact on the health and well-being of many, many people across the +county. If, collectively, we fail to stop the acceleration of new cases, we will have no choice but to look at +additional actions." + + +Upper Midwest, Plains States See COVID Cases Rising. +The Washington Post (11/12, A1, Gowen, Bailey, 14.2M) reports, "Covid's long, dark +winter has already arrived in the Upper Midwest, as cases and deaths surge, snatching lives, overwhelming +hospitals, exhausting health-care providers and raising fears that the region's medical system will be completely +overwhelmed in the coming days." Experts "say that cases are surging in the region as the weather has turned +colder and more people are forced inside - into more poorly ventilated indoor spaces where transmission thrives +- with the virus arriving even in remote areas in largely conservative states where Republican leaders have +resisted mask mandates or business closures, asking their residents to rely instead on personal responsibility." In +Minnesota, Gov. Tim Walz (D) "has warned of more 'nightmare' numbers to come, even as the state has +instituted new restrictions on bars, restaurants and social gatherings in an attempt to stop the spread." NBC +Nightly News +(11/12, story 2, 1:40, Holt, 4.9M) reported that in Michigan, "officials warn the state's healthcare system could +soon capsize amid a nearly five fold surge in COVID hospitalizations since just last month... Hospitals +throughout the state are understaffed and overwhelmed, with cases and hospitalizations doubling every two +weeks." +North Dakota Nurses Association Reject Policy Allowing COVID-Positive Employees To Continue Working. +The Hill (11/12, Weixel, 2.98M) reports that in a statement on Wednesday, the North Dakota +Nurses Association rejected "a policy that would allow COVID-positive nurses to continue treating patients at +coronavirus units of hospitals and nursing homes if they are not symptomatic." They association "said the policy +does not address the root of the problem and called for a statewide mask mandate and other public health +measures to be implemented first." On Monday, Gov. Doug Burgum (R) announced the policy "as a way to ease +pressure on hospitals that are short-staffed and nearing capacity, as COVID-19 cases surge uncontrollably | +throughout the state." North Dakota "is currently the worst-hit state in the country in terms of coronavirus cases +per 100,000 residents, but is one of 15 states without a mask mandate." +Chicago Mayor Issues Stay-At-Home Advisory. +Reuters (11/12, Caspani, O'Brien) reports Chicago +Mayor Lori Lightfoot (D) "issued a stay-at-home advisory and Detroit stopped in-person schooling on Thursday +to staunch the coronavirus outbreak as more than a dozen states reported a doubling of new COVID-19 cases in +the last two weeks." Lightfoot "on Thursday issued a 30-day advisory calling upon residents to stay at home and +have no visitors, even during Thanksgiving festivities." According to Reuters, Illinois "has emerged as the +pandemic's new epicenter in the region as well as across the country." +Bloomberg (11/12, Singh, 4.73M) reports Lightfoot's advisory urges +"residents to avoid leaving home except for work, school and other essentials as new Covid-19 cases and +hospitalizations surge." The restrictions "will take effect on Monday and stay in place for 30 days, or until the +health commissioner changes it. If the city continues on the current path, at least 1,000 more Chicagoans could +die from the virus by the end of the year, Lightfoot said during a press conference on Thursday." +CNN (11/12, +Parks, Jones, Jimenez, Asmelash, 83.16M) reports on its website that Lightfoot said in the release, "The gains we +have made this past year have been the result of our willingness to work together. Even in this difficult moment, +we will continue to unite as we always have for our city in order to halt the rise we're seeing, shake out of the + + +fatigue we've been experiencing, and make the crucial difference in what our future is going to look like." +The Chicago Tribune < https://www.chicagotribune.com/coronavirus/ct-coronavirus-chicago-stay-homelightfoot-20201112-kvlxvdam35f2bn47k5hzegxqte-story.html> (11/12, Munks, Pratt, 2.65M) reports that at a +coronavirus briefing on Thursday, Gov. J.B. Pritzker (D) said, "If things don't take a turn in the coming days, we +will quickly reach the point when some form of a mandatory stay-at-home order is all that will be left. ... With +every fiber of my being, I do not want us to get there. But right now, that seems like where we are heading." +The Chicago Sun-Times +(11/12, 875K) says "more people have contracted the virus in Illinois over the past 15 days - nearly 140,000 - +than during all of summer." Of "all 536,542 people who have tested positive in Illinois so far during the eightmonth pandemic, almost half of them have been diagnosed just since the beginning of October alone." +NYC Schools Seen As Likely To Close Again Amid Resurgence Of COVID. +The New York Times (11/12, +Shapiro, 18.61M) reports New York City's school system - despite having coronavirus transmission being +"strikingly low, with a positive-test rate of just .17 percent according to the most recent data, prompting one of +the city's top health officials to declare that the public schools are among the safest public places around" - is +expected to shut down by Thanksgiving, if not earlier. The move "would be perhaps the most significant setback +yet for the city's recovery since the bleak days of spring, when it was a global center of the pandemic and all the +schools were shuttered." +Meg Oliver of the CBS Evening News +(11/12, +Brulliard, 14.2M) reports the "record-breaking surge in US coronavirus cases is being driven to a significant +degree by casual occasions that may feel deceptively safe, officials and scientists warn - dinner parties, game +nights, sleepovers and carpools." The White House coronavirus task force "has been urging states that are virus +hot spots to curtail maskless get-togethers of family and friends, saying in reports that asymptomatic attendees +*cause ongoing transmission, frequently infecting multiple people in a single gathering. +559 +On NBC Nightly News (11/12) about New York City's Thanksgiving restrictions, HHS +Secretary Azar said, "We've got real practical suggestions" for managing the risks, including opening "your +window if you can to increase ventilation," turning on ceiling fans, and using "single-serving" utensils for food. +Azar said, "The most important thing is, even if we sacrifice this year for Thanksgiving and Christmas, we want +to make sure that everyone in your family is available next year for Thanksgiving and Christmas so you can + + +celebrate fully." +Birx Encourages Mask Wearing To Stem Fall Surge. WFRV-TV + Green Bay, WI +(11/12, 16K) reported that White House Coronavirus Task Force Coordinator Deborah Birx touted the +effectiveness of mask mandates and "said other countries have already had success in stemming the tide of the +virus when they get aggressive with prevention." Birx said, "Even though this fall surge is more rapid, resulting +in more hospitalizations, we already have countries that are successful in flattening the curve, because they put in +a mask mandate, they told you not to gather and take your mask off, and they closed bars and restaurants." Birx +"is asking Americans to hang on for another four to six weeks when it comes to limiting contact." +Clinical Laboratories Warn COVID Testing May Be Delayed. +Politico +(11/12, Lim, 4.29M) reports the American Clinical Laboratory Association, which "represents private labs, +including LabCorp and Quest," warned that labs may soon be facing processing delays for COVID tests amid the +surge of infections nationwide. Quest Diagnostics "this week said its average turnaround time for PCR testing is +two days, but private labs say results will take longer to process once the number of new samples begins to +exceed testing capacity." Association of Public Health Laboratories CEO Scott Becker said, "Labs are doing +everything they can to eke out whatever additional capacity they can, but they are limited by supplies and in +some cases test kits." +Lewandowski Tests Positive For COVID. +USA Today (11/12, Fritze, Santucci, 10.31M) reports Trump campaign +adviser Corey Lewandowski "has tested positive for COVID-19, the latest member of the president's inner circle +to contract the illness in recent weeks." Lewandowski "was present on election night at the White House for a +gathering after initial results showed Trump ahead in several states." Chief of Staff Meadows and HUD +Secretary Carson, "who were also present at the gathering, also tested positive in recent days." The Hill + (11/12, Samuels, 2.98M) says the "White House election night party has emerged as the latest +super-spreader event inside the building. +CNN (11/12,Acosta, +Collins, Vazquez, 83.16M) reports on its website that Lewandowski "said he is feeling fine and will stay home as +a precaution." He "joins a growing list of individuals close to the President to have tested positive for the virus +this week after attending campaign events in the lead-up to and days after the election." In addition to +Lewandowski, Meadows, and Carson, Trump adviser David Bossie and White House Political Affairs Director +Brian Jack "all tested positive for the coronavirus this week." The New York Times + (11/12, Haberman, 18.61M) reports similarly on this story. +Ivanka Trump, Kushner Withdrew Children From School After White House Outbreak. +The New York Daily News (11/12, Crane-Newman, +2.52M) reports Ivanka Trump and Jared Kushner withdrew their children from school "after fellow parents + + +complained about the president's top aide and his daughter failing to follow pandemic protocols amid a COVID- +19 outbreak in the White House." They "withdrew their three children from Milton Gottesman Jewish Day +School in Washington, DC, three weeks after a coronavirus outbreak in the Oval Office and two weeks before +Election Day," and enrolled them at a Maryland school. +Alaska Congressman Tests Positive For COVID. +The AP (11/12, Thiessen) reports Rep. Don Young (R-AK) "announced +Thursday that he has tested positive for COVID-19, a day after the 87-year-old won his 25th term in the US +House." On Twitter, Young wrote, "I am feeling strong, following proper protocols, working from home in +Alaska and ask for privacy at this time." The AP says Young's "positive test came after he was campaigning for +re-election in Alaska, which is experiencing a surge of cases. +The Washington Post (11/12, +Itkowitz, 14.2M) reports Young "downplayed the coronavirus in its early days, calling it the 'beer virus,' a +seeming reference to Corona beer." Young said in March, 'It attacks us senior citizens. I'm one of you. I still say +we have to as a nation and state go forth with everyday activities. " Reuters < https://www.reuters.com/article/ushealth-coronavirus-usa-congress-factb/factbox-u-s-representative-young-latest-lawmaker-to-test-positive-forcovid-19-idUSKBN27T005> (11/12) says Young is the latest of the 17 Republican and nine Democratic +members of the House and Senate to "have tested positive or are presumed to have had COVID-19." +WSJournal: Delaware COVID Settlement Allows Churches To Be Treated Neutrally. +In an editorial, the Wall Street Journal < https://www.wsj.com/articles/covid-and-the-church-in-delaware- +11605223486> (11/12, Subscription Publication, 7.57M) says the decision by Delaware Gov. John Carney (D) to +settle with a pastor alleging the state's emergency orders discriminate against churches means Carney has agreed +to treat houses of worship neutrally. +WSJournal: Biden's COVID Team Would Push For Lockdowns. +In an editorial, the Wall Street Journal +(11/12, Subscription Publication, 7.57M) says Joe Biden's coronavirus advisory committee members believe +lockdowns are beneficial, but in fact they would have negative economic and public health consequences. The +Journal advises Biden to diversify by calling the Great Barrington Declaration authors to join his committee. +Administration Leaving Stimulus Talks To McConnell As Pelosi, Schumer Signal No Compromise. +Bloomberg (11/12, Mohsin, Litvan, Wasson, 4.73M) reports the Trump +Administration is "stepping back from negotiations" over a coronavirus stimulus bill and "leaving it to" Senate +Majority Leader McConnell to "revive long-stalled talks." According to Bloomberg, "While the White House +probably would consult with GOP lawmakers on details of a Covid-19 relief bill, it's now unlikely to take the +lead on talks," and "would only take over if negotiations have to be restarted completely." + + +Meanwhile, the Washington Post (11/12, Werner, 14.2M) reports that on +Thursday, "Congressional Democratic leaders accused Republicans...of refusing to confront the dramatically +worsening coronavirus pandemic and instead acquiescing to" President Trump's "false insistence that he won +last week's presidential election." Trump "tweeted incessantly about the need for an economic relief bill before +the Nov. 3 election, but he has been silent on the matter ever since, and initial signs that congressional +Republicans wanted a deal also have cooled." House Speaker Pelosi and Senate Minority Leader Schumer "said +that [Joe] Biden's election win constitutes a mandate for their demands for a new multitrillion-dollar relief bill, +particularly given how coronavirus case numbers are jumping." +The AP (11/12) says Pelosi and Schumer "adopted a combative posture on +COVID-19 relief on Thursday, pressing their case for a $2 trillion bill that's a nonstarter for Republicans and +faulting the GOP for dragging its feet on acknowledging Biden's victory." According to the AP, "The +message.. was that Republicans should concede Biden won and immediately return to negotiations on COVID +relief, with the Democrats' $2.4 trillion 'HEROES Act' as the starting point." Pelosi told reporters: "It's most +unfortunate that the Republicans have decided that they will not respect the will of the people. It's like the house +is burning down, and they just refuse to throw water on it." +According to Politico (11/12, +Everett, Ferris, 4.29M), "Prospects for a new stimulus bill this year just about hit rock bottom on Thursday" as +Pelosi and Schumer "said they have no plans to budge from their position of demanding a $2 trillion coronavirus +relief measure, and no less." Politico adds that McConnell "rejected their approach," and "said that he still +believes a bill of about $500 billion is the way to go, even though Senate Democrats have repeatedly rejected his +proposal." Reuters (11/12, Cornwell) quotes +McConnell as saying, "I gather she and the Democratic leader in the Senate still are looking at something +dramatically larger. That's not a place I think we're willing to go." Reuters reports that although "a senior official +in Trump's administration said it was leaving any negotiations about a coronavirus relief package to McConnell +and Pelosi for the time being," there is "no sign such talks were imminent." +The New York Times +(11/12, Smialek, Cochrane, Fandos, Rappeport, 18.61M) says "in holding firm to their respective positions - +Democrats demanding $2.4 trillion as a starting point, with Republicans proposing a fraction of that amount - +congressional leaders appeared to be closing the door on the possibility of a year-end compromise." +The AP (11/12) reports that Biden's transition team announced on Thursday that +he has spoken with Pelosi and Schumer "about 'intensifying' the country's coronavirus response and coping with +the economic fallout the pandemic has inflected." According to the AP, "They also discussed the 'urgent need' to +use the lame duck congressional session to approve bills on slowing the spread of COVID-19, as well as +economic relief for "working families and small businesses, support for state and local governments trying to +keep front-line workers on the payroll,' expanded unemployment insurance and expanded access to affordable +health care." +Federal Judge Schedules Conference On Trump Defamation Suit. +The Hill (11/12, Budryk, 2.98M) reports that Judge Lewis Kaplan "on Thursday signaled +columnist E. Jean Carroll's defamation lawsuit against President Trump can move forward, scheduling a +telephone conference in the case for Dec. 11." The conference scheduling follows Kaplan's earlier denial of the +Justice Department's attempt to "take over the case." Carroll's lawyer, Roberta Kaplan, said in a statement to + + +ABC News, "We look forward to finally moving ahead with discovery in the case, which has been on hold since +Trump filed his motion for a stay last February, and look forward to the initial conference in E Jean Carroll's +case on Dec. 11, if the parties cannot agree on a schedule." +At Least Four Dead As Eta Moves Through Southeast. +The CBS Evening News (11/12, story 8, +1:05, Holt, 4.9M), Sam Brock said, "A nightmare in North Carolina: a deadly November storm steam rolling +through the Southeast, forcing water rescues across the region." The AP < https://apnews.com/article/tropicalstorm-eta-dumps-rain-on-florida-68fa08d7d6e2c76c19cbdc8dda491875> (11/12, Anderson, Frisaro) reports Eta +"raced off the Southeast Atlantic seacoast late Thursday, spreading heavy rains and gusty winds around the +Carolinas only hours after blustering across north Florida... The storm system triggered flash flooding, multiple +water rescues and road closures, and at least one collapsed bridge in South Carolina." +The Washington Post (11/12, +Cappucci, 14.2M) says "after a 3,000-mile journey, an impact on seven countries, four landfalls and two bouts as +a hurricane, the two-week rampage of Tropical Storm Eta was progressing through its final destructive act." +ABC World News Tonight (11/12, story 6, 1:05, Muir, 6.57M) and the New York Times + (11/12, Vigdor, Paybarah, 18.61M) +also report. +Appeals Court Upholds Harvard Affirmative Action Ruling. +The New York Times (11/12, +Hartocollis, 18.61M) reports, "A federal appeals court on Thursday ruled that Harvard's admissions process did +not violate civil rights law, but the victory for the university could be short-lived should the case be taken up by +the Supreme Court." The case has "elevated efforts by conservative activists," who have sought "to reach the +Supreme Court, where an increasingly conservative tilt because of three justices appointed by President Trump +has made it appear more likely that they could prevail despite more than 40 years of precedent." +The Washington Post (11/12, Anderson, 14.2M) says that "Students for Fair Admissions, a group opposed to the +use of race in admissions decisions, sued the university in 2014 in an effort to halt what it alleged was unlawful +discrimination" against Asian-American applicants. US District Judge Allison Burroughs "ruled in 2019 for +Harvard on all counts" in the case, a decision that appellate Judges Jeffrey Howard and Sandra Lynch upheld +Students for Fair Admissions president Edward Blum said while the group is "disappointed" in the ruling, the +suit "is now on track" for a ruling by the Supreme Court. +The Wall Street Journal (11/12, Korn, Subscription Publication, 7.57M) reports that Howard and +Lynch said in a 104-page opinion that Harvard has targeted measurable goals in considering race and that +variances in admission rates for minority students invalidates arguments that the university used quotas, adding +that the school's subjective criteria does not indicate bias toward Asian-American applicants. +WSJournal: Harvard Ruling Signals Need For Definitive Supreme Court Decision. In an editorial, the Wall Street + + +Journal (11/12, Subscription +Publication, 7.57M) argues that cases around affirmative action like the Harvard case continue to surface because +the Supreme Court has failed to offer clear definitions of how or how much race should be considered as a factor +in admissions. The Journal says that an appeal presents an opportunity for the Supreme Court to offer +clarification in accordance with the majority opinion of Americans who reject the consideration of race. +Deputy AG Rosen Reportedly Blocked Charges Against Zinke. +The Washington Post (11/12, Eilperin, Zapotosky, 14.2M) reports that Deputy Attorney General Jeffrey Rosen "deferred a bid +from line prosecutors to move forward with possible criminal charges against former interior secretary Ryan +Zinke, saying they needed to gather more evidence and refine the case." According to the Post, "The move late +last year by Rosen...angered some career prosecutors in the Justice Department's Public Integrity Section and has +delayed for months the release of an Interior Department Office of Inspector General report about Zinke's +conduct." At issue is whether Zinke "made false statements to Interior investigators who were looking into his +decision not to grant a petition by two Indian tribes to operate a commercial casino off reservation land" in +Connecticut. +International News +Chinese Government Stopping Taiwan's Participation In WHO Meeting. +The Wall Street Journal (11/12, Deng, Subscription Publication, 7.57M) reports that opposition from +members of the Chinese Communist Party is stopping Taiwan - which has not recorded locally transmitted +infections in approximately seven months - from participating in a World Health Organization meeting to +address the CÓVID-19 pandemic. +Prime Minister Says Japan Does Not Need To Declare COVID State Of Emergency. +Suga said Friday that Japan does not need a state-of-emergency declaration over the coronavirus pandemic, +"adding that experts backed that view." Speaking to reporters, "he said the government's initiative to boost +domestic tourism with subsidies also did not need to be revised." +Germany, France See Slowing Of COVID Cases, But Hospitals Remain Crowded. +The AP (11/12, Moulson) reports, "The surge of new coronavirus cases appears +to be slowing in Germany and France, generating hopes that the two European heavyweights are beginning to +regain control over the pandemic." However, "authorities said Thursday that hospitals are crowded and are likely +to face further strain in the coming weeks." German Minister of Health Jens Spahn "told his compatriots to brace +for a long winter, regardless of whether a partial shutdown succeeds in bringing down the caseload," while +Lothar Wieler, head of Germany's national disease control center, said there are "already more cases in intensive + + +care than in April, and the cases have doubled in the past two weeks." +Germans Protesting COVID Restrictions Becoming Increasingly Violent. The Washington Post + (11/12, Morris, Beck, 14.2M) reports there is "a growing violent +undercurrent at large-scale street demonstrations against coronavirus restrictions" in Germany. The Post says the +"developments point to an increasingly radicalized movement of virus skeptics in Germany, embraced by the +country's far-right extremist groups and energized by global conspiracy theories, notably those put forth by the +US-born QAnon movement." Last weekend, "far-right groups marched alongside the demonstrators..stoking +concerns among security officials that they will gain recruits and draw more demonstrators to violence, with +bomb- and weapon-making material already circulating in coronavirus-skeptic circles online." +South Africa Opens To Foreign Visitors. +The AP (11/12, Magome) reports, "In an effort to revive its tourism industry, +South Africa has opened up international travel to visitors from all countries, President Cyril Ramaphosa has +announced." South Africa "will now admit foreign visitors providing they produce negative COVID-19 test +results, Ramaphosa said in a broadcast address Wednesday night." According to the AP, the step makes South +A frica "one of the world's countries most open to international travel" and "comes as cases of the disease are +slowly increasing in the country. Ramaphosa said his government will closely monitor any signs that +international visitors increase transmission rates." +US Allies In Iraq Said To Fear Targeting By Iran. +The Washington Post (11/12, Loveluck, Ryan, Salim, +14.2M) reports, "Iraqis who have worked closely with the U.S. military in their country have grown increasingly +alarmed that they could be targeted for attack, fearing their personal identifying information has been obtained +by Iran-backed militias." According to Iraqi officials, the US military provides personal information, "including +names, addresses and license plate numbers...to secure permission for...translators to move around Iraq." While a +US military spokesperson said the US-led coalition "does not share personally identifiable information about the +translators with the Iraqi military or government," The Post says three documents "show that such information +provided by the U.S.-led coalition has been circulated by various elements of the Iraqi security forces over the +past year" and Iran-backed militias "have recently been escalating their attacks on American interests in Iraq." +NYTimes Analysis: Syrian Refugees Resist Return Under Current Leadership. +The New York Times +(11/12, Hubbard, 18.61M) reports that "the Syrian government hosted a lavish conference in the capital, +Damascus, this week aimed at trying to get the more than six million refugees who fled the country's civil war to +come home," but "many refugees say they are not ready to return" as long as President Bashar al-Assad "and his +government remain in power." While al-Assad "appears to be secure and the big battles have subsided" since +protests calling for his ouster, "Syria is a shattered country, with Mr. al-Assad ruling only part of its territory" +and "on top of material concerns, most of the refugees fled violence committed by Mr. al-Assad's government, +and they now fear that going home could mean arrest or forced conscription into his army." al-Assad largely +ignored such concerns in this week's conference, blaming "an international conspiracy" for the war and accusing +"Arab and Western countries of...preventing [refugees] from returning." + + +NYTimes Analysis: Afghan Officials Do Not Expect Biden To Stop Trump's Troop Withdrawal. +The New York Times +(11/12, Gibbons-Neff, 18.61M) says, "It is a desperately difficult time for Afghanistan. American troops, +honoring President Trump's deal with the Taliban, are still on their way out of the country, despite the stalling of +peace talks between the insurgency and the Afghan government, and a wave of intensified Taliban offensives +near important cities." The Times adds, "Officials in Kabul are very aware that Americans are tired of the war - a +fact made clear by a near absence of the issue in presidential debates, and by [Joe] Biden's seeming agreement +with President Trump's desire to get out of Afghanistan." However, according to the Times, "in Mr. Biden, +Afghan officials said they hoped to gain a less capricious and more communicative ally, though they know he is +unlikely to stop the troop withdrawal." +Five Americans, Two Others Killed In Crash Of Peacekeeping Force Helicopter In Sinai. +NBC Nightly News (11/12, story 8, +1:15, O'Donnell, 4.06M) that it is "the single worst loss of American life in the nearly four decades US troops +have patrolled the Sinai. About 450 Americans are part of an international force set up to monitor the 1979 peace +treaty between Egypt and Israel." +The New York Times +(11/12, Kershner, Schmitt, 18.61M) reports that the Multinational Force and Observers peacekeeping force +"consists of 1,154 troops from 13 countries, including Australia, Britain, Fiji, the United States and Uruguay:" +The Washington Post (11/12, Raghavan, Hendrix, 14.2M) +reports that in a statement, the MFO "suggested there was no indication that the event was terrorism related. 'At +this point, there is no information to indicate the crash was anything except an accident,' the force said." The +Wall Street Journal (11/12, Youssef, Malsin, Subscription Publication, 7.57M) also reports. +Pompeo To Visit Golan Heights, West Bank Israeli Settlement. +Axios (11/12, Ravid, 521K) reports Secretary of State Pompeo "is planning to visit the Golan +Heights and an Israeli settlement in the West Bank next week, both firsts for a U.S. secretary of state." Since +1967, "all previous U.S. administrations have treated the West Bank and Golan Heights as occupied territory." +Axios says the trip "seems intended to highlight the Trump administration's policy shifts on Israel. For Pompeo, +it also has domestic political significance ahead of a possible presidential run in 2024." + + +Wolf Planning To Visit Several Latin American Countries In Early December. +The Washington Post (11/12, Miroff, 14.2M) reports Acting +DHS Secretary Wolf "is making plans to travel to several countries in Latin America next month, a proposal that +has raised concerns about the necessity of such a trip in the middle of the coronavirus pandemic. The trip is +tentatively scheduled for the week of Dec. 7, and it could include stops in El Salvador, Panama, Colombia, Brazil +and Ecuador, according to three people with knowledge of the plans." +Russian Military Operations Off Coast Of Alaska Impact Private US Ships. +The New York Times +(11/12, 18.61M) reports on Russian military operations "inside the U.S. economic zone off the coast of Alaska" +in August, "the latest in a series of escalated encounters across the North Pacific and the Arctic." Private US +fishing ships received warnings "in a mixture of Russian and accented English" to leave the area. One captain +told the Times, "It was frightening, to say the least. The Coast Guard's response was: Just do what they say." +Hong Kong Legislature Opens Without Pro-Democracy Lawmakers. +The New York Times (11/12, +Wang, May, 18.61M) reports that on Thursday, Hong Kong's legislature opened after lawmakers from the prodemocracy opposition were either ousted by the Chinese Communist Party or resigned to protest the ousters. The +Times adds, "Unfazed, the remaining pro-Beijing camp got to work, reviewing a bill on parking spaces and +discussing flu vaccines." According to the Times, the opposition "could only stand outside for one final protest, +hanging two banners criticizing Hong Kong's chief executive - and then taking them down just a few minutes +later before security could do so." The Wall Street Journal (11/12, Khan, Subscription Publication, 7.57M) +reports senior Chinese officials have rejected international criticism of the terminations and the mass resignation. +EU Plans Pro-LGBTQ Policies In Response To Hungary And Poland. +The New York Times +(11/12, Pronczuk, Novak, 18.61M) reports the European Union has "unveiled policies intended to strengthen the +rights of L.G.B.T.Q. people, proposals that appear aimed particularly at right-wing governments in Hungary and +Poland that have promoted discrimination." The European Commission moves "would classify hate crime, +including homophobic speech, on a list of 'E.U. crimes' that also contains offenses such as drug trafficking and +money laundering. ... The proposal would also protect same-sex families in all 27 of the bloc's members, and +promises more funding for organizations promoting equality." +Researchers Conclude World "Already Past A Point Of No Return For Global Warming." +USA Today (11/12, Rice, 10.31M) reports, "Even if human-caused greenhouse gas +emissions can be reduced to zero, global temperatures may continue to rise for centuries afterward, according to +a scientific study" published in the British journal Scientific Reports on Thursday. The authors write, "The world + + +is already past a point of no return for global warming." The only way "to stop the warming, they say, is that +'enormous amounts of carbon dioxide have to be extracted from the atmosphere.** +NYTimes Analysis: Nobel Peace Prize Repeatedly Awarded To Dubious Winners. +The New York Times (11/12, +Gladstone, 18.61M) writes that "at least six times in recent decades," the Nobel Peace Prize has been awarded to +"recipients whose actions and behavior - either before or after the honor was given - have been viewed as +unworthy or in some cases even absurd." Ethiopian Prime Minister Abiy Ahmed, the 2019 laureate, has moved +"to violently suppress the Tigray region and risk plunging Africa's second most-populous country into a +disastrous civil war"; the peace agreement pushed through by then-Colombian President Juan Manuel Santos, the +2016 winner, largely collapsed; "even [Barack] Obama himself questioned" his 2009 selection, "given that he +had yet to achieve any significant result for the cause of world peace"; then-South Korean President Kim Daejung was honored in 2000, and two decades later, "the prospect of peace between the two Koreas seems even +more remote"; efforts at peace between Israel and Palestine "have repeatedly faltered" since three statesmen +were honored for their work in 1994; and Aung San Suu Kyi, honored in 1991, has rejected evidence that Burma +"has systematically and brutally persecuted the country's Rohingya Muslim minority." +The Big Picture +Headlines From Today's Front Pages. +Wall Street Journal: +US Backs Down On TikTok +As Covid-19 Surges To New Levels Across US, States Impose Flurry Of Measures + +China's President Xi Jinping Personally Scuttled Jack Ma's Ant IPO < https://www.wsj.com/articles/chinapresident-xi-jinping-halted-jack-ma-ant-ipo-11605203556> +Deposit Interest Rates Are Taking A Pandemic Nosedive +World's Explorers, Hemmed In By Pandemic, Offer Tips For Coping With Lockdown + +New York Times: +Election Officials Directly Contradict Trump on Voting System Fraud + +N. Y.C. Schools May Close Again, a Grim Sign of a Global Dilemma + +Wrong Again: How Polls Misread 2020 Voters < https://www.nytimes.com/2020/11/12/us/politics/election-pollstrump-biden.html> +Republicans' Wall of Support For President Begins to Crack + +'Are We Getting Invaded?' A 21st-Century Cold War in the Arctic + +Washington Post: + + +"We're The Ones Who Won": A GOP House Guarantee For 2022 + +Democrats Renew Calls For Expanded Virus Relief Bill +As Trump Tweets, Many Duties Of His Office Languish +Upper Midwest Faces A Reckoning +Iraqis Fear Work For US Makes Them Militia Targets +A Blueprint For Back-To-School +Financial Times: +Central Bank Chiefs Upbeat On Vaccine Boost To Global Economy +Covid Vaccine Presents Pharma With Shot At Redemption And Profits < https://www.ft.com/content/Ob18aac0- +50a3-4694-9d28-ccbc44debcb2?FTCamp=engage/CAPI/email/Channel_Bulletin//B2B> +Republican Resistance To Biden Victory Starts To Crack +Washington Times: Photos Show China Expanding Nuclear Arms Plants + +First Vaceines Will Go To Select Groups +Trump Supporters Start To Give Up On Legal Challenges + +Obama-appointed Judges Get Fraud Cases +Trump Bans Funding For Chinese Military +Story Lineup From Last Night's Network News: +ABC: COVID Surge; Eli Lilly Antibody Treatment; GOP-Election Results; Trump-Pandemic; Egypt-US Troops +Killed; Tropical Storm Eta; Ahmaud Arbery Case; California-Small Plane Crash; Minnesota-Vehicle Pile-Up; +Biden-Pope Francis; Country Music Awards. +CBS: COVID Surge; COVID-New York City; Tropical Storm Eta; Obama-Election Fraud Comments; GOP- +Stacey Abrams; Obama-Memoir; Tropical Storm Eta; Egypt-US Troops Killed; California-Small Plane Crash; +COVID Vaccines; Grocery Stores Restricting Items; Rockefeller Center Christmas Tree; Holiday Travel; Tribute +to Veterans. +Network TV At A Glance: +COVID Surge - 14 minutes, 30 seconds +GOP-Election Results - 5 minutes, 40 seconds +Tropical Storm Eta - 4 minutes, 10 seconds +Egypt-US Troops Killed - 1 minute, 55 seconds +Story Lineup From This Morning's Radio News Broadcasts: +ABC: Georgia-Hand Recount; COVID Surge; Alex Acosta-Epstein Case; UN-AI-Shabab extremists. +CBS: COVID Surge; Biden-Pope Francis; Trump-2024; Tropical Storm Eta; Egypt-US Troops Killed; +FOX: COVID Surge; Pennsylvania-Absentee Ballots; COVID-Student Athletes. + + +NPR: COVID Surge; Georgia-Hand Recount; Trump Campaign Staff; Cybersecurity and Infrastructure Security +Agency-No Evidence of Voter Fraud. +Washington's Schedule +Today's Events In Washington. +White House: +* President Trump +- Receives an update on Operation Warp Speed. +* Vice President Pence - +- Keynotes Council for National Policy Meeting. +US Senate: +* No public schedule released +US House: +* House Speaker Nancy Pelosi holds weekly press conference +Location: HVC Studio A, U.S. Capitol Visitor Center, Washington, DC; 10:45 AM +* House of Representatives on recess from 2 Oct - 16 Nov +Cabinet Officers: +* Secretary of State Pompeo begins France / Turkey / Georgia / Israel / UAE / Qatar / Saudi Arabia trip - +and Sardi Arabia, With agenda, respectively i Erading meeting President me, the Macron oregate ser +ind Saudi Arabia, with agenda +Minister Benjamin Netanyahu in Israel; meeting Abu Dhabi Crown Prince Mohammed bin Zayd in the United +Arab Emirates; meeting Emir Tamim bin Hamad Al Thani and Deputy Prime Minister and Foreign Affairs +Minister Mohammed bin Abdulrahman Al Thani in Qatar; and meeting Crown Prince Mohammed bin Salman in +Saudi Arabia +Visitors: +* No visitors scheduled. +This Town: +* OAS Permanent Council High-Level Virtual Dialogue - Organization of American States High-Level Virtual +Dialogue: "Water and Strategic Partnerships for Integration in Central America'. Speakers include Guatemalan + + +Vice President Guillermo Castillo Reyes, Honduran Vice President Ricardo Antonio Alvarez, El Salvadoran Vice +President Felix Ulloa, Central American Integration System Secretary General Marco Vinicio Cerezo Arevalo, +Global Environment Facility CEO and Chair Carlos Manuel Rodriguez, World Bank 2030 Water Resources +Group Global Program Manager Karin Krehnak, Inter-American Development Bank Water and Sanitation Chief +Sergio Campos, and Nestle Chair Paul Bulcke; 10:00 AM +* CSIS / U.S. Naval Institute online Maritime Security Dialogue - 'Information Warfare: From A Supporting +Role To A Leading Role' online Maritime Security Dialogue online event hosted by Center for Strategic and +International Studies and the U.S. Naval Institute, with Deputy Chief of Naval Operations for Information +Warfare/Director of Naval Intelligence Vice Adm. Jeffrey Trussler; 10:00 AM +* CSIS online conversation with U.S. Ambassador to Lebanon - "Lebanon's Challenges' Center for Strategic and +International Studies Commission on Strengthening America's Health Security online event with U.S. +Ambassador to Lebanon Dorothy Shea, who discusses the evolving humanitarian, health, economic, and political +crises in Lebanon, the aftermath of the 4 Aug Beirut explosion and evolution of U.S. policy since; 10:00 AM +* Chilean President Pinera speaks on CFR event - Council on Foreign Relations hosts Chilean President +Sebastian Pinera for an online event, to discuss short term and long term economic recovery after coronavirus +(COVID-19), Chile's new constitution, global governance, and the shifting geopolitics of Latin America; 11:00 +AM +* Hudson Institute event on 5G in the U.S. - 'Creating an American 5G Advantage' Hudson Institute virtual +discussion, with Office of the Director of Defense Research and Engineering Principal Director for SG Dr Joseph +Evans, Oracle Senior Director for Strategic Initiatives Cheryl Davis, AT&T Vice President of Security and +Technology Policy Chris Boyer, Parallel Wireless CEO and President Steve Papa, and Hudson Institute's Bryan +Clark, Dr Dan Patt, and Tom Duesterberg; 12:00 PM +* BPC online discussion on "telehealth' with Independent Sen. Angus King - 'What's Next for Telehealth: +Sustaining and Expanding Access After COVID-19' Bipartisan Policy Center online discussion, on the benefits +of telehealth during the coronavirus (COVID-19) pandemic and what things look like for the future of telehealth +in Maine and throughout the country. Featured speakers include Independent Sen. Angus King, Stratis Health +President Jennifer Lundblad, Bipartisan Policy Center Associate Director of the Health Project Dena +McDonough, Western Maine Health Family Medicine Physician Dr Lisa Miller, and Northern Light Acadia +Hospital President Scott Oxley; 12:00 PM +* Axios hosts virtual event on the future of health care with Dem Sen. Tina Smith - Axios hosts 'Health Care: +2021 virtual event on the future of health care in America, including how to expand health insurance access and +the path forward to universal coverage following the presidential election and amidst another wave of +coronavirus (COVID-19) pandemic concerns. Speakers include Democratic Sen. Tina Smith, The Foundation for +Research on Equal Opportunity President Avik Roy, and UnitedHealthGroup OptumHealth Services CEO +Heather Cianfrocco; 12:30 PM +* Progressive Caucus Center 'Meeting the Moment' summit day two, with Dem Members of Congress - +Progressive Caucus Center holds 'Meeting the Moment: Building a More Resilient Nation' event, day two, with +speakers today including House Speaker Nancy Pelosi and fellow Democratic Reps. Pramila Jayapal, Mark +Pocan, Ilhan Omar, Deb Haaland, Jamie Raskin, Chuy Garcia, Veronica Escobar, and Jared Huffman, actor and +activist Alyssa Milano, Be a Hero Fund founder Ady Barkan, Poor People's Campaign's Rev. Dr William Barber, +United We Dream Executive Director Greisa Martinez, Demos President Sabeel Rahman, AFL-CIO Secretary- +Treasurer Liz Schuler, Data for Progress Vice President Julian Brave NoiseCat, People's Action Institute +Executive Director George Goehl, home care worker Brenda Williams, and Center for International Policy +President and CEO +Copyright 2020 by Bulletin Intelligence LLC Reproduction or redistribution without permission prohibited. +Content is drawn from thousands of newspapers, national magazines, national and local television programs, +radio broadcasts, social-media platforms and additional forms of open-source data. Sources for Bulletin +Intelligence audience-size estimates include Scarborough, Gfk. MRI, comScore, Nielsen, and the Audit Bureau +of Circulation. Data from and access to third party social media platforms, including but not limited to Facebook, +Twitter, Instagram and others, is subject to the respective platform's terms of use. Services that include Factiva +content are governed by Factiva's terms of use . +Services including embedded Tweets are also subject to Twitter for Website's information and privacy policies +. The FBI News Briefing is published five days a week by + + +Bulletin Intelligence, which creates custom briefings for government and corporate leaders. We can be found on +the Web at BulletinIntelligence.com, or called at (703) 483-6100. diff --git a/vision-fixhub/ds9-parsed-01/26a98b75eb76228610dc223094756b7fa0ac6c9deb130d93ce3ca160ec9b7595.receipt.json b/vision-fixhub/ds9-parsed-01/26a98b75eb76228610dc223094756b7fa0ac6c9deb130d93ce3ca160ec9b7595.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..d388233e2c0c3de4fd7f69e950493604efc8e52c --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/26a98b75eb76228610dc223094756b7fa0ac6c9deb130d93ce3ca160ec9b7595.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -832, + "dataset": "marble-joined", + "doc_id": "26a98b75eb76228610dc223094756b7fa0ac6c9deb130d93ce3ca160ec9b7595", + "engine": "marble-apple-vision", + "event_count": 191, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "2a1673f7330dd0a67c2795ec5ccae30b5c928c2f468f38a39188d0f907cb8087", + "output_sha256": "2e3f7240ad7c681555da5eaf54ffc42aa353d22bf48df98fc7f9a67c8905b87f", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/26ac2b664e49694155470cc25992bd1f84e6071802cc20f97bcd7d58b106afe8.md b/vision-fixhub/ds9-parsed-01/26ac2b664e49694155470cc25992bd1f84e6071802cc20f97bcd7d58b106afe8.md new file mode 100644 index 0000000000000000000000000000000000000000..25904e269ade56b4676b9a6d683e32aa7f72969f --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/26ac2b664e49694155470cc25992bd1f84e6071802cc20f97bcd7d58b106afe8.md @@ -0,0 +1,69 @@ +From: +To: +Ce: +Subject: RE: Subpoena requests for flights/travel +Date: Wed, 22 Jan 2020 03:20:29 +0000 +Thanks! I was planning on making those calls tomorrow; just wanted to get things moving so it was in place to +go. +- +On Jan 21, 2020 7:21 PM, +" 4 +P wrote: +We'll get them prepped. Have you guys confirmed with their relevant contact people that they won't disclose? Totally +understand the value of the subpoenas but a little nervous sending subpoenas naming +without +knowing that the info will be kept confidential. +Subject: Subpoena requests for flights/travel +Hi all, +Can we get subpoenas for the below airlines for any and all domestic flights? +Identifiers: +Ghislaine Maxwell and/or Ghislaine Borgerson +• DOB +• 1994-1998 and at least since July 2019-present +EMAIL: +Airline Reporting Corporation +Online Service: Airline Reporting Corporation +Online Attn: Attn: TIP Product Team +Online Service Address: 3000 Wilson Blvd., Suite 300 +Arlington, VA 22201 + + +Delta Airlines, Inc. +Contact Name: +Online Service: Delta Airlines Inc, +Online Service Address: P.O. Box 20574 +Atlanta, GA 30320 +Note(s): Subpoenas are accepted via email and facsimile. Email is preferred. +American Airlines +Contact Name: +Online Service: American Alines +Online Attn: Attn: Corporate Security +Online Service Address: 4333 Amon Carter Blvd. +Ft. Worth, TX 76155 +Alaska Airlines +Online Service: Alaska Airlines +Online Service Address: 19300 International Blvd +Seattle, WA 98168 +E-mail Address: +Southwest Airlines +Contact Name: Legal Department +Online Service Address: P.O. Box 36611 +Dallas, TX 75235 +E-mail Address: +EMAIL or FAX +United Airlines Corporate Security +Contact Name: +E-ma +Send +Emai +fax - + + +FAX +JETBLUE AIRWAYS CORPORATION +Online Service: JETBLUE AIRWAYS CORPORATION +Online Attn: +ATTN: Legal Department +Online Service Address: 2701 Queens Plaza N., Suite 1 +Long Island City, NY 11101 +Legal Department will accept legal process/subpoenas by Fax or US Mail. diff --git a/vision-fixhub/ds9-parsed-01/26ac2b664e49694155470cc25992bd1f84e6071802cc20f97bcd7d58b106afe8.receipt.json b/vision-fixhub/ds9-parsed-01/26ac2b664e49694155470cc25992bd1f84e6071802cc20f97bcd7d58b106afe8.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..955f1b998da29e49dddfc167b6de3dd6a77b77c9 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/26ac2b664e49694155470cc25992bd1f84e6071802cc20f97bcd7d58b106afe8.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -36, + "dataset": "marble-joined", + "doc_id": "26ac2b664e49694155470cc25992bd1f84e6071802cc20f97bcd7d58b106afe8", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "04e05a4787802572627dcad989bfce0dfc62b885a065429067ae5ef0144dc24c", + "output_sha256": "a01688a7bf55c0f9d6f83df334458773eab1b7ecd559fe1a36b635c9018c14df", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/26ed14bc6a7ff9e55c91884cd2ed00b37bf58d79490a884f7b4b040c5c3e1a1e.md b/vision-fixhub/ds9-parsed-01/26ed14bc6a7ff9e55c91884cd2ed00b37bf58d79490a884f7b4b040c5c3e1a1e.md new file mode 100644 index 0000000000000000000000000000000000000000..0ca01c444369716114935e40c7dde38e89b6da50 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/26ed14bc6a7ff9e55c91884cd2ed00b37bf58d79490a884f7b4b040c5c3e1a1e.md @@ -0,0 +1,128 @@ +From: +To: +Subject: RE: 338 E. Washington Road, Bradford, NH +Date: Mon, 06 Jul 2020 23:52:41 +0000 +Inline-Images: image001 jPg; image002.jpg +We can't use a trial subpoena with out a trial date -I do want this information for bail purposes, but I'm not sure how we +could obtain it. We could ask +to just call her and interview her and see what information she can provide (or if she +can refer us to a non-lawyer involved in the process we could talk to). +From: +Sent: Monday, July 6, 2020 7:50 PM +To: +Subject: FW: 338 E. Washington Road, Bradford, NH +We could serve a trial subpoena, I guess? But probably not a GJ subpoena?? And do we want this sooner rather than +later, for use at the bail arg? (Also apologies if either of you has already moved ahead with this, my inbox remains a slight +disaster, though to be fixed by the end of the day, come hell or high water.) +From: +To: +(NY) (FBI) < +Sent: Monday, July 06, 2020 13:29 +Cc: +Subject: FW: 338 E. Washington Road, Bradford, NH +Hey all, +FYI... see below. The attorney who handled the purchase closing for 338 E. Washington Road, Bradford, NH. I spoke with +her on the phone and she is willing to speak further after going through the proper channels. +From: +To: +Cc: +Sent: Monday, July 6, 2020 12:04 PM +| (BS) (FBI) < +1. (NY) (FBI) < +Subject: RE: 338 E. Washington Road, Bradford, NH +Thank you for the introduction | +and nice to meet you +7. I am a real estate attorney in NH. I was retained +by "Jen and Steve Marshal" and handled the purchase closing for Granite Reality, LLC which was the buying entity of the +property located at 338 E. Washington Road, Bradford, NH where Ghislaine Maxwell was arrested on Thursday July 2, +2020. I handled the title and settlement for the closing and was retained for additional services. +So that I do not breach my ethics obligations pursuant to the NH Bar, 1 presume you may proceed with issuing a subpoena +for my file. +Thank you + + +Regards, +Attorney at Law +Admitted to Practice in NH and MA +Phone +Fax +Clickl +Ito watch our YouTube Channel—delivering content on real estate topics on a weekly basis! +Celebrating 13 Years of Service +Locations: Bedford, NH - Concord, NH - Hampton, NH - Keene, NH - New London, NH - Windham, NH - Norwich, VT - +Andover, MA +Mailing Address For All Correspondence: +FRAUD ALERT: DO NOT WIRE FUNDS unless you have called our firm to verify wire instructions. Even if an email appears as if it was generated by +this firm or a party to your transaction, CALL US at +P to verify the information before transmitting your funds. +This email message is intended only for the named recipients. It may contain confidential information that is privileged or +that constitutes attorney work product. If you are not the intended recipient, you are hereby notified that any +dissemination, distribution or copying of this email and any attachments is not authorized and is strictly prohibited. If you +have received this email in error, please notify the sender by replying to this email and delete the message and any +attachments from your system. +From: +Toi +Cc: +(BS) (FBI) < +Sent: Monday, July 6, 2020 11:58 AM +1. (NY) (FBI) < +Subject: RE: 338 E. Washington Road, Bradford, NH +Hello +I hope that you had a nice weekend and good July 4th. CC'ed on this email is Special Agent | +up with you directly about Ghislaine Maxwell. +She will follow +Thank you again for reaching out and don't ever hesitate to be in touch, +Special Agent +Federal Bureau of Investigation - Boston +From:/ +Sent: Friday, July 3, 2020 6:58 PM + + +To: I +(BS) (FBI) < +Subject: Re: 338 E. Washington Road, Bradford, NH +Thank you +. I appreciate your assistance. +Happy Fourth! +Attorney at Law-NH & MA +From: +(BS) (FBI) < +Sent: Friday, July 3, 2020 6:44 PM +ToL +Subject: Re: 338 E. Washington Road, Bradford, NH +HITT +I remember meeting! Thank you for reaching out! That was a great conference, I really enjoyed being part of it. +I will reach out to the agents involved in that case and be in touch shortly (it will likely be Monday). +Thanks again for reaching out, I hope that you are doing well! Have a great July 4th. +Special Agent +Federal Bureau of Investigation - Boston Division +From: +To: +Sent: Friday, July 3, 2020 5:34 PM +| (BS) (FBI) < +Subject: 338 E. Washington Road, Bradford, NH +Dear +We met at the Mortgage Banker's conference in Portsmouth, NH in February. +I handled the real estate closing for 338 E. Washington Road, Bradford, NH where Ghislaine Maxwell was arrested +yesterday. I have information regarding my legal representation that could be of interest. I am hoping you may be willing +to connect me with an agent so that I may be helpful in providing my file. +Thank you +Regards, + + +Attorney at Law +Admitted to Practice in NH and MA +Phone +Fax +Click +to view our YouTube channel +Celebrating 13 Years of Service +Locations: Bedford, NH - Concord, NH - Hampton, NH - Keene, NH - New London, NH - Windham, NH - Wilder, VT - +Andover, MA +Mailing Address For All Correspondence: +FRAUD ALERT: DO NOT WIRE FUNDS unless you have called our firm to verify wire instructions. Even if an email appears as if it was generated by +this firm or a party to your transaction, CALL US atl +to verify the information before transmitting your funds. +This email message is intended only for the named recipients. It may contain confidential information that is privileged or +that constitutes attorney work product. If you are not the intended recipient, you are hereby notified that any +dissemination, distribution or copying of this email and any attachments is not authorized and is strictly prohibited. diff --git a/vision-fixhub/ds9-parsed-01/26ed14bc6a7ff9e55c91884cd2ed00b37bf58d79490a884f7b4b040c5c3e1a1e.receipt.json b/vision-fixhub/ds9-parsed-01/26ed14bc6a7ff9e55c91884cd2ed00b37bf58d79490a884f7b4b040c5c3e1a1e.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..85c9e798419dfc58fde9320acb42013318bb9efc --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/26ed14bc6a7ff9e55c91884cd2ed00b37bf58d79490a884f7b4b040c5c3e1a1e.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -48, + "dataset": "marble-joined", + "doc_id": "26ed14bc6a7ff9e55c91884cd2ed00b37bf58d79490a884f7b4b040c5c3e1a1e", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "04de0d6de85f255249f379af25e8024ff57a55411328610b877534577fda7db5", + "output_sha256": "018b337fc6f51fb4b6765a40e759b7e5061dac0460ce69bbfd8274e064788509", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/26fd6262d28036ccd807eba281077a76e124edb6ad84781dac277ecd116d24c2.md b/vision-fixhub/ds9-parsed-01/26fd6262d28036ccd807eba281077a76e124edb6ad84781dac277ecd116d24c2.md new file mode 100644 index 0000000000000000000000000000000000000000..a5a926abffe5739cc07b770a83b07eadf35a8b7a --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/26fd6262d28036ccd807eba281077a76e124edb6ad84781dac277ecd116d24c2.md @@ -0,0 +1,104 @@ +LAW OFFICES OF BOBBI C. STERNHEIM +212-243-1100 • Main +917-306-6666 • Cell +888-587-4737 • Fax +33 West 19th Street - 4th Floor +New York, New York 10011 +bc@sternheimlaw.com +February 1, 2021 +Honorable Alison J. Nathan +United States District Judge +United States Courthouse +40 Foley Square +New York, NY 10007 +Re. United States v. Ghislaine Maxwell +20 Cr. 330 (AJN) +Dear Judge Nathan: +By letter to the Court, dated January 25, 2021 (Dkt. 117 at 2-3), the MDC raised objection +to the Court's order, unopposed by the government, directing the MDC to permit Ms. Maxwell to +use on a laptop computer on weekends and holidays. (Dkt. 116 at 2). The MDC has failed to +state a valid or compelling reason for opposing the Court's directive. +The MDC does not identify any valid reason why Ms. Maxwell cannot have access to the +laptop computer on weekends and holidays. The MDC does not argue, for example, that access +to the laptop cannot be provided because of issues related to safety or security, staffing, or (to +quote the government) the need to "manag[e] its inmate population." Instead, in opposition to +the Court's order, the MDC repeats its stock response: Ms. Maxwell has received significant +amount of time to review her discovery and has more contact with counsel than any other MDC +inmate is allotted. The MDC's fixation on the relative time Ms. Maxwell has been given to +review discovery is totally misguided. The government has produced millions of pages of +discovery. Ms. Maxwell has the right to review all of them in order to prepare her defense for +trial. To do that, she needs access to the laptop for as much time as possible, including the +weekends and holidays because the prison computers are incapable of reading the millions of +discovery documents. Ms. Maxwell loses 10 or more hours per week due to delay in receiving +the laptop, problems caused by the MDC computer, and inability to access the computer during +morning and afternoon counts on the weekends. Comparing Ms. Maxwell to other inmates does +not justify restricting her use of the laptop to review discovery. +The MDC's proposed solution that Ms. Maxwell can simply use the prison computer on +the weekends and holidays to review discovery—is utterly inadequate. As Ms. Maxwell has +pointed out on many occasions, the prison computer is incapable of reading a significant portion +of the discovery, including but not limited to native files, Excel files, some video and audio files, +and anything requiring Cellebrite software. The MDC concedes this fact in their letter-Ms. +Maxwell cannot review all of her discovery on the prison computer. And using it causes a +colossal waste of time. For example, if Ms. Maxwell locates a document on the prison computer + + +LAW OFFICES OF BOBBI C. STERNHEI/ +for which she needs to review the native image, many of which are embedded in other files, she +must write down the Bates number for that document and then wait until Monday to find the +same document using the laptop computer so that she can review the full document. Moreover, +the MDC computer shuts down every two hours, requiring Ms. Maxwell to reboot the computer +and find her place in the documents to resume her review. This process can take 20-30 minutes, +all of which is lost time. In addition, the power of central processing unit of the MDC computer +is very slow. Uploading videos can take up to a half hour, time that cannot be used to review +other documents. When the computer automatically shuts down, videos need to be re-opened, +requiring Ms. Maxwell to locate the portion of the video she was viewing when the computer +shut down. In sum, using the prison computer is a problem, not a solution. +Ms. Maxwell's review of discovery is challenging enough on the laptop computer that +was provided. Even with the laptop, Ms. Maxwell is unable to search, unable to print, and +unable to tag or highlight documents for later review. She must review millions of pages of +unwieldy documents produced in various formats (native, image, text) one page at a time—with +no filtering or organizing —and record millions of Bates numbers and notes of her review by +hand on the limited amount of paper she is provided. And she is not permitted to have any +supplies to organize the voluminous legal papers. Hard drives provided by the government have +been mishandled by MDC staff (dropped on the floor and slammed on a cart) causing them to +become degraded and unstable and to randomly shut down. While the laptop does not solve all of +these issues, it performs far better than the MDC computers. The time, resources and funds +expended on problems caused by the electronic discovery and the computers is unnecessary, +wasteful, and frustrating. The MDC is in no position - and is neither qualified nor experienced - +to challenge Ms. Maxwell's and her counsel's claim that she needs access to the laptop on the +weekends and holidays to even hope to finish reviewing the millions of pages of documents +produced in discovery. +The MDC's assertion that Ms. Maxwell's access to her attorneys is a reason to deny her +access to the laptop computer on weekend and holidays is non-sensical. One has absolutely +nothing to do with the other. And it ignores the fact that, aside from time to review discovery or +communicate with counsel, Ms. Maxwell is far more restricted than all other MDC inmates. +Other inmates have unlimited time to communicate with other inmates. With exception of +inmates detained in the SHU for disciplinary reasons, all other MDC inmates have unlimited +time to interact with other inmates. Other than calls with family or communication with counsel, +Ms. Maxwell has no human contact except with guards who wield power over her, overmanage +her, and have psychologically and physically abused her. And complaints regarding +mistreatment by guards have led to reprisals against Ms. Maxwell. +Rather than state a valid reason for opposing the Court's directive, the MDC's opposition +shines a klieg light on the deficiencies of its electronics and the limitations imposed on all +inmates, most especially those detained pretrial. The restrictions placed on pretrial detainees goes +beyond deprivation of liberty. Their ability to prepare for trial is compromised, their access to +counsel is restricted, and their right to effective assistance of counsel is jeopardized. The +pandemic has made the situation even more dire. Requiring pretrial detainees, including Ms. +Maxwell, to review terabytes of electronic discovery on inadequate computers further tips an +already unlevel playing field to the detriment of criminal defendants. +2 + + +LAW OFFICES OF BOBBI C. STERNHEI/ +There are no reasonable conditions to assure that as a pretrial detainee Ms. Maxwell will +be as prepared for trial as a defendant on bail. Permitting Ms. Maxwell to use the laptop on +weekends and holidays is a reasonable and minimum accommodation for the difficulties entailed +in reviewing enormous amounts of electronic discovery, and one that imposes no burden on the +BOP nor any security issues. The Court's order directing the MDC to permit Ms. Maxwell +access to the computer on weekends and holidays should remain in effect. +Very truly yours, +Bobbi C. Sternheim +BOBBI C. STERNHEIM +ce: Sophia Papapetru, MDC counsel +Government Counsel +3 diff --git a/vision-fixhub/ds9-parsed-01/26fd6262d28036ccd807eba281077a76e124edb6ad84781dac277ecd116d24c2.receipt.json b/vision-fixhub/ds9-parsed-01/26fd6262d28036ccd807eba281077a76e124edb6ad84781dac277ecd116d24c2.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..bec95dc6d0f1530960a6b723f9953f1e0180b0b9 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/26fd6262d28036ccd807eba281077a76e124edb6ad84781dac277ecd116d24c2.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -36, + "dataset": "marble-joined", + "doc_id": "26fd6262d28036ccd807eba281077a76e124edb6ad84781dac277ecd116d24c2", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "5b1eb72879ab69ca40f052bc417cecf5f64ea07feaf4906bc053da6cd40778bb", + "output_sha256": "dedd3a63e96e0aae5677c1c95f777dd633b3ec5636183758bfe19e86093ffb21", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2712eb6c551759d6c8ad22fa8bcaa01cc38271636d107fec0585db30a8b48790.md b/vision-fixhub/ds9-parsed-01/2712eb6c551759d6c8ad22fa8bcaa01cc38271636d107fec0585db30a8b48790.md new file mode 100644 index 0000000000000000000000000000000000000000..a0d8dcac03d07971bda895cbb72dd665798e3924 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2712eb6c551759d6c8ad22fa8bcaa01cc38271636d107fec0585db30a8b48790.md @@ -0,0 +1,46 @@ +U.S. Department of Justice +United States Attorney +Southern District of New York +The Silvio J. Mollo Building +One Saint Andrew's Plaza +New York, New York 10007 +November 9, 2021 +BY ELECTRONIC MAIL +Christian Everdell, Esq. +Cohen & Gresser LLP +800 Third Avenue +New York, NY 10022 +Laura Menninger, Esq. +Jeffrey Pagliuca, Esq. +Haddon, Morgan and Foreman, P.C. +150 East Tenth Avenue +Denver, CO 80203 +Bobbi Sternheim, Esq. +Law Offices of Bobbi C. Sternheim +33 West 19th Street-4th Fl. +New York, NY 10007 +Re: +United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) +Dear Counsel: +Today the Government is producing additional materials, including Jencks Act and +Giglio material, regarding witnesses who may be called to testify at trial in the above-referenced +case. Enclosed please find an index detailing the materials included in today's production. +Please note that this letter, the enclosed index, and the enclosed materials are governed +by the July 31, 2020 Protective Order in this case. In particular, the materials are designated +as "confidential" under the Protective Order. The index is itself designated as "confidential," +because it includes information regarding records designated as "confidential" under the +Protective Order. The Department of Justice directed this office to cease the dissemination of +materials marked with the word "confidential" in order to avoid potential confusion with markings +reserved for classified documents. Accordingly, in order to note the appropriate designation of +this production under the operative Protective Order in this case, the materials being produced +today are marked with the following label: "SUBJECT TO PROTECTIVE ORDER +PARAGRAPHS 7, 8, 9, 10, 15, and 17." This marking directly refers to the specific paragraphs +of the Protective Order that govern today's production. + + +Page 2 +Very truly yours, +DAMIAN WILLIAMS +United States Attorney +by: s/ +Assistant United States Attorneys diff --git a/vision-fixhub/ds9-parsed-01/2712eb6c551759d6c8ad22fa8bcaa01cc38271636d107fec0585db30a8b48790.receipt.json b/vision-fixhub/ds9-parsed-01/2712eb6c551759d6c8ad22fa8bcaa01cc38271636d107fec0585db30a8b48790.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..650d482d00e37c83ca0c58e82da3de4769f3f325 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2712eb6c551759d6c8ad22fa8bcaa01cc38271636d107fec0585db30a8b48790.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "2712eb6c551759d6c8ad22fa8bcaa01cc38271636d107fec0585db30a8b48790", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "bad37f0231b56509b1d977bbbb4b1f7955971f2f3493a26e289f5aef48d872d8", + "output_sha256": "ff964ee5bd7ab84449652b7a8db00bd4c2dec479b8aa4f9f2d86d8f97b4f599f", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/271417055ddfa91a90197fe9404b885f145c3730d6a71bb222faee26467df53d.md b/vision-fixhub/ds9-parsed-01/271417055ddfa91a90197fe9404b885f145c3730d6a71bb222faee26467df53d.md new file mode 100644 index 0000000000000000000000000000000000000000..7158f61e5c30bf4123774c1b88b410ce8378c38e --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/271417055ddfa91a90197fe9404b885f145c3730d6a71bb222faee26467df53d.md @@ -0,0 +1,98 @@ +From: +To: Tracy Chapell < +Cc: " +Subject: RE: Fedex +Date: Tue, 13 Jul 2021 19:34:26 +0000 +Attachments: 2008-02-21_SUBPOENA_RESPONSE_-_FEC_FILE__35777_FGJ_07-103(WHB)- +TUES._NO._ OLY-79.pdf; 2008-02- +21_CERTIFICATION_OF_BUSINESS_RECORDS_REGARDING_TRACEY_L_FERRA +RA.pdf +Inline-Images: image001 jpg +Thanks, Tracy. We'd like to identify a records custodian who could testify, in the event that it would be necessary. +We found the attached cover letter and certification from FedEx in 2008, in case they are helpful in finding the specific +production on your end. +Thanks, +From: Tracy Chapell < +Sent: Wednesday, July 7, 2021 11:07 AM +To: | +Cc: +Subject: RE: Fedex +Good morning, +Please see attached. Let me know if you need anything further. +Thank you, +Tracy Chapell +Senior Paralegal +Express +Federal Express Corporation +Legal Department +From: +Sent: Tuesday, July 6, 2021 12:33 PM +To: Tracy Chapell < +Cc: +Subject: [EXTERNAL] RE: Fedex += + + +Caution! This email originated outside of FedEx. Please do not open attachments or click links from an unknown +or suspicious origin. +Hi Tracy, +We'd like someone to sign an affidavit for now, but we'd also like to identify someone who could testify at trial if need be. +The trial is for Ghislaine Maxwell, scheduled to start in New York in November. +l've attached a proposed declaration, though if FedEx has its own standard format, that will likely work too. +Thanks, +From: Tracy Chapell < +Sent: Tuesday, July 6, 2021 10:49 AM +To: | +Cc: +Subject: RE: Fedex +Good morning, +I have reviewed the records and they seem to be our records. Are you needing someone to sign an affidavit or appear in +person at trial? (is this "the" Jeffrey Epstein?) +Thank you, +Tracy Chapell +Senior Paralegal +FedEx +Express +Federal Express Corporation +Legal Department +From: | +Sent: Tuesday, July 6, 2021 9:25 AM +To: Tracy Chapell wrote: +Yes, please. And what would you like us to review in the index? +From: +To: +(USANYS) [Contractor] < +Sent: Wednesday, October 14, 2020 9:01 AM + + +One more thing - we previously discussed making a note on the cover about the text/native files from the Relativity +export being confidential given they do not bear physical stamps. Do we still want to do this before sending the letters? +From: +(USANYS) [Contractor] +Sent: Wednesday, October 14, 2020 8:49 AM +To: +Before I email them and share the productions will you take a look at the anonymizing index attached? +From: +To: +Sent: Tuesday, October 13, 2020 7:55 PM +(USANYS) [Contractor] < +(USANYS) +Here are the final cover letters. You can send them to defense counsel and give them USAfx access whenever it is ready. +Thanks a lot. +From: +To: +Cc: +(USANYS) [Contractor] < +Sent: Tuesday, October 13, 2020 1:08 PM +Redactions and stamping are all set. Everything is currently being zipped for upload to USAfx. I've drafted up cover +letters to both Noel and Thomas. They are attached and saved on the shared. +From: +To: +Cc: +Sent: Tuesday, October 13, 2020 12:10 PM +(USANYS) [Contractor] < +Great! +From: +(USANYS) [Contractor] < +Sent: Tuesday, October 13, 2020 12:01 PM +To: | +Cc: | +Once 1 apply the redactions and stamp those documents, the production will be ready to go out. I will let you know once +that is finished. +From: +Sent: Tuesday, October 13, 2020 11:42 AM +To: l +(USANYS) [Contractor] < +Cc:| +Subject: FW: Discovery review project + + +As per the attached, there are no additional redactions in the two outstanding FOIA email files. Let us know where the +discovery stands. +Thanks, +From: +To: +Cc: +Sent: Friday, October 09, 2020 4:06 PM +I apologize for the delay, I've reviewed the two files please see attached V3 of the spreadsheet. +I am flagging 2 parts I was uncertain about, similar to earlier. (See below & in the spreasheet) +On Emails 2_Part 4: 1 did note the same category as earlier with an email chain from Tartaglione's counsel regarding +leak/retaliation at MCC of a news story of Tartaglione questioned about attack on Epstein, and also on pg. 104 where +Epstein informs a psychologist that Tartaglione discussed potentially injuring him without a guards' report. +But both of those I was a bit uncertain whether they should be withheld. +Hope this helps! +From: +To: +Cc: +Sent: Friday, October 9, 2020 10:39 AM +Subject: Re: Discovery review project +Perfect. +Sent from my iPhone +On Oct 9, 2020, at 10:38 AM, +> wrote: +Hi +Yes of course! I'm in class right now, but I should be able to work on this afternoon, and hopefully turn it back around +by around 3pm if that's okay? +From: +To: +(USANYS) 4 +Sent: Friday, October 9, 2020 10:32 AM + + +There are replacements for the two corrupt files in the same shared directory you used before. Would you be able to +take a look at those today and add them to this version of the spreadsheet (which has a few edits from what you +Thanks so much, +From: +To: +Cc:| +Sent: Wednesday, October 07, 2020 12:02 PM +Okay, I finished up the remaining (pending the 2 pdfs I cannot open). I also noticed an error in the previous excel sheet, +please utilize V2 moving forward (attached). +I grouped & highlighted 3 portions of different PDFs that, potentially could be withheld, as they're email +correspondence regarding Tartaglione but in relation to an Epstein incident. I tried to better define them in the +spreadsheet and color coded by grouping. For the most part, each group is the same email chain, albeit with a +response or two added. +From: +Sent: Wednesday, October 7, 2020 10:42 AM +To: +Cc: +Thanks for this. I will ask our paralegal to check out the damaged documents. +From: +To: +Cc: +Sent: Wednesday, October 07, 2020 10:38 AM +Hi +Following up with a quick update, I've got 6 PDF's left to review. Wanted to flag that for some reason 2 of the PDF's +(Emails 2_Part4 & Emails 3_Part 2) will not open and I get a "document is damaged" error from Adobe. I've tried +logging out of the portal and restarting computer but no luck so far. +I'm attaching the current spreadsheet so you can see how I've gone about flagging portions of the PDFs. I've noted a +few uncertain areas in the notes where it may be Tartaglione issue but related to Epstein/request to be interviewed or +for preservation. + + +Hope this is on the right track! +From: | +Sent: Friday, October 2, 2020 2:12 PM +To: 1 +Cc: l +Subject: Discovery review project +Hello +As we discussed, I would like you to review the email files only in the folder listed below. Please identify any pages in +the documents that relate solely to (1) the conditions of confinement for Tartaglione or (2) emails with +I regarding Touhy. You should create a document (spreadsheet maybe) that identifies the name of the PDF tile +and the pages that fall in each category, so that the paralegals can redact those pages. +Here's where you will find the documents +You only need to review the emails, not the other documents in the folder. +Let me know if you have any questions or issues once you start working on the project. Let's aim for the end of the +day on Wednesday. +Thanks for your help, +Assistant United States Attorney +United States Attorney's Office +Southern District of New York +Tel: +Fax: \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/27c18d0bb13bd7502b52d71752c82f6d9448f4316eea21d9564bc2442be934c2.receipt.json b/vision-fixhub/ds9-parsed-01/27c18d0bb13bd7502b52d71752c82f6d9448f4316eea21d9564bc2442be934c2.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..a713d3f41d8e591191c18858c8e1511c0a6e9fc9 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/27c18d0bb13bd7502b52d71752c82f6d9448f4316eea21d9564bc2442be934c2.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -1418, + "dataset": "marble-joined", + "doc_id": "27c18d0bb13bd7502b52d71752c82f6d9448f4316eea21d9564bc2442be934c2", + "engine": "marble-apple-vision", + "event_count": 7, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "40b1610f84de4fdabb9f67063105a605b0f544d34c721945caba3f875404acea", + "output_sha256": "8c4d9b2233873f75c3ce059823ce91b5e08471cef9201a437317a3b2acb59039", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/27fecd3101b287dc56aa07847d8433b0f8862b3263c4cdaade3cd1664899a82a.md b/vision-fixhub/ds9-parsed-01/27fecd3101b287dc56aa07847d8433b0f8862b3263c4cdaade3cd1664899a82a.md new file mode 100644 index 0000000000000000000000000000000000000000..37290f67a261536d6cefddf35c4c4d3e503e3083 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/27fecd3101b287dc56aa07847d8433b0f8862b3263c4cdaade3cd1664899a82a.md @@ -0,0 +1,21 @@ +From: " +To: " +Subject: RE: bank records +Date: Mon, 01 Jun 2020 18:05:36 +0000 +Definitely. I will be able to handle this. +From: +To: +Sent: Monday, June 1, 2020 11:12 AM +Subject: bank records +Hil +For the Epstein case, are you able to assist with getting a copy of some recent bank subpoena returns to our case agent, +?? We were hoping to leave a copy for her downstairs at 1 Saint Andrews sometime this week. I'm not sure +who might be in the office to handle this, but if you could possibly coordinate that, it would be extremely helpful. +Thanks! ( +The returns are saved here: +FirstBank Puerto Rico +Much appreciated- +Assistant United States Attorney +Southern District of New York +One Saint Andrew's Plaza +New York, NY 10007 diff --git a/vision-fixhub/ds9-parsed-01/27fecd3101b287dc56aa07847d8433b0f8862b3263c4cdaade3cd1664899a82a.receipt.json b/vision-fixhub/ds9-parsed-01/27fecd3101b287dc56aa07847d8433b0f8862b3263c4cdaade3cd1664899a82a.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..14e118f74b074552b95595b1644920bd911a2c08 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/27fecd3101b287dc56aa07847d8433b0f8862b3263c4cdaade3cd1664899a82a.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "27fecd3101b287dc56aa07847d8433b0f8862b3263c4cdaade3cd1664899a82a", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "b0007b7e7cdfb301e4e5b6f3fbc5cd540ae93e3588bd5972c80fc1e42906b177", + "output_sha256": "da2d472ef56e43f4fa3c66a0b08eacdec23b83d707f07eb70809b94f3996fda8", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2806486134ac1f833dba7fc0383cfbb846b55831600b490cf613b8e66c46b792.md b/vision-fixhub/ds9-parsed-01/2806486134ac1f833dba7fc0383cfbb846b55831600b490cf613b8e66c46b792.md new file mode 100644 index 0000000000000000000000000000000000000000..4d18a2ecf343ac1314b543b43d08b4b4eb26205a --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2806486134ac1f833dba7fc0383cfbb846b55831600b490cf613b8e66c46b792.md @@ -0,0 +1,105 @@ +From: " +ToL +Subject: RE: Notification - Pretrial Services Intake +Date: Mon, 06 Jul 2020 21:50:43 +0000 +Attachments: 2020-07- +02,_ United_States_v._Maxwell, _20_Cr._330_(AJN),_detention_memorandum_(ECF) pdf +Hi +Thanks very much -- is there a particular time you'd like to speak this evening? +Thanks, +-----Original Message- +From: +Sent: Monday, July 6, 2020 1:34 PM +To: +Cc: +Subject: Re: Notification - Pretrial Services Intake +Please provide a contact number where I can call you about this case this evening. +Also when you reach out to defense counsel, only copy me from my office. +Thanks +U.S. Pretrial Services +> On Jul 6, 2020, at 1:30 PM, +> wrote: +> +> Good afternoon, +> +> Below please find the completed form for defendant Ghislaine Maxwell (DOB +USMS No. 02879- +509). We expect Maxwell will be arraigned and have a bail hearing before Judge Nathan this Friday 7/10. +Attached please find the indictment and the Government's motion for detention. +> +> Maxwell arrived in SDNY approximately this morning, and we expect she will be housed at the MDC. I will +send a separate email cc'ing Maxwell's attorneys so that they can coordinate with your office to set up an +> Please let me know if you have any questions or need any additional information. +> Thank you, + + +> +> +> +> AUSA NAME: +> PHONE NO: +> CELL: +> +> +> +> PHONE NO: +> CELL: +> +> +> +> PHONE NO: +> CELL: +> +> +> +> Docket No.: +> 20 Cr. 330 (AJN) +> If Indicted: Yes +> USDJ: Nathan +> Referred to Mag Court for Arraignment: [Yes/No] +> +> +> +> Charge(s): +> 18 U.S.C. 371 (conspiracy to entice minors to travel to engage in +> illegal sex acts) +> 18 U.S.C. 2422 (enticement of a minor to travel to engage in illegal +> sex acts) +> 18 U.S.C. 371 (conspiracy to transport minors with intent to engage in +> illegal sex acts) +> 18 U.S.C. 2423(a) (transportation of a minor with intent to engage in +> illegal sex act) +> 18 U.S.C. 1623 (perjury) +> ** attach Complaint/Indictment to this email ** +> +> DEFENDANT +> D Counsel +> [FD/CJA/Retained?] +> D Counsel Name +> D Counsel Contact Info +> Ghislaine Maxwell +> Retained +> Chris Everdell +> Mark Cohen +> + + +> +> Interpreter Required? No +> If Yes, Language: +> Location/ETA of Defendants): MDC +> Other Remarks: +> Please see attached motion for detention +> +> +> +> +> +> +> Assistant United States Attorney +> Southern District of New York + +> +> <2020-07-02, United States +> v. Maxwell, 20 Cr. 330 (A.JN), detention memorandum.pdf» diff --git a/vision-fixhub/ds9-parsed-01/2806486134ac1f833dba7fc0383cfbb846b55831600b490cf613b8e66c46b792.receipt.json b/vision-fixhub/ds9-parsed-01/2806486134ac1f833dba7fc0383cfbb846b55831600b490cf613b8e66c46b792.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..95b8bf81dba5ee8c8a23b168c88b9360f6ec0b4c --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2806486134ac1f833dba7fc0383cfbb846b55831600b490cf613b8e66c46b792.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -36, + "dataset": "marble-joined", + "doc_id": "2806486134ac1f833dba7fc0383cfbb846b55831600b490cf613b8e66c46b792", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "5bd0cb15251148485aa33ed2d053ede5a3aa1c1c9b38f485521681b79340db52", + "output_sha256": "8dee0fa56c006d5da12746f1e66c2a66905eaecba8b72e59aa847d0b60919be2", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/280f707f5d1efbff2afc6b9b2544b1c0ac1a18990096974d211753f6621c960b.md b/vision-fixhub/ds9-parsed-01/280f707f5d1efbff2afc6b9b2544b1c0ac1a18990096974d211753f6621c960b.md new file mode 100644 index 0000000000000000000000000000000000000000..d84cc16df5cf1b2642a999c47aea218ef3c8dc0a --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/280f707f5d1efbff2afc6b9b2544b1c0ac1a18990096974d211753f6621c960b.md @@ -0,0 +1,63 @@ +From: " +To: +Ce: +Subject: RE: CORRECTED: Subpoena and Request for Emails +Date: Fri, 12 Jul 2019 11:59:39 +0000 +Importance: Normal +Well that covers all the bases I guess! Thanks very much! +From: +Sent: Friday, July 12, 2019 07:59 +To +Cc: +Subject: RE: CORRECTED: Subpoena and Request for Emails +He doesn't have any approved social visitors yet. +>>> +> 7/12/2019 7:56 AM > > > +Adam, would we be able to get any visitor logs? Does that require a supplemental subpoena? Thank you! +Fromi +Sent: Friday, July 12, 2019 07:55 +To: +Cc: +Subject: Re: CORRECTED: Subpoena and Request for Emails +H +I checked and confirmed we have no calls or emails for Epstein at this time. +Thank you, +Supervisory Staff Attorney +CLC New York +Metropolitan Correctional Center +150 Park Row +Mann Mark Mown Mark +10007 +>>> +subpoena and request. +'' = +> 7/11/2019 9:53 PM >>> +Apologies, my prior email was missing some of the contact information for Epstein's attorneys. Please disregard the prior + + +Attached please find a revised subpoena with a corrected list of attorney phone numbers to exclude. +In addition, please accept our written request for the e-mail correspondence of inmate Jeffrey Epstein (76318-054) from +Best, +Assistant United States Attorney +Southern District of New York +1 St. Andrew's Plaza +New Vork NV 10007 +From: I +Sent: Thursdav, July 11. 2019_9:43 PM +To: A +Cc: +Eric (USANYS) ‹ +Subject: Subpoena and Request for Emails +Importance: High +P; Blachman, +Attached please find a subpoena for recordings of Jeffrey Epstein's phone calls, excluding any attorney calls. +In addition to the materials requested in the enclosed subpoena, please accept our written request for the e-mail +trateen +we could receive the requested materials as soon as possible. As always, please feel free to o +any questions or concerns. +or me with +Thanks very much, +Assistant United States Attorney +Southern District of New York +1 St. Andrew's Plaza +N 10007 diff --git a/vision-fixhub/ds9-parsed-01/280f707f5d1efbff2afc6b9b2544b1c0ac1a18990096974d211753f6621c960b.receipt.json b/vision-fixhub/ds9-parsed-01/280f707f5d1efbff2afc6b9b2544b1c0ac1a18990096974d211753f6621c960b.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..f06aaec10aaaaf4b3ea4a8e8ff4195efaff77c35 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/280f707f5d1efbff2afc6b9b2544b1c0ac1a18990096974d211753f6621c960b.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "280f707f5d1efbff2afc6b9b2544b1c0ac1a18990096974d211753f6621c960b", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "31bde2219a9e9a4a0febdb53fb0224fd67649ea4a8901fece084eabebd20a1c7", + "output_sha256": "94d5f732afb5e1569dfc3d39b15f7fc5a4216ee7eea5ad7c5346c7d1555c5aed", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/281d986e1a86bdc1fad5872f7ab3a77f3d0c79f6f845422ab3c0843e23177da9.md b/vision-fixhub/ds9-parsed-01/281d986e1a86bdc1fad5872f7ab3a77f3d0c79f6f845422ab3c0843e23177da9.md new file mode 100644 index 0000000000000000000000000000000000000000..6cfa2120700cfa4f65410fefe96d3a604ad9bf56 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/281d986e1a86bdc1fad5872f7ab3a77f3d0c79f6f845422ab3c0843e23177da9.md @@ -0,0 +1,86 @@ +From: Gloria Allred < +To: " +L. (NY) (FBI)" ≤ +Cc: " +Subject: RE: Urgent. I have a new alleged victim of E I have a new client who was a victim of +Epstein. She is willing to fly to New York for the victim meeting on Oct. 23. May I call you +at 5:45 P.M. to discuss ? +Date: Mon, 21 Oct 2019 16:12:12 +0000 +Inline-Images: image003.jpg; image004.png; image005.jpg; image006.png +It is +Gloria Allred +Allred, Maroko & Goldberg +6300 Wilshire Blvd., Suite 1500 +Los Angeles, CA 90048 +www.amglaw.com +www.gloriaallred.com +ALLRED, MAROCO & GOLDBERG +RECOGNIZED BY +Best Lawyers +Martindale-Hubbell" +From: +To: +. (NY) (FBI) < +Sent: Monday, October 21, 2019 9:02 AM +P; Gloria Allred < +Cc: +Subject: RE: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to fly to +New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ? +Hi Gloria, +Is this client +? 1 know you've already forward | +wants to attend, we will need that info ASAP. Can you let me know. +information to Victim Services. If it is not I +, and your client +Thanks, +FBI New York +VCAC/Human Trafficking +C: + + +From: +Sent: Monday, October 21, 2019 9:40 AM +To: Gloria Allred < +| [mailto: +P; +Cc: +L. (NY) (FBI) < +Subject: RE: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to fly to +New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ? +Gloria, +We will make ourselves available to meet with your new client on 10/23. Because the victim meeting is being run by the +FBI, their victim services folks are handling travel logistics. I'm ccing L +. who should be able to hopefully help +coordinate travel. Would you please provide L +with your new client's name as it appears on her ID, date of birth, +email address, and phone number? +Thanks, +Assistant United States Attorney +Southern District of New York +1 St. Andrew's Plaza +New York, NY 10007 +From: Gloria Allred < +Sent: Friday, October 18, 2019 5:02 PM +To: +Cc: +Subject: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to fly to +New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ? +Gloria Allred +Allred, Maroko & Goldberg +6300 Wilshire Blvd., Suite 1500 +Los Angeles, CA 90048 +www.amglaw.com +www.gloriaallred.com +Best Lawyers +Martindale-Hubbell + + +This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the +addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS +COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER NAMED +ABOVE AT +- Thank you. +This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the +addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS +COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER NAMED +. Thank you. diff --git a/vision-fixhub/ds9-parsed-01/281d986e1a86bdc1fad5872f7ab3a77f3d0c79f6f845422ab3c0843e23177da9.receipt.json b/vision-fixhub/ds9-parsed-01/281d986e1a86bdc1fad5872f7ab3a77f3d0c79f6f845422ab3c0843e23177da9.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..f461523f5bac58163e2bf9ad7e209b03560fe50c --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/281d986e1a86bdc1fad5872f7ab3a77f3d0c79f6f845422ab3c0843e23177da9.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -36, + "dataset": "marble-joined", + "doc_id": "281d986e1a86bdc1fad5872f7ab3a77f3d0c79f6f845422ab3c0843e23177da9", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "268662af51f820732ee9015a07e72e2a6ba93705d1842e8037d15090a6c65b8a", + "output_sha256": "72c90fb0af0333b0811473aa0a2f5ff020d0911fbf73dce0adbad8bf9d0a81c8", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/283cdd1fd7afee053c1baa24b9db6bd9e00f076e16fecd913cd817577fed2408.md b/vision-fixhub/ds9-parsed-01/283cdd1fd7afee053c1baa24b9db6bd9e00f076e16fecd913cd817577fed2408.md new file mode 100644 index 0000000000000000000000000000000000000000..05b7b454f9078ac66ceb32008237655b8fa1e448 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/283cdd1fd7afee053c1baa24b9db6bd9e00f076e16fecd913cd817577fed2408.md @@ -0,0 +1,2217 @@ +1 +2 +3 +4 +5x +6 +7 +8 +9x +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +UNITED STATES GRAND JURY +SOUTHERN DISTRICT OF NEW YORK +UNITED STATES OF AMERICA +-V- +TOVA NOEL and +MICHAEL THOMAS +(2019R01089) +: +: +: +United States Courthouse +Foley Square +New York, New York +November 14, 2019 +2:18 p.m. +APPEARANCE S: +Assistant United States Attorney +ISAAC GARDNER +Acting Grand Jury Reporter +FREE STATE REPORTING, +Court Reporting +D.C. Area | + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +11/14/19 +2 +(Colloquy Precedes) +(Witness Enters Room) +(Time Noted: 2:21 p.m.) +called as a witness, having been duly sworn by +the Foreperson of the Grand Jury, was examined and +testified as follows: +BY MS. +Q. Good afternoon. +A. Good afternoon. +e. +Would you please state and spell your name? +A. +Where do you work? +A. +The FBI. +Q. I'll ask you to just speak into the microphone a +little bit more. +What's your title at the FBI? +A. +Special agent. +Are you assigned to a particular unit at the FBI? +A. +Yes, the Violent Crimes Task Force. +Q. In preparing to testify today, have you spoken +with other people, including other law enforcement officers +about this case? +A. +Yes. +e. +Have you reviewed reports and documents prepared +by others regarding this case? +FREE STATE REPORTING, INC. +Court Reporting + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +11/14/19 +3 +A. +Yes. +Q. Will your testimony be based in part on those +conversations and documents? +A. +Yes. +MS. +Ladies and gentlemen, some of the +testimony you'll hear today from Special Agent +will +include hearsay. That means that she will not be testifying +solely from her personal observations, but what others have +told her and what she's read in reports and documents +prepared by others. +Hearsay evidence is admissible and proper in the +grand jury proceedings, and you're permitted to rely on it +in determining whether there's probable cause to indict the +Defendants. If you want to hear the testimony of other +witnesses, you can request it and we'll make reasonable +efforts to bring that witness before you. +BY MS. +2. Special Agent +1, before we get into the result +of the investigation, could you just describe for the grand +jury what your investigation has entailed since August 10th, +2019? +A. +Numerous interviews of employees at MCC and +inmates that were housed at MCC. There was extensive, +intensive video review of the video available in the SHU +from July 23rd to August 10, 2019. And there have been +FREE STATE REPORTING, INC. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +11/14/19 +4 +records that were subpoenaed and reviewed from MCC regarding +their records, bank records and phone records. +2. And you said "SHU, " is that the Special Housing +Unit at the MCC? +A. Yes. +Q. We'll get to that in a moment. Why was the video +review only of July 23rd through August 10th of this year? +A. Because that was the available video that we had +of the Special Housing Unit in MCC. +Q. So MCC didn't have video before July 23rd? +A. Correct. +2. So let's talk about some of the relevant people +and entities that we'll be discussing today. +First, what is the MCC? +A. It is a federal detention facility that's located +in Manhattan, and it's run by the Federal Bureau of Prisons, +or BOP. It is used to house inmates who have been charged +with federal crimes in the Southern District of New York and +are awaiting trial. +0. Does the MCC employ correctional officers? +A. +Yes. +l. What is their function? +A. Their primary duty is to ensure the care, custody +and control of the inmates who are housed at MCC. +Who is Tova Noel? +FREE STATE REPORTING, INC. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +19 +20 +21 +22 +23 +24 +25 +11/14/19 +5 +A. +She is one of the Defendants in this +investigation. She is a correctional officer at MCC. She +has been employed there since 2016. As of August 2019, her +primary assignment was in the SHU at MCC. +9. What shifts did she work on August 8th, August 9th +and August 10th? +A. On August 8th, she worked a regular shift from 12 +p.m. to 8 p.m. in the SHU. And then on August 9th, she +worked a regular shift from 4 p.m. to 12 p.m. in the SHU. +And then she worked an overtime shift in the SHU from +12 a.m. to 8 a.m. +Who is Michael Thomas? +A. +He is also a Defendant and also employed at MCC +since approximately 2007. In around 2013, he was assigned +as a materials handler supervisor, but he would also work +overtime shifts as a correctional officer. +e. What shifts did Thomas work on August 8th, 9th and 18 +10th? +A. +On August 8th, he was on leave. And then on +August 9th, he worked an overtime shift from 12 a.m. to 8 +a.m. in the SHU. And then August 10th, he worked in the SHU +from 12 a.m. to 8 a.m. +Who was Jeffrey Epstein? +A. And then Jeffrey Epstein was an inmate in MCC +between his arrest of July 6th and August 10th, and he was +FREE STATE REPORTING, INC. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +11/14/19 +6 +detained there pending trial for sex trafficking charges. +Q. I'd like to talk about the MCC and Special Housing +Unit generally. How many inmates are housed at the MCC at +any given time? +A. Approximately 750. +Q. What is the SHU, or Special Housing Unit? +A. That is a unit that is separated from the general +inmate population, and that is to ensure the safety of those +inmates and staff. +9. Where within the MCC is the SHU located? +A. +It's on the ninth floor. +e. On the ninth floor? +A. Um-hmm. +Q. How many inmates are housed in the SHU at any +given time? +A. Approximately - around 70, give or take a few. +Q. I'd like to talk about how you get into the SHU. +So a correctional officer, how would they get into the SHU +from the first floor of the MCC? +A. Pretty much access into the SHU is through the +control center, which is on the first floor of MCC, and the +correctional officer would request access to the doors +leading into the SHU from control. +And just to clarify, the control center controls +access; is that right? +FREE STATE REPORTING, INC. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +11/14/19 +7 +A. +Correct. +2. So an officer gets off the elevator on the ninth +floor, and then what happens? +A. And then there's a door leading into the -- like +another little room before you get to the SHU. But that +door, the officer has to request access from control in +order to access it. +e. So control buzzes the officer into the first +locked door? +A. Yes. +Q. And then what happens? +A. +And then there's another locked door that the +officer inside of the SHU has the key for, and that officer +unlocks the door and lets the other correctional officer in. +Okay. This is a photograph of the SHU; is that +right? +A. +Yes. +What is the vantage point that we're looking at? +A. +Right in front, there's a desk with computers. +This is the correctional officers' desk. And then you are +looking out into what they call the multi-purpose area of +the SHU. +2. So you described, when you get off of the ninth +floor, there's one locked door that's controlled by the +control center? +FREE STATE REPORTING, INC. + + +11/14/19 +8 +1 +2 +3 +4 +5 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +A. +Yes. +Q. And then there's a second locked door that can be +opened from the inside by an officer in the SHU? +A. +Correct. +e. So once you go through the second locked door, +6 where would you be? +A. Then you would be in that big, massive, like, +center space right there. +l. The multi-purpose area? +A. +The multi-purpose area. +Okay. And then how are the cells divided within +the SHU? +A. +The cells are contained within tiers, and there +are six tiers in the SHU. +Is a tier like a hallway? +A. +Yes. +e. +A. +How many tiers are there within the SHU? +six. +How many cells are there within each tier? +A. +Eight. +9. So directing your attention to the stairway up on +the upper left, what does that lead to? +A. +That's I-tier. +Is that one of the tiers? +A. +Yes, that's one of the tiers. +FREE STATE REPORTING, INC. + + +FREE STATE REPORTING, +INC. +Court Reporting + + +1 +2 +3 +4 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +11/14/19 +9 +e. How is it accessed you to each tier controlled +(verbatim)? +A. There is a metal door, what is referred to as a +grill, and it is accessed by a key, and that key is held by +5 one of the SHU officers. +e. So there's a locked door here to get into the +tier; is that right? +A. Yes. +Q. And then within the tier, are the cell doors also +locked? +A. +Yes. +Who has access to the cell doors? +A. +That would be one of the SHU officers as well. +e. +How is that controlled, is it a key? +A. +It's a key, um-hmm. +2. Can you see one of the cell doors up on the upper +left of this photograph? +A. +Yes. +What are the cells made out of? +A. +Metal and concrete. +What is an institutional count? +A. +An institutional count is when the correctional +officers go around and count the inmates inside of their +cells. +Does the BOP require correctional officers at the +FREE STATE REPORTING, INC. + + +FREE STATE REPORTING, +INC. +Court Reporting + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +11/14/19 +10 +MCC to conduct regular counts? +A. Yes. +e. Why? +A. That is -- basically, it serves two purposes, and +one is a welfare check to make sure that the inmates are +alive. And then two, it's to make sure that all the inmates +that are supposed to be there are there. +e. So no one's escaped? +A. +Exactly. +Q. On weekdays, what time is the institutional count? +A. There's a 4 p.m., +a 10 p.m., a 12 a.m., a 3 a.m. +and a 5 a.m. +So five institutional counts -- +A. +Yes. +A. +- per weekday? +Per weekday +l. Okay. Is it one of the most basic and essential +aspects of the correctional officers' job? +A. +Yes. +Is the count itself to ensure that the inmates are +alive and haven't escaped? Is that one of the most +important and essential functions of the institution, of the +MCC? +A. +Yes. +Can you describe how -- focusing just on the SHU, +FREE STATE REPORTING, INC. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +11/14/19 +11 +how do officers conduct the institutional count? +A. +So it takes two officers. By policy, you're +supposed to have two officers. One officer has the key to +the grill, which is the access into the tier, and then the +other officer would have the key to each cell. The officer +with the key to the grill lets the other officer in. That +officer goes down the tier, or down range. And they are to +at least look inside each cell and make sure that the +inmates are alive. And they count how many are in that +cell. And then that officer comes back down. +The two officers are to switch places, and the +other officer goes down, counts, and then comes back. And +then the two officers will compare the numbers that they got +of the inmates on that tier. +9. Okay. And in the SHU, there's six tiers. +A. Yes. +2. So the officers do that? That same one goes down +and counts, the other goes down and counts, and they switch. +They do that six times; is that right? +A. Yes. +Q. Once they have the total number for the housing +unit, what do they do with that? +A. +At that point, they call the control center and +give them that number that they, that they have for the +count. +FREE STATE REPORTING, INC. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +11/14/19 +12 +So, for instance, if the correctional officers +have 72 inmates in the SHU, they would call the control +center and say, we have 12 inmates; is that right? +A. +Yes. +Q. Are they also required to document the count on a +count slip? +A. Yes. +Q. Is the count slip an official MCC document? +A. +Yes. +What information is on a count slip? +A. It is the number of inmates counted, the date, the +time, and then the officers are supposed to print and sign +their names as well as the -- what unit it is for that +count. +Once the officers complete the count slip, say the +4 p.m. count, what happens to the physical count slip? +A. It's taken down to the control center. +0. What does the control center do once they've +collected all the count slips from all the housing units? +A. They compare it to how many inmates are on record. +So the roster, basically. +2. So, for instance, if the roster says we have 750 +inmates, the control center would add up all of the count +slips, and if it reaches 750, then what happens? +A. +Then the count can be cleared. +FREE STATE REPORTING, INC. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +11/14/19 +13 +What happens if a housing unit turns in an +incomplete or incorrect count slip? +A. +Then at that point, that unit would have to do a +bed book count. +Q. A bed book count? +A. Um-hmm. +Q. Backing up. Can the control center clear the +institutional count if one of the count slips is incorrect +or incomplete? +A. No. +Q. So the housing unit that has the wrong, or +incomplete, count slip has to do a bed book count? +A. Right. +9. What is that? +A. That's pretty much when the officers have to, +basically do a redo, but it's more intensive in that they +have to compare each individual inmate to the inmate roster. +9. Are records of the institutional count maintained +by the MCC? +A. +Yes. +Are they provided to a supervisor at the MCC? +A. +Yes. +So on this slide, we have a video that we're going +to play. Can you just describe before we play the video the +vantage points that we're looking at from this camera angle? +FREE STATE REPORTING, INC. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +11/14/19 +14 +A. +Basically, this is looking down into the multipurpose area. Over in the cornier right there, you see a +desk; that is the correctional officers' desk. +2. So is this the opposite vantage point to the +photograph you saw earlier? +A. +Yes. +l. I'm going to press "play." This is just an +example of a count; is that correct? +A. +Correct. +Q. And I'll ask you to narrate what we're seeing as +it's playing. And it's been sped up, right? +A. +Yes. So that is two officers that you use. +They're going to each tier. And being that this is an +example of a 3 a.m. count, they have that flashlight just so +they can look inside and see inmates inside their cells. +2. Just speaking about the count, you mentioned that +you had reviewed hundreds of hours of videotape from July +23rd through August 10th; is that right? +A. +Yes. It was myself and an analyst, another FBI +employee that reviewed the video. +What was one of the purposes of that video review +for such a long time period? +A. It was to review the times around the times that +the count should have been conducted to see if correctional +officers actually did counts in MCC in the SHU area. +FREE STATE REPORTING, INC. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +11/14/19 +15 +What did you find? +A. That the majority of the counts were conducted. +2. How did you determine whether a count was +conducted? +A. +So we would review - so let's say, for instance, +this 3 a.m. we would review 2:30 a.m. to 3:30 a.m. So a +count, by policy, is supposed to be conducted around 3 a.m. +So we would give them that little leeway of 30 minutes +before and 30 minutes after. +Q. How could you tell if a count was done? +A. As we saw in this video, you would see the two +officers, which, by policy, is what's required, go to each +and every tier. So if we saw two officers go to each and +every tier, that's what's indicative of a count being +conducted. +Q. Within 30 minutes -- +A. +Within that -- +-- of either side of the actual institutional +count? +A. +Yes. +Okay. Looking at this camera angle, is this the +only camera angle that was available in the SHU? +A. +Yes. +Where were the cameras supposed to have been in +the SHU? +FREE STATE REPORTING, INC. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +11/14/19 +16 +A. +There was another camera, basically to the right +of this one out in the multi-purpose area. And then there +were other cameras in the tiers themselves. +Based on the investigation, did you come to learn +why those cameras were not recording or functioning? +A. Yes. Those cameras were on another DVR, and there +was a system failure previously on that DVR that, basically, +the cameras stopped recording because of that. +Q. Did that happen in advance of August 9th? +A. +Yes. +e. So you've reviewed hundreds of hours of this +camera angle; is that right? +A. Yes, extensive, extensive video. +Q. And you're able to see whether officers walked +towards each of the six tiers; is that right? +A. +Yes, you can see whether they walked towards them, +yes. +Q. Are there any cameras in the SHU that are into +each individual inmate's cell? +A. No. +Would that be an invasion of privacy? +A. +Probably, yes. +Q. So I'd like to talk about what 30-minute rounds +are. So you talked about the institutional count that +applies to every housing unit at the MCC. Does the SHU have +FREE STATE REPORTING, INC. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +11/14/19 +17 +any additional counts or rounds that are required? +A. Yes. They are supposed to do rounds every 30 to +40 minutes. +Q. What's the purpose of those -- we'll call them +30-minute rounds? +A. It's pretty much kind of like a count. It's like +a welfare check of the inmates, except, at this time, they +don't actually count each inmate. +So two officers are required to walk down each +tier every 30 minutes; is that right? +A. Yes. +Q. And that's 24-hours a day; is that right? +A. Correct. +l. Are the officers required to document the fact +that the counts were performed? +A. +Yes. +Q. Or the rounds were performed? +A. +Yes. +How do they do that? +A. +They do that on a 30-minute check sheet. +Q. Is this an example of such a sheet up here on the +slide? +A. +A. +Yes. +Can you describe what it shows? +So that's one for the Special Housing Unit, the +FREE STATE REPORTING, INC. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +23 +24 +25 +11/14/19 +18 +SHU, and it's for Tier G. And then it says when a count -- +I mean, I'm sorry, when a round started and when it ended. +And then it gives the total. And then the officer is +supposed to sign off on that. +Is the 30-minute round form signed and reviewed by +a supervisor during each shift? +A. Yes. +e. You mentioned earlier that Jeffrey Epstein first +arrived at MCC on July 6th, 2019? +A. Yes. +8. +When was he assigned to the SHU? +A. +On July 10th, 2019. +Q. Why was he assigned to the SHU? +A. Because he was a high-profile inmate, and also +because of what he was being charged with, there are risk +factors for suicide and safety concerns that go along with +that. +Who determined that he had risk factors for +suicide? +A. +The psychologists at MCC. +l. Please describe what, if anything, happened on 22 +July 23rd, 2019. +Q. On July 23rd, 2019, Epstein was housed in the SHU, +and some MCC officers responded to an emergency call, and +Epstein was found on the floor of his cell with a bed sheet +FREE STATE REPORTING, INC. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +11/14/19 +19 +around his neck. +Q. Is that a photograph of the sheet on the right on +this slide? +A. +Yes. +Q. Were either of the Defendants one of the officers +who responded to this incident? +A. Yes, Thomas, +Thomas. +Q. What happened after Epstein was found in this way? +A. +At that point, he was transferred out of the SHU +and put on suicide watch. +Q. What is suicide watch? +A. Suicide watch is when an inmate is housed in a +cell in the hospital wing and under constant supervision by +either staff or a specially trained inmate. +Q. When an inmate is on suicide watch, can they wear +their own clothes? +A. No. +Q. What are - what must they wear? +A. +It's a suicide smock. +2. The photo on the left, is that a picture of the +suicide smock? +A. +Yes. +How long was Epstein on suicide watch? +A. +He was on suicide watch for approximately 24 +hours. +FREE STATE REPORTING, INC. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +11/14/19 | +20 +What happened after that? +A. +And then at that point, he was transferred to +psychological observation. +9. What is psychological observation? +A. It's like a step down from suicide watch. They're +still constantly under observation, but it's less +restrictive. +e. Based on your interviews with the psychology +staff, did you come to learn that approximately a week on +suicide watch and psychological observation was a usual +amount of time or an unusual amount of time to be on that +status? +A. Unusual. +Q. In what way? +A. Longer than usual. +Q. On July 30th, 2019, what happened? +A. He was transferred back to the SHU. +2. Did the psychology department provide any +instructions about whether he should be housed with a +cellmate? +A. +Yes. They recommended that he would be housed - +that he should be housed with a cellmate. +Was he in fact assigned a cellmate? +A. +Yes. +Which cell was Epstein assigned to when he +FREE STATE REPORTING, INC. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +11/14/19 +21 +returned to the SHU on July 30th? +A. +He was on I-tier. +And the picture that you +showed earlier and you said, is that a cell that you can +see, it was, it was that one. +Is that the closest cell to the officers' desk? +A. +Yes. +Q. When you're sitting at the desk, can the officers +see all the way into the cell? +A. No. +Q. When you're an inmate in that cell and you're +standing at the window of the cell, can you see down into +the officers' desk? +A. Yes. +Q. And approximately how many feet away was Epstein's +cell from the officers' desk? +A. Fifteen. +e. On this slide, starting with the photo on the +left, what does this depict? +A. +That is what I referred to as the grill, that +first door leading inside a tier, and that's I-tier. +And then looking in the photograph in the center, +what does this depict? +A. +That's Epstein's cell. +Q. And the door is open; is that right? +A. +Yes, um-hmm. +FREE STATE REPORTING, INC. +Court Reporting + + +1 +2 +3 +4 +5 +6 +7 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +11/14/19 +22 +So looking into the cell, this is what you would +see head on; is that right? +A. +Um-hmm. +Q. And then what's the photo on the right? +A. That's the right side of his cell that you can't +see just looking straight in. +What, if anything, happened 8 a.m. on August 9th, 8 +e. +2019? +A. +Of MCC. +That's when Epstein's cellmate was transferred out +Was his cellmate transferred out in a routine +pre-arranged transfer? +A. +Yes. +Q. Was Epstein reassigned a cellmate? +A. No. +2. Who were the officers on duty in the SHU from the +afternoon of August 9th into the morning of August 10th? +A. August 9th, the 4 p.m. to 12 p.m. was +Officer Noel. Also, there was Officer +and then +Officer +The first officer you mentioned, is that +A. +Yes. +e. And we'll refer to him as Officer 1, or +What time did he work on the SHU on August +FREE STATE REPORTING, INC. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +11/14/19 +23 +9th? +A. +A. +He as there 2 p.m. to 10 p.m. +And the other officer, is that +Yes. +And we can refer to him as Officer 2, or +What time did he work in the SHU on +Officer +August 9th? +A. 4 p.m. to 12 a.m. +What time did Officer Thomas, Michael Thomas, work +in the SHU on August 10th? +A. 12 a.m. to 8 a.m. +2. Who were the officers on duty in the SHU from 12 +a.m. August 10th through 8 a.m. August 10th? +A. +That was Officer Noel and Officer Thomas. +e. And they were the only officers on duty; is that +right? +A. +Yes. +Q. Let's talk about the 4 p.m. institutional count on +August 9th. Who was responsible for conducting the count? +A. +That was around the 4 p.m. would have been +Officer Noel and +Based on the video review, did they conduct the +count? +A. +No. +l. Did they sign a count slip that falsely stated +FREE STATE REPORTING, INC. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +11/14/19 +24 +that they had performed the 4 p.m. count? +A. +Yes. +Is that the count slip you see right here? +A. +Yes. +Q. Did the control center clear the 4 p.m. count in +reliance on this false count slip? +A. Yes. +Q. What happened that evening? +A. +So Epstein returned to the SHU from his attorney +conference. And then at that point, he -- in the SHU, he +was escorted by Officer Noel and another officer - I +couldn't quite see exactly who that was -- to I-tier. +9. What time was Epstein escorted back into his cell? +A. Approximately 7:49 p.m. +l. And the other officer, was it either +or Officer +? +A. Yes. +Q. Did Officer Noel and the other officer, whoever it +was, leave Epstein's tier shortly thereafter? +A. Yes. +Q. Let's talk about the 10 p.m. institutional count. +Who was responsible for conducting that count? +A. +That was Officer Noel and Officer +2. Did the video show that they conducted the 10 p.m. +count? +FREE STATE REPORTING, INC. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +11/14/19 +25 +A. +No. +Q. Did they sign a false count slip saying that the +10 p.m. count had been done? +A. +Yes. +Q. In reliance on that count slip, did the control +center clear the 10 p.m. count? +A. Yes. +Q. So I want to ask you about some movement on the +video at either side of the 10 p.m. count, which was not +done. Did you see any movement at approximately 9:20? +A. Yes. Iwo officers, one being Officer Noel, were +moving to several of the tiers. They didn't go to all of +them, but I couldn't quite tell exactly what they were doing +on the tiers at that time. +Q. So you saw them walk up to some, but not all the +tiers, at about 9:20? +A. Um-hmm. Yes. +e. +10:30? +Okay. +And then did you see any movement again at +A. +Yes. +Officer Noel, by herself, went up to each +tier. +After Officer Noel -- and was that brief? Did she +spend a brief amount of time -- +A. It was a brief amount of time, um-hmm. +After Officer Noel walked up to each tier at +FREE STATE REPORTING, INC. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +11/14/19 +26 +10:30, did you see anyone else go up to Epstein's tier after +10:30 p.m.? +A. I did not see anyone else, no. +Q. Let's talk about the 12 a.m. count. You mentioned +that Officer Thomas came on duty at 12 a.m. replacing +Officer +¡ is that right? +A. +Yes. +e. So who was responsible for conducting the 12 a.m. +institutional count? +A. That was Officer Noel and Officer Thomas. +Q. Did the video show that they conducted the 12 a.m. +count? +A. NO. +2. Did they sign and complete a false count slip +saying that they had completed that count? +A. Yes. +Q. Is that the count slip we see here? +A. +Yes. +In reliance of that false count slip, did the +control center clear the 12 a.m. count? +A. +Yes. +0. Who was responsible for conducting the 3 a.m. and +5 a.m. institutional counts? +A. Officer Noel and Officer Thomas. +Q. And that was in the SHU, correct? +FREE STATE REPORTING, INC. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +11/14/19 +27 +A. +Yes. +Did the video show that they completed either the +3 a.m. or the 5 a.m. count? +A. No. +Q. They did not? +A. No. +Q. Did they sign and complete false count slips +saying that they had in fact completed the 3 a.m. and the +5 a.m. counts? +A. Yes. +And are those the count slips we see here? +A. +Yes. +Q. Did the control center, in reliance on these false +count slips, clear the 3 a.m. and 5 a.m. counts? +A. +Yes. +Q. So earlier, we saw an example of a count that was +done, correct? +A. Um-hmm. +So I'd like to play -- which count is this? +A. +The 5 a.m. +Okay. On August 10; is that right? +A. +Yes. +Okay. So describe what we're seeing. +A. So in reviewing the hours 4:30 a.m. to 5:30 a.m. +this is pretty much the activity that you see during that +FREE STATE REPORTING, INC. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +11/14/19 +28 +time. +And that is no activity? +A. Right. +2. Did Noel and Thomas conduct any of the required +30-minute rounds during their shift from 12 a.m. to +approximately 6:30 a.m.? +A. No. +0. Did Noel complete and sign 30-minute round forms +saying that they had in fact done so? +A. Yes. +Approximately how many false entries did she make +on those 30-minute round forms? +A. +Approximately 75. +Q. Let's talk about what they were doing overnight. +What were Noel and Thomas doing overnight when they were not +doing counts or rounds? +A. So for the most part, they were over at the +correctional officers' desk. Every now and then, you would +see Noel kind of - like in that previous example, around 5, +she would kind of get up and in that multi-purpose area, and +then go back over to the desk. So there was a general lack +of movement throughout the night. +Were Noel and Thomas using the computers? +A. +Yes, they were on the computer. Noel searched for +furniture sales and benefit websites. And then Thomas, +FREE STATE REPORTING, INC. +Court Reporting + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +11/14/19 +29 +around 1 a.m., 4 a.m., and 6 a.m., he searched for +motorcycle sales and looked at sports news. +2. At approximately 4 a.m., did anyone come into the +SHU? +A. +Yes, one of the overnight supervisors. +Q. What happened? +A. She entered the SHU through that door 46, which is +off to the right of the camera view, and walked over towards +the desk where Noel and Thomas was. And then she left. +Q. Did any other officer come into the SHU during the +night? +A. +There was one other officer, and that was around +5:30 a.m., and that officer was working in 10 South, which +is through that door 46. Michael Thomas had given him a +break, and he came into the SHU and went out of view, and +got some food and came back to his duty location in +10 South. +Q. Aside from those two and Noel and Thomas, did you +see anyone else in the SHU that night? +A. No. +Q. At approximately 6 a.m. on August 10th, did you +see any movement on the camera? +A. +Yes. Usually after 6 a.m. is when the inmates in +the SHU are served breakfast, so there was a cart that was +rolled into the SHU in that multi-purpose area. +FREE STATE REPORTING, INC. +Court Reporting + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +11/14/19 +30 +And shortly after 6:30 a.m., what did you see? +A. Officer Noel and Officer Thomas got up from the +desk and they went towards I-tier. +And that was the tier in which Epstein was housed, +correct? +A. +Correct. +Q. At 6:33 a.m., what happened? +A. There was an alarm that was activated in the SHU. +Epstein was found alone in his cell but not responsive. And +you can see on the camera, there is, like, a flurry of +activity at that time. +Who was the first person to respond to the alarm +that had been activated? +A. +It was -- +e. other than Thomas and Noel? +A. One of the supervisors. +What happened when the supervisor got to the SHU? +A. +When he got to the SHU, he was approached by Noel, +and she told him that Epstein hung himself. +0. Did the supervisor arrive within 1 to 2 minutes of +the alarm being activated? +A. +Yes. +Q. when the supervisor walked up to Epstein's cell, +what did he see inside? +A. +He saw Officer Thomas performing CPR on Epstein, +FREE STATE REPORTING, INC. +Court Reporting Iranscription + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +11/14/19 +31 +who was on the floor. +Q. +Who was one of the second people to arrive at the +scene? I'll rephrase that. +A. +okay. +Q. In the investigation, did a law enforcement agent +speak to a nurse who arrived shortly after the supervisor to +the scene? +A. Yes. +e. +What did the nurse see? +A. +The nurse saw CPR being performed on Epstein. He +was on the floor, and there was a noose around his neck. +Did the nurse attempt to revive Epstein? +A. +Yes. +Q. Was there any sign of life? +A. +No. +2. Was Epstein transferred to a hospital shortly +thereafter? +A. Yes. +What happened? +A. +He was pronounced dead? +Q. Did the New York State Office of the Chief Medical +Examiner conduct an autopsy on Mr. Epstein's body? +A. +Yes. +What did they determine? +A. +That Epstein died from -- it was a suicide by +FREE STATE REPORTING, INC. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +11/14/19 +32 +hanging. +Q. +When the supervisor responded to the SHU during +the scene that we just described where Epstein was still -- +his body was still in the cell, did the supervisor speak +with Thomas and Noel? +A. +Yes. +Q. And what happened? +A. Noel and Thomas basically said they were, like, we +messed up, we didn't do the 3 a.m. or the 5 a.m. count. +Q. So what did Noel specifically say? +A. She said we didn't complete the 3 a.m. or the +5 a.m. counts. And then Thomas said that -- don't blame +her, it wasn't her fault, we messed up. +Q. Did Thomas also say, we didn't do any rounds? +A. Yes. +e. Special Agent +1, you mentioned earlier that +you reviewed bank accounts. Did you review the bank +accounts, or did you or other FBI personnel review the bank +accounts, for Officers Thomas and Noel? +A. +Yes. +Q. Was there any evidence that they were bribed in +any way? +A. +No. +e. Special Agent +1, have you told the grand jury +everything you know about this case, or you merely answered +FREE STATE REPORTING, INC. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +11/14/19 +33 +the questions I've asked? +A. I answered the questions that you asked. +2. And when you testified about conversations you had +with others or documents you reviewed, did you testify to +the exact words used or just the substance of the +conversations and documents? +A. The substance. +Q. Are you willing to return to the grand jury if the +grand jurors have any questions for you? +A. Yes. +MS. +I'll ask that Special Agent +FOREPERSON. +Sure. +With the Foreperson's permission, +be excused. +(Witness Excused) +(Time Noted: 3:01 p.m.) +(Colloguy Follows) +FREE STATE REPORTING, +INC. +Court Reporting + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +11/14/19 +34 +(Colloquy Precedes) +(Witness Recalled) +(Time Noted: 3:14 p.m.) +FOREPERSON. +The witness is reminded that she's +still under oath. +BY MS. +Special Agent +I, you testified about the +existence of time stamps on the video that you discussed. +Focusing in particular on August 9th and August 10th. +A. Yes. +Q. Did you take steps to ensure that those time +stamps were accurate? +A. +Yes. +Q. And were they accurate? +A. Yes. +2. Describe one of the things that you did to ensure +that they were accurate. +A. For instance, the body alarm went off at +approximately 6:33, and on camera, that's where you see the +flurry of activity in the SHU. +So where there are independent records of events +occurring, you also saw that happening on the recorded time +stamp of the video? +A. Yes. +e. Was the video you reviewed for August 9th and 10th +FREE STATE REPORTING, INC. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +11/14/19 +35 +continuous, or did it show any signs that it had been +tampered with in any way? +A. +No. +l. Yes, it was continuous? +A. It was continuous and did not show signs that it +was tampered with. +2. Okay. You testified that the majority of counts +were actually done prior to August 9th. Did you ever see -- +I'll rephrase that. Was one count -- more than one count +ever missed in a row? +A. No. +Q. And today, you testified about Noel and Thomas +missing five counts in a row; is that correct? +A. +Yes, well, Noel would have missed the five, but, +yes. +2. What do supervisors do to ensure that the counts +are actually done? +A. That's something that they take the officer's word +on. That when the officer says, I did this; they take that +as the truth. +9. Do officers receive any training about the counts +and the importance of the counts? +A. They receive annual refresher training concerning +what their job duties. They have post orders posted at -- +where they are stationed, and they are to read those. And +FREE STATE REPORTING, INC. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +11/14/19 +36 +through interviews that we conducted, that was one thing +that many of the officers said was that the counts are +important, they are supposed to be done. +e. What do supervisors do to ensure that the +30-minute rounds are done? +A. I'm sorry, can you - +0. What do supervisors do to ensure that the +30-minute rounds are done? +A. +As far as the 30-minute rounds, that is -- again, +that's one of the things that the supervisors are saying +that when my correctional officers tell me that they did +this, then that's their word, they're giving me their word +that they actually conducted that 30-minute round. +l. You testified about reviewing the bank accounts +for the officers and saw no evidence that they were bribed. +Based on the investigation, did the investigation reveal +that the officers had engaged in any unusual spending +patterns purchased expensive items or taken any steps to +show that they had an influx of cash after the August 10th +suicide? +A. +No. +You saw no evidence of that? +A. +No. +Q. And Special Agent +, just a clean-up question, +you've been testifying about a PowerPoint that I've marked +FREE STATE REPORTING, INC. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +11/14/19 +37 +Grand Jury Exhibit 1. Did you review this prior to +testifying? +A. Yes. +Q. And is it accurate, and did it aid you in +testifying here today? +A. +Yes. +MS. +With that, I'll ask for the +witness to be excused. +FOREPERSON. +Sure. +(Witness Excused) +(Time Noted: +3:18 +p.m.) +(Colloquy Follows) +FREE STATE REPORTING, +Court Reporting + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +CERTIFICATE +I hereby certify that the foregoing is a true and +accurate transcription, to the best of my skill and ability, +from my electronic notes of this proceeding. +November 15, 2019 +Date +Isaac Gardner +Acting Grand Jury Reporter +Free State Reporting, Inc. +FREE STATE REPORTING, +Court Reporting \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/283cdd1fd7afee053c1baa24b9db6bd9e00f076e16fecd913cd817577fed2408.receipt.json b/vision-fixhub/ds9-parsed-01/283cdd1fd7afee053c1baa24b9db6bd9e00f076e16fecd913cd817577fed2408.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..ac701b8233cc9340283412f77e838e8bbdf447fd --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/283cdd1fd7afee053c1baa24b9db6bd9e00f076e16fecd913cd817577fed2408.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -2483, + "dataset": "marble-joined", + "doc_id": "283cdd1fd7afee053c1baa24b9db6bd9e00f076e16fecd913cd817577fed2408", + "engine": "marble-apple-vision", + "event_count": 42, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "297b9b0981dcec2ab38d2a41d21a89dd48843a98e74449d120aa3dd44202a6bf", + "output_sha256": "2f29275e7bd4741ffff3c9d0d1d50759be00b77ce8bba9fe47bf504834d9a674", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/28513915d07277f5e9429d13e7537ba308feacf0dbf998c637138bce1657b351.md b/vision-fixhub/ds9-parsed-01/28513915d07277f5e9429d13e7537ba308feacf0dbf998c637138bce1657b351.md new file mode 100644 index 0000000000000000000000000000000000000000..717a8ee113a07f4126aa6d9293719e1ed05579a7 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/28513915d07277f5e9429d13e7537ba308feacf0dbf998c637138bce1657b351.md @@ -0,0 +1,369 @@ +THE JEFFREY E. EPSTEIN 2001 TRUST TWO +WHEREAS, THE JEFFREY E. EPSTEIN 2001 TRUST TWO was +created by a Trust Agreement dated November 8, 2001, between JEFFREY E. +EPSTEIN, as Grantor, and JEFFREY E. EPSTEIN and JEFFREY A. SCHANTZ, as +Trustees; and +WHEREAS, article TWELFTH of the Trust authorizes the Grantor to +revoke or amend the Trust, in whole or in part; and +WHEREAS, the Grantor desires to amend and restate THE JEFFREY +E. EPSTEIN 2001 TRUST TWO as hereinafter set forth; +NOW, THEREFORE, THE JEFFREY E. EPSTEIN 2001 TRUST +TWO is amended and restated as follows: +FIRST +The Trustees shall retain such property, IN TRUST, for the following +purposes: +(a) +During the life of the Grantor, to pay any part or all of the +income from such property and such sums from any part or all of the principal of the +-1- +GJ_000266 + + +trust as the Trustees, in their discretion, from time to time determine for any reason +whatsoever to, for, or on behalf of the Grantor. Any income not so paid shall +annually be added to the principal. +(b) +On the death of the Grantor, the remaining income and +principal of this Trust, including any property received by this trust as a result of the +Grantor's death pursuant to his will or otherwise shall be retained by the Trustees, IN +TRUST, for the benefit of +and +("the beneficiaries"), for the following purposes: +(1) To annually pay to each beneficiary an amount of +money equal to the "applicable percentage" (as hereinafter defined) of the amount of +money that the respective beneficiary earns from bona fide employment. The +Trustees shall have sole and absolute discretion as to whether or not any income is +the result of bona fide employment and such determination shall not be subject to +review by any court. In making such determination, the Trustees shall consider the +time devoted to such employment and the nature of the work performed and each +beneficiary shall submit such documentation demonstrating the same as the Trustees +may request. +It is the express intention of the Grantor, JEFFREY E. +EPSTEIN, that this trust supplement the income earned by each beneficiary from her +-2- +GJ_000267 + + +own labor in bona fide gainful employment (i.e., a real job with real work). The +Grantor, JEFFREY E. EPSTEIN, hereby instructs the Trustees that if any beneficiary +has engaged in any plan, scheme or any other conduct whatsoever, to attempt to +thwart such intent by seeking a distribution hereunder for any earnings which are not +due to such beneficiary's own labor in bona fide gainful employment (e.g., by +claiming earnings grossly disproportionate to a particular job or earnings from a "no +show" job), then such beneficiary shall no longer be eligible to receive any +distribution whatsoever from this trust. The determination of whether any +beneficiary has engaged in any such conduct shall be made by the Trustees in their +sole and absolute discretion and shall not be subject to review by any court. +(2) +The "applicable percentage" shall be 200% with +respect to the year of the Grantor's death and shall increase by an additional 100% of +earnings each year thereafter. +(3) +Each beneficiary wishing to seek a distribution from +the trust for any year shall present the Trustees with a written request and with +documentation, such as Form W-2, to support entitlement to a distribution by no later +than March 1 following the year in question. The beneficiary shall also provide the +Trustees with any additional information or documentation that the Trustees may +request in order to verify that income was earned from bona fide employment. +-3- +GJ_000268 + + +(4) +The Trustees shall make their determination as to each +beneficiary's right to a distribution as soon as practicable after receipt of the +requested information and thereafter shall distribute as they have so determined to do. +(5) +The trust term for the beneficiaries trust shall operate +on a calendar year basis continuing until all trust assets have been exhausted. In the +final year of said trust, distributions shall be proportionate if insufficient assets are +available for full distributions. +SECOND +If, pursuant to a mandatory distribution of principal, any minor +becomes entitled to any share of the principal of any trust created hereunder, the +property constituting such share shall be retained by the Trustees, IN SEPARATE +TRUST, to pay to such minor any part or all of the income, including income +previously accumulated, and the principal as the Trustees may, in their discretion, +determine to be reasonably necessary for the minor's support, maintenance, +education, health or other benefit, or, in the case of income, accumulate any part or +all for his benefit. All income and principal not previously paid as above authorized +shall be paid to such minor upon his attaining the age of twenty-one years, or in the +event of and upon his prior death to his estate. +-4- +GJ_000269 + + +THIRD +Any income or principal the Trustees are authorized in their discretion +to pay to a minor may, in the discretion of the Trustees, be paid for the benefit of +such minor to a parent or guardian of such minor, or to the custodian for such minor +under the Uniform Gift to Minors Act, or similar Act, of an appropriate state. The +receipt of the parent, guardian or custodian to whom any income or principal is paid +shall be a full discharge of the Trustees from liability with respect to such payment +and from further accountability therefor. +FOURTH +Wherever the Trustees are directed or authorized to pay income or +principal to any person, the Trustees shall be authorized in their discretion to apply +income or principal to or for the use of such person. +FIFTH +In exercising any discretion the Trustees, or such of them as are +authorized to act, may, but shall not be required to, consider and accept as correct any +statement which they believe to be reliable made by any person, including a person +interested in the way in which the discretion is exercised. The Trustees, in exercising +-5- +GJ_000270 + + +any discretionary authority given to them under any provision of this agreement, shall +not be required to take into account any other resources of income or of principal +available to the person to whom a distribution is under consideration. +SIXTH +The word "issue" as used in this agreement shall mean issue per +stirpes. The word "discretion" as used in this agreement shall mean "sole, exclusive, +and unrestricted discretion." The word "taxes" as used in this agreement shall +include all interest thereon and penalties with respect thereto. Unless the context +otherwise requires, the use of the masculine and feminine shall be interchangeable, +and the use of the singular and plural shall be interchangeable. +-6- +GJ_000271 + + +SEVENTH +All estate, succession, legacy, generation skipping transfer taxes and +inheritance taxes, federal, state, and other, which may be payable by reason of the +Grantor's death, whether in respect of property passing under this agreement or in +respect of property not passing under this agreement, shall be paid out of the property +disposed of pursuant to article FIRST section V paragraph (b) of THE JEFFREY E. +EPSTEIN 2001 TRUST ONE. +EIGHTH +In extension and not in limitation of authority which the Trustees +would otherwise have pursuant to law or pursuant to other provisions of this +agreement, the Grantor directs that they have the following discretionary powers: +(a) +To retain for as long a period of time as they may consider +advisable or proper any property of any kind which may at any time be in their hands. +(b) +To sell at public or private sale or to exchange any property +which may at any time be in their hands, without application to court, on any terms +which they may consider advisable or proper, including terms involving an extension +of credit for any period of time and with or without security. +-7- +GJ_000272 + + +(C) +To invest in or otherwise acquire any property, real or +personal, of any kind, without limitation, without being bound by any provision of +law restricting investments by trustees, including but not limited to common and +preferred stocks, domestic or foreign, interests in partnerships and limited liability +companies, secured and unsecured obligations, mutual and common funds, other +securities, mortgages, commodity futures and contracts, repurchase agreements, and +interests and options in any of the foregoing. +(d) +To acquire and retain property without regard to any principles +of diversification. +(e) +To acquire, exercise or sell conversion, subscription and other +rights and options, and to grant options for any period of time. +(f) +To hold securities in the names of nominees or in such form as +to pass by delivery. +(g) +To employ attorneys, accountants, investment advisers, +security analysts, brokers, agents, clerks, bookkeepers, stenographers and assistants, +and to pay on a regular basis the fair and reasonable value of their services, and in +connection with this power a Trustee who is an attorney, an accountant or a broker or +any firm of attorneys, accountants or brokers of which a Trustee is a partner or +-8- +GJ_000273 + + +employee may be retained on behalf of the trust hereunder and compensated for +services rendered. +(h) +To borrow money for any purpose, including but not limited to +the payment of taxes, this power to include the power to borrow from income for the +benefit of principal or from principal for the benefit of income, with or without +interest, and to pledge or mortgage property as security for money borrowed. +(i) +To lend money or other property to any person, corporation, +partnership, estate, trust or other entity, including a beneficiary hereunder even if +such beneficiary is a Trustee, and to lend, without interest, income to or for the +benefit of principal and principal to or for the benefit of income. +(i) +To distribute income or principal in cash or in kind or partly in +each. Such distributions may be made to any trustee, beneficiary or remainderman +with property that is like or different from the property used to make any other +distribution to any other trustee, beneficiary or remainderman. +(k) +To operate, repair, alter and improve any real property which +they may hold or in which they may hold an interest or a participation; to erect or +demolish buildings thereon; to enter into leases for such real property or any part +thereof or any interest or participation therein for any period of time; to mortgage +such real property or any part thereof or any interest or participation therein for any +-9- +GJ_000274 + + +period of time; to grant options with respect to such real property, mortgages and +leases or any interest or participation therein for any period of time; to perform, +modify, waive provisions of, extend, renew, terminate or otherwise act in respect of +any such leases, mortgages or options; to cause such real property or any interest or +participation therein or any part thereof and themselves to be insured against any and +all risks; to retain an agent or agents for any of the foregoing purposes; and to do or +omit to do anything of any kind or nature with respect to any such real property or +any part thereof or any interest or option with respect thereto and the management +thereof which they may in their discretion consider advisable, whether or not such act +or omission is hereinabove specifically mentioned, without being bound by any +restrictions which might otherwise be applicable and without court approval. +(1) +To determine, in case of reasonable doubt on their part, +whether any property coming into their hands constitutes income or principal, and +whether any payment or expenditure made by them shall be charged to income or to +principal. +(m) +To retain any interest in, to invest in and become a member of, +any real estate partnership or joint venture; to comply with all the terms and +provisions of every real estate partnership or joint venture relating to any investment +at any time held by them; to succeed the Grantor as a member of any such partnership +-10- +GJ_000275 + + +or joint venture, and to vote, execute consents, exercise all rights and take such other +action with respect to any real estate partnership or joint venture as they, in their +discretion, deem advisable. +(n) +To become or continue to be an officer, director, or employee +of any corporation, the stock of which may be owned by the Grantor's estate or the +trust created hereunder and as such officer, director or employee to receive a salary, +bonus, or other compensation in reasonable amount for services rendered to said +corporation. +(o) To delegate to any one of the Trustees any nondiscretionary +power, including but not limited to the power, singly or with others, to sign checks, +withdrawal slips, instructions for the receipt or delivery of securities or other +property, and instructions for the payment or receipt of money, and the power, singly +or with others, to have access to any safe deposit box or other place where property of +any trust created pursuant to this agreement is deposited. +(p) +To transfer any property which they may at any time hold to +any jurisdiction which they deem advisable. +The Trustees shall continue to have all the powers herein vested in +them until the final distribution of all property in their hands. +-11- +GJ_000276 + + +NINTH +The Grantor makes the following provisions with respect to the Trustees: +(a) +JEFFREY A. SCHANTZ is authorized to designate one or +more additional or successor Trustees and is further authorized to remove any Trustee +acting hereunder by a written and acknowledged instrument. Designations shall be in +writing and may be revoked in writing by the maker thereof at any time prior to the +qualification of the person designated +(b) +If JEFFREY A. SCHANTZ resigns or at any time ceases to act +as Trustee, without having designated an additional or successor Trustee, the Grantor +appoints DARREN INDYKE as Trustee in his place. +(c) +Any Trustee may resign by giving notice to take effect on the +date specified in said notice. +(d) +A Trustee may resign or qualify only by a written instrument +mailed or delivered to the Grantor or a Trustee then acting. +(e) +No Trustee acting hereunder shall be liable for any loss or +damage which may occur hereunder, unless due to willful default, deliberate +wrongdoing, or willful violation of an express provision hereof. +(f) +No Trustee at any time acting hereunder shall be required to (i) +give any bond, undertaking, or other security for the faithful performance of his +-12- +GJ_000277 + + +duties in any jurisdiction, or be liable for the acts or omissions of any other Trustee, +(ii) file periodic reports in or to any court or (iii) give notice of appointment as +Trustee to any court. Each Trustee acting hereunder is specifically relieved from any +and all of the duties which would otherwise be placed upon him by Chapter 59 or +Title 15 of the Virgin Islands Code. +(g) +Any reference herein to the Trustees shall include survivors, +successors and additional Trustees. +The Grantor authorizes the Trustees to (i) divide any trust into +separate trusts and (ii) combine separate trusts with substantially similar provisions. +TENTH +The Grantor, or any other person, with the consent of the Trustees, +shall have the right to make additions to any trust hereunder by will or otherwise by +transferring to the Trustees additional real or personal property. +-13- +GJ_000278 + + +ELEVENTH +The Trustees hereby accept the trust and agree to execute it to the best +of their ability +TWELFTH +The Grantor retains the right at any time or times during his life to +revoke, in whole or in part, this agreement and the trust created hereunder and to +receive the entire income and principal. +The Grantor retains the right at any time or times during his life to +amend this agreement and the trust created hereunder. +The Grantor may revoke or amend this agreement and the trust created +hereunder by a written and acknowledged instrument. The right to revoke or amend +the trust shall be a personal right of the Grantor and may not be exercised on his +behalf by any guardian, conservator, committee or other such entity. +This Agreement and the trust created hereunder shall become +irrevocable and unamendable upon the Grantor's death. +-14- +GJ_000279 + + +THIRTEENTH +If any beneficiary under this trust shall in any way directly or +indirectly (a) contest or object to the probate of the Grantor's will or to the validity of +any disposition or provision of the Grantor's will or of this trust or (b) institute or +prosecute, or be in any way directly or indirectly instrumental in the institution or +prosecution of, any action, proceeding, contest, objection or claim for the purpose of +setting aside or invalidating the Grantor's will or this trust or any disposition therein +or provision thereof, then the Grantor directs that (a) any and all provisions in this +trust for such beneficiary and his issue in any degree shall be null and void and (b) +the trust property shall be disposed of as if such beneficiary and his issue in any +degree had all failed to survive the Grantor. +FOURTEENTH +This Agreement and the trust hereby created shall be construed and +governed by the laws of the United States Virgin Islands applicable to agreements +made, delivered and performed therein. +-15- +GJ_000280 + + +FIFTEENTH +This Agreement and the trust created hereunder may be referred to as +"The Jeffrey E. Epstein 2001 Trust Two." +IN WITNESS WHEREOF, the undersigned has executed this +amendment and restatement on February March 8, 2002. +JEFFREY E. EPSTEIN, Grantor +-16- +GJ_000281 + + +TERRITORY OF VIRGIN ISLANDS +DIVISION OF ST. THOMAS/ST. JOHN +) ss. : +) +On the 8"' day of March in the year 2002, before me, the undersigned, personally +appeared JEFFREY E. EPSTEIN, personally known to me or proved to me on the +basis of satisfactory evidence to be the individual whose name is subscribed to the +within instrument and acknowledged to me that he executed the same in his capacity, +and that by his signature on the instrument, the individual or the person upon behalf +of which the individual acted, executed the instrument. +ваш op +Notary Public +PAUL HOFFMAN +NOTARY PUBLIC +COMMISSION NO. LN 011-00 +COMMISSION EXPIRES JUNE 27. 2004 +-17- +GJ_000282 \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/28513915d07277f5e9429d13e7537ba308feacf0dbf998c637138bce1657b351.receipt.json b/vision-fixhub/ds9-parsed-01/28513915d07277f5e9429d13e7537ba308feacf0dbf998c637138bce1657b351.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..eaf891757d0141341cfeb6e319336aecd034a008 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/28513915d07277f5e9429d13e7537ba308feacf0dbf998c637138bce1657b351.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -358, + "dataset": "marble-joined", + "doc_id": "28513915d07277f5e9429d13e7537ba308feacf0dbf998c637138bce1657b351", + "engine": "marble-apple-vision", + "event_count": 18, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "65bf9ec2e0ae0987e55bb6d6d0a12f7362ab31fb1b232051752692292edcf845", + "output_sha256": "9f9a8c71c1868f77fede7e915e79368f6020b61c2af552ad335cd97323986d48", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2872700343321f4ecb6eb8557b952c6852ab25cba5b04478195ecd83c74df51b.md b/vision-fixhub/ds9-parsed-01/2872700343321f4ecb6eb8557b952c6852ab25cba5b04478195ecd83c74df51b.md new file mode 100644 index 0000000000000000000000000000000000000000..2ed18a19e4beeeb6bd3eccc2a6474004e36357eb --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2872700343321f4ecb6eb8557b952c6852ab25cba5b04478195ecd83c74df51b.md @@ -0,0 +1,30 @@ +From: +To: +(USANYS) [Contractor]" < +(USANYS) [Contractor]" < +Cc: +Subject: FW: +& +302's +Date: Mon, 09 Aug 2021 19:02:36 +0000 +Attachments: (U)) +-(UL +t-+ Vol.pdf; I ++notes+6.23.21042045.pdf; +tnotest3.23.21153113.pdf; IMG_1838 jpg +(USANYS)" +Hi team, +Could you please add this to 3500 for the Maxwell case? Thanks! +From: [ +Sent: Monday, August 9, 2021 2:15 PM +To: +(USANYS) < +Subject: +& +302's +See attached. +Detective +NYPD / FBI +Child Exploitation Human Trafficking Task Force +Office: +I (NY) (FBI) < diff --git a/vision-fixhub/ds9-parsed-01/2872700343321f4ecb6eb8557b952c6852ab25cba5b04478195ecd83c74df51b.receipt.json b/vision-fixhub/ds9-parsed-01/2872700343321f4ecb6eb8557b952c6852ab25cba5b04478195ecd83c74df51b.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..3d0d354299ffff1d2df0dbd7c11c31fabbf37b46 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2872700343321f4ecb6eb8557b952c6852ab25cba5b04478195ecd83c74df51b.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "2872700343321f4ecb6eb8557b952c6852ab25cba5b04478195ecd83c74df51b", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "a4cdd072072fba25c30d3b4584d9a0be3eb118fde42042fffba29a82cde93fbf", + "output_sha256": "a0c23612489c1f43274109843ad2f0fb69d7f32ff31e661d38e931f8422b2ebe", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/287ce81b40c9a4bf14b3aa591e07baa5a5e0333f425e09b868a39e18e97335e6.md b/vision-fixhub/ds9-parsed-01/287ce81b40c9a4bf14b3aa591e07baa5a5e0333f425e09b868a39e18e97335e6.md new file mode 100644 index 0000000000000000000000000000000000000000..efc83d8992de39a6ebccf59a4f09c71d1b561aba --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/287ce81b40c9a4bf14b3aa591e07baa5a5e0333f425e09b868a39e18e97335e6.md @@ -0,0 +1,609 @@ +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 1 of 14 +U.S. Department of Justice +United States Attorney +Southern District of New York +The Silvio J. Mollo Building +One Saint Andrew's Plaza +New York, New York 10007 +July 12, 2019 +VIA ECE +The Honorable Richard M. Berman +United States District Court +Southern District of New York +United States Courthouse +500 Pearl Street +New York, New York 10007 +Re: +United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) +Dear Judge Berman: +The Government respectfully submits this letter in response to the defendant's Motion for +Pretrial Release (the "Release Motion"), dated July 11, 2019 (Dkt. 6), and in further support of its +Memorandum in Support of Detention (the "Detention Memo"), submitted to Magistrate Judge +Pitman on July 8, 2019, which is attached hereto and incorporated herein (Ex. A). +PRELIMINARY STATEMENT +The defendant is a serial sexual predator who is charged with abusing underage girls for +years. A grand jury has returned an indictment alleging that he sexually exploited dozens of +minors, including girls as young as 14 years old, in New York and Florida. To this day, he is a +registered sex offender designated by New York State in the highest category of risk to reoffend, +despite unsuccessfully attempting to have that classification lowered. And any doubt that the +defendant is unrepentant and unreformed was eliminated when law enforcement agents discovered +hundreds or thousands of nude and seminude photographs of young females in his Manhattan +mansion on the night of his arrest, more than a decade after he was first convicted of a sex crime +involving a juvenile. +The defendant also faces substantial evidence of his guilt, founded on the corroborated +testimony of numerous victims, and this case presents the very real possibility that he will go to +prison for the rest of his life. The defendant has at his disposal a vast fortune, the details of which +remain largely concealed from the Court. He also has a history of obstruction and manipulation +of witnesses, including, as detailed herein, as recently as within the past year, when media reports +about his conduct reemerged. And he continues to show a shocking lack of understanding of the +gravity of the harm he has perpetrated, including through the minimization of his conduct and +casual disparagement of victims in his arguments. +Against this backdrop of significant-and rapidly-expanding evidence, serious charges, +and the prospect of a lengthy prison sentence, the defendant proposes to be released on conditions +that are woefully inadequate. The Release Motion misconstrues and misunderstands the relevant + + +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 2 of 14 +July 12, 2019 +Page 2 +law, seeks to diminish and demean the harm caused to the many victims of the defendant's +appalling sexual abuse, and utterly fails to meet its burden of rebutting the presumption that no +condition or combination of conditions will reasonably assure the appearance of the defendant as +required and the safety of the community. Rather than even attempting to address the grave risks +of releasing a defendant with extraordinary financial resources and a history of abusing minors, +the defendant instead proposes a bail package that amounts to little more than a barely-secured +bond masquerading as a 14-point plan. The Court should reject the defendant's application and +order him detained pending trial. +Among other things, the proposed bail package contemplates the defendant pledging as the +principal security a property that has already been identified by the Government as subject to +forfeiture upon the defendant's conviction, and which therefore is of no value as collateral. His +proposed global waiver of extradition is unenforceable, and even if enforceable would be little +comfort to victims forced to wait additional years while the defendant is located and returned to +this country. The promise to "deregister or otherwise ground" his private jet is meaningless given +his wealth and ability to easily secure other means of travel. The two co-signers he proposes only +further highlight his minimal community ties, including his lack of any family in or near the +District. Electronic monitoring would merely give the defendant less of a head start in fleeing +and does not guard against the risk of him endangering victims in the very home where he has +continued to hoard nude images of young women and girls. And the private security force he +proposes to guard his gilded cage, a proposal already rejected by this Court in similar +circumstances, simply reinforces the obvious fact that the defendant should be housed where he +can be secured at all times: a federal correctional center. +The defendant faces a presumption of detention, Pretrial Services has recommended +detention, and victims of the defendant seek his detention. Because there are no set of conditions +short of incarceration that can reasonably assure the appearance of the defendant or reasonably +protect the community from the dangers he poses if released, the Court should order him detained. +BACKGROUND +As previously set forth, a federal grand jury in this District returned an indictment (the +"Indictment") charging the defendant with violating Title 18, United States Code Section 1519, +and conspiracy to commit the same. +As charged by the grand jury, the facts giving rise to those counts involve a years-long +scheme to sexually abuse underage girls. Specifically, the defendant enticed and recruited dozens +of minor girls to engage in sex acts with him, for which he paid the vietims hundreds of dollars in +cash, in at least two different states. Victims were initially recruited to provide "massages" to the +defendant, which would be performed nude or partially nude, would become increasingly sexual +in nature, and would typically include one or more sex acts, including groping and direct or indirect +contact with victims' genitals. To perpetuate this exploitation of underage girls, the defendant +actively encouraged certain victims to recruit additional girls to be similarly sexually abused. He +paid these victim-recruiters hundreds of dollars for each additional girl they brought to him, +creating a network of underage victims for him to exploit in New York and Palm Beach. + + +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 3 of 14 +July 12, 2019 +Page 3 +The defendant, through counsel, continues to evidence a complete lack of appreciation for +the gravity of the offenses with which he is charged.' As an initial matter, there can be no plausible +suggestion that the allegations against the defendant involve isolated or aberrational conduct; they +involve repeated, regular acts of sexual abuse committed over a period of many years. And +following the defendant's prior conviction, as described previously by the Government, the +defendant continued to maintain at least hundreds and possibly thousands of nude photos of young +subjects. The defendant's victims in this case, often particularly vulnerable girls, were as young +as 14 years old when he abused them. The defendant knew he was abusing minors, including +because victims told him directly they were underage. And he preyed on his victims habitually +and repeatedly—day after day, month after month, year after year. +The defense calls these disturbing alleged acts "simple prostitution." Mag. Tr. 12:12; see +also D. Tr. at 6:15-19 ("This is basically the Feds today ... redoing the same conduct that was +investigated 10 years ago and calling it, instead of prostitution, calling it sex trafficking"). That +characterization is not only offensive but also utterly irrelevant given that federal law does not +recognize the concept of a child prostitute-there are only trafficking victims because a child +cannot legally consent to being exploited. Defense counsel's repeated assertion that the +Government's case is infirm because no threats or coercion are alleged eg., Mag. Tr. at 12 +("There was no coercion. There were no threats. There was no violence."), 17 (there was no +coercion. There was no intimidation. There is no deception."); Release Motion at 2 ("There are +no allegations ... that he forced, coerced, defrauded, or enslaved anybody ....")—is equally +irrelevant because the offense with which the defendant has been charged requires no such proof. +See, e.g., United States v. Afyare, 632 F. App'x 272, 278 (6th Cir. 2016) ("We hold that § 1591(a) +criminalizes the sex trafficking of children (less than 18 years old) with or without any force, fraud, +or coercion, and it also criminalizes the sex trafficking of adults (18 or older), but only if done by +force, fraud, or coercion."). +Far more important, the defense has already effectively conceded that the Government will +be able to present evidence of the actual primary elements of the charged offense i.e., that the +defendant engaged in sex acts for money with girls he knew were underage. See Release Motion +at 2. On this record, the Government agrees with Pretrial Services that the defendant should be +detained pending trial. He poses a tremendous risk of flight and a danger to the community, and +he cannot overcome the statutory presumption in favor of detention in this case. +' Such arguments are unsurprising from a defendant who previously compared himself to a "person +who steals a bagel" or a tragic mythical figure. See, e.g., Amber Southerland, Billionaire Jeffrey +Epstein: I'm a sex offender, not a predator, N.Y. Post (2011) (**I'm not a sexual predator, I'm an +"offender," the financier told The Post yesterday. 'It's the difference between a murderer and a +person who steals a bagel."); Philip Weiss, The Fantasist, NY Magazine (2007) (**It's the Icarus +story, someone who flies too close to the sun, ' I said. 'Did Icarus like massages?' Epstein asked."). +2 "Mag. Tr." refers to the transcript of the hearing before Magistrate Judge Pitman on July 8, 2019; +"D. Tr." refers to the transcript of the hearing before this Court on July 8, 2019. + + +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 4 of 14 +July 12, 2019 +Page 4 +ARGUMENT +The Government respectfully submits that the defendant cannot overcome the statutory +presumption in favor of detention in this case for the following reasons, among others: +1. +Victims Seek Detention +Pursuant to the Crime Victims' Rights Act ("CVRA"), a crime victim has the right to be +reasonably heard at certain public proceedings in the district court, including proceedings +involving release. 18 U.S.C. § 3771(a)(4). Consistent with that requirement, the Government has +been in contact with victims and counsel identified through this investigation in connection with +the argument regarding bail. +Multiple victims and/or their counsel have asked the Government to seek detention (and to +inform the Court of their views in that respect) for multiple reasons. First, they believe that the +defendant's continued detention is necessary under the CVRA's right to be reasonably protected +from the accused. 18 U.S.C. § 3771(a)(1). They have specifically conveyed to the Government +that they would be fearful for their safety if the defendant were released. For the reasons articulated +herein, the Government believes those concerns to be well-founded. +Additionally, certain victims have asked the Government to advise the Court that they are +specifically concerned about the defendant's proposal to be released even if under conditions that +included home detention and full-time private guards. They believe it would be unfair to victims +of a wealthy defendant, like Epstein, if he were to be given greater freedoms than others would be +in similar circumstances, and that such an arrangement would be inconsistent with their rights. +They specifically asked the Government to advise the Court that they believed such an arrangement +could result in harassment and abuse by the defendant. 3 +II. The Defendant's Proposal Does Nothing to Mitigate His Flight Risk +Each of the relevant factors to be considered as to flight risk—the nature and circumstances +of the offense, the strength of the evidence, and the history and characteristics of the defendant +counsel strongly in favor of detention, and the defendant's proposed package would do nothing +whatsoever to mitigate those risks. +A. Defendant Proposes No Infringement Upon His Ability to Use his Vast Wealth to Flee +It might not be immediately apparent to a reader of the Release Motion that the defendant +is extravagantly wealthy and worth, according to records relating to the defendant recently +obtained by the Government from a financial institution ("Institution-1"), more than $500 million. +3 The Government is aware of at least one additional attorney for a victim who has publicly stated +that her client supports the pretrial detention of the defendant. The Government is unaware of any +victim who has expressed support for the defendant being granted pretrial release on bail. + + +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 5 of 14 +July 12, 2019 +Page 5 +Indeed, while the defendant has still not filled out a financial affidavit, under penalty of +perjury, in connection with his application for bail, his token effort to account for his finances +makes painfully clear the need for detention. The defendant reports having an extraordinary +amount of money in both total assets and cash or cash-equivalent holdings. And while the +defendant repeatedly represents in his Release Motion that his assets are "in the United States," +there is absolutely nothing in the defendant's minimal financial submission to verify that. +Indeed, and as discussed further below, even assuming the defendant's assets are presently +in the United States, nothing in the proposed package would prevent the defendant from +transferring liquid assets out of the country quickly and in anticipation of flight or relocation. The +defendant is an incredibly sophisticated financial actor with decades of experience in the industry +and significant ties to financial institutions and actors around the world. He could easily transfer +funds and holdings on a moment's to places where the Government would never find them so as +to ensure he could live comfortably while a fugitive. +But perhaps most important, even were the defendant to sacrifice literally all of his current +assets, there is every indication that he would immediately be able to resume making millions or +tens of millions of dollars per year outside of the United States. He already earns at least +$10,000,000 per year, according to records from Institution-1, while living in the U.S. Virgin +Islands, traveling extensively abroad, and residing in part in Paris, France; there would be little to +stop the defendant from fleeing, transferring his unknown assets abroad, and then continuing to do +whatever it is he does to earn his vast wealth from a computer terminal beyond the reach of +extradition.* +That the defendant faces up to 45 years of incarceration on the current counts with which +he is charged provides the motive for him do so and is another significant factor in assessing the +risk of flight. See United States v. Jackson, 823 F.2d 4, 7 (2d Cir. 1987). So too is the strength of' +the evidence, detailed above and in the Government's Detention Memo. Indeed, that evidence, +already robust less than a week ago when the Indictment was unsealed, is growing stronger by the +day. Just since the Indictment was unsealed, several additional women, in multiple jurisdictions, +have identified themselves to the Government as having been victimized by the defendant when +they were minors. Moreover, pursuant to judicially-authorized search warrants, the Government +has discovered and seized a significant volume of photographs of nude and seminude young +women and girls in the defendant's Manhattan residence, and is in the process of reviewing dozens +of electronic dises that contain still more such photos. And dozens of individuals have called the +Government in recent days to convey information regarding the defendant and the allegations +* As noted in the Government's Detention Memo, the defendant is a frequent traveler and regularly +travels to and from the United States, including approximately more than 20 flights in which he +traveled to or from a foreign country since 2018 alone. Extensive international travel of this nature +further demonstrates a significant risk of flight. See, e.g., United States v. Anderson, 384 F. Supp. +2d 32, 36 (D.D.C. 2005). +5 The Government's review of these materials, seized earlier this week, remains ongoing. + + +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 6 of 14 +July 12, 2019 +Page 6 +contained in the Indictment. All this in less than a week, and all in addition to an Indictment that +already alleges the existence of dozens of victims in New York and dozens of victims in Florida. +B. The Proposed Bond is Inadequate to Overcome the Presumption of Detention +The defendant's "slate of highly restrictive" measures which purportedly "amply suffice to +secure his release" are neither highly restrictive nor amply sufficient. Rather, they are effectively +standard conditions of home confinement, monitoring, and bond unsecured by the defendant's +assets broken out into 14 pieces. The Government will address the most concerning and salient +elements of the defendant's proposal below. +1. Lack of Meaningful Bond Security +The defendant proposes that the Court accept his Manhattan mansion as the primary +security for a personal recognizance bond of an indeterminate amount, to be co-signed by the +defendant's brother and a friend. Release Motion at 4. This is plainly insufficient. +As an initial matter, and as noted above, the defendant's Manhattan mansion has been +identified in the Indictment as subject to forfeiture because it is alleged to have been used to +commit or facilitate the commission of the sex trafficking offenses charged there. See 18 U.S.C. +§ 1594(c)(1). Because the defendant would thus be likely to lose that property following a +conviction, it provides no value whatsoever as collateral. See 18 U.S.C. § 3142(g)(4) ('In +considering the conditions of release described ... the judicial officer ... shall decline to accept +the designation, or the use as collateral, of property that, because of its source, will not reasonably +assure the appearance of the person as required."). And while the defendant offers to also pledge +his private jet as additional collateral, there is absolutely no reason to assume that the defendant +would not readily trade his private plane for his freedom. Indeed, the defendant, who has a net +worth of more than $500 million, by his own admission recently sold a second plane and thus +presumably has cash on hand to replace the posted aircraft without difficulty if need be. +Nor does the proposed security of properties owned by two identified co-signers +meaningfully change the calculus. As further described below, the defendant provides no +information about the value or equity of the property of his brother, Mark (the "Palm Beach +Property"), or the significance of that property in the context of his brother's own net worth." +Similarly, the defendant provides no details regarding the "investment interests" of his friend Mr. +Mitchell, nor any reason to believe the loss of those "interests" would be meaningful to Mr. +Mitchell, let alone the defendant. More generally, given the defendant's proffered net worth, the +defendant could easily make his co-signers whole - and even reward them - were he to flee. +The proposed security, in sum, should give the Court little comfort the defendant would +appear in Court if released on bail. +" In fact, the defendant's own submission makes clear that the Palm Beach Property is not his +brother's exclusive residence and that his brother lives elsewhere for half of the year. + + +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 7 of 14 +July 12, 2019 +Page 7 +2. Co-Signers, Moral Suasion, and Ties to the Community +The dearth of detailed financial information about the defendant himself, much less his +brother or friend, further shows the hollowness of the proposal. The Court cannot possibly +evaluate whether there would be any incentive whatsoever for those the two proposed co-signers +to exercise moral suasion over the defendant—or whether, as noted above, the defendant could +easily compensate them, perhaps many times over, for any loss they incurred through the +defendant's flight from justice. The defendant provides no information about his brother other +many names pove +than that he lives half the year in the home he purportedly would pledge, and even less information +about Mr. Mitchell, other than that he is "Mr. Epstein's friend," his "close personal friend of +decades," and his "close personal friend." Release Motion at 4, 9. Their willingness to "guarantee" +his appearance, Release Motion at 9, is meaningless in the absence of such information. +Moreover, the notion that any individual co-signer could meaningfully secure a bond for +this defendant strains credulity. Given the defendant's wealth and his extraordinary risk of flight, +any bond for this defendant would assuredly have to be in the hundreds of millions of dollars to +even be claimed to be sufficient to guard against the risks posed by the defendant's release. The +defendant offers no reason to believe any co-signers could meaningfully sign such a bond, much +less these two particular individuals, which is yet another reason the proposed package is patently +insufficient. +3. The Defendant's "Consent" to Extradition is Unenforceable and Impractical +The defendant's offer to sign a so-called "consent" to extradition provides no additional +reassurance whatsoever. As an initial matter, the Government would need to find and re-arrest the +defendant before such a waiver would even come into play. Moreover, even assuming the +Government could locate and apprehend the defendant, numerous courts have recognized that such +purported waivers are unenforceable and effectively meaningless because any defendant who signs +such a purported waiver and then flees will assuredly contest the validity and/or voluntariness of +the waiver, and will get to do so in the jurisdiction of his choosing (i.e., the one to which he chose +to flee). See, e.g., United States v. Morrison, No. 16-MR-118, 2016 WL 7421924, at *4 (W.D.N.Y. +Dec. 23, 2016); United States v. Kazeem, No. 15 Cr. 172, 2015 WL 4645357, at *3 (D. Or. Aug. +3, 2015); United States v. Young, Nos. 12 Cr. 502, 12 Cr. 645, 2013 WL 12131300, at *7 (D. Utah +Aug. 27, 2013); United States v. Cohen, No. C 10-00547, 2010 WL 5387757, at *9 n.11 (N.D. +Cal. Dec. 20, 2010); United States v. Bohn, 330 F. Supp. 2d 960, 961 (W.D. Tenn. 2004); United +States v. Stroh, No. 396 Cr. 139, 2000 WL 1832956, at *5 (D. Conn. Nov. 3, 2000); United States +v. Botero, 604 F. Supp. 1028, 1035 (S.D. Fla. 1985). . The Department of Justice's Office of +International Affairs is unaware of any country anywhere in the world that would consider an +anticipatory extradition waiver binding. And, of course, the defendant could choose to flee to a +jurisdiction with which the United States does not have an extradition treaty. +Beyond being impossible to guarantee, extradition is typically a lengthy, complicated and +expensive process, and the possibility that it would be successful neither provides any real +deterrent to the defendant's incentive to flee nor any measure of justice to the victims who would +be required to wait years for his return. + + +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 8 of 14 +July 12, 2019 +Page 8 +4. Home Confinement and Electronic Monitoring Provide No Assurance +The defendant's proposal of ankle-bracelet monitoring should be of no comfort to the +Court. In particular, the defendant's endorsement of a GPS monitoring bracelet rather than a radio +frequency bracelet is farcical because neither one is useful or effective after it has been removed. +At best, home confinement and electronic monitoring would reduce his head start should he decide +to cut the bracelet and flee. See United States v. Zarger, No. 00 Cr. 773, 2000 WL 1134364, at *1 +(E.D.N.Y. Aug. 4, 2000) (rejecting defendant's application for bail in part because home detention +Cr. 099, 2002 WL 31410262, at *3 (E.D.N.Y. Oct. 10, 2002) (same). +5. Private Security is Inadequate, Unfair, and Impractical Here +The defendant also proposes the use of a private security force to march him to and from +court under the threat of deadly force. This proposal should be rejected. +At the outset, it is far from clear that private jail, which seeks to replicate the conditions of +a government-run detention facility in the defendant's home, is a condition of "release" that +implicates the Bail Reform Act. "[T]here is a debate within the judiciary over whether a defendant, +if she is able to perfectly replicate a private jail in her own home at her own cost, has a right to do +so under the Bail Reform Act and the United States Constitution." United States v. Valerio, 9 F. +Supp. 3d 283, 292 (E.D.N.Y. 2014) (Bianco, J.) (collecting cases). The Second Circuit has never +directly addressed this issue. See United States v. Sabhnani, 493 F.3d 63, 78 n.18 (2d Cir. 2007) +("The government has not argued and, therefore, we have no occasion to consider whether it would +be "contrary to the principles of detention and release on bail' to allow wealthy defendants 'to buy +their way out by constructing a private jail." (citations omitted)). Indeed, a decision by this Court +reasoned that "the very severe restrictions" in the private jail proposal presented to him did "not +appear to contemplate release' so much as it describes a very expensive form of private jail or +detention." United States v. Zarrab, 2016 WL 3681423, at *10 (S.D.N.Y. June 16, 2016). +Courts have long been troubled by private jail proposals like the defendant's which, "at +best 'elaborately replicate a detention facility without the confidence of security such a facility +instills."" United States v. Orena, 986 F.2d 628, 632 (2d Cir. 1993) (quoting United States v. Gotti, +776 F. Supp. 666, 672 (E.D.N.Y. 1991) (rejecting private jail proposal)); see also Valerio, 9 F. +Supp. 3d at 295 ("The questions about the legal authorization for the private security firm to use +force against defendant should he violate the terms of his release, and the questions over whether +the guards can or should be armed, underscore the legal and practical uncertainties indeed, the +imperfections of the private jail-like concept envisioned by defendant, as compared to the more +secure option of an actual jail."). A private security firm simply cannot replicate the controlled +environment of a federal correctional facility, in which, typically, all of the needs to the prisoner +can be attended to without placing the prisoner in the community at large; the defendant's proposed +private jail arrangement would have the effect of permanently placing him in just such a highflight-risk circumstance. The risk of a public escape attempt while in the community and involving + + +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 9 of 14 +July 12, 2019 +Page 9 +armed private guards attempting to stop the defendant, potentially by force rather than the +defendant being in the environment of a federal facility—also greatly magnifies the danger of the +defendant's flight to the public. See United States v. Boustani, 356 F. Supp. 3d 246, 257 (E.D.N.Y +2019). "This is why, as the Government correctly notes, federal prisoners should be detained in +facilities run by trained personnel from federal correctional facilities." Id. at 258 (citing Sabhnani, +493 F.3d at 74 n. 13 ("To the extent [armed private guards] implies an expectation that deadly force +may need to be used to assure defendant['s] presence at trial ... [s]uch a conclusion would, in fact, +demand a defendant's detention"). +The Second Circuit has held it is not legal error "for a district court to decline to accept," +as "a substitute for detention," a defendant hiring private security guards to monitor him. United +States v. Banki, 369 Fed. App'x 152, 153-54 (2d Cir. 2010). In the same decision, the Second +Circuit noted that it was "troubled" by the possibility of "allow[ing] wealthy defendants to buy +their way out by constructing a private jail." (internal quotation marks omitted)). Id.; accord, e.g., +United States v. Cilins, No. 13 Cr. 315 (WHP), 2013 WL 3802012, at *3 (S.D.N.Y. July 19, 2013) +("*'it is contrary to underlying principles of detention and release on bail that individuals otherwise +ineligible for release should be able to buy their way out by constructing a private jail, policed by +security guards not trained or ultimately accountable to the Government, even if carefully +selected'" (quoting Borodin v. Ashcroft, 136 F. Supp. 2d 125, 134 (E.D.N.Y. 2001)); Valerio, 9 +F. Supp. 3d at 293-94 (E.D.N.Y. 2014) ("There is nothing in the Bail Reform Act that would +suggest that a defendant (or even, hypothetically, a group of defendants with private funding) has +a statutory right to replicate or construct a private jail in a home or some other location."). +The defendant's payment of his guards also raises the conflict of interest inherent in having +the defendant having extraordinary influence over a private security company tasked with guarding +him, leaving the company's incentives entirely aligned with the defendant. See, e.g., Boustani, +356 F. Supp. 3d at 257 (in finding that private armed guards would not reasonably assure the +appearance of a defendant, noting a "clear conflict of interest private prison guards paid by an +inmate" and noting that in a recent S.D.N.Y. case involving private security guards the defendant +"was outside of his apartment virtually all day, every weekday; was visited by a masseuse for a +total of 160 hours in a 30-day period; and went on an unauthorized visit to a restaurant in +Chinatown with his private guards in tow"); see also United States v. Tajideen, 17 Cr. 046, 2018 +WL 1342475, at *5-6 (D.D.C. Mar. 15, 2018) (finding Zarrab "particularly instructive" and further +noting: "While the Court has no reason to believe that the individuals selected for the defendant's +security detail would intentionally violate federal law and assist the defendant in fleeing the Court's +jurisdiction, it nonetheless is mindful of the power of money and its potential to corrupt or +undermine laudable objectives. And although these realities cannot control the Court's ruling, they +also cannot be absolutely discounted or ignored."). +Finally, in Zarrab this Court found that "the Defendant's privately funded armed guard +proposal is unreasonable because it helps to foster inequity and unequal treatment in favor of a +very small cohort of criminal defendants who are extremely wealthy, such as Mr. Zarrab." 2016 +WL 3681423, at *13; see also Boustani, 356 F. Supp. 3d at 258 ("although this Defendant has vast +financial resources to construct his own "private prison,' the Court is not convinced 'disparate +treatment based on wealth is permissible under the Bail Reform Act) (quoting United States v. + + +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 10 of 14 +July 12, 2019 +Page 10 +Bruno, 89 F. Supp. 3d 425, 432 (E.D.N.Y. 2015) (***Even if Defendant had the financial capacity +to replicate a private jail within his own home, this Court is not convinced that such a set of +conditions would be sufficiently effective in this case to protect the community from Defendant, +or that such disparate treatment based on wealth is permissible under the Bail Act.")); Borodin, +136 F. Supp. 2d at 134 (E.D.N.Y. 2001) (Nickerson, J.) ("It is contrary to underlying principles of +detention and release on bail that individuals otherwise ineligible for release should be able to buy +their way out by constructing a private jail, policed by security guards not trained or ultimately +accountable to the government, even if carefully selected."). +If the defendant's appearance can only be assured through use of round-the-clock guards, +the defendant belongs in a federal detention center, not released under bail conditions that +effectively create a private prison of one, using guards to be paid by the defendant himself. It is +frankly outrageous for the defendant to suggest that preventing him from using his vast wealth to +duplicate a private prison that cannot control, monitor, and contain him consistent with the +requirements of the Bail Act would cause him to somehow "bear a special disadvantage." Release +Motion at 12 n.9. Indeed: "What more compelling case for an order of detention is there than a +case in which only an armed guard and the threat of deadly force is sufficient to assure the +defendant's appearance?" Zarrab, 2016 WL 3681432, at *12 (quoting United States v. Valerio, 9 +F. Supp. 3d at 295). +III. +The Defendant Provides No Assurance He is Not a Danger to the Community and a +Risk to Obstruct Justice +A. Danger to the Community +In the first instance, the defendant's argument that 14 years without a criminal conviction +eliminates "any danger presumption" should be rejected. Were that the case which is certainly +is not—a lack of criminal record for any defendant would automatically rebut the presumption +applicable to crimes such as sex trafficking. That is manifestly incorrect. See United States v. +Artis, 607 F. App'x 95, 97 (2d Cir. 2015) (finding that a defendant's lack of criminal record was +"not so compelling as to defeat the presumption or to manifest clear error in the district court's +determination that no combination of release conditions ... could reasonably assure against +dangerousness and the risk of flight"). Moreover, here, the defendant not only has a criminal +record, but has been convicted of a sex crime involving a minor. +But the ongoing and forward-looking danger posed by the defendant is further +demonstrated by the defendant's maintenance of a substantial collection of photographic trophies +of his victims and other young females in his mansion, as discovered by the Government through +its search warrants. As indicated in the Detention Memo, the many dises found in the defendant's +residence included those with hand-written labels including the following: "Young [Name] + +[Name]," "Mise nudes 1," and "Girl pies nude." Not surprisingly, the Government has found that +such discs contain photographs of sexually suggestive photographs of fully- or partially-nude +females appearing to be underage. + + +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 11 of 14 +July 12, 2019 +Page 11 +B. Danger to Obstruct Justice +The defendant has also already demonstrated a willingness to use intimidation and +aggressive tactics in connection with a criminal investigation. Far from being "musty," Release +Motion at 6 n.6, the defendant's past behavior in connection with being investigated for sexually +abusing children is the best predictor of his likely incentives and activities in connection with being +charged with sexually abusing children. For example, in the incident the defendant now claims +was not attributable to or authorized by him, the contemporaneous police report indicates that +pressure tactics were at the very least coordinated closely with individuals in the defendant's orbit. +See Palm Beach Police Report (the "Police Report") (Ex. B). According to the Police Report, the +parent of one of the defendant's victims was driven off the road by a private investigator. The +Police Report provides further information regarding victim and witness threats and intimidation +reported against an individual who was directly in contact with an assistant of the defendant, +followed "immediately" by a call to that same individual from a phone number associated with the +defendant's businesses and associates. +Separately, and in addition, there are also extensive allegations of obstruction and +tampering in connection with civil lawsuits brought against the defendant following his 2008 +conviction. See Doe v. United States, 08 Civ. 80736 (S.D. Fla.), Dkt. 291-15 at 21-23, 31. +Moreover, police reports suggest that an associate of Epstein's was offering to buy victims" silence +during the course of the prior investigation. Specifically, one victim reported that "she was +personally contacted through a source that has maintained contact with Epstein," who "assured +[the victim] that she would receive monetary compensation for her assistance in not cooperating +with law enforcement." Indeed, the victim reported having been told: "Those who help him will +be compensated and those who hurt him will be dealt with. " See Palm Beach Police Report +(Ex. C). +And Epstein's efforts to influence witnesses continue to this day. As in the past, within +recent months. he paid significant amounts of money to influence individuals who were close to +him during the time period charged in this case and who might be witnesses against him at a trial. +By way of background, on or about November 28, 2018, the Miami Herald began publishing a +series of articles relating to the defendant, his conduct, and the circumstances of his prior +conviction and the non-prosecution agreement ("NPA"). Records obtained by the Government +from Institution-1 appear to show that just two days later, on or about November 30, 2018, the +defendant wired $100,000 from a trust account he controlled to an individual named as a possible +co-conspirator in the NPA. The same records appear to show that just three days after that, on or +about December 3, 2018, the defendant wired $250,000 from the same trust account to another +individual named as a possible co-conspirator in the NPA and also identified as one of the +defendant's employees in the Indictment. Neither of these payments appears to be recurring or +repeating during the approximately five years of bank records presently available to the +Government. +This course of action, and in particular its timing, suggests the defendant was +attempting to further influence co-conspirators who might provide information against him in light +of the recently re-emerging allegations + + +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 12 of 14 +July 12, 2019 +Page 12 +IV. The Defendant Raises Legal Arguments Not Relevant Here +Finally, the defendant raises certain legal arguments he contends he will litigate at the +appropriate stage and which he further suggests mitigate in favor of bail. None is meritorious, and +certainly none should give the Court any comfort whatsoever that the defendant would, if granted +bail, refrain from fleeing so he could attempt to vindicate himself via dubious legal strategies. +Nevertheless, the Government will address the defendant's arguments briefly in turn. +A. The Non-Prosecution Agreement Does Not Preclude Prosecution +As an initial matter, as the Court itself noted at the parties" initial appearance earlier this +week, and as the defendant appears to concede, the instant Indictment charges conduct well beyond +the scope of the NPA - that is, alleged conduet that occurred here in New York and involving New +York based victims. D. Tr. 6-8; Release Motion at 2. For present purposes, that alone is sufficient +to put this issue to rest, because even assuming the defendant were to mount a meritorious +challenge to the NPA, he would still have to stand trial on Count Two of the Indictment and +additional charges brought based on New York conduct. +But more generally, the reasons the defendant can be prosecuted in the Southern District +of New York-or anywhere else outside the SDFL—are manifold. The language of the NPA +overwhelmingly refers to the SDFL, and the core terms and text of the agreement are limited to +the SDFL. The prefatory language states: "THEREFORE, on the authority of R. Alexander +Acosta, United States Attorney for the Southern District of Florida, prosecution in this District for +these offenses shall be deferred in favor of prosecution by the State of Florida."? The final +paragraph of the prefatory language also states, among other things, that after fulfilling the terms +of the agreement, "no prosecution for the [sex abuse] offenses set out on pages 1 and 2 of this +Agreement, nor any other offenses that have been the subject of the joint investigation by the +Federal Bureau of Investigation and the United States Attorney's Office, nor any offenses that +arose from the Federal Grand Jury investigation will be instituted in this District." +In its terms section, the NPA further states that Epstein's signature "is not to be construed +as an admission of civil or criminal liability or a waiver of any jurisdictional or other defense" as +to any victim whose identity was not disclosed by SDFL to Epstein, as provided for in the NPA, +and additionally states that neither Epstein's signature nor any resulting waivers or civil +settlements "are to be construed as admissions or evidence of civil or criminal liability or a waiver +of any jurisdictional or other defense as to any person." These provisions show the parties +contemplated possible criminal prosecutions in other jurisdictions and/or based on victims not +initially identified in the Florida investigations (whether in Florida or elsewhere). The final +substantive paragraph of the NPA states that "Epstein hereby requests that the United States +Attorney for the Southern District of Florida defer [.. ] prosecution." +It is well settled in the Second Circuit that "a plea agreement in one U.S. Attorney's office +does not, unless otherwise stated, bind another." United States v. Prisco, 391 F. App'x 920, 921 +"All emphases relating to the NPA are added unless otherwise specified. + + +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 13 of 14 +July 12, 2019 +Page 13 +(2d Cir. 2010) ("A plea agreement binds only the office of the United States Attorney for the +district in which the plea is entered unless it affirmatively appears that the agreement contemplates +a broader restriction.") (citing United States v. Annabi, 771 F.2d 670, 672 (2d Cir. 1985) (per +curiam)). Moreover, any references in an NPA to the "Government" or the "United States" do not +abrogate these principles. Annabi, 771 F.2d at 672 ("[A] plea agreement whereby a federal +prosecutor agrees that "the Government" will dismiss counts of an indictment... might be thought +to bar the United States from reprosecuting the dismissed charges in any judicial district unless the +agreement expressly limits the scope of the agreement .... However, the law has evolved to the +contrary."). "The mere use of the term "government' in the plea agreement does not create an +affirmative appearance that the agreement contemplated barring districts other than the particular +district entering into the agreement." United States v. Salameh, 152 F.3d 88, 120 (2d Cir. 1998) +(citations and internal quotation marks omitted); see also United States v. Brown, No. 99-1230, +2002 WL 34244994, at *2 (2d Cir. Apr. 26, 2002) (in analyzing an SDFL plea agreement, +reiterating the holding of Annabi and noting that it applies "even if the plea agreement purports to +bind 'the Government'" or the "United States") (summary order); United States v. Bruno, 159 F. +Supp. 3d 311, 321 (E.D.N.Y. 2016) ("The Court disagrees with Defendant's argument that the +phrase 'United States" shows an intent to bind all United States Attorney's Offices. Rather, the +plea agreement covers only Defendant's liability in the SDFL.").* +In sum, this issue is a distraction that has little relevance to the bail determination and does +nothing to address the defendant's risk of flight or mitigate the danger he poses to the community. +B. The Defendant Wrongly Argues the Statute Does Not Apply to His Sex Trafficking +Next, the defendant wrongly argues that the "principal conduct" giving rise to the charges +is his payment of underage girls for sex acts, and that such conduct could not possibly fall under +the charged statutes. As the defendant implicitly concedes, Release Motion at 14, this is an issue +for a motion to dismiss. Nevertheless, the defendant's argument is incorrect for two reasons. +First, although the defendant undoubtedly participated on the demand side of the crime, he +was also instrumental on the supply side given his role in recruiting and causing others to recruit +additional victims. He organized, funded, and perpetuated a sex trafficking scheme in two states, +including with co-conspirators. The fact that he did so for his own eventual and frequent sexual +gratification does not vitiate his role in enticing and recruiting victims, consistent with the elements +of the offense with which he is charged. The defendant was the leader of a sex-trafficking +enterprise, not a mere consumer. +& This analysis similarly extends to a non-prosecution agreement. See United States v. Laskow, +688 F. Supp. 851, 854 (E.D.N.Y. 1988) ("Defendant's argument, in effect, is that unless there is +an explicit statement to the contrary, it is presumed that a non-prosecution agreement binds offices +of the United States Attorney that are not parties to the agreement. This position is at odds with +the law in this Circuit, which presumes a narrow reading of the boundaries of a plea agreement +unless a defendant can affirmatively establish that a more expansive interpretation was +contemplated.") (citing Annabi, 771 F.2d at 672). + + +Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 14 of 14 +July 12, 2019 +Page 14 +Second, he is also wrong on the law. Courts have found that Section 1591 applied to both +suppliers and consumers of commercial sex acts. See, e.g., United States v. Jungers, 702 F.3d +1066, 1069 (8th Cir. 2013) (upholding the conviction of a defendant who attempted to pay for oral +sex from an underage girl and explaining: "The sole issue raised on appeal is whether '[t]he plain +and unambiguous provisions of 18 U.S.C. § 1591 apply to both suppliers and consumers of +commercial sex acts.' We conclude they do.") (alteration in original). The lone case cited by the +defendant, Fierro v. Taylor, No. 11 Civ. 8573, 2012 WL 13042630 (S.D.N.Y. July 2, 2012), relied +heavily on the statutory interpretation undertaken by two district courts in the District of South +Dakota, United States v. Bonestroo, No. 11 Cr. 40016, 2012 WL 13704 (D.S.D. Jan. 4, 2012), and +United States v. Jungers, 11 Cr. 40018, 2011 WL 6046495 (D.S.D. Dec. 5, 2011), both of which +were explicitly overruled by the Eighth Circuit decision in Jungers, 702 F.3d 1066. In the seven +years since Fierro has been decided, it does not appear to have been cited by a single other court. +Additionally, other cases in this Circuit and elsewhere have upheld convictions of procurers or +customers. See United States v. O'Connor, 650 F.3d 839 (2d Cir. 2011) (upholding convictions +under Section 1591 of both the buyer and seller of a child); United States v. Cook, 782 F.3d 983 +(8th Cir. 2015) (rejecting a constitutional challenge that Section 1591 would be void for vagueness +if applied to purchasers); United States v. Mikoloyck, No. 09 Cr. 036, 2009 WL 4798900 (W.D. +Mo. Dec. 7, 2009) ("contrary to defendant's argument, 18 U.S.C. § 1591 clearly applies to those +who attempt to purchase underage sex, not merely the pimps of actual exploited children") (citing +United States v. Roberts, 174 F. App's 475 (11th Cir. 2006) (in which defendant was convicted +under sections 1591(a) and 1594(a) even though no actual children were involved)). +CONCLUSION +As set forth above, the defendant's proposed bail package is insufficient and insubstantial +Pretrial Services, victims, and the Government all recommend pretrial detention due to the unusual +and concerning confluence of factors in this case, including the defendant's extraordinary wealth, +demonstrated willingness to interfere with victims and witnesses, continued possession of lewd +photographs of young females, and both the incentive and means to flee prosecution. +Very truly yours, +GEOFFREY S. BERMAN +United/States Attorney +By: +Assistant United States Attorney +Southern District of New York +Tel: +Cc: +Martin Weinberg, Esq., and Reid Weingarten, Esq., counsel for defendant \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/287ce81b40c9a4bf14b3aa591e07baa5a5e0333f425e09b868a39e18e97335e6.receipt.json b/vision-fixhub/ds9-parsed-01/287ce81b40c9a4bf14b3aa591e07baa5a5e0333f425e09b868a39e18e97335e6.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..2aa8050a2cfcbc9afd0331e7286075aed5c3fb4c --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/287ce81b40c9a4bf14b3aa591e07baa5a5e0333f425e09b868a39e18e97335e6.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -912, + "dataset": "marble-joined", + "doc_id": "287ce81b40c9a4bf14b3aa591e07baa5a5e0333f425e09b868a39e18e97335e6", + "engine": "marble-apple-vision", + "event_count": 16, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "a8c563a1aa385f36fd2bd95dc67780cc3cc57b3476250454e4bb486701a1ac6d", + "output_sha256": "000c7c86a9e308255946b0dd5f3575c639eaddcdb4505b6cb6ff0e16fa2ea07b", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/28801b644514f159b87aff289b931ff47087787b585a0e5a5b3330ed34b29cb6.md b/vision-fixhub/ds9-parsed-01/28801b644514f159b87aff289b931ff47087787b585a0e5a5b3330ed34b29cb6.md new file mode 100644 index 0000000000000000000000000000000000000000..eefb1fc1ae27c77ad9451d01271abf206615eb6f --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/28801b644514f159b87aff289b931ff47087787b585a0e5a5b3330ed34b29cb6.md @@ -0,0 +1,28 @@ +From: " +To: +(USANYS)" 4 +(USANYS)" { +(USANYS)" < +Cc: " +Subject: RE: GM - MLAT Request to France +Date: Fri, 08 Jan 2021 17:09:05 +0000 +Attachments: MLAT_France_v1 docx +Some light comments on this. Thanks +From: [ +(USANYS) + +Sent: Thursday, January 7, 2021 9:31 PM +To: +(USANYS) < +Cc: +Subject: GM - MLAT Request to France +(USANYS) < +Attached for your review is a draft MLAT to France regarding the witness we mentioned earlier this week, • +1. The DOJ Attaché met with the Paris Prosecutor's Office about Brunel today. We understand that they +indicated a willingness to assist on the basis of an MLAT request, and that more generally, they seemed willing to help us +as long as the sharing is reciprocal. Happy to discuss. +Thanks, +Assistant United States Attorney +United States Attorney's Office +Southern District of New York +One St. Andrew's Plaza +New York, New York 10007 diff --git a/vision-fixhub/ds9-parsed-01/28801b644514f159b87aff289b931ff47087787b585a0e5a5b3330ed34b29cb6.receipt.json b/vision-fixhub/ds9-parsed-01/28801b644514f159b87aff289b931ff47087787b585a0e5a5b3330ed34b29cb6.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..86675f8fa0c53619b03bba5c0fd612168b8c87fb --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/28801b644514f159b87aff289b931ff47087787b585a0e5a5b3330ed34b29cb6.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "28801b644514f159b87aff289b931ff47087787b585a0e5a5b3330ed34b29cb6", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "b533e81993630355e4acfa9265ef764604558497ae57cd674f4a8add21dcf4c7", + "output_sha256": "4ffda9010236e457aeacd292bcd8a48d48ca6ac213a09e3e59e31a0d8705b38b", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/28b0bed740f02a58d99960d8139337ecd4a41908e9aa38a6128c04f20fa46650.md b/vision-fixhub/ds9-parsed-01/28b0bed740f02a58d99960d8139337ecd4a41908e9aa38a6128c04f20fa46650.md new file mode 100644 index 0000000000000000000000000000000000000000..994725828b6f3dfa6e16df83e303c5284ea00bc2 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/28b0bed740f02a58d99960d8139337ecd4a41908e9aa38a6128c04f20fa46650.md @@ -0,0 +1,90 @@ +Case 1:20-cr-00330-AJN Document 37 Filed 07/30/20 + +USDC SDNY +DOCUMENT +ELECTRONICALLY FILED +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +DOC#:_ +DATE FILED:7/30/2020 +United States of America, +-V- +Ghislaine Maxwell, +Defendant. +20-CR-330 (AJN) +MEMORANDUM +OPINION & ORDER +ALISON J. NATHAN, Distriet Judge: +Both parties have asked for the Court to enter a protective order. While they agree on +most of the language, two areas of dispute have emerged. First, Ms. Maxwell seeks language +allowing her to publicly reference alleged victims or witnesses who have spoken on the public +record to the media or in public fora, or in litigation relating to Ms. Maxwell or Jeffrey Epstein. +Second, Ms. Maxwell seeks language restricting potential Government witnesses and their +counsel from using discovery materials for any purpose other than preparing for the criminal trial +in this action. The Government has proposed contrary language on both of these issues. For the +following reasons, the Court adopts the Government's proposed protective order. +Under Federal Rule of Criminal Procedure 16(d)(1), "[alt any time the court may, for +good cause, deny, restrict, or defer discovery or inspection, or grant other appropriate relief." +The good cause standard "requires courts to balance several interests, including whether +dissemination of the discovery materials inflicts hazard to others ... whether the imposition of +the protective order would prejudice the defendant," and "the public's interest in the +information." United States v. Smith, 985 F. Supp. 2d 506, 522 (S.D.N.Y. 2013). The party +seeking to restrict disclosure bears the burden of showing good cause. Cf. Gambale v. Deutsche +Bank AG, 377 F.3d 133, 142 (2d Cir. 2004). +1 + + +Case 1:20-cr-00330-AJN Document 37 Filed 07/30/20 Page 2 of 3 +First, the Court finds that the Government has met its burden of showing good cause with +regard to restricting the ability of Ms. Maxwell to publicly reference alleged victims and +witnesses other than those who have publicly identified themselves in this litigation. As a +general matter, it is undisputed that there is a strong and specific interest in protecting the +privacy of alleged victims and witnesses in this case that supports restricting the disclosure of +their identities. Dkt. No. 29 at 3 (acknowledging that as a baseline the protective order should +"prohibit[] Ms. Maxwell, defense counsel, and others on the defense team from disclosing or +disseminating the identity of any alleged victim or potential witness referenced in the discovery +materials"); see also United States v. Corley, No. 13-cr-48, 2016 U.S. Dist. LEXIS 194426, at +*11 (S.D.N.Y. Jan. 15, 2016). The Defense argues this interest is significantly diminished for +individuals who have spoken on the public record about Ms. Maxwell or Jeffrey Epstein, because +they have voluntarily chosen to identify themselves. But not all accusations or public statements +are equal. Deciding to participate in or contribute to a criminal investigation or prosecution is a +far different matter than simply making a public statement "relating to" Ms. Maxwell or Jeffrey +Epstein, particularly since such a statement might have occurred decades ago and have no +relevance to the charges in this case. These individuals still maintain a significant privacy +interest that must be safeguarded. The exception the Defense seeks is too broad and risks +undermining the protections of the privacy of witnesses and alleged victims that is required by +law. In contrast, the Government's proffered language would allow Ms. Maxwell to publicly +reference individuals who have spoken by name on the record in this case. It also allows the +Defense to "referenc[e] the identities of individuals they believe may be relevant... to Potential +Defense Witnesses and their counsel during the course of the investigation and preparation of the +defense case at trial." Dkt. No. 33-1, I 5. This proposal adequately balances the interests at +2 + + +Case 1:20-cr-00330-AJN Document 37 Filed 07/30/20 Page 3 of 3 +stake. And as the Government's letter notes, see Dkt. No. 33 at 4, to the extent that the Defense +needs an exception to the protective order for a specific investigative purpose, they can make +applications to the Court on a case-by-case basis. +Second, restrictions on the ability of potential witnesses and their counsel to use +discovery materials for purposes other than preparing for trial in this case are unwarranted. The +request appears unprecedented despite the fact that there have been many high-profile criminal +matters that had related civil litigation. The Government labors under many restrictions +including Rule 6(e) of the Federal Rules of Criminal Procedure, the Privacy Act of 1974, and +other policies of the Department of Justice and the U.S. Attorney's Office for the Southern +District of New York, all of which the Court expects the Government to scrupulously follow. +Furthermore, the Government indicates that it will likely only provide potential witnesses with +materials that those witnesses already have in their possession. See Dkt. No. 33 at 6. And of +course, those witnesses who do testify at trial would be subject to examination on the record as to +what materials were provided or shown to them by the Government. Nothing in the Defense's +papers explains how its unprecedented proposed restriction is somehow necessary to ensure a +fair trial. +For the foregoing reasons, the Court adopts the Government's proposed protective order, +which will be entered on the docket. +This resolves Dkt. No. 29. +SO ORDERED. +Dated: July 30, 2020 +New York, New York +Alia Of Notor +ALISON J. NATHAN +United States District Judge +3 diff --git a/vision-fixhub/ds9-parsed-01/28b0bed740f02a58d99960d8139337ecd4a41908e9aa38a6128c04f20fa46650.receipt.json b/vision-fixhub/ds9-parsed-01/28b0bed740f02a58d99960d8139337ecd4a41908e9aa38a6128c04f20fa46650.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..de384f1388545aa3d0dfbf9dddeeb80599274cc7 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/28b0bed740f02a58d99960d8139337ecd4a41908e9aa38a6128c04f20fa46650.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -47, + "dataset": "marble-joined", + "doc_id": "28b0bed740f02a58d99960d8139337ecd4a41908e9aa38a6128c04f20fa46650", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "a7e329c47e6ed17f86a0c4b13f4b2dd0415267e5a69faca12056c20bc94be368", + "output_sha256": "ddb10a8e1f33c110989f37d9407bc719be94f703630a211b80cbb6055ba8adbe", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/28b619e01de73745581cae36d8fec331b93c04bbb7fc6dd8e5563c362820c410.md b/vision-fixhub/ds9-parsed-01/28b619e01de73745581cae36d8fec331b93c04bbb7fc6dd8e5563c362820c410.md new file mode 100644 index 0000000000000000000000000000000000000000..e109ab77a22f6489cb8740bd4d92ba6e7328ce0b --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/28b619e01de73745581cae36d8fec331b93c04bbb7fc6dd8e5563c362820c410.md @@ -0,0 +1,1147 @@ +FY-2019 Annual Training +WEEK 1: Monday, March 4, 2019 to Friday, March 8, 2019, at +WEEK 2: Monday, March 11, 2019 to Friday, March 15, 2019, at +WEEK 3: Monday, March 18, 2019 to Friday, March 22, 2019, at +WEEK 4: Monday, March 25, 2019 to Friday, March 29, 2019, at +WEEK 5: Monday, April 1, 2019 to Friday, April 5, 2019, at +WEEK 6: Monday, April 8, 2019 to Friday, April 12, 2019, at +WEEK 7: Monday, April 15, 2019 to Friday, April 19, 2019, at +WEEK 8: Monday, April 22, 2019 to Friday, April 26, 2019, at +WEEK 9: Friday, May 3, 2019, at +Monday, (8:00am-4:30pm) +Time +8:00 am - 9:00 am +9:00 am - 9:30 am +Class +Ethics/Standards of Conduct +LGL-0110-BXX +Oath of Office +Core Values = Video (12 min) (slide 3) +Instructors) +9:30am - 10:30am +10:30 am - 11:00 +11:00am - 11:30am +11:30 am - 12:00 pm +12:00 pm - 12:30 pm +12:30 pm - 4:30pm +Discrimination and the EEO Process +Video Continuity of Operations (COOP) +CSV-0387-GXX +Video Weapons of Mass Destruction (WMD) +CSV-0388-GXX +Lunch +Key Control +CSV-5141-BXX +Sexually Abusive Behavior Prevention & +Intervention Program (PREA) +CPG-0230-BXX +-Managing Inmate Sexual Behaviors, +-Employee Assistance Program (EAP), +-Suicide Prevention +-Mental Health - Video (30 min) (slide 3) +(MDC Brooklyn) +pg. 1 + + +FY-2019 Annual Training +Tuesday, (8:00am-4:30pm) +Time +8:00am - 8:30am +8:30am - 9:00am +9:00am - 10:00am +10:00 am - 10:30 am +10:30 am - 12:00 pm +Class +Supervision of Offenders +GNR-0154-BXX +BOP Re-Entry Strategy - "Game of Life" +-First Responder +-Infectious Diseases (MRSA/PPD) GNR-0152-BXX +Diversity Management - Video (2 min) (slide 7) +-Safety/OSHA +InstructorS) +Diversity Instructor +12:00 pm - 12:30 pm +12:30pm - 4:30pm +Lunch +CPR/AED Certification Year +GNR-0147-BXX +CPR Instructors* +Wednesday, (8:00am-4:30pm) +Time +6:00am - 2:00pm +Class +-Firearms Training at FCI Danbury +Instructors) +Various Firearms Instructors +pg.2 + + +2018 Annual Training +Thursday, FY 18(8:00am-4:30pm) +Time +8:00am - 8:30am +8:30 am - 10:00am +10:00 am - 10:30 am +10:30 am - 11:30 am +11:30am - 12:00pm +12:00 pm - 12:30pm +12:30 pm - 3:30 pm +3:30 pm - 4:30 pm +Class +Incident Report Writing and Inmate Discipline +Process +GNR-0159-BXX +- Use of Force Regulations and Tactics +- Escort Procedures +-Security Procedures +- Oleoresin Capsicum (OC) User +Re-Familiarization CSV-0707-BXX +Incident Command Systems +Information Security Awareness +IPD-0010-BXX +Lunch +-Union's Presentation +-Countering Inmate Extremism +-Emergency Management +-Addressing Inmate Sexual Misconduct +Inmate Beliefs & Practices +Instructors) +Alternate DHO +ICS Instructor +Friday, FY 18(8:00am-4:30pm) +Time +8:00am - 12:00pm +12:00pm -12:30pm +12:30pm-4:30pm +Class +Self-Defense +Lunch +Disturbance Control +Instructor(s) +Self Defense Instructors* +CSV-0770-BXX +CSV-0350-BXX +DCT instructors* +pg. 3 + + +2018 Annual Training +DCT Instructors: +(Lead) +*Diversity Instructor: +(Lead) +*Alternate DHO: +*Self Defense Instructors: +(Lead) +(Lead) +(Lead) +*OC Instructors: +*CPR Instructors: +(Lead) +(Lead) +(Lead) +- due to re-cert +*ICS Instructors +pg. 4 + + +Monday, March 4, 2019 A.M. +Reporting Wrongdoing: Whistleblowers & their Rights & Protections: LGL-0321-GXX - 1 hour +Neapons of Mass destructions (WMD): CSV-0388-GXX - 1 hour +Continuity of Operations (COOP): CSV-0387-GXX - 1 hour +Last Name +First Name +LAN ID# +Department +1. +Custody +2. +Custody +3. +Custody +4. +Custody +5. +Custody +6. +Custody +7. +Custody +8. +Custody +9. +Custody +10. 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JAFELL +tealth Our +Warekauce +1 | Page +Sienature \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/28b619e01de73745581cae36d8fec331b93c04bbb7fc6dd8e5563c362820c410.receipt.json b/vision-fixhub/ds9-parsed-01/28b619e01de73745581cae36d8fec331b93c04bbb7fc6dd8e5563c362820c410.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..ca6a54c2503899eb346155e14797dca34dc7178d --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/28b619e01de73745581cae36d8fec331b93c04bbb7fc6dd8e5563c362820c410.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -1807, + "dataset": "marble-joined", + "doc_id": "28b619e01de73745581cae36d8fec331b93c04bbb7fc6dd8e5563c362820c410", + "engine": "marble-apple-vision", + "event_count": 22, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "1a5b747351d93bdbaf75e2f66313fc9c5c2ff6fa6410c99101ae6b8299410d22", + "output_sha256": "47478446ea1b39c2f2d82b81e68815a25a800cc5f82bbd1eb47f534c4f813d0b", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/28bf784470ced638b741df61843dfc2cc3b31620bbe9cdc2131376dfe444dc2e.md b/vision-fixhub/ds9-parsed-01/28bf784470ced638b741df61843dfc2cc3b31620bbe9cdc2131376dfe444dc2e.md new file mode 100644 index 0000000000000000000000000000000000000000..6eb3a4fe4e326db88749139620125177e51d15dc --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/28bf784470ced638b741df61843dfc2cc3b31620bbe9cdc2131376dfe444dc2e.md @@ -0,0 +1,26 @@ +From: " +(USANYS)" - +To: " +Cc: " +(USANYS)". +Subject: Final +Date: Thu, 30 Jan 2020 22:58:26 +0000 +This is the final language. Would you mind sending out and then forwarding us the sent email once transmitted? Thanks +On November 20, 2019, Prince Andrew publicly offered to cooperate with our investigation into Jeffrey Epstein's crimes, +stating in a press release: "Of course, I am willing to help any appropriate law enforcement agency with their investigations, +if required." In early January 2020, our Office responded to the Prince's public offer by contacting you to set up the +interview that the Prince claimed to be willing give us. More than three weeks after our initial contact with you, we still +had no date for an interview, nor did we even have a commitment from you that the Prince in fact would agree to an +interview. +On January 27, 2020, at a press event held by Safe Horizon to which Mr. Berman was invited, Mr. Berman was asked: "As +part of [the Epstein] investigation have you reached out to interview Prince Andrew, and has he been cooperative?" +Mr. Berman responded: "Ordinarily, our office doesn't comment on whether an individual cooperates or doesn't +cooperate with our investigation. However, in Prince Andrew's case, he publicly offered, indeed in a press release, offered +to cooperate with law enforcement investigating the crimes committed by Jeffrey Epstein and his coconspirators. So l +think in that context, it's fair for people to know whether Prince Andrew has followed through with that public +commitment. So let me say that the Southern District of New York and the FBI have contacted Prince Andrew's attorneys +and requested to interview Prince Andrew and to date, Prince Andrew has provided zero cooperation." +Mr. Berman's statement corrected a public misimpression - created by the Prince himself -- that the Prince is cooperating +with our investigation. +As soon as the Prince commits to a date for the interview that he so publicly offered to us more than two months ago, we +would be prepared to announce that he has agreed to be interviewed. diff --git a/vision-fixhub/ds9-parsed-01/28bf784470ced638b741df61843dfc2cc3b31620bbe9cdc2131376dfe444dc2e.receipt.json b/vision-fixhub/ds9-parsed-01/28bf784470ced638b741df61843dfc2cc3b31620bbe9cdc2131376dfe444dc2e.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..c0761b6edfeb65f681db4ba59d775a2321cb59f7 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/28bf784470ced638b741df61843dfc2cc3b31620bbe9cdc2131376dfe444dc2e.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "28bf784470ced638b741df61843dfc2cc3b31620bbe9cdc2131376dfe444dc2e", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "5dd824451596c1fa5add7c0eacab919f4f1c5171b95fbb5620c4ff10205f4694", + "output_sha256": "b3939c793e42328d24760edb4c0d2c59e23970009342ebb3e6992d24fcaf3c00", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/28fcfb9f2209e20dd9e7e5faf6eb70edf7f42a506ff1cb285e0f2fae76070986.md b/vision-fixhub/ds9-parsed-01/28fcfb9f2209e20dd9e7e5faf6eb70edf7f42a506ff1cb285e0f2fae76070986.md new file mode 100644 index 0000000000000000000000000000000000000000..e3b971463d533c7f245f11a12a81c9411fa290db --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/28fcfb9f2209e20dd9e7e5faf6eb70edf7f42a506ff1cb285e0f2fae76070986.md @@ -0,0 +1,16 @@ +Search Results +Total Records: 2 1 record not geocoded. +Event Type +A-SUMMONS +SOMUR +Description +Occurred: THUR 04/25/2013 13:29:00 ID: 7094202118 - VEHICLES: +NO PARKING (NON-COM) +Occurred: THUR 04/15/2010 +PEOPLE: EPSTEIN, JEFFREY (PERP), DOB: +GENDER: MALE +NYPDFINEST +12/10/2018 +14:00:20 +PEOPLE: EPSTEIN, JEFFREY; 20A- +I, RACE: WHITE, diff --git a/vision-fixhub/ds9-parsed-01/28fcfb9f2209e20dd9e7e5faf6eb70edf7f42a506ff1cb285e0f2fae76070986.receipt.json b/vision-fixhub/ds9-parsed-01/28fcfb9f2209e20dd9e7e5faf6eb70edf7f42a506ff1cb285e0f2fae76070986.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..05eb607b7f8a1bead0d289e6a5b55609b96bae23 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/28fcfb9f2209e20dd9e7e5faf6eb70edf7f42a506ff1cb285e0f2fae76070986.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "28fcfb9f2209e20dd9e7e5faf6eb70edf7f42a506ff1cb285e0f2fae76070986", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "80e0ee6996439a92e038f5dcb05003533524e6b689fc26b13b88bf12ded4f31a", + "output_sha256": "9a6bff56c920c8f1f0c34ce116df3d17cdbeec9ee4d9229b14c6c9aacd1ac46e", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/290c999bec8cebb7da590512d66bd89299365677d27ec25f5a5eaf27b4c1be70.md b/vision-fixhub/ds9-parsed-01/290c999bec8cebb7da590512d66bd89299365677d27ec25f5a5eaf27b4c1be70.md new file mode 100644 index 0000000000000000000000000000000000000000..37edd27c468ed2b48179dc8bdbc796b44e27927b --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/290c999bec8cebb7da590512d66bd89299365677d27ec25f5a5eaf27b4c1be70.md @@ -0,0 +1,11 @@ +Event: Accepted: Epstein Estate +Start Date: 2020-11-09 21:30:00 +0000 +End Date: 2020-11-09 22:00:00 +0000 +Location: Skype Meeting; Conference ID: 570 579 045; +Class: X-PERSONAL +Comment: +Date Created: 2020-11-09 15:47:16 +0000 +Date Modified: 2020-11-09 15:47:16 +0000 +Priority: 5 +DTSTAMP: 2020-11-09 15:38:29 +0000 +Attendee: Weinstein, Marc A. diff --git a/vision-fixhub/ds9-parsed-01/290c999bec8cebb7da590512d66bd89299365677d27ec25f5a5eaf27b4c1be70.receipt.json b/vision-fixhub/ds9-parsed-01/290c999bec8cebb7da590512d66bd89299365677d27ec25f5a5eaf27b4c1be70.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..f3bef92cc1114c70d49e8ad51c962add5574f96b --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/290c999bec8cebb7da590512d66bd89299365677d27ec25f5a5eaf27b4c1be70.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "290c999bec8cebb7da590512d66bd89299365677d27ec25f5a5eaf27b4c1be70", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "7a39c633446787e315404e8131479ab1af7aab5fffbaa1a59bc53f46d047e8e9", + "output_sha256": "7e0c68fc4c5e82579da42a139d45aa9f10190094a3911cae7ce4bd7a09696a2a", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2930823e42f5b02f1548aad23d3822b76ffb86cda0d6106ef06eb8f0f71a118e.md b/vision-fixhub/ds9-parsed-01/2930823e42f5b02f1548aad23d3822b76ffb86cda0d6106ef06eb8f0f71a118e.md new file mode 100644 index 0000000000000000000000000000000000000000..1f4b6e51eaadd521cd9c160fe78bde343ad487f3 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2930823e42f5b02f1548aad23d3822b76ffb86cda0d6106ef06eb8f0f71a118e.md @@ -0,0 +1,9 @@ +From: +To: +Subject: Maxwell motions 3 of 3 +Date: Wed, 03 Feb 2021 22:07:54 +0000 +Attachments: 1.25.2021_Filing_ 3.zip +Assistant United States Attorney +Southern District of New York +1 St. Andrew's Plaza +New York. NY 10007 diff --git a/vision-fixhub/ds9-parsed-01/2930823e42f5b02f1548aad23d3822b76ffb86cda0d6106ef06eb8f0f71a118e.receipt.json b/vision-fixhub/ds9-parsed-01/2930823e42f5b02f1548aad23d3822b76ffb86cda0d6106ef06eb8f0f71a118e.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..8003e349a57f24c484078c87584e2ee43dd148d2 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2930823e42f5b02f1548aad23d3822b76ffb86cda0d6106ef06eb8f0f71a118e.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "2930823e42f5b02f1548aad23d3822b76ffb86cda0d6106ef06eb8f0f71a118e", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "a5253ce2786ec08bf4a82c9b0f815b0159cf84785705f5e59e778838f135c50d", + "output_sha256": "80d881117ebbbd078cf5db94a12e03d767931c7b0c5fa161f345ffdfc50514d7", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/293eb3aab572255db2431567701fbf717371d3b8b41c579180d2c5abc130f738.md b/vision-fixhub/ds9-parsed-01/293eb3aab572255db2431567701fbf717371d3b8b41c579180d2c5abc130f738.md new file mode 100644 index 0000000000000000000000000000000000000000..b23eefdf4436abbe82dabf8876cabdbc617a8940 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/293eb3aab572255db2431567701fbf717371d3b8b41c579180d2c5abc130f738.md @@ -0,0 +1,55 @@ +Service Request #25630 +Programming Profiles and Users in NICE Vision +Status: Closed +Priority: P3 (Next Day) +Type: Service Contract +Assigned To: Jeff Cranor, Jeff McKenzie, Justin +Houston +Customer: FBOP MCC New York MS0109 (130104.001) +Contact: +Date Created: Sep 24, 2019 +Next Appt.: +Service Location: Main Location +150 PARK ROW +NEW YORK, NY 10007 +Bill To: FBOP MCC New York MS0109 (130104.001) +150 PARK ROW +NEW YORK, NY 10007 +PO #: +Additional Information & Custom Fields: +Is this a emergency request: Yes. You must call 844-802-0188 +Is the system in question under +any warranty: +What is the system in question : +When was the problem first +discovered: +Today +PO Number: +Who reported the problem initally: +Is this a consistent prominent +CONSISTENT +Is this problem effecting all users: YES +Is there power to the device in YES +question: +Do you have a spare device te: Unknown +Can you send a picture of the No +device: +Has any work been done in the No +area involved: +Can you describe what is or is not Installation of new Nice Vision system. +happening: +Material Required For Request: PHONE SUPPORT +Who Requested the service call : +Detailed Description: +needs assistance in creating users and profiles. +Schedule + + +When +Assigned To +Sep 24, 2019, all-day | Jeff Cranor, Justin Houston, Jeff McKenzie +Comment +Jeff Mckenzie is working on this. +Equipment - No Equipment +No Comments +Details - No Detail Items diff --git a/vision-fixhub/ds9-parsed-01/293eb3aab572255db2431567701fbf717371d3b8b41c579180d2c5abc130f738.receipt.json b/vision-fixhub/ds9-parsed-01/293eb3aab572255db2431567701fbf717371d3b8b41c579180d2c5abc130f738.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..8ac8d67fb712fdae0860cdebd4caf18c105e3518 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/293eb3aab572255db2431567701fbf717371d3b8b41c579180d2c5abc130f738.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "293eb3aab572255db2431567701fbf717371d3b8b41c579180d2c5abc130f738", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "f193f6768bd0c78ff751de8169675cb4507f6d86d23623c8abdf80c6447acbd0", + "output_sha256": "f1244a3fc77c56b306570791c642157eb33b636a17aacc7a9661550759bdc698", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/29439887326f52f1d6074101d083bd76e74aacdd699e274ccb2ed83b1eaf9b2b.md b/vision-fixhub/ds9-parsed-01/29439887326f52f1d6074101d083bd76e74aacdd699e274ccb2ed83b1eaf9b2b.md new file mode 100644 index 0000000000000000000000000000000000000000..b4764fb5fde9efd7b8209febf5b46ffd94169f09 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/29439887326f52f1d6074101d083bd76e74aacdd699e274ccb2ed83b1eaf9b2b.md @@ -0,0 +1 @@ +No Images Produced diff --git a/vision-fixhub/ds9-parsed-01/29439887326f52f1d6074101d083bd76e74aacdd699e274ccb2ed83b1eaf9b2b.receipt.json b/vision-fixhub/ds9-parsed-01/29439887326f52f1d6074101d083bd76e74aacdd699e274ccb2ed83b1eaf9b2b.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..db6a1708a6d960c7f4e3be450e2fa2a52bcd355a --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/29439887326f52f1d6074101d083bd76e74aacdd699e274ccb2ed83b1eaf9b2b.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "29439887326f52f1d6074101d083bd76e74aacdd699e274ccb2ed83b1eaf9b2b", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "5bbb548c135e304cb8bfb314bb5b5d330cc340277242a34c6149f6048a16536d", + "output_sha256": "3874328764c818fba06683a6d5ddc2edc2d7850aaf4ba18646f81d3f8420a729", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/295c6366a7532838c60a5a2c6cfef3f7111cdfc20b669bb70c0261fa5d283344.md b/vision-fixhub/ds9-parsed-01/295c6366a7532838c60a5a2c6cfef3f7111cdfc20b669bb70c0261fa5d283344.md new file mode 100644 index 0000000000000000000000000000000000000000..d6f38dcf49ad029c06af2acbbad0ce25500d3496 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/295c6366a7532838c60a5a2c6cfef3f7111cdfc20b669bb70c0261fa5d283344.md @@ -0,0 +1,44 @@ +From: " +(USANYS)" • +To: " +(USANYS)" < +Subject: RE: Epstein catch up +Date: Sun, 17 Nov 2019 20:25:17 +0000 +That was new information to me as well. When we spoke a week ago while you were out, I asked them where +things were with +thisis how fither attorney prot real the noikely of be helpin an his pons up although we definitely did +---Original Message---- +From: +(USANYS) < +Sent: Sunday, November 17, 2019 3:22 PM +To: +I (USANYS) < +Subject: FW: Epstein catch up +I am surprised to hear, without prior consultation, that they have asked to come in. +-----Original Message----- +From: +To: +Sent: Sunday, November 17, 2019 1:00 PM +(USANYS) < +Ce: +(USANYS) +Subject: Re: Epstein catch up +Sure, happy to catch up — we tried to stop by a couple times on Friday but missed you, so can set a time for this +veek. Untortunately we have conflicts tomorrow from 5:30 on — we could potentially do Wednesday but +Maurene will be in White Plains so would have to call in, or if there are available times on Tuesday we could tr +for that. +Just as backdrop, the meeting in California did not add any significant information except that we almost +certainly couldn't bring an enticement charge (based on timing / location facts), and she's still not sure whether +she wants to pursue a criminal case so we'll circle back with her attorneys later this month. She also didn't want +to talk about specific conduct at this meeting so we don't have any additional info there. Meanwhile we're +continuing to work on the pile of memos, and I don't think there's any additional update other than that +coming in for a limited proffer (just talking about her background, to start) a week from Tuesday. +> On Nov 16, 2019, at 21:18, L +(USANYS) { +> wrote: +> +> Can we find a time in the near future to catch up on a few things, including hearing more about your interview +last week? Unfortunately both l +Tand I have to be out portions of Monday/Tuesday. Would Monday at 530 +work for you guys? If not, can we aim for Wednesday morning. Thanks +> Sent from my iPhone diff --git a/vision-fixhub/ds9-parsed-01/295c6366a7532838c60a5a2c6cfef3f7111cdfc20b669bb70c0261fa5d283344.receipt.json b/vision-fixhub/ds9-parsed-01/295c6366a7532838c60a5a2c6cfef3f7111cdfc20b669bb70c0261fa5d283344.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..b8f5b3c008f4cd58b01247c5780720320ea447aa --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/295c6366a7532838c60a5a2c6cfef3f7111cdfc20b669bb70c0261fa5d283344.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "295c6366a7532838c60a5a2c6cfef3f7111cdfc20b669bb70c0261fa5d283344", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "bf48d766382a84fc2e01a0c992dd6b46840e51f590ab048f838c2f154f54c4be", + "output_sha256": "f9ef445a5afab38c5b785c6e5a7bfe6ebfabb7c45a2115a5ffda463efe24c2fe", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2973d5ebb46ea7701f81b583bc08484af994137dc744db570cdcb67d728c380c.md b/vision-fixhub/ds9-parsed-01/2973d5ebb46ea7701f81b583bc08484af994137dc744db570cdcb67d728c380c.md new file mode 100644 index 0000000000000000000000000000000000000000..02926a3f69828c0c462ea1e32106840d048f4b3f --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2973d5ebb46ea7701f81b583bc08484af994137dc744db570cdcb67d728c380c.md @@ -0,0 +1,25 @@ +Formatted Name +Charisma Edge +Email • Internet, Pref +Job Title +ASSOCIATE WARDEN +Last Updated +2020-07-20 19:10:44 +0000 +Name +Program IE +//Novell Inc//Groupwise 12.0.4 +Telephone Number • Voice, Pref +Ext. 6451 +Telephone Number • Voice, Work +Ext. 6451 +Telephone Numb +Unique Identifier +835B5E40-11C6-0000-B3D6-FE66A7708950 +VCard Version +2.1 +X-GWTYPE +USER +X-GWUDF +11(BES User ID)981 +X-GWUDF +10(BES Ref ID)O diff --git a/vision-fixhub/ds9-parsed-01/2973d5ebb46ea7701f81b583bc08484af994137dc744db570cdcb67d728c380c.receipt.json b/vision-fixhub/ds9-parsed-01/2973d5ebb46ea7701f81b583bc08484af994137dc744db570cdcb67d728c380c.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..d9884933334b8c295652798f50596a42eeffba2c --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2973d5ebb46ea7701f81b583bc08484af994137dc744db570cdcb67d728c380c.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "2973d5ebb46ea7701f81b583bc08484af994137dc744db570cdcb67d728c380c", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "11fc6bde78ed42705978ec1eeb9b22f1e8e97250d740c324380e358180747c29", + "output_sha256": "267bce90f4b3e487be27061e404aaaf25155930b0050d68b364fa5d10ba0e485", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2999d28c4418c631f9af50ec4fac6d81fe2e150c64497e12b4a4968db9892551.md b/vision-fixhub/ds9-parsed-01/2999d28c4418c631f9af50ec4fac6d81fe2e150c64497e12b4a4968db9892551.md new file mode 100644 index 0000000000000000000000000000000000000000..650a392a7b952c84ec545453e029007f0e5b6f67 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2999d28c4418c631f9af50ec4fac6d81fe2e150c64497e12b4a4968db9892551.md @@ -0,0 +1,5 @@ +From: "Berman, Geoffrey (USANYS)" ‹ +To: "l +Subject: +Date: Wed, 14 Aug 2019 00:52:36 +0000 +I will need a summary of our forfeiture options re Epstein Thursday morning, ok? Geoff diff --git a/vision-fixhub/ds9-parsed-01/2999d28c4418c631f9af50ec4fac6d81fe2e150c64497e12b4a4968db9892551.receipt.json b/vision-fixhub/ds9-parsed-01/2999d28c4418c631f9af50ec4fac6d81fe2e150c64497e12b4a4968db9892551.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..277f490e1c7663a6b811a122598e3f39beefd308 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2999d28c4418c631f9af50ec4fac6d81fe2e150c64497e12b4a4968db9892551.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "2999d28c4418c631f9af50ec4fac6d81fe2e150c64497e12b4a4968db9892551", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "5b3f206e726d129b5482fed840614012aad7b7919cc3b988fe97cf20d5b022d8", + "output_sha256": "d0383f016f958ca355fd64a3ed6fb7cdb0bfa2df4e0ea5f39aa828f6568c5a79", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2a0f6e892b31f03846189883ead29da5f6f83e67f068036b049a02d68094aebb.md b/vision-fixhub/ds9-parsed-01/2a0f6e892b31f03846189883ead29da5f6f83e67f068036b049a02d68094aebb.md new file mode 100644 index 0000000000000000000000000000000000000000..976c9fc001d361b57513a705923e209db0058959 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2a0f6e892b31f03846189883ead29da5f6f83e67f068036b049a02d68094aebb.md @@ -0,0 +1,88 @@ +From: "l +To: "l +Ce: "l +(USANYS)" ≤ +(USANYS)". +(USANYS)" • +Subject: Re: Epstein FOIA Update +Date: Sun, 11 Apr 2021 22:01:51 +0000 +(USANYS)" +430 is fine for me. +Sent from my iPhone +On Apr 11, 2021, at 5:39 PM, +I (USANYS) { +> wrote: +I should be free anytime tomorrow after an initial conference at 10:30. Thanks. +From: +(USANYS) < +Sent: Sunday, April 11, 2021 5:31 PM +To:| +(USANYS) < +Cc:| +| (USANYS) < +Subject: Re: Epstein FOIA Update +• (USANYS) < +Unfortunately have something at 4 with Audrey though it should be over at 430 if you can all do then? +Sent from my iPhone +On Apr 11, 2021, at 3:58 PM, +(USANYS) < +> wrote: +Sorry, but any chance we could do 4:00 or later? I have a call scheduled at 3:00. If not, I can have someone else cover +the 3:00 call. +Thanks. +On Apr 11, 2021, at 3:20 PM, +(USANYS) < +> wrote: +3 works for me. Please let me know if I can help with logistics here-happy to circulate invite/dial in if helpful. +Thanks. +Sent from my iPhone +On Apr 11, 2021, at 2:44 PM, +(USANYS) 4| +> wrote: +No problem. Can we say 3? I'II see if Audrey thinks it makes sense for her to join in the first instance. + + +Sent from my iPhone +On Apr 10, 2021, at 4:12 PM, D +(USANYS) < +> wrote: +I understand from Audrey's email that you are scheduling a call for Monday. I unfortunately have conflicts +between 11 and 3. I apologize in advance if this complicates scheduling. +Sent from my iPhone +On Apr 10, 2021, at 8:29 AM, +(USANYS) < +> wrote: +Thanks, I +1. Will review the transcript and then we can find a time to meet early in the week. It may make +sense to meet first as a smaller group with you/l +_to best understand the lay of the land and then loop +in the substantive case teams. +Sent from my iPhone +On Apr 9, 2021, at 7:21 PM, +(USANYS) < +> wrote: +All, +I'm writing to bring everyone up to speed in the Epstein FOIA. We had a pretty rough, approximately 2 hour +oral argument today before Judge Engelmayer. It may be easier to share the transcript (which I have same-day +ordered and will circulate once received) and/or to talk things through on a call. In sum, the Court is very +skeptical of the breadth of the 7(A) withholdings here and will enter an Order on Monday directing that the +withheld documents be produced to the Court for in camera review. In connection with that, the Court will +direct that any material withheld under 7(A) in connection with the Tartaglione case be specifically marked +out as such (as compared to the broader set of material withheld on account of its likelihood of interference +with Noel). Basically, the Court has concerns that too much has been withheld on the theory of interference +with the criminal cases and will undertake its own assessment of the withholding of the documents. +The Court was also interested in exactly how much of the withheld materials have been produced to the Noel +defendants under Rule 16, and it sounds like it will ask us to make specific representations about precisely +which documents have been produced in Noel. +Also, as you will see from the transcript, the Court directed that I communicate to Audrey that he wants her to +consider this case and to evaluate whether it is necessary to confer with Main Justice on the FOIA response +here (specifically whether more documents might be produced on reconsideration). In particular, the Court +perceived a possibility that the recent change in administration could have some bearing on this. I plan to +communicate this to Audrey as soon as we have the transcript (I've asked for that piece of it tonight). +As noted I will follow up once I have the transcript and will also circulate the Court's Order when it comes out +on Monday. I think it would probably make sense to have a call thereafter and will circulate an invite for early +next week. I am also available to speak over the weekend if anyone would like to talk sooner. +Thanks, + + +Assistant United States Attorney diff --git a/vision-fixhub/ds9-parsed-01/2a0f6e892b31f03846189883ead29da5f6f83e67f068036b049a02d68094aebb.receipt.json b/vision-fixhub/ds9-parsed-01/2a0f6e892b31f03846189883ead29da5f6f83e67f068036b049a02d68094aebb.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..ebf5a71e0616d3614c85259d5ad1c2b8c7f339ef --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2a0f6e892b31f03846189883ead29da5f6f83e67f068036b049a02d68094aebb.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -36, + "dataset": "marble-joined", + "doc_id": "2a0f6e892b31f03846189883ead29da5f6f83e67f068036b049a02d68094aebb", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "f6df0899bc22606d74940da6eacc214cc170a2976b60d7f5dc6287237dc0e3d4", + "output_sha256": "69a614f76f5f5f3dc1fc344f10d9eba4ea3e122abf406848740cbfb1ca79523c", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2a1ed2c9e6a1c7f4e321f52493f81bccbcedbb52a2bd496d807548b8183f98a4.md b/vision-fixhub/ds9-parsed-01/2a1ed2c9e6a1c7f4e321f52493f81bccbcedbb52a2bd496d807548b8183f98a4.md new file mode 100644 index 0000000000000000000000000000000000000000..1c048354ec40859fab4a2f420fe3ad1f06de8fa7 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2a1ed2c9e6a1c7f4e321f52493f81bccbcedbb52a2bd496d807548b8183f98a4.md @@ -0,0 +1,59 @@ +From: " +To: " +Subject: RE: CACI Proposal-USAO SDNY US v. Maxwell Epstein Scanning +Date: Wed, 24 Mar 2021 18:49:41 +0000 +Great. One time I would be very happy to have wasted my time. +From: +To: +Sent: Wednesday, March 24, 2021 2:47 PM +PiL +Subject: RE: CACI Proposal-USAO SDNY US v. Maxwell Epstein Scanning +Thank you, •. It sounds like the Florida vendor came through, and according to I +now working on loading it. Fingers crossed this works out... +the product looked ok, so +From: | +Sent: Tuesday, March 23, 2021 4:42 PM +To:/ +Subject: Fwd: CACI Proposal-USAO SDNY US v. Maxwell Epstein Scanning +I have +and +cancel it. CACI understands. +I going ahead with this. It will be in place if Florida breaks down. If Florida comes through, we just +Sent from my iPad +Begin forwarded message: +From: " +Date: March 23, 2021 at 4:40:09 PM EDT +Cc: "l +Subject: Fwd: CACI Proposal-USAO SDNY US v. Maxwell Epstein Scanning +Please go ahead with this. Time sensitive. +I suggest using AFF for now. +Sent from my iPad +Begin forwarded message: +From: " +Date: March 23, 2021 at 3:56:48 PM EDT +To: "I + + +Cc:I +Subject: CACI Proposal-USAO SDNY US v. Maxwell Epstein Scanning +Hello +I hope this email finds you well and that you are having a wonderful Tuesday. +In response to the Request for Proposal, attached is CACI's proposal information for your review and +consideration. +Please let me know if you have any questions +Respectfully, +| Contracts Administration +CACI INC. - Federal +Shared Services Center +7725 West Reno Ave. +Oklahoma City, OK 73127 +Cell Phone: +Office Phone: +Email: +This electronic message contains information from CACI International Inc or subsidiary companies, which may be company sensitive, proprietary, privileged or +otherwise protected from disclosure. The information is intended to be used solely by the recipients) named above. If you are not an intended recipient, be +aware that any review, disclosure, copying, distribution or use of this transmission or its contents is prohibited. If you have received this transmission in error, +please notify us immediately at +With the exception of messages sent by authorized CACI contracts or purchasing personnel, nothing in +this message may be interpreted as a digital or electronic signature that can be used to: (a) authenticate either the submission or the acceptance of a proposal +or offer to contract, or (b) modify an existing contract. diff --git a/vision-fixhub/ds9-parsed-01/2a1ed2c9e6a1c7f4e321f52493f81bccbcedbb52a2bd496d807548b8183f98a4.receipt.json b/vision-fixhub/ds9-parsed-01/2a1ed2c9e6a1c7f4e321f52493f81bccbcedbb52a2bd496d807548b8183f98a4.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..63849115f5374643154f2617c24f88fc7660395a --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2a1ed2c9e6a1c7f4e321f52493f81bccbcedbb52a2bd496d807548b8183f98a4.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "2a1ed2c9e6a1c7f4e321f52493f81bccbcedbb52a2bd496d807548b8183f98a4", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "edc5a4019217da537d81c7ae9d31d5d8d12799b089efbd47476b27b7ab6c46a7", + "output_sha256": "08a52e4c3d693ca4310bf9d77040a1b28efe1e1d4306034fb458af72f8580b2c", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2aa0bac183a0589a093fa1ca26c82575a0df2a151924d35107402a4800d3f29c.md b/vision-fixhub/ds9-parsed-01/2aa0bac183a0589a093fa1ca26c82575a0df2a151924d35107402a4800d3f29c.md new file mode 100644 index 0000000000000000000000000000000000000000..008c600eac2214b877c96260e50c3b6f79123222 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2aa0bac183a0589a093fa1ca26c82575a0df2a151924d35107402a4800d3f29c.md @@ -0,0 +1,128 @@ +PRESS FIRMLY TO SEAL +FLAT RATE +POSTAGE REQUIRED +PRESS FIRMLY TO SEAL +UNITED STATES +POSTAL SERVICE. +PRIORITY® +MAIL +UNITED STATES +POSTAL SERVICE• +wapa.com +$7.35 +US POSTAGE +Flat Rate Env +Click-N-Ship® +9405 5036 9930 0083 4913 74 0073 5000 0032 0530 +P +08/13/2019 +Mailed from 10128 +062S0000000312 +PRIORITY MAIL 2-DAY™ +GUERNSEY'S AUCTION HOUSE +Expected Delivery Date: 08/15/19 +GUERNSEY'S +0004 +HOOTIVE FOO +GLOZ 6 I 90V +03A/8X +•Date of delivery specified* +• USPS TRACKING™ included to many major +international destinations. +• Limited international insurance. +• Pick up available.* +• Order supplies online.* +• When used internationally, a customs +declaration label may be required. +* Domestic only +Carrier - Leave if No Response +COOO +SHIP +TO: ATTORNEY GENERAL BARR +US DEPARTMENT OF JUSTICE +950 PENNSYLVANIA AVE NW +WASHINGTON DC 20530-0009 +USPS TRACKING # +To schedule free +Package Pickup, +scan the QR cod +9405 5036 9930 0083 4913 74 +Electronic Rate Approved #038555749 +PS00001000014 +EP14F Oct 2018 +OD: 12 1/2 x 91/2 +USPS.COM/PICKUP +X +* Domestic only. +* For Domestic shipments, the maximum welght Is 70 Ibs. For International shipments, the maximum weight is 4 Ibs. + + +GUERNSEY'S +ALCTIONEERS & BROKERS SINCE 1975 +August 13, 2019 +Attorney General William Barr +U.S. Department of Justice +950 Pennsylvania Avenue +Washington, DC 20530 +Re: Property of the late Jeffrey Epstein +Dear Attorney General Barr: +Although obviously what herein is being proposed is premature, we wanted to provide the following food for thought. +There may well come a day when the Property of the late Jeffrey Epstein will be disposed of and, to this end, Guernsey's is ideally +suited to both maximizing the financial potential of said property, while spreading nationwide messages in support of young women. +The auction process, open to all bidders, is fair with no hint of favoritism. Properly marketed, such an event would absolutely attract +a massive audience. (Larger audiences = greater prices.) And Guernsey's, long known for its pioneering work with the media, is prepared to help raise awareness by propelling any messages that the Dept. of Justice wishes to send to potential future victims or +Formed nearly half a century ago, Guernsey's has been responsible for many of the most memorable and successful auctions in history. The world's largest auction - the contents of the ocean liner SS United States - was a Guernsey's event as was the landmark Cold +War auction of artwork from the Soviet Union. The definitive auctions devoted to such accomplished individuals as John F. Kennedy; +Franklin Roosevelt and Gerald Ford were Guernsey's events as were the sales focused on Princess Diana, Duke Ellington, Mickey +Mantle, Elvis Presley and the Beatles. +We have had the privilege of working with many of our nation's most prominent museums including the Smithsonian, and have +raised substantial amounts for countless non-profit and charitable organizations. (Working directly with First Lady Betty Ford, funds +from the Gerald Ford Auction were used to build one of Paul Newsman's Hole-in-the-Wall Gang camps for very sick children.) In +virtually every direction our events have taken us, we have produced world record results. Not once through the decades have we ever +been involved in a litigious matter nor been asked to appear in a court of law for any unpleasant reason. On the other hand, judges +have often reached out to us for assistance. +Perhaps the most noteworthy of our projects with a court came when we were first asked to inventory, and eventually sell, the complete archive of Rosa Parks. Through a multi-year effort, we successfully sold Mrs. Parks Archive to the Buffett Foundation which, +with our assistance, donated the critically important material to the U.S. Library of Congress. A letter from the Michigan judge oversceing the entire matter is enclosed. +Down the road, simply the mentioning of Jeffrey Epstein's name will no doubt raise issues; fingers will be pointed. To deal with the +aftermath, one needs an impartial, capable, experienced team. Guernsey's can provide just that. Thank you for any consideration +given our request. It would be my pleasure to meet with members of your staff to address any questions you might have. +Arlan Ettinger +President + + +COUNTY OF WAYNE +STATE OF MICHIGAN +FREDDIE G. BURTON, Jr. +JUDGE OF PROBATE +DETROIT +January 15, 2015 +1209 COLEMAN A. YOUNG MUNICIPAL CENTER +DETROIT, MICHIGAN 48228 +Mr. Arlan Ettinger, President +Guernsey's +108 East 73d Street. +New York, NY 10021 +RE: The Estate and Trust of Mrs. Rosa L. Parks +Dear Arlan: +This letter is long overdue as I have been intending to share with you my heartfelt +appreciation for Guernsey's incredibly important work regarding the Rosa Park collection of +personal property items ("Property"). +As you may recall, in late 2006, through the efforts of Attorneys John Chase, Jr. and +Melvin D. Jefferson, Jr., your firm was asked to come to Detroit to take control of the Property +for inventory and transport to your secure storage facility in New York. It was the expectation +of all parties participating in the legal matter before the Wayne County Probate Court that +maintenance and storage of the Property would be for a short period of time. None of us thought +seven (7) years would pass before this very important collection would find a deserving home. +In the summer of 2014 through the indefatigable efforts of your firm, the Howard G. +Buffett Foundation learned of the availability of the Property and presented a proposal that not +only placed the collection in the hands of an organization that will allow the public to marvel at +the incredible depth of Mrs. Parks commitment to the fair treatment of all people, but also +preserves for history the legacy of Mrs. Parks. +I believe it is fair to say that without the willingness of Guernsey's to maintain its +commitment and dedication to preserve the Rosa Parks Property there would be no collection to +commemorate her historic efforts. +Accordingly, I offer a humble "thank you" for Guernsey's incredibly impressive work. +Warmest regards, +Freddie I Bushr +Freddie G. Burton, Jr. +Judge of Probate diff --git a/vision-fixhub/ds9-parsed-01/2aa0bac183a0589a093fa1ca26c82575a0df2a151924d35107402a4800d3f29c.receipt.json b/vision-fixhub/ds9-parsed-01/2aa0bac183a0589a093fa1ca26c82575a0df2a151924d35107402a4800d3f29c.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..82e24a33dccbd341f9705aa85587be57c961ca48 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2aa0bac183a0589a093fa1ca26c82575a0df2a151924d35107402a4800d3f29c.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -44, + "dataset": "marble-joined", + "doc_id": "2aa0bac183a0589a093fa1ca26c82575a0df2a151924d35107402a4800d3f29c", + "engine": "marble-apple-vision", + "event_count": 7, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "cd953a8ba70192da0fa0541ba80e48cb463ca04c55a44c0e2b160e3d428ad967", + "output_sha256": "223389f8306672af6b77efa705e7851db7afb559e7e46978feca8e9925da3be0", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2aa7df40f9bead6fa0d54d0f9ec8ccbd3f2adeeba740f6f162f9782adfc99a0e.md b/vision-fixhub/ds9-parsed-01/2aa7df40f9bead6fa0d54d0f9ec8ccbd3f2adeeba740f6f162f9782adfc99a0e.md new file mode 100644 index 0000000000000000000000000000000000000000..2f1ecf410d396a5e51d92cd1d906d8790c85bbe9 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2aa7df40f9bead6fa0d54d0f9ec8ccbd3f2adeeba740f6f162f9782adfc99a0e.md @@ -0,0 +1,94 @@ +From: Michael Bachner +To: +Ce: "l +D' 4 +Subject: Re: +Attorney Proffer +Date: Sat, 15 Feb 2020 20:50:37 +0000 +Inline-Images: ~ WRD000.jpg +let me confirm that I am correct on the London Paris thing. +Michael Bachner +Bachner & Weiner, PC +Please excuse typographical errors. Messages sent through dictation. +https://www.actl.com/ +NOTICE: The information contained in this communication is legally privileged and/or +confidential information, which is intended only for use of recipient. If the reader of this communication is not +email from your system. Nothing in this email should be construed as a legal opinion or tax advice. +On Feb 15, 2020, at 3:44 PM, +> wrote: +Got it -- I had that down as London, rather than Paris, so that's helpful. And I should say, these questions aren't +immediately time-sensitive, I just didn't want to forget to ask, since I'm reviewing the notes now. +thanks, +From: Michael Bachner +Sent: Saturday, February 15, 2020 15:41 +To: +Cc: +Subject: Re: +Attorney Proffer +Hi +is away for the weekend. In our meeting I indicated that she stayed in the Paris apartment with +her husband on one occasion. I will get back to you on Monday or Tuesday regarding the other questions +you've asked today as well as at the meeting. Have a nice weekend + + +Michael Bachner +Bachner & Weiner, PC +Please excuse typographical errors. Messages sent through dictation. +<~WRD000.jpg> +https://www.actl.com/ +NOTICE: The information contained in this communication is legally privileged and/or +confidential information, which is intended only for use of recipient. If the reader of this communication is not +the intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you are +hereby notified that any dissemination, distribution, or reproduction of this communication is strictly +prohibited. If you have received this communication by error, please immediately notify the sender by e-mail +and delete this email from your system. Nothing in this email should be construed as a legal opinion or tax +On Feb 15, 2020, at 3:05 PM, +• wrote: +Michael, +Following up on our meeting, one additional question / clarification we have from reviewing our notes is about +whether +•ever visited certain Epstein properties other than his New York mansion and the brief visit to the +Palm Beach residence. I apologize if you addressed that and I missed it, but we wanted to add it to the list of +additional questions - in particular, whether she ever visited the New Mexico ranch, the Little St. James Island, the +Great St. James island, and/or the Paris residence. Also, is it correct that she just visited the Palm Beach residence the +one time you referenced? It's not a problem or issue if she visited any of those other locations, we just wanted to +clarify one way or the other. And happy to discuss via phone if that's useful. +thank vou, +From: +Sent: Thursday, Feb +To: Michael Bachne +CC: +Subject: RE: +Attorney Proffer +Michael, +We do understand that your attorney proffer today will be preliminary, and to the best of your client's current +recollection and to the best of your current understanding, and without, e.g., having been provided documents or +other materials by the Government. + + +We also confirm that your statements will be considered to be made pursuant to Fed. R. Evid. 410 and Fed. R. Crim. P. +11(f), and therefore under those protections. Regarding Rule 408, we'll just note what we have for other counsel in +this case and others who have made similar statements or submissions, which is that we don't take any position on the +effect or application of Rule 408 in a prospective or hypothetical dispute in civil litigation, because it doesn't implicate +any rights the Government would or would not have, but you can consider us advised that your position is that your +statements are also covered under 408. (While our Office itself can't guarantee the protections of Rule 408 because +any dispute on that issue would be beyond our purview, we are also not taking the position that we believe it does not +thank vou, +From: Michael Bachner +Sent: Thursday, February 13, 2020 10:08 +To: +Subject: ( +ttorney Proffer +Hi +Prior to our meeting today, 1 am writing to confirm that statements I make to you today +are preliminary and subject to further refinement once Ms +and I have the benefit of additional +document review and refreshed recollection if necessary based upon input we may receive from your office. +My statements to you are intended in hypothetical form only and in any event, we understand that the +provisions of FRE 408 and 410 apply. +Please advise if my understanding is correct. +Thanks. +Michael Bachner +Bachner & Associates, PC +Kimage001 jpg> +https://www.actl.com/ diff --git a/vision-fixhub/ds9-parsed-01/2aa7df40f9bead6fa0d54d0f9ec8ccbd3f2adeeba740f6f162f9782adfc99a0e.receipt.json b/vision-fixhub/ds9-parsed-01/2aa7df40f9bead6fa0d54d0f9ec8ccbd3f2adeeba740f6f162f9782adfc99a0e.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..9e545de06f46fcab8b5c518cf998e8299e8e298b --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2aa7df40f9bead6fa0d54d0f9ec8ccbd3f2adeeba740f6f162f9782adfc99a0e.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -36, + "dataset": "marble-joined", + "doc_id": "2aa7df40f9bead6fa0d54d0f9ec8ccbd3f2adeeba740f6f162f9782adfc99a0e", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "d527f1ff037ba15193300008d0144669035044474fd8db76fa32f78e6859ca53", + "output_sha256": "fa609b99270b639b80254169fcda59767f9a64c761cf63353b382df0c2e49bf4", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2aa932887253a30fd7ea1faf9f8c9923fd85355752fca160e73cc288848c0312.md b/vision-fixhub/ds9-parsed-01/2aa932887253a30fd7ea1faf9f8c9923fd85355752fca160e73cc288848c0312.md new file mode 100644 index 0000000000000000000000000000000000000000..d101b4ac4558322444a1a7cf84ec6cd6c08f1eb2 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2aa932887253a30fd7ea1faf9f8c9923fd85355752fca160e73cc288848c0312.md @@ -0,0 +1,40 @@ +DEPARTMENT OF JUSTICE | OFFICE OF THE INSPECTOR GENERAL +MEMORANDUM OF INVESTIGATION +Case Number: +2019-010614 +Reporting Office: +New York Field Office +Interview of B +Chief Psychologist, Federal Bureau of Prisons +On October 27, 2021, Special Agent +Jand Senior Special Agent +U.S. Department +of Justice Office of the Inspector General (OIG), conducted a voluntary interview of f +Psychologist, Federal Bureau of Prisons (BOP), Metropolitan Correctional Center (MCC) New York, New York, at +the OIG's New York Field Office. 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 in charge of the MCC Psychology Unit that was responsible to conduct mental +health evaluations and treatments of MCC New York inmates when Epstein was housed at the MCC New York in +July and August 2019. The interview was recorded, and the recording has been transcribed. The interview +transcript and documents discussed with +L 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 October 27, 2021. +2. OlG Warnings and Assurances Form signed by +dated October 27, 2021. +3. FBI 302 of +•interview conducted on August 29, 2019. +4. BOP After Action Review dated August 10, 2019. +Prepared By: +Preparer Title: +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. diff --git a/vision-fixhub/ds9-parsed-01/2aa932887253a30fd7ea1faf9f8c9923fd85355752fca160e73cc288848c0312.receipt.json b/vision-fixhub/ds9-parsed-01/2aa932887253a30fd7ea1faf9f8c9923fd85355752fca160e73cc288848c0312.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..1cc0a5a1a8380a72f89e6f5974f2e7bc9b9e5d5a --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2aa932887253a30fd7ea1faf9f8c9923fd85355752fca160e73cc288848c0312.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "2aa932887253a30fd7ea1faf9f8c9923fd85355752fca160e73cc288848c0312", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "7a6d8835c01c16ecc0beff53f5fd1be9b5e1a5814cfd0a165dc0318f07ac1280", + "output_sha256": "b72d7e73531ca8a15bada2599cd34071cb60c2ed6091cb17fc2c40920a1261e0", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2ab319d43ffaedc3dbf2a4be32e915271c2aedc7d18827c23f3ea7a9e2ced52d.md b/vision-fixhub/ds9-parsed-01/2ab319d43ffaedc3dbf2a4be32e915271c2aedc7d18827c23f3ea7a9e2ced52d.md new file mode 100644 index 0000000000000000000000000000000000000000..b4764fb5fde9efd7b8209febf5b46ffd94169f09 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2ab319d43ffaedc3dbf2a4be32e915271c2aedc7d18827c23f3ea7a9e2ced52d.md @@ -0,0 +1 @@ +No Images Produced diff --git a/vision-fixhub/ds9-parsed-01/2ab319d43ffaedc3dbf2a4be32e915271c2aedc7d18827c23f3ea7a9e2ced52d.receipt.json b/vision-fixhub/ds9-parsed-01/2ab319d43ffaedc3dbf2a4be32e915271c2aedc7d18827c23f3ea7a9e2ced52d.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..97eb5ebc4c0efafaa4ee03546bff94b6c2d22876 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2ab319d43ffaedc3dbf2a4be32e915271c2aedc7d18827c23f3ea7a9e2ced52d.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "2ab319d43ffaedc3dbf2a4be32e915271c2aedc7d18827c23f3ea7a9e2ced52d", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "dcb31b06c8447fa3d6533f2148a604d7ce942467c3bef0fc4fb33f3216cf32ca", + "output_sha256": "3874328764c818fba06683a6d5ddc2edc2d7850aaf4ba18646f81d3f8420a729", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2ac2c22c829fa4148f7d865e4145dd43ba88be54d6ffa588de20ff05437142d3.md b/vision-fixhub/ds9-parsed-01/2ac2c22c829fa4148f7d865e4145dd43ba88be54d6ffa588de20ff05437142d3.md new file mode 100644 index 0000000000000000000000000000000000000000..1cf7a2a5e7051b714d322a99c9ab1965d8e7f958 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2ac2c22c829fa4148f7d865e4145dd43ba88be54d6ffa588de20ff05437142d3.md @@ -0,0 +1,51 @@ +Can you not just move him to another cell? He will not have lunch in Attorney Conference. He will go back to his cell to eat. +He knows this. +Sent from my Verizon, Samsung Galaxy smartphone +Original message -- +From: +Date: 7/28/19 8:52 AM (GMT-05:00) +To: " +Cc: +Subject: Re: Suicide Watch/ +Update +>>> +" 07/28/2019 08:52 >>> +He also complained that he is in Attorney Conference from about 8 AM to about 8 PM each day and he said yesterday he +>>> +Good morning, +Thank you. +> 7/28/2019 7:51 AM >>> +Sent from my Verizon, Samsung Galaxy smartphone +Original message - +From: +Date: 7/28/19 7:49 AM (GMT-05:00) +To: " +Co: +Subject: Fwd: Suicide Watch/ +Update +>>> +AW +' 07/28/2019 07:49 >>> +Inmate Epstein seems psychologically stable. +He complained that his right arm was numb and hanging carlier. +saw him. +He again said his right arm still feels somewhat numb and he said he cannot make a fist with that hand. He also said he has +numbness on his neck. I informed +He stated the toilet in his cell was running for 45 minutes last night and he could not take the noise. He is going to try the +toilet before going to legal today and if it does not shut off, he will be moved to another cell. +Thanks, + +SDNY_00012619 + + +>>> +|7/28/2019 7:36 AM >>> +Inmate Lopez #20472-038 is being taken off of +Suicide Watch +None +1. Epstein #76318-054 +Pending Bedspace for SHU +1, Lopez #20472-038 +Thank you, + +SDNY_00012620 \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/2ac2c22c829fa4148f7d865e4145dd43ba88be54d6ffa588de20ff05437142d3.receipt.json b/vision-fixhub/ds9-parsed-01/2ac2c22c829fa4148f7d865e4145dd43ba88be54d6ffa588de20ff05437142d3.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..1e2a63f8b90ed9d803d82202da3582340d936ec8 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2ac2c22c829fa4148f7d865e4145dd43ba88be54d6ffa588de20ff05437142d3.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -36, + "dataset": "marble-joined", + "doc_id": "2ac2c22c829fa4148f7d865e4145dd43ba88be54d6ffa588de20ff05437142d3", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\"]", + "idempotent": true, + "input_sha256": "6dfa89f401de694ec9538672667588dd77f582fb8ada5a2562f0317b22354a48", + "output_sha256": "0a25ad53823d94fa35fd7cef18d9ffc4c571952338d89634557da294789a7628", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2ac908a101c258b84840126d863c93a4858e3420d47c919a6277502323f82df3.md b/vision-fixhub/ds9-parsed-01/2ac908a101c258b84840126d863c93a4858e3420d47c919a6277502323f82df3.md new file mode 100644 index 0000000000000000000000000000000000000000..2b44a866bed5d2897ae91f11e8895cc292ac0742 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2ac908a101c258b84840126d863c93a4858e3420d47c919a6277502323f82df3.md @@ -0,0 +1,304 @@ +Case Name +PART ONE +Callaghan v. LIRR +American Council of the Blind of New York, Inc. et al +USA v. Salvador +Francis v. DTA Fee Owner LLC et al +USA v. Person +The Metropolitan Transportation Authority et al v. The Travelers Indemnity of America et al +USA v. Montanez-Elias +PART ONE +Gemini Insurance Company v. Titan Construction Services +ATTORNEY ADMISSIONS +Goldman v. Complex Media, Inc. +USA v. Jaquez +S.I. et al v. NYC Dep't of Education +Gunnells v. Teutul et al +Gunnells v. Teutul et al +Shepard et al v. Wo Hop City, Inc. +AmTrust North America, Inc. et al v. KF&B, Inc. +USA v. Bright +Brinson v. Quincy Amusements, Inc. +Ferring B.V. et al v. Allergan Inc. et al +USA v. Butler +USA v. Smith Pitterson +USA v. Pena +SEC v. Im +In re GSE Bonds Antitrust Litigation +PART ONE +Gemini Insurance Company v. Titan Construction Services +Ferring B.V. et al v. Allergan Inc. et al +USA v. Sanchez +Kwan v. Sahara Dreams Co. Il Inc et al +Talarico v. Port Authority +Islam et al v. Tribute Hospitality Group LLC et al +Federal Insurance Company et al v. Weinstein +Pena v. C-Town Supermarket +USA v. Burton +USA v. Sanchez +USA v. De La Nuez +USA v. Pedraza +USA v. Jagana +PART ONE +Hemandez v. The Fresh Diet +CIVIL AND CRIMINAL PROCEEDINGS CALENDAR +Week of 07/22/2019 +Case No. +18-cv-7656 +18-CV-5792 +18-CR-849 +17-cv-1937 +18-cr-751 +17-CV-5298 +19-CR-121 +17-CV-8963 +19-CV-2955 +13-CR-337 +19-cv-1845 +19-CV-5312 +19-CV-5331 +18-CV-9634 +17-CV-5340 +19-mj-4952 +19-CV-5026 +12-CV-2650 +18-cr-834-10 +19-CR-468 +11-tr-1032-41 +17-cv-3613 +19-CV-1704 +17-CV-8963 +12-CV-2650 +18-cr-390 +17-cv-4058 +18-cv-909 +16-cv-2100 +18-cv-2526/18-cv-7524/18-| +19-CV-4213 +18-cr-409 +18-cr-390 +18-CR-743 +19-CR-457 +18-CR-676 +12-cv-4339 +Proceedings +Judge +Abrams +Jury Selection +PMC +Sentencing. +Status Conference +Change of Plea +Telephone Conference +Sentencing +Gardephe +Engelmayer +Engelmayer +Crotty +Crotty +Engelmayer +Rakoff +Abrams +Bench Trial +Pauley +IPTC +Status Conference +IPTC +Initial Conference +Initial Conference +IPTC +PTC +Conference +PTC +Bench Trial +Sub of Counsel +Pretrial Conference +VOSR +PTC +Oral Argument +Bench Trial +Bench Trial +Sentencing +Oral Argument +PTC +Status Conference +Status Conference +Initial Conference +Sentencing +Sentencing +Sentencing +Pretrial Conference +Sentencing +Bench Trial +*PLEASE NoTE: This is only a partial list of week's proceedings. Proceeding dates and times are subject to change without notice. +DPM - Daniel Patrick Moynihan courthouse, 500 Pearl Street +TM = Thurgood Marshall courthouse, 40 Centre Street +WP = White Plains courthouse, 300 Quarropas Street +Room +TM 1506 +TM 705 +TM 1305 +TM 1305 +DPM 14C +DPM 14C +TM 1305 +DPM 14B +TM 1506 +DPM 208 +TM 1506 +Date +7/22/19 +7/22/19 +7/22/2019 +7/22/2019 +1/22/19 +7/22/19 +7/22/2019 +7/22/19 +7/23/19 +7/23/19 +7/23/19 +7/23/19 +7/23/19 +7/23/19 +7/23/19 +7/23/19 +7/23/19 +7/23/19 +7/23/19 +7/23/19 +7/23/19 +7/23/19 +7/23/19 +7/23/19 +7/23/19 +7/23/19 +7/24/19 +7/24/19 +7/24/19 +7/24/19 +7/24/19 +7/24/19 +7/24/19 +7/24/2019 +7/24/2019 +7/24/19 +7/24/19 +7/24/19 +7/24/19 +7/24/19 +7/25/19 +7/25/19 +Time +9:00 AM +9:00 AM +10:00 AM +11:00 AM +11:15 AM +11:30 AM +4:00 PM +4:00 PM +9:00 AM +9:30 AM +10:00 AM +10:45 AM +11:00 AM +11:00 AM +11:00 AM +11:00 AM +11:15 AM +11:30 AM +12:00 PM +12:00 PM +2:00 PM +2:00 PM +2:00 PM +4:00 PM +4:00 PM +4:00 PM +9:00 AM +9:30 AM +10:00 AM +10:30 AM +11:00 AM +11:00 AM +11:30 AM +11:45 AM +12:00 PM +2:00 PM +2:30 PM +3:00 PM +4:00 PM +4:00 PM +9:00 AM +9:30 AM + + +Case Name +USA v. Cruz +Ferring B.V. et al v. Allergan Inc. et al +USA v. Lubrun +Santos, Jr. v. Lamin Trucking Corp et al +Hamzat v. City Of New York et al +McNeely et al v. Metropolitan Life Insurance Company et al +USA v. Brown +USA v. Chestnut +USA v. Hernandez +USA v. Hunter +USA v. Zubiate +USA v. Amarizan +USA v. Zeller +USA v. Perez +USA v. Martinez +PART ONE +Spray Moret, LLC v. Hudson Outerwear Inc et al +Palacios v. P. Mejias Cleaning Services et al +NATURALIZATION +USA v. Ruiz +USA v. Rodriguez +USA v. Pivnick +People of The State of New York v. Debt Resolve, Inc. et al +Chen v. Nielsen et al +Creswell Investments, LTD v. Brazil + Qi Limited et al +Cotton v. NY State Office of Parks Recreation and Historic Preservation +O'Rourke v. Eldorado Holding Co +The Innocence Project, Inc. v. National Museum of Healt +Olsen v. Sildan Corporation +Harbus v. Fansided Inc. +City Of New York v. Travelers Property Casualty Company +Valdiviezo v. City of NY et al +Lesser et al v. TIAA Bank FSB +Garey v. Glasses USA, Inc +Olsen v. Officina Profumo Farmaceutica Di Santa Maria N +Traynor v. Western Digital Technologies, Inc. +De La Rosa v. Aspenly Co. LLC et al +Wu v. William Doyle Galleries, Inc. +Basurto et al v. Eda Food Inc. et al +Wiseman v. Goldner et al +Chiykowski v. Goldner et al +Tancredi v. The Rector, Church-Wardens and Vestrymen of +Bishop v. Island Yacht Management, Inc. +Moore et al v. Presco Contracting, LLC et al +Room +Date +Time +Initial Conference +Initial Conference +Initial Conference +PDC +IPTC +Initial Conference +Initial Conference +Initial Conference +PDC +Case Management Conference +Case Management Conference +IPTC +IPTC +PDC +IPTC +PDC +*PLEASE NoTE: This is only a partial list of week's proceedings. Proceeding dates and times are subject to change without notice. +DPM - Daniel Patrick Moynihan courthouse, 500 Pearl Street +TM = Thurgood Marshall courthouse, 40 Centre Street +WP = White Plains courthouse, 300 Quarropas Street diff --git a/vision-fixhub/ds9-parsed-01/2ac908a101c258b84840126d863c93a4858e3420d47c919a6277502323f82df3.receipt.json b/vision-fixhub/ds9-parsed-01/2ac908a101c258b84840126d863c93a4858e3420d47c919a6277502323f82df3.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..2f1c9c9c542c67af60c388692f72471f4817a437 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2ac908a101c258b84840126d863c93a4858e3420d47c919a6277502323f82df3.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "2ac908a101c258b84840126d863c93a4858e3420d47c919a6277502323f82df3", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "87148e94df56dcfa4ecbee83a4692b7a9915de30b20d79a729d7ce53d9a16bdc", + "output_sha256": "1f28c1282b2da7e5965714b689a365106d774017f8dd967052cb357ccc5836e2", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2ad06c72888274240db3c5e08d20d9aca23c8d81348f2af42b1fbcd1ef0328d4.md b/vision-fixhub/ds9-parsed-01/2ad06c72888274240db3c5e08d20d9aca23c8d81348f2af42b1fbcd1ef0328d4.md new file mode 100644 index 0000000000000000000000000000000000000000..620c7706415998cbe98587135e2e8c7a5ffb8285 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2ad06c72888274240db3c5e08d20d9aca23c8d81348f2af42b1fbcd1ef0328d4.md @@ -0,0 +1,138 @@ + +SUBSCRIBER INFORMATION +FINANCIAL LIABLE PARTY +Name: +Credit Address: +Customer Since: 02/27/2014 +Photo ID Type: +Photo ID Number: +DOB: +Contact Name: +Contact Home Phone: +Contact Home Email: +Photo ID State: +SSN/TaxID/FEIN: +Contact Work Phone: +Contact Work Email: +BILLING PARTY +Account Number: +Name : ( +Billing Address: +Account Status: Active +Billing Cycle: 31 +USER +INFORMATION +MSISDN: +MSISDN Active: +02/27/2014 - Current +Name : +User Address: +Service Start Date: 10/18/2012 +Payment Type: Postpaid +Contact Name: +Contact Home Phone: +Contact Home Email: +IMSI : +Dealer Info: I9PZ1 I9PZ1 I9PZ1 +Contact Work Phone: +Contact Work Email: +STATUS CHANGE HISTORY +Status Change Reason +AT&T PROPRIETARY +The information contained here is for use by authorized person only and + + +is not for general distribution. + +SUBSCRIBER INFORMATION +FINANCIAL LIABLE PARTY +Name: +Credit Address: +Customer Since: 02/27/2014 +Photo ID Type: +Photo ID Number: +DOB: +Contact Name: +Contact Home Phone: +Contact Home Email: +Photo ID State: +SSN/TaxID/FEIN: +Contact Work Phone: +Contact Work Email: +BILLING PARTY +Account Number: +Name: +Billing Address: +Account Status: Active +Billing Cycle: 31 +USER INFORMATION +MSISDN: +MSISDN Active: 05/16/2014 - Current +Name: KARYNA B +User Address: +Service Start Date: 05/16/2014 +Payment Iype: Postpaid +Contact Name: KARYNA B +Contact Home Phone: +Contact Home Email: +IMSI: +Dealer Info: SWDNR BWDNR BWDNR +Contact Work Phone: +Contact Work Email: +STATUS CHANGE HISTORY +Status Change Reason +AT&T PROPRIETARY + + +The information contained here is for use by authorized person only and +is not for general distribution. + +SUBSCRIBER INFORMATION +FINANCIAL LIABLE PARTY +Name: +Credit Address: +Customer Since: 02/27/2014 +Photo ID Type: +Photo ID Number: +DOB: +Contact Name: +Contact Home Phone: +Contact Home Email: +Photo ID State: +SSN/TaxID/FEIN: +Contact Work Phone: +Contact Work Email: +BILLING PARTY +Account Number: +Name : +Billing Address: +Account Status: Active +Billing Cycle: 31 +USER +INFORMATION +MSISDN: +MSISDN Active: 09/19/2016 - Current +Name: +User Address: +Service Start Date: 09/19/2016 +Payment Type: Postpaid +Contact Name: +Contact Home Phone: +Contact Home Email: +IMSI: +Dealer Info: ZJETE ZJETE ZJETE +Contact Work Phone: +Contact Work Email: +STATUS CHANGE HISTORY +Status Change Reason + + +The information contained +here +is +not +for +AT&T PROPRIETARY +for use by +authorized person only and +general distribution. \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/2ad06c72888274240db3c5e08d20d9aca23c8d81348f2af42b1fbcd1ef0328d4.receipt.json b/vision-fixhub/ds9-parsed-01/2ad06c72888274240db3c5e08d20d9aca23c8d81348f2af42b1fbcd1ef0328d4.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..53c070d99296d03f6f56494206741000f625934f --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2ad06c72888274240db3c5e08d20d9aca23c8d81348f2af42b1fbcd1ef0328d4.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -202, + "dataset": "marble-joined", + "doc_id": "2ad06c72888274240db3c5e08d20d9aca23c8d81348f2af42b1fbcd1ef0328d4", + "engine": "marble-apple-vision", + "event_count": 8, + "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "116790ef036d8e1bf65f51eb6cccf6835d70fbd73c28245c6e12e73d8b107191", + "output_sha256": "beeb6b1902d4b64e5f31869a4a9f4a03224d2e3f8bc2eb294dc3ee58566a0a78", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2ad9ba59330ba3389a16eefcc73c3e2bc973d36ead7a07ff7c9cc4d9dea4a112.md b/vision-fixhub/ds9-parsed-01/2ad9ba59330ba3389a16eefcc73c3e2bc973d36ead7a07ff7c9cc4d9dea4a112.md new file mode 100644 index 0000000000000000000000000000000000000000..d437ed2e782a8770f0c89bbc23c3b37201752c2a --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2ad9ba59330ba3389a16eefcc73c3e2bc973d36ead7a07ff7c9cc4d9dea4a112.md @@ -0,0 +1,20 @@ +From: " +(USANYS)" < +To: "l +Subject: RE: lunch run? +Date: Wed, 13 Nov 2019 18:30:40 +0000 +|" ‹ +Ah that's right- good luck! +From: +To: +Sent: Wednesday, November 13, 2019 1:30 PM +I (USANYS) < +Subject: Re: lunch run? +Hey sorry — I'm en you're to California today for Epstein, through Friday. See you when I'm back! +Sent from my iPhone +On Nov 13, 2019, at 12:25, +(USANYS) I +> wrote: +Assistant United States Attorney +United States Attorney's Office +Southern District of New York diff --git a/vision-fixhub/ds9-parsed-01/2ad9ba59330ba3389a16eefcc73c3e2bc973d36ead7a07ff7c9cc4d9dea4a112.receipt.json b/vision-fixhub/ds9-parsed-01/2ad9ba59330ba3389a16eefcc73c3e2bc973d36ead7a07ff7c9cc4d9dea4a112.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..ee0585bbae8d99fd96688f818babfbbdc798a72c --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2ad9ba59330ba3389a16eefcc73c3e2bc973d36ead7a07ff7c9cc4d9dea4a112.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "2ad9ba59330ba3389a16eefcc73c3e2bc973d36ead7a07ff7c9cc4d9dea4a112", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "3f1e899cfe5c649bbdae7399ddcfe6ba5ebbdc3e73fcf5aa8ec6f5d5a556d6d1", + "output_sha256": "f0e1941452f907671bd9e83649b319d780cc4262239f956e552f9e4991908f61", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2aeacf4b35c9609261852476dcc63b1e83ad8bdaa1e223d392eae73ec8753fae.md b/vision-fixhub/ds9-parsed-01/2aeacf4b35c9609261852476dcc63b1e83ad8bdaa1e223d392eae73ec8753fae.md new file mode 100644 index 0000000000000000000000000000000000000000..ad4a91646ebd84dc9dd348bb6e9a195da45e68c2 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2aeacf4b35c9609261852476dcc63b1e83ad8bdaa1e223d392eae73ec8753fae.md @@ -0,0 +1,389 @@ +Training Sign-In-Sheet +MCC New York +Hours: 1 +Course +Name +SHU Suicide Prevention +Training +Last Name +First Name +1. +2 +3. +Date: +Course +Code +BOP# +September 6, 2019 +Signature +10. +11. +13 +14 +15. +20. +28. +Signature + + +A: : +I. NoeL +: +•* SM SUICIDE +6/6/19 +sign-in Sheet +Signature +10.260-2019 + + +2/28/19 +• SHU Suide Prevention Tani (1h8) + + +MCC NEW YORK +TRAINING PARTICIPANT SIGN-IN LOG +COURSE TITLE: +Suicide Prevention/SHU Training +TRAINING DATE(S): From: December 7, 2018 +TRAINING TIMES: +INSTRUCTOR(S): +LAST NAME (PRINTED) +1. +2. +3. +4. +5. +6. +7. +8. +9. +10. +11. +12. +13. +14. +15. +16. +17. +18. +19. +20. +FIRST NAME (PRINTED) +COURSE CODE: +To: December 7. 2018 +TOTAL TRNG HRS. 1 kL +To: 17:00pm +NOTE: INSTRUCTOR(S) MUST ATTACH AGENDA +OR SUMMARY OF TRAINING +BOP ID +SIGNATURE +OFFICE +USE +• +By signing above you attest to not only attending the above named training course, +but also to understanding the course material, policies and procedures pertaining to +the training. +SENSITIVE - LIMITED OFFICIAL USE + + +Special +Housing +Unit Management +Suicide Prevention +Objectives +• Understand suicide risk associated with +locked units and single cells +• Identify high risk groups +- mentally ill inmates +- behavior disordered inmates +- sex offender and protective custody inmates +Objectives +• Discuss management strategies for +specific at risk inmates in this SHU +• Review emergency response procedures +1 + + +BOP Inmate Suicides +Rate per 100,000 +40 +35 +30 +25 +20 +15 +10 +Locked Units +• Locked units include SHUs, SMUs, ADX, +Seclusion, Extended lock down units, etc. +• Every year between 30 and 80% of inmate +suicides occur on a locked unit +• Single Cells in locked units are especially +risky for high-risk inmates +Single Cell Suicides +in SHU +Double Cel +HU Suicides +• Single Cell +SHu Suicides +2013 +2014 +2015 +2016 +2 + + +Single Cells +It is recommended that all SHU inmates be +double-celled unless there is a compelling +reason not to do so +- Reduces isolation +- Reduces privacy +- Provides distraction +- Provides rescue opportunity +Single Cells +When an inmate cannot be double celled: +- Place at-risk inmates in higher visibility cells +- Reduce or eliminate tie-off points +- Increased monitoring of property +- Additional out of cell contacts with +Psychology, Health Services, Unit Team, +Recreation, Education, and Religious +Services +High Risk Inmates +Discuss local policies to ensure specific +inmates are not single celled. These may +include: +- Psychology Advisory List (TRU-SCOPE) +- Special notation on cell door +- Special notation on SHU board +- SHU Program +- Other +Do Not Cell +Alone +3 + + +Good SHU Management is +Good Suicide Prevention +• Complete SHU rounds as directed by policy and +document them accurately +• Observe inmates & report concerns to the SHU +Lieutenant, Psychology Services, and/or the +next shift, as appropriate +• Respond to inmate concerns and accommodate +reasonable requests promptly +Good SHU Management is +Good Suicide Prevention +• Prior to entering a SHU cell to provide +assistance staff should ensure their safety which +may include waiting for assistance +• Cut down tools should never be used for any +purpose other than responding to a suicide +emergency +• Know the location of the AED and how to use it +Behavior Disordered +Inmates +• 30% suicides are committed by behaviorally +disordered inmates in SHU +• At risk for suicide AND accidental death +• Must be assessed by psychology EVERY time +they make a new threat of self-harm +• Must be taken seriously! +4 + + +a +Working with +Behavior Disordered Inmates +• Negative perceptions or frustrations may impact +your professional judgment and need to be +monitored +• Manage through collaboration between +departments +• A group approach is indicated for the most +demanding cases +Working with +Behavior Disordered Inmates +• Manage with positive reinforcement +- Catch them being good +- Praise progress, not perfection - "small steps" +- Address reasonable requests promptly +- Set one goal that is guaranteed to occur +• If a Suicide Risk Management Plan is in +effect, follow it exactly +What is a Suicide +Risk Management Plan? +• The Plan we will discuss today is not the same +as the plan used by the institution when an +inmate is in restraints +• A Suicide Risk Management Plan is also NOT: +- Punishment +- Stricter rules +- Extreme deprivation +- Social isolation +- Less work for staff +5 + + +âLY•!!!va +Suicide Risk Management Plan +The goal of a Suicide Risk Management Plan is to +increase inmate safety by decreasing behaviors +that create risk for suicide or accidental death when +the inmate cannot be engaged in positive change +behaviors +Suicide Risk Management Plan +• A Suicide Risk Management Plan IS: +- Feedback: immediate and frequent +- Reinforcement of positive behaviors or +neutral behaviors that replace harmful +behaviors +- Collaboration: between psychology, custody. +other departments, and executive staff +- Targeted: self-harm behaviors and other +behaviors that place the inmate in danger +(cutting, cell fires, etc.) +Creating a +Suicide Risk Management Plan +Psychology Services identifies key issues +through observation of the inmate and input +from staff: +- High risk behaviors +- Elements of the environment that +perpetuate dangerous behavior +- Reinforcers that may be used to reward +positive behavior +6 + + +âLY+!!!va +Creating a +Suicide Risk Management Plan +• These are combined into a brief, +individualized plan that indicates: +- Management strategies +-When reinforcers will be provided +-What harmful behaviors will trigger more +intensive risk management strategies +Enacting a +Suicide Risk Management Plan +• Present the plan to the inmate; this is +usually done collaboratively by the Captain +and Chief Psychologist +• Be prepared: Behaviors usually get worse +before they get better +• All staff need to adhere to the plan +• Discuss concerns and issues along the +way to ensure staff members are being +Behavior Disordered Inmates +• Place PDS Photo +Here +• Inmate's Name & +Location +• List Risk Factors & +Warning Signs Specific to +the Inmate +* Discuss Helpful +Interventions: Especially +Preventative +Interventions +7 + + +Mentally !!! Inmates +• Approximately 30 to 60% of BOP suicides are +completed by mentally ill inmates +• Disorders most frequently include Depression, +Bipolar Disorder, and Schizophrenia +• Symptoms may include psychosis, poor hygiene, +lack of energy. poor appetite, insomnia, +agitation, and lack of interest in things that were +once of interest +Mentally III Inmates +• Monitor these inmates closely, look for changes +in mood and behavior and report them to +Psychology +• Build positive rapport with these inmates to +assist them with problem solving and meeting +their needs +• During shake downs, ensure medications are +not being hoarded and property has not been +modified to allow self-hamm +Mentally III Inmates +• Place PDS Photo +Here +• Inmate's Name & +Location +• List Risk Factors & +Warning Signs Specific to +the Inmate +• Discuss Helpful +Interventions: Especially +Preventative +Interventions +8 + + +¡vâoätä8ÇA +Sex Offenders and +Protective Custody +• Both of these groups are at heightened risk for +suicide +- Both groups may be fearful of other inmates +- Both groups may be experiencing shame +• Double-cell all inmates whenever possible +• Convey requests to speak to Psychology +immediately +• Place in higher visibility cells +Emergency Response +• Always initiate life saving measures +• Ensure the response reflects the emergent +nature of the situation +• All staff should carry personal protective +gear +Lesson Learned +From Local Mock Drills +9 + + +ıyâ®â!!â7üл]»!0ú§âvâ!!â4âлª*Ịvú§âvä‡âЗäл{жỊ©ú§â+ä‹â1ẳ»Ĩж1©ú§âжä»â0çA§ +Psychology Advisory +List +• The Advisory List +- identifies inmates with mental health +conditions who may become dangerous, selfdestructive, or suicidal when placed into the +SHU. +PSY Alert +• PSY Alert is an enhanced tracking and +monitoring system to ensure: +- Special psychological needs +are reviewed and considered +by Psychology Services +- Safety and security concems +are highlighted for +non-psychology staff +Phone a Friend +• You are required to refer an inmate to +Psychology Services if you observe behaviors +that indicate she or he may be at risk for suicide +• Call to collaborate in managing high risk inmates +• Call to discuss small +problems before they +get big +10 + + +1VE0ya0/2Đ18A5 +Review of Objectives +* Understand suicide risk associated with locked units +and single cells +• Identify high risk groups +- mentally ill inmates +- behavior disordered inmates +- sex offender and protective custody inmates +• Discuss management strategies for specific at risk +inmates in this SHU +• Review emergency response procedures +QUESTIONS? +11 \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/2aeacf4b35c9609261852476dcc63b1e83ad8bdaa1e223d392eae73ec8753fae.receipt.json b/vision-fixhub/ds9-parsed-01/2aeacf4b35c9609261852476dcc63b1e83ad8bdaa1e223d392eae73ec8753fae.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..9bd9831fa76bd13b7a770798415194875fec63d1 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2aeacf4b35c9609261852476dcc63b1e83ad8bdaa1e223d392eae73ec8753fae.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -293, + "dataset": "marble-joined", + "doc_id": "2aeacf4b35c9609261852476dcc63b1e83ad8bdaa1e223d392eae73ec8753fae", + "engine": "marble-apple-vision", + "event_count": 17, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "2422454548119a3c338e737c3e41628ae97a89c039fcef7976f71b029cc3745f", + "output_sha256": "6913f8c4e0625f9d408b159ee243e40796ed40a2a28f6b4621f73715c8c45c14", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2afa53a925d5adc2f77c5f4268350d2bdf85cc7c27ee6319fc4db9a7442b0c38.md b/vision-fixhub/ds9-parsed-01/2afa53a925d5adc2f77c5f4268350d2bdf85cc7c27ee6319fc4db9a7442b0c38.md new file mode 100644 index 0000000000000000000000000000000000000000..b0ff76c24a6e68d1c2a7213b1cd9068b90a4b814 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2afa53a925d5adc2f77c5f4268350d2bdf85cc7c27ee6319fc4db9a7442b0c38.md @@ -0,0 +1,45 @@ +FD-302 (Rev. 5-8-10) +- 1 of 1- +FEDERAL BUREAU OF INVESTIGATION +OFFICIAL RECORD +Date of entry +03/27/2019 +, date of birth (DOB) +was interviewed at +residence +West Palm Beach, Florida. After being +advised of the identity of the interviewing Agents and the nature of the +interview, +provided the following information: +has been contacted repeatedly by news outlets regarding JEFFREY +EPSTEIN. +was not interested in news stories. +stated, +"Something bad happened to me, and I dealt with it the best way I could." +provided that +does +not remember all of the smaller details, +like where phone calls that would set up massages originated from, but +remembers "large details" like what EPSTEIN's house looked like and +what "we did." +provided that any new victims identified would need protection. +was "harassed" by EPSTEIN's private investigators and the media +when the case was initially investigated years ago. +and +girls +were followed, watched, threatened, and harassed. +still talks with +likely not speak with Agents about EPSTEIN. +, but advised that +will +was interested in meeting for another interview and is willing +to be contacted further. +Investigation on +03/20/2019 +at West Palm Beach, Florida, United States (In Person) +File # +31E-NY-3027571 +_Date drafted 03/25/2019 +by +This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your agency; it and its contents are not +to be distributed outside your agency. diff --git a/vision-fixhub/ds9-parsed-01/2afa53a925d5adc2f77c5f4268350d2bdf85cc7c27ee6319fc4db9a7442b0c38.receipt.json b/vision-fixhub/ds9-parsed-01/2afa53a925d5adc2f77c5f4268350d2bdf85cc7c27ee6319fc4db9a7442b0c38.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..4e25b0d05c511d4214889dd03c52a9225bf2aa1f --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2afa53a925d5adc2f77c5f4268350d2bdf85cc7c27ee6319fc4db9a7442b0c38.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "2afa53a925d5adc2f77c5f4268350d2bdf85cc7c27ee6319fc4db9a7442b0c38", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "bab4ef42d09f4ca2b880a917fc6aad1f69216b886ad681a1789c7a0d04747779", + "output_sha256": "3800e9551cd31684757366f585bb2c626d8553a161c9c562ddb9939968ce152c", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2b27af4148ef83b9fa84ecb38f750b6a101f24ae73c1a02d4eb1d1810c005579.md b/vision-fixhub/ds9-parsed-01/2b27af4148ef83b9fa84ecb38f750b6a101f24ae73c1a02d4eb1d1810c005579.md new file mode 100644 index 0000000000000000000000000000000000000000..5d162d8dc3ab1548c89c15393e9e1ec863c68302 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2b27af4148ef83b9fa84ecb38f750b6a101f24ae73c1a02d4eb1d1810c005579.md @@ -0,0 +1,35 @@ +From: +To: +Subject: +Date: +Attachments: +2 +Re: 11 AWOL Staff +Wednesday, August 14, 2019 11:22:24 AM +IEXT. htm +Thanks Jim. I can't tell you enough how much this is appreciated. +Sent from my Verizon, Samsung Galaxy smartphone +• Original message --- +From: + +Date: 8/14/19 11:18 AM (GMT-05:00) +To: +CC. " +Subject: Re: 11 AWOL Staff +>>> +Boss, +08/14/2019 11:18 > >> +The following staff were on AWOL status during the week of August 4-10, 2019, all for a total of 40 hours: +(OWCP ended, has not returned, no current LWOP approval.) +OWCP ended, has not returned, no current LWOP approval.) +OWCP ended, has not returned, no current LWOP approval.) +(OWCP ended, has not returned, no current LWOP approval.) +(Probationary officer injured in motorcycle accident. Has recent approval LWOP so he'll be +changed) +(Out due to surgery, no current LWOP approval) +(OWCP ended, has not returned, no current LWOP approval.) +(Extended military orders have expired, no LWOP approval) +(Out for surgery due to work related injury, no LWOP approval - LWOP ready to be signed) +(OWCP denied case, has been out trying to get medical retirement) +OWCP ended, has not returned, no current LWOP approval.) +Also, attached is the augmentation agreement. There is no agreement concerning Overtime sign up procedures. diff --git a/vision-fixhub/ds9-parsed-01/2b27af4148ef83b9fa84ecb38f750b6a101f24ae73c1a02d4eb1d1810c005579.receipt.json b/vision-fixhub/ds9-parsed-01/2b27af4148ef83b9fa84ecb38f750b6a101f24ae73c1a02d4eb1d1810c005579.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..4282bc791624a92dd1a3dccc591b94cf33ee41a9 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2b27af4148ef83b9fa84ecb38f750b6a101f24ae73c1a02d4eb1d1810c005579.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "2b27af4148ef83b9fa84ecb38f750b6a101f24ae73c1a02d4eb1d1810c005579", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "f635124e50effb06a6963eff302c7327ddf9a5858625c05d96d2db1f4274d667", + "output_sha256": "e06f4d621008a0c1d78ce6a010eb45631a17c313da28005ab5abb0aab0e14d50", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2b4c5c7993beb3ab3f36c195968a5c512a39c52325d4444e5ce2a32a7bc6b347.md b/vision-fixhub/ds9-parsed-01/2b4c5c7993beb3ab3f36c195968a5c512a39c52325d4444e5ce2a32a7bc6b347.md new file mode 100644 index 0000000000000000000000000000000000000000..848e266535bca85ae44a57982e7deb190e39e96b --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2b4c5c7993beb3ab3f36c195968a5c512a39c52325d4444e5ce2a32a7bc6b347.md @@ -0,0 +1,2042 @@ +From: +To: +Subject: [EXTERNAL EMAIL] - FBI Public Affairs News Briefing Thursday, July 30, 2020 +Importance: Normal +Priority: Normal +Sensitivity: None +Mobile version and searchable archives available at fbi.bulletinintelligence.com +. +, +"If the Federal Government and its brilliant Law Enforcement (Homeland) didn't go into Portland one week ago, +there would be no Portland - It would be burned and beaten to the ground. If the Mayor and Governor do not +stop the Crime and Violence from the Anarchists and Agitators immediately, the Federal Government will go in +and do the job that local law enforcement was supposed to do!" +Trump later tweeted, "@FoxNews +reported incorrectly what the Federal Government is doing with respect to Portland. We are demanding that the +Governor & Mayor do their job or we will do it for them. To complicated to discuss in a Tweet, but bad reporting +by Fox (possibly on purpose!). @DHSgov" +Fox News < https://www.foxnews.com/us/federal-agents-leave-portland-oregon> (7/29, Wallace, 27.59M) reports +on its website that federal agents deployed in Portland will begin a "phased withdrawal" from the city's +downtown area starting Thursday, Oregon Gov. Kate Brown (D) announced earlier Wednesday. Acting DHS +Secretary Wolf said in a statement that he and Brown had reached a joint plan to end "the violent activity in +Portland directed at federal properties and law enforcement officers." In his statement, Wolf said President +Trump and the Administration have been consistent in their message that "violent criminal activity" directed at +federal properties and law enforcement will not be tolerated and that "state and local leaders must step forward +and police their communities." +Later Wednesday, Wolf alleged on Fox News' Ingraham Angle (7/29) that Brown is using "very irresponsible" language. "She is describing law + + +enforcement officers, civil law enforcement officers who wake up every day you come up with a badge on come +up with the uniform on and protect the community and federal officers, as an occupying force and responsible +for the violence we see in Portland. ... It is the violent rioters and criminals that we have seen over 60 days that +are the occupying force." +The AP (7/29, Selsky, Ranen) reports Brown +announced federal agents will begin a "phased withdrawal" from the city as they "work alongside state police to +guard the exterior of the courthouse." A "limited number of other federal agents," however, "will remain inside +the courthouse." CNBC (7/29, Higgins, 3.62M) says on its website, "While Brown's statement +indicated that some federal officers, including all Customs and Border Protection and Immigration and Customs +Enforcement agents, will depart as soon as Thursday, Wolf indicated that DHS agents will remain." Wolf "wrote +that the DHS would keep its personnel in Portland 'until we are assured that the Hatfield Federal Courthouse and +other federal properties will no longer be attacked and that the seat of justice in Portland will remain secure." +Wolf, Politico (7/29, Cohen, 4.29M) reports, +"said he was pleased that Oregon officials had agreed to maintain +the first line of defense for the courthouse, but he also suggested that a lackadaisical response from Brown and +Portland city officials essentially forced the feds to make their controversial move to call in reinforcements." +Wolf is quoted as saying, "If she would've done it earlier, we would've been able to address the situation very +differently... If violent individuals decide to commit a conscious decision to break federal law, we're going to +hold those people accountable. With Oregon State Police there, we hope it doesn't get to that. ...That's what +occurs in every other city across the country. We hope that's what's going to occur there as well." +The Federalist (7/29, Reynolds, 126K) reports that while "Wolf and Brown both claimed to +have reached a decision together," their announcements "emphasize very different aspects" of what it calls "an +ambiguous agreement." +The New York Times +(7/29, A1, Baker, 18.61M), meanwhile, reports that "hours before the announcement of the agreement, President +Trump doubled down on the need for the increased federal presence in Portland." Trump is quoted as saying, +"You hear all sorts of reports about us leaving. We're not leaving until they've secured their city. We told the +governor. We told the mayor. Secure your city. If they don't secure their city soon, we have no choice. We're +going to have to go in and clean it out." +The Washington Times (7/29, Dinan, 492K) calls the agreement "a possible solution to months of violent +clashes that have stained the city," the AP (7/29, +Flaccus, Balsamo) notes "each side declared victory," while the Washington Post + (7/29, A1, Berman, Miroff, Lang, Fahrenthold, 14.2M) says "the specific +timing of how this would play out remained unclear." +On its editorial page, the Wall Street Journal (7/29, Subscription Publication, 7.57M) welcomes the announcement, which it says puts the +responsibility to restore order back on state and local leaders. USA Today + (7/29, Hauck, 10.31M), the Wall Street Journal (7/29, A1, Levy, +Gurman, Subscription Publication, 7.57M), Townhall + (7/29, +O'Brien, 177K), and the Daily Caller (7/29, Talcott, 716K), among other news outlets, + + +also report on the announcement. +Former Prosecutor Warns Trump Making Cities Less Safe. Former federal prosecutor Michael J. Stern argues in +USA Today (7/29, 10.31M) that Trump "has cast the battle between protesters +and federal law enforcement in the same way he cast "The Apprentice' - with heroes and villains and an +audience that does not know it is being played." Trump's "Portland strategy," Stern says, is: "Look tough and +beat Biden. But he's making cities less safe." +Protests +Administration Announces Deployment Of Agents To Cleveland, Milwaukee, Detroit. +Reuters (7/29, Chiacu, Alper, Hay, Borter, Layne), meanwhile, reports "the +withdrawal in Oregon coincided with the announcement of a deployment of federal law enforcement officials to +Cleveland, Milwaukee and Detroit, expanding a separate program aimed at curtailing a surge of murders and +other violent crimes in some cities." NBC Nightly News + (7/29, story 5, +2:00, Holt, 5.97M) said as part of the operation, the Administration is "sending federal agents, not tactical teams, +to help fight crime" in the more cities. +USA Today (7/29, Phillips, 10.31M) reports the Justice Department plans to +send 42 agents to Detroit and "more than 25 each to Cleveland and Milwaukee - cities that officials said have +seen rising violent crime rates." The federal officers, drawn from "the FBI, Drug Enforcement Administration +and other agencies, will help local and state officials in ongoing criminal investigations, according to the Justice +Department." +Fox News (7/29, Blitzer, 27.59M) reports, "The initiative first launched in Kansas City, Mo., on +July 8, and expanded to Chicago and Albuquerque one week ago." Detroit, Cleveland, and Milwaukee "will see +increased resources from the FBI, U.S. Marshals Service, Drug Enforcement Administration, and the Bureau of +Alcohol, Tobacco, Firearms and Explosives that will aim to reduce crime, particularly gun violence." +CNN +(7/29, Perez, 83.16M) reports that the federal agents "will work on gun and other criminal cases previously +identified as within federal jurisdiction in coordination with local and federal prosecutors. Justice officials +previously announced that hundreds of federal officers were being sent to Chicago, Kansas City and +Albuquerque as part of an initiative called Operation Legend." +The Hill +(7/29, Feuerherd, 4.57M) reports, "Operation Legend is named after 4-year-old LeGend Taliferro, who was shot +and killed in Kansas City while she was sleeping, and launched earlier this month in the city." + + +The CBS Evening News (7/29, Chasmar, 492K) reports Chief Craig "said Tuesday his city isn't seeing the riots that +are occurring in other major cities across the country because his police department is supported by the mayor +and fellow Detroiters who are 'fed up' with the "misguided radicals' fomenting chaos." +The Washington Times (7/29, Mordock, 492K) reports Detroit Mayor Mike Duggan on Twitter Wednesday +"assured residents his city didn't initiate the surge in federal officers." Duggan tweeted +, "Today's announcement of additional +federal agency staff was not initiated by the City of Detroit. So long as they are used in the continuing effort to +enforce federal laws on illegal gun trafficking and gang violence, DPD will continue its strong partnership with +those agencies." Meanwhile, Milwaukee Mayor Tom Barrett last week said he was "extremely concerned" about +the deployment. +US Attorney Distinguishes Federal Role In Portland From Crime-Fighting Assistance In Other Cities. The AP + (7/29, Richmond) reports that on Wednesday, +federal prosecutors "worked..to dispel concerns that federal agents headed to a number of U.S. cities will be +used to break up protests, insisting that the agents will work side-by-side with local and state investigators to +solve violent crimes." President Trump "announced last week that he was sending agents to more U.S. cities...to +combat a rise in violent crime." Matthew Krueger, the US Attorney in Milwaukee, "told reporters during a news +conference...that the media was confusing agents' missions," and that "agents being sent to cities other than +Portland were part of a U.S. Department of Justice effort to bolster manpower in high-crime cities." Sen. Tammy +Baldwin (D-WI) "said that after speaking with Krueger, she is supportive of the operation in Milwaukee," but +"faulted Trump's administration for not being clear from the outset." +Federal Agents Headed For Detroit. +The AP (7/29, Ferretti, 825K) reports, +"Schneider told The News last week that he was actively working with Washington, D.C., to 'bring more federal +resources and more federal law enforcement agents to Michigan.' The effort, he noted, is an extension of +Operation Relentless Pursuit, a program rolled out in Detroit last winter by U.S. Attorney General William Barr." + + +The News adds, "The program to assist local law enforcement establish new task forces to track down the most +violent offenders also is targeted at Memphis, Baltimore, Kansas City, Cleveland, Milwaukee and Albuquerque, +Barr said in December when he announced the program alongside Craig and leaders of the FBI, ATF, DEA and +U.S. Marshals Service." +The Detroit Free Press < https://www.freep.com/story/news/local/michigan/detroit/2020/07/29/detroit-federallaw-enforcement-violence/5534691002/> (7/29, Baldas, 1.52M) reports, "Federal law enforcement agencies +have a message for Detroit: We are coming to help your city fight violence, not harass or intimidate your +protesters. 'Let me be perfectly clear ... there are no federal troops coming to Detroit, or anywhere in Michigan +to interfere with protesters,'" Schneider said Wednesday. The Free Press adds, "Many Detroiters have expressed +concern and fears about the federal intervention as it comes amidst a national Black Lives Matter movement that +has turned violent in other cities across the country. Detroit protests have thus far been mostly peaceful, though +many locals fear their city could turn into another Portland, where chaos and mayhem broke out following the +arrival of federal agents," but "that's not why federal agents are coming here, the leaders stressed on +Wednesday." +MLive (MI) (7/29, A fana, 925K) reports, +"The plan is to send 42 federal agents from the FBI, +DEA, Alcohol, Tobacco, Firearms and Explosives and U.S. Marshals to Detroit to fight gun and gang violence. +The city will also get $1 million to combat gang and gun violence from the Bureau of Justice Assistance." +Schneider "cited a spike in violent crime as the reason. He said homicides have increased by 31% in Detroit. +"These numbers keep going up. This flood in violence keeps threatening our safety. More and more, our children +are being caught in the crossfire and murdered in senseless gun violence,' Schneider said, referring to the May 21 +death of Nathaniel Mesiah Roby, a 4-year-old who was shot in his home." +The Detroit Metro Times (7/29, Neavling, 219K) reports, "As long as +the agents leave protesters alone, Detroit Mayor Mike Duggan and police Chief James Craig said they support +the additional resources." +WDIV-TV Detroit (7/29, Johncox, 460K) reports from Detroit, "FBI Special +Agent in Charge Steve D'Antuono announced during a news conference Wednesday a $25,000 reward for +information leading to the arrest of those responsible for the death of a 4-year-old boy in Detroit." Nathaniel +"Messiah" Roby-Townsend "died just after midnight on May 21 when someone fired shots into his family's +home on Birwood Street near Seven Mile Road. Family members said the children were in bed when someone +drove by and opened fire, hitting Nathaniel. He was rushed to a hospital where he was pronounced dead." +Among local news outlets also reporting are WJR-AM Detroit (7/29, 19K), WJBK-TV Detroit +(7129, 103K), WDIV-TV Detroit (7/29, Johncox, 460K), WXYZ-TV + +Detroit (7/29, Chowdhry, 236K), WXYZ-TV Detroit +(7/29, 236K), WJBK-TV Detroit (7/29, 103K), Deadline Detroit + (7/29, Lengel), and WWJ-TV Detroit (7/29). +Cleveland To See 25 New Federal Agents In Operation Legend. + + +The Cleveland Plain Dealer (7/29, Caniglia, 895K) reports, "Federal authorities said +Wednesday that Cleveland will get 25 federal agents over the next several months to stem a spike in violent +crime." The Plain Dealer adds, "Nearly $10 million in federal money also will go toward hiring 30 Cleveland +police officers and seven state officers, U.S. Attorney Justin Herdman told reporters at a press conference. 'We +can't waste any time here,' Herdman said, citing a 35 percent increase in shootings in the city over the same time +last year. Homicides have jumped 32 percent, according to the Cuyahoga County Medical Examiner's Office. +Herdman's comments came days after the White House announced that the U.S. Justice Department selected +Cleveland and a handful of other cities would receive additional federal officers." +WEWS-TV Cleveland (7/29, 223K) reports, "As Cleveland +authorities introduced the launch of "Operation Legend' - a violent crime reduction effort in the city - they also +announced a $25,000 reward regarding the murder of a 17-year-old boy." WKYC-TV adds, "Officials with the +Cleveland Division of the FBI are asking for the public's help in finding the person(s) responsible for the May 25 +shooting, which claimed the life of Eric Hakizimana as he stopped at a traffic light at the intersection of W. 80th +and Detroit. Eric Smith, Special Agent in Charge of the Cleveland FBI, discussed details of the teen's death +during a press conference Wednesday morning. 'Eric was violently pulled from his vehicle, shot and left to die +on the streets of Cleveland. His murderer then drove away in Eric's vehicle." +WEWS-TV Cleveland (7/29) reports, "Police said an +unknown male approached Hakizimana's car, dragged him out of the vehicle, shot him and fled the area in his +vehicle. 'Eric and his family are refugees from their home country of the Democratic Republic Congo, having +fled violence and war there for a refugee camp in Uganda. Eric and his family came to the United States unable +to imagine violence would follow them to a street light at West 80th and Detroit with the sudden and tragic loss +of their son,' Smith said. A $25,000 reward is being offered as part of funds allocated from 'Operation Legend.'' +WKYC-TV < https://www.wkyc.com/video/news/local/cleveland/operation-legend-explained-cleveland/95- +08d260ea-8e9b-4578-baa8-e3c75897106f> Cleveland (7/29, 223K) also reports. +Milwaukee To Get More Than 25 Federal Agents. +The Milwaukee Journal Sentinel (7/29, Spicuzza, 632K) reports, "More than 25 federal +agents will be coming to Milwaukee as part of Operation Legend, a program aimed at addressing violent crime, +Matthew D. Krueger, U.S. attorney for Wisconsin's Eastern District, said Wednesday." The Journal Sentinel +adds, "Agents from the FBI, Drug Enforcement Administration, Bureau of Alcohol, Tobacco, Firearms and +Explosives, and U.S. Marshals Service will join work that's already underway by existing federal, state and local +task forces, Krueger said. Ten of the federal agents will be assigned to work in Milwaukee temporarily to provide +"immediate assistance,' and the others will be assigned over the next year to provide long-term assistance, he +said." + + +WDJT-TV +Milwaukee (7/29, 65K) reports, "Between 25 and 30 federal agents will be coming to Milwaukee through the +FBI, ATF, U.S. Marshal Service and the DEA to expand on existing partnerships with the Milwaukee Police +Department. 'These aren't beat cops, Wisconsin Eastern District U.S. Attorney Matthew Krueger said. 'These +are trained investigators, who do often longer term investigations or who know how to do a deeper dive on +things. "" Milwaukee "is one of six cities currently involved in 'Operation Legend, along with Detroit, +Cleveland, Chicago, Kansas City and Albequerque." WDJT-TV adds, "The city's homicide rate is currently 85 +percent higher than it was at this time last year. "That's the reason why we need to focus our attention to reduce +violent crime in this area, Milwaukee FBI Special Agent in Charge Robert Hughes said." +The Milwaukee Journal Sentinel (7/29, Dirr, 632K) reports, "Federal officials +on Wednesday announced a reward of up to $25,000 for information leading to the arrest of the person who +killed Qunyonce Louis-Moore, 16, in Milwaukee. She was fatally shot about 10:30 p.m. on June 30 while on a +walk with friends on the 3400 block of North 8th Street. Qunyonce died at the scene. 'Please, I beg you, if you +have any information at all please, please come forward and let us know, and we will do everything we can to +bring justice to the individual that took her life,' said FBI Special Agent in Charge Robert Hughes, calling +Qunyonce's homicide a 'senseless act."" WISN-TV Milwaukee (7/29, 265K) also reports. +Two Protesters Charged In Attack On Wisconsin State Lawmaker. +The Wisconsin State Journal (7/29, Treleven, 372K) reports that "tips from a former physical therapy client and from coworkers led police to the identities of two women who were arrested this week for the alleged attack on state +Sen. Tim Carpenter last month during a Downtown protest, according to court documents filed Wednesday." +Kerida E. O'Reilly and Samantha R. Hamer, both of Madison, were charged Wednesday "with substantial battery +as party to a crime for the alleged attack on Carpenter." +The New York Times (7/29, +Hauser, 18.61M) reports Carpenter "said on June 24 that he was punched and kicked in the head after he took a +cellphone video of protesters who had been marching through downtown Madison for several hours to protest +police violence and racism." +US Charges Eight Pittsburgh Protesters. +KDKA-TV Pittsburgh +(7/29, 144K) reports, "Eight Pittsburgh protesters who were involved in the May 30 demonstrations in +downtown Pittsburgh have been criminally indicted, according to U.S. Attorney Scott Brady's office. The people +indicted include 31-year-old George Allen of Pittsburgh, 25-year-old Nicholas Lucia of Pittsburgh, 25-year-old +Andrew Augustyniak-Duncan of Carnegie, 24-year-old Raekwon Dac Blankenship of Pittsburgh, 24-year-old +Devin Montgomery of Pittsburgh, 22-year-old Da'Jon Lengyel of McKees Rocks, 35-year-old Christopher West +of Pittsburgh and 29-year-old Brandon Benson of Pittsburgh." +The Gant (PA) Daily (7/29, Shirey) reports, "The alleged criminal acts occurred while Pittsburgh Police officers were +engaged in responding to the violent demonstration in downtown Pittsburgh on May 30, at the same time that +many other citizens were lawfully protesting over the death of George Floyd in Minneapolis, Minn. The + + +indictments were returned under seal on July 22, and the final two indictments were unsealed on Wednesday. +*The actions of the accused were uncalled for and prevented law enforcement officers from carrying out their +duties to protect and serve our community,' said FBI Pittsburgh Special Agent in Charge Michael Christman. +"The FBI respects the rights of people to peacefully exercise their First Amendment freedoms but will not stand +by and let those with a violent agenda take over peaceful protests."*' +Seattle Police Union Leader Rejects Mayor's Claim Trump Using Agents As "Dry Run For Martial Law." +Fox News (7/29, Kaplan, +27.59M) reports, "Denying federal law enforcement assistance to combat violence is 'unconscionable,' Seattle +Police Officers Guild President Michael Solan told 'America's Newsroom' on Wednesday, reacting to comments +made by Seattle Mayor Jenny Durkan earlier this week." Speaking on CNN Monday, Durkan said President +Trump "clearly targeted cities run by Democratic mayors. He's said so himself. He's using law enforcement as a +political tool." Durkan continued, 'I hate to say it, but I really believe that we are seeing the dry run for martial +law." In response, Solan said, "To deny any type of assistance from any law enforcement entity to me is +unconscionable and I have yet to hear one elected official show concern for the officers that were hurt this past +weekend." +Seattle Mayor Loses Bid To Stop Recall Petition. The AP + +(7/29) reports that a judge "who ruled earlier this month that a recall petition against Seattle Mayor Jenny +appeal to a higher court, but the ruling marks another legal win" for his opponents "in what would be a long +process to oust her from office in a special recall election." +Oakland Approves Resolution To Keep City "Safe" From "Trump's Federal Agents." +Fox News (7/29, +Casiano, 27.59M) reports the Oakland City Council approved a resolution Tuesday to keep the city "safe from +President Trump's federal agents." The "unanimous vote" approved legislation that cited the ongoing protests in +Portland. +Judge Restricts Use Of Force Against Protesters In Oakland. Axios (7/29, Ayesh, 521K) reports that a judge +issued a preliminary injunction on Wednesday "restricting police from using stinger grenades, rubber bullets and +pepper balls against protesters in Oakland." US Magistrate Joseph Spero's injunction "follows a request from the +Anti-Police Terror Project, a nonprofit watchdog group, which accused local police of using excessive force +against Black Lives Matters protesters." The order, however, "does not apply to federal officers." +Morgan, Miller: Democrats Emboldening Protesters By Failing To Condemn Violence. +Acting CBP Commissioner Morgan said on WMAL-AM Washington (7/29, "I'm disgusted at" House Speaker Pelosi calling +his officers stormtroopers. Morgan said such comments are "emboldening and encouraging what I refer to as +violent criminal anarchists. ... This is politics being put before public safety." Morgan, appearing on Washington +Watch (7/29, Morgan, Schweppe, Dennard, Gonzalez), +said, "The last 62 days there have been peaceful protests that have been taken over, hijacked, by violent + + +anarchists every single night with the willful intent to destroy federal property and hurt federal agents." +White House senior advisor Stephen Miller said on WSB-AM + Atlanta (7/29, +52K), "The Democratic Party decided to rally behind purposeless anarchists in Portland launching incendiary +devices." Miller added, "Democrats have fully thrown in their lot with this new brand of domestic terrorism." In +Portland there are "heroic law enforcement officers doing shifts in unimaginable circumstances, trying to keep +federal property…safe." +Rove: Biden Likely To Lose Support From Center For Failing To Condemn Protesters. Karl Rove, writing in his +Wall Street Journal < https://www.wsj.com/articles/rioters-attack-more-than-a-courthouse-11596061930> (7/29, +Subscription Publication, 7.57M) column, welcomes the deal brokered by the Administration with authorities in +Oregon. Rove also writes that by failing to condemn violent protesters in Portland, Joe Biden is likely to lose +support from centrists voters who are tired of the violence. +Poll: Support Drops For Protests, But Many Disapprove Of Trump's Response. +Reuters (7/29, Kahn) reports that "Americans' support for +the Black Lives Matter protests has declined since the immediate aftermath of the death of George Floyd in May +renewed a national conversation on race, yet more than half still disapprove of President Donald Trump's +response, according to a Reuters/Ipsos opinion poll." The July 27-28 poll "also showed a largely partisan +reaction to Trump's decision to deploy federal agents to quell demonstrators." According to the poll, "52% of +American adults say they are sympathetic" to the protesters, "about 12 percentage points lower than a similar +poll that ran in mid-June." The poll also "showed 54% of Americans disapprove of Trump's handling of the +protests, which is only a slight improvement from a similar poll that ran in mid-June when 58% disapproved." +AP Analysis: Trump's Focus On Crime Is A Campaign Gambit. Under the headline "As Crime Surges On His +Watch, Trump Warns Of Biden's America," the AP +(7/29, Madhani) reports the President is "painting a dystopian portrait of what Joe Biden's America might look +like, asserting crime and chaos would ravage communities should the former vice president win the White House +in November." The AP adds, "Left unsaid: A recent surge in violent crime in several American cities has +happened on his watch." According to the AP, "With echoes of Richard Nixon's law-and-order campaign in 1968 +- when American streets were rife with racial protests and Nixon campaigned vowing to crack down and restore +order in an appeal tailored to white voters - Trump is trying to energize his conservative base while also making +an appeal to a small patch of undecided voters by posing the question: Which man will keep you safer?" +Pentagon Training Course Refers To Protesters, Journalists As "Adversaries." +Politico (7/29, +Seligman, 4.29M) reports that a "new mandatory Pentagon training course aimed at preventing leaks refers to +notesters and protect sensitive iversanies n a he train senato des ared to can neededepo mense rel +low to better protect sensitive information. +Defense Secretary Esper, "as well as a July 20 memo outlining his concerns about operational security and +directing all DoD personnel - military, civilian and on-site contractors - to take the course within the next 60 +days." +UN Rights Panel Questions Police Tactics Against Protesters. + + +The New York Times (7/29, Cumming-Bruce, 18.61M) reports, "Law-enforcement authorities are obligated to protect +and facilitate peaceful demonstrations, an influential United Nations human rights panel said on Wednesday, +challenging tactics the police have used against anti-racism protests in American cities and around the world." +The UN Human Rights Committee said the international treaty "governing civil and political rights requires +states to allow peaceful demonstrations, not to block or disrupt them without a compelling reason." +Video Of NYPD Pulling Protester Into Unmarked Van Draws Criticism. +The CBS Evening News (7/29, story 8, 0:25, Muir, 7.22M) reported that "witnesses say it was excessive." +NBC Nightly News (7/29, story 5, 2:00, Holt, 5.97M) similarly said video of the arrest "has struck a raw nerve." NBC's +Gabe Gutierrez added, "The NYPD said the protester was wanted for damaging police cameras during five +separate incidents around City Hall." Fox News (7/29, Pagones, 27.59M) reports on its website that the NYPD released new video +footage that "appears to show the woman...after she allegedly damaged city-owned surveillance cameras on five +separate occasions, officials said." The woman, identified by "several social media accounts and reports," is +believed to be 18-year-old Nikki Stone. +The New York Times < https://www.nytimes.com/2020/07/28/nyregion/nypd-protester-van.html> (7/29, Zaveri, +Gold, 18.61M) reports Stone, police said, was "one of 12 protesters arrested on Tuesday," charged with "criminal +mischief and making graffiti, which are misdemeanor offenses, and released early Wednesday morning." +Whistleblower Alleges LAPD Encouraged Excessive Force And Retaliation. +The Los Angeles Times (7/29, 4.64M) reports that a "longtime +Los Angeles police SWAT sergeant is suing the LAPD, alleging the unit is run by a SWAT Mafia' of veteran +cops who encourage the use of deadly force and ostracized him for revealing its behavior." Sgt. Tim Colomey, +"who spent 11 years as a SWAT supervisor until last November, has filed a whistleblower lawsuit alleging +retaliation for revealing how a group of veteran officers controlled the tactical unit's operations and membership +and punished him and other enemies for speaking out." Colomey alleges in the suit filed Tuesday that those +leaders "glamorize the use of lethal force, and direct the promotions of officers who share the same values while +maligning the reputations of officers who do not." +Minneapolis Police Search For Man Who Incited Violent Protests. +ABC World News Tonight (7/29, Rosenthal, Mazzei, +18.61M) reports Rep. Val Demings (D-FL), a former Orlando police chief, has emerged as a finalist to be Joe +Biden's running mate, but a review of her record shows a complicated history involving police misconduct. +Crime sharply declined while Demings served as police chief, "but use of force by officers remained high." +Police misconduct cases are "also the focus of renewed scrutiny for another top contender," Sen. Kamala Harris +(D-CA), "who has been criticized for not aggressively prosecuting officers accused of wrongdoing as +California's attorney general." +Floyd Hologram To Tour US And Replace Confederate Statues. +The New York Daily News (7/29, +Braine, 2.52M) reported that a "hologram effigy" of George Floyd "will tour the US, traveling roughly along the +route of the 1961 Freedom Rides." In Richmond, Virginia, the hologram "will replace the statue of Robert E. +Lee," which protesters removed in June. +Counter-Terrorism +California Man Named As Alleged White Supremacist Leader. +The Sacramento (CA) Bee (7/29, Stanton, 567K) +reports, "The shadowy online white supremacist leader who is alleged to be a 27-year-old Orangevale man is one +of the most violent extremists in the movement today, but his unmasking may result in his followers fleeing his +influence, a researcher into American hate movements says." Andrew Richard Casarez, "who allegedly posted +online for years as the 'Vie Mackey,' the leader of a Dylann Roof-worshipping group known as the 'Bowl +Patrol,' is under investigation by the Sacramento County Sheriff's Office for alleged hate crimes and earlier this +month had a 9 mm firearm seized by detectives who obtained an emergency restraining order," but "But public +reports of his identity - first by the website Anonymous Comrades Collective on July 7 and then by the +Huffington Post a week ago - may scare off followers of the Bowl Patrol, said Cassie Miller, a senior research +analyst with the Southern Poverty Law Center." +Counter-Intelligence +Justice Department Agrees To Release FBI Texts From McCabe. +The Washington Examiner < https://www.washingtonexaminer.com/news/doj-agrees-to-release-fbi-texts-fromandrew-mccabe> (7/29, Dunleavy, 448K) reports the Justice Department has agreed "to release at least some of +fired FBI Deputy Director Andrew McCabe's text messages following a yearslong FOIA lawsuit pursued by +Judicial Watch, a conservative watchdog group." The Justice Department "told a DC federal court last week that +it had found dozens of potentially relevant texts from the FBI official who played a key role in the Trump-Russia + + +investigation and the Clinton emails investigation." DOJ lawyers "told the court and Judicial Watch that they +would need until the end of August to review the records before agreeing to a production schedule." Judicial +Watch first filed "its FOIA lawsuit for these McCabe text messages back in 2017 on behalf of retired FBI +supervisory special agent Jeffrey Danik." +FBI Memo Highlights Mystery Sources Tied To Steele Dossier. +The Daily Caller (7/29, +716K) reports an FBI memo declassified this month" led to the revelation that Igor Danchenko was the primary +source of information for dossier author Christopher Steele." Danchenko's statements to the FBI "have called +into question some of the longstanding media narratives about the sourcing for Steele's dossier." In particular "is +the role, if any, that a Belarusian-American businessman named Sergei Millian played as a source for Danchenko +and Steele." Steele "told the FBI he believed that Millian was the source of several explosive allegations in the +dossier." But Danchenko "told the FBI that he believes he may have talked to Millian just once in a brief phone +call." +Barr Says He Won't Wait Until After Election To Reveal Durham's Findings. +The Washington Post (7/29, Zapotosky, +Demirjian, 14.2M) reports Attorney General Barr "reiterated this week that he will not wait until after +November's election to release whatever US Attorney John Durham finds in his examination of the FBI's 2016 +investigation into President Trump's campaign, raising fears among Democrats that Barr and Durham could +upend the presidential race with a late revelation." Republicans have been "eagerly awaiting Durham's findings — +hopeful that the prosecutor Barr handpicked last year to investigate the investigation of possible coordination +between Trump's 2016 campaign and Russia will validate their fierce criticisms of the bureau." Democrats, +meanwhile, "have worried" that Durham is "aiding a political stunt designed to undercut an investigation that +dogged Trump's presidency." As the election draws near, both sides "have grown increasingly anxious, with +liberals fretting over an October surprise, and Republicans wondering whether Durham's work could push into +the next administration." +Collins Insists Barr Has "Every Right" To Release Durham Report Before Election. Fox News + (7/29, Kaplan, 27.59M) +reports Rep. Doug Collins (R-GA) "told 'Outnumbered Overtime' on Wednesday that Attorney General Barr has +'every right' to release the results of Durham's investigation into the Russia probe's origins before the 2020 +election." Rep. Debbie Mucarsel-Powell (D-FL) asked Barr, "Under oath, do you commit to not releasing any +report by Mr. Durham before the November election?" The attorney general responded, "No," Mucarsel-Powell +asked, "So you won't go by Department of Justice policy that you won't interfere in any political investigation +before the November election?" Barr insisted, "We won't interfere. In fact, I made it clear I'm not going to +tolerate it." +US Expands Espionage Charges Against Former Twitter Employees. +ZDNet (7129, Kwan, 299K) reports, "Fresh off dismissing spying charges against two former +Twitter employees and another individual on Tuesday, the US government has unfurled a new superseding +indictment that accuses the three individuals of even more offences." ZDNet adds, "The two former Twitter +employees, Ahmad Abouammo and Ali Alzabarah, and the third person named Ahmed Almutairi were originally + + +charged with fraudulently accessing private information and acting as illegal agents of a foreign government for +allegedly spying on Twitter users critical of the Saudi royal family. This time around, the individuals have been +charged with seven offences instead of two. The charges include acting as an agent for a foreign government +without notice to the attorney general; conspiracy to commit wire fraud; wire fraud; money laundering; +destruction, alteration, or falsification of records in federal investigations; aiding and abetting; and criminal +forfeiture." +Arkansas Professor Indicted After Allegedly Hiding China Ties To Secure NASA Grant Money +Fox News (7/29, Ruiz, +27.59M) "Federal prosecutors have secured dozens of indictments on wire and passport fraud charges against a +University of Arkansas professor who allegedly hid ties to China to obtain NASA grant money. Investigators +arrested 63-year-old Simon Saw-Teong Ang in May on a single charge of wire fraud for allegedly hiding his ties +to the Chinese government and Chinese businesses while receiving federal grant money. Now the Fayetteville, +Ark. resident faces 42 counts of wire fraud and two counts of passport fraud after a grand jury indictment, the +Justice Department (DOJ) announced Wednesday." +The AP (7/29, Adame, 307K) reports, "Simon Ang "knowingly made materially fraudulent +misrepresentations and omissions' on a 2016 NASA grant application and a 2017 U.S. Air Force grant +application submitted by Ozark Integrated Circuits, Inc., states an indietment entered into the case record +Wednesday. The fraud led to wire transfers to University of Arkansas, Fayetteville accounts, the indictment +states. Additionally, Ang, a Fayetteville resident, faces two counts of making a false statement in applying for a +passport." The indictment "alleges that Ang failed to disclose participation in Chinese talents plans,' described +as 'a Chinese government national strategy' that involves the recruitment of experts from around the world." +US Officials Claim Russia Is Behind Coronavirus Disinformation Campaign. +The AP (7/29, Tucker, Litvinova) reports that +anonymous US officials "say Russian intelligence officers are spreading disinformation about the coronavirus +pandemic through English-language websites." According to the AP, the officials claim "two Russians who have +held senior roles in Moscow's military intelligence service known as the GRU have been identified as +responsible for a disinformation effort meant to reach American and Western audiences." +Trump Says He Did Not Raise Taliban Bounties Allegations In Call With Putin. +Ben Tracy reported on the CBS Evening News + (7/29, story 4, +0:20, O'Donnell, 4.28M) that President Trump "admits" that "he did not mention US intelligence suggesting +Russia paid Taliban-linked fighters to kill American troops in Afghanistan" when he talked with Russian + + +President Vladimir Putin last week. Trump said, "Frankly, that's an issue that many people said was fake news." +Terry Moran reported on ABC World News Tonight +(7/29, story 5, +2:20, Muir, 7.22M) that Trump said in an interview with Axios, "I have never discussed it with him, no." He +added, "if it reached my desk, I would have done something about it. It never reached my desk." +Reuters (7/29) reports that in an interview for "Axios on HBO," +President Trump "said he never questioned Russian leader Vladimir Putin about U.S. intelligence reports that +Moscow paid the Taliban to kill American troops in Afghanistan." According to Reuters, Trump previously "has +called the reports a hoax and casts doubt on them." The Daily Beast https://www.thedailybeast.com/trumpadmits-hes-never-mentioned-bounties-to-putin-because-he-thinks-its-fake-news> (7/29, 1.39M) reports that +"asked why he skirted the issue with Putin last week," Trump replied: "That was a phone call to discuss other +things, and frankly that's an issue that many people said was fake news." +Politico (7/29, Forgey, +4.29M) quotes the President as saying, "I think a lot of people. If you look at some of the wonderful folks from +the Bush administration, some of them, not any friends of mine, were saying that it's a fake issue, but a lot of +people said it's a fake issue." According to Politico, Trump "did not identify which officials from former +President George W. Bush's administration had spoken dismissively of the alleged Russian bounties, but he told +reporters outside the White House on Wednesday that former Secretary of State Colin Powell 'says it's not +true."" Politico says Powell "criticized the media's initial reaction to the bounty story earlier this month, telling +MSNBC that our military commanders on the ground did not think that it was as serious a problem as the +newspapers were reporting and television was reporting."" +The New York Times (7/29, +Crowley, 18.61M) reports that the President "said the purpose of last week's call with Mr. Putin was "to discuss +nuclear proliferation, calling that issue 'a much bigger problem than global warming."" Axios + (7/29, Swan, Lawler, 521K) reports that Trump "has spoken to Putin at least eight times +since intelligence about the alleged Russian bounties was reportedly included in the President's Daily Brief - his +written intelligence briefing - in late February." Axios adds, "Trump's team says he was not verbally briefed on +the matter before a June 26 report from the New York Times brought the controversy out into the open." +According to Axios, 'There's no clear consensus within the intelligence community about the strength of the +evidence that Russia paid the bounties." +The Washington Post (7/29, +Wagner, 14.2M) says "some of Trump's own senior intelligence officials viewed the information as credible +enough to warn the Pentagon and allies so they could ensure they had measures in place to protect their forces in +Afghanistan and to begin developing options for responding to such a Russian operation, national security +adviser Robert C. O'Brien said earlier in the month." +CNBC (7/29, Breuninger, Mangan, 3.62M) reports that Joe Biden's campaign "blasted...Trump's +conduct as 'absolutely despicable' after Trump said he did not ask...Putin about alleged Russian bounties on U.S. +troops in Afghanistan." Andrew Bates, a spokesman for Biden, in a statement said, "Months after the U.S. +intelligence community sounded the alarm — to Donald Trump and to our allies - that Russia was placing +bounties on the heads of American servicemen and women in a war zone, our president continues to turn his +back on those who put their lives on the line for our country, and on his own duty. This continues an indefensible +pattern of Donald Trump weakening the United States in the world in a manner that no American president ever +has before, and it's absolutely despicable." USA Today + (7/29, Jackson, 10.31M) reports Democratic opponent Joe Biden and others "say Trump + + +is too chummy with the Russian autocrat, and has refused to confront him on matters ranging from Russian +interference in the 2016 presidential election to the allegations over bounties." +Bloomberg (7/29, Egkolfopoulou, 4.73M) reports Biden spokesman Andrew Bates said in a +statement, "The most critical and sacred obligation of a commander-in-chief is to protect those who serve our +nation in harm's way. But months after the U.S. intelligence community sounded the alarm - to Donald Trump +and to our allies - that Russia was placing bounties on the heads of American servicemen and women in a war +zone, our president continues to turn his back on those who put their lives on the line for our country, and on his +own duty." Also reporting on the story is Reuters < https://www.reuters.com/article/us-usa-afghanistan-russiatrump/trump-says-if-russian-bounty-reports-were-true-he-would-be-angry-about-it-idUSKCN24U275> (7/29). +House Panel Votes To Give All Members Access To Classified Intelligence On Foreign "Disinformation" +Campaign. +CNN (7/29, +Herb, Cohen, Raju, 83.16M) reports Democratic congressional leaders "sent FBI Director Wray a letter urging +an FBI briefing to all lawmakers about the foreign interference efforts." Sources "told CNN the Democrats' +classified addendum included concerns about a Russian-linked "disinformation' campaign to target former Vice +President Joe Biden in the 2020 election, including that information from entities with ties to Russia was being +provided to Senate Homeland Security Chairman Ron Johnson, who is leading an investigation into Biden." +Democrats have not "publicly explained the material they shared with the FBI." The Intelligence Committee +"voted behind closed doors to make the classified addendum available to any House member who requests it." +The vote was "along party lines, with Republicans opposed," according to two sources familiar with the matter. +Republicans have "dismissed the Democratic complaints as a partisan attack, and Johnson has denied receiving +disinformation from foreigners." +The Hill (7/29, Miller, 2.98M) reports the evidence, "compiled in a 'classified addendum,' was +submitted to the FBI earlier this month by Speaker Nancy Pelosi (D-CA), Senate Minority Leader Charles +Schumer (D-NY), House Intelligence Committee Chairman Adam Schiff (D-CA), and Senate Intelligence +Committee Vice Chair Mark Warner (D-VA)." The Democratic leaders "pointed to it in requesting an immediate +all-members classified briefing from the FBI on election threats." Schiff "said in a statement Wednesday that the +evidence, which had previously been available to view only for members of the House Intelligence Committee, +was being made public for all House lawmakers in response to multiple requests." +"Gang Of Eight" At Odds Over Releasing Information On Election Interference. +Politico (7/29, +Desiderio, Bertrand, 4.29M) reports that the "Gang of Eight" congressional leaders "responsible for reviewing +the nation's most closely held secrets is engaged in an unusual and bitter partisan fight over how much +information to share with the public about election interference." The "public spat" is "highly unusual for the +group, whose obligations normally rise above the political fray and rarely descend publicly into the partisan +squabbles that define Capitol Hill." Politico adds, "The in-fighting has intensified so rapidly" that Senate +Intelligence Chairman Marco Rubio "even suggested this week that his committee's annual hearing on global +threats might not go on as planned, citing 'heavy politicization.'" +Federalist: Schiff Seeks To Start Another Russian Interference Probe. + + +The Federalist (7/29, Davis, 126K) reports that House Intelligence Chairman Adam +Schiff "is once again assisting and amplifying a foreign influence operation meant to divide Congress and the +American people, multiple lawmakers told The Federalist on Wednesday. Schiff called a surprise hearing of his +committee Wednesday "to vote on making Schiff's classified allegations against congressional Republicans +available for review to the entire House of Representatives. The vote passed on party lines. At issue is a packet of +information that was allegedly sent to several Republicans by Ukrainian politician Andriy Derkach." Derkach +"told Politico last week that his goal was to "creat[e] an inter-parliamentary association called "Friends of +Ukraine STOP Corruption."" Derkach "said he sent the same materials to several Democrats as well." +Brennan Memoir Says Trump Denied Him Access To Documents And Notes. +The Washington Post (7/29, Harris, 14.2M) reports that when former CIA director John Brennan decided to +write a memoir in the fall of 2018, "he asked the agency for his official records, including his notes and any +documents that he had reviewed and signed that were classified." But the request was denied in "a break with +decades of tradition." Brennan "learned that the CIA was following the orders of the man he had spent the +previous two years publicly excoriating." In his memoir, Brennan writes that Trump "had issued a directive... that +purportedly forbids anyone in the intelligence community from sharing classified information with me." +Brennan's book, "Undaunted: My Fight Against America's Enemies, at Home and Abroad," is "scheduled to be +published on Oct. 6." +NBC News (7/29, 6.14M) reports that, "in the book, Brennan said he'd been trying for +months to get a hold of his records and notes, but kept running into brick walls." The Post quoted the book "as +saying Trump 'had issued a directive ... that purportedly forbids anyone in the intelligence community from +sharing classified information with me' in August of 2018." +The Hill (7/29, Moreno, 2.98M) reports Mark Zaid, an attorney "who has represented +government whistleblowers and former intelligence agency employees who have gone on to write memoirs, told +the Post that the blocking of the records was 'unprecedented, as far as I know.""' He said, "This is demonstrative, +once again, of a vindictive, political president whose actions have nothing to do with actual national security +decisions." +The Washington Examiner < https://www.washingtonexaminer.com/news/john-brennan-blocked-from-accessingclassified-information> (7/29, Chaitin, 448K) reports the White House "confirmed the directive was being +enforced, which is news considering the New York Times reported in May of last year that the president never +revoked Brennan's security clearance." +Brennan Book Says McConnell, Nunes Were Silent In Face Of Evidence Of Russian Election Meddling. The +New York Times (7/29, Barnes, +18.61M) reports that in the waning days of the Obama Administration as "intelligence officials laid out evidence +of Russia's 2016 election interference campaign to congressional leaders," some congressional leaders called for +Russia to be punished, but Senate Majority Leader McConnell and then-House intelligence Chairman Nunes +"remained silent," according to Brennan's book. Brennan writes, "I was not surprised that McConnell and +Nunes, early and ardent partisan defenders of Mr. Trump, were silent in the face of what everyone else +recognized was a clear national security threat." + + +FireEye Reports New Disinformation Campaign From Eastern Europe. +Business Insider (7/29, Elder, 3.67M) reports that researchers with cybersecurity firm FireEye "have discovered a +sophisticated disinformation campaign originating in Eastern Europe that they believe could be aimed at +disrupting the 2020 US election." BI adds that "bad actors are hacking media websites to post fraudulent stories, +creating fake journalist personas, and spreading anti-US disinformation, researchers from FireEye warned +Wednesday. The tacties are reminiscent of Russian meddling around the 2016 election - but are significantly +more sophisticated, researchers say." +New Study Warns Germany is Emerging As Key Target For Russia, China Interference. +Fox News (7/29, Norman, 27.59M) +reports a UK-based think tank is "warning Germany is now on the frontline of a new Cold War" as it has +become a key target for Chinese and Russian interference." The declaration made in "a report released +Wednesday by the Royal United Services Institute - which studies international security and defense - comes as +Germany is preparing for a federal election next year." John Kampfner, a senior associate fellow at RUSI and +author of the report, said, "Russia's activities are largely political, attempting to undermine public confidence in +democratic institutions. China's have been focused mainly on economic assets." The report "adds that the +combination has put Germany 'on the frontline of a new Cold War."" In his writing, Kampfner "says the threats +Germany faces from Russia are mostly linked to cybersecurity." +Business Insider (7/29, Payne, 3.67M) reports the report by the London-based defence think tank +"comes as the White House formally announced that it will pull out thousands of troops from Germany." It +suggests that the "Kremlin is waging a campaign of political interference in the country, focused on creating +instability in the region." The threat from Russia "comes as Beijing also focuses on expanding its own influence +in Germany, posing 'a series of political and economic-based hazards emanating from China."" +Op-Ed: The US-China Consulate Closures May Impact Espionage. +In a commentary in Axios (7/29, 521K), Zach Dorfman of the Aspen Institute writes, "A decision last +week by the Trump Administration to shutter the Chinese consulate in Houston over allegations that China used +it for spying set off a predictable diplomatic firestorm." He contends, "The Trump Administration's moves +against Russia's diplomatic facilities in San Francisco and Seattle were carefully calibrated reactions to major +normative violations of US and UK sovereignty. But the rationale for the Houston closure rests on far murkier +grounds... The Houston closure may have been designed to send a general warning to China about Beijing's +ubiquitous spying, and Houston may have been selected precisely because it is such a low-profile facility." He +concludes, "There are also potential costs to the US' actions. For instance, we don't know what the CIA thinks of +the move... The Trump Administration let politics...eclipse the prerogatives of national security." +Op-Ed: US Intelligence Community Needs To Keep Up Pressure On China's Spying. +In an op-ed on the Fox News (7/29, +27.59M) website, Daniel Hoffman writes, "Having served as CIA director, Pompeo understands well how the +exposure of increasingly brazen Chinese cloak and dagger espionage on US soil could be a bellwether for a 21st + + +century Cold War... Espionage has been a critically important tool, on which General Secretary Xi has relied to +project power abroad and exercise Orwellian big brother control over China's population at home." He contends, +"Countering Chinese espionage is of the highest priority for US national security as it should be for so many +other nations also under siege from Chinese spying." He concludes, "Pompeo's speech was therefore a call for +our IC to keep up the pressure on China by uncloaking and disrupting Chinese spying operations both +unilaterally and in close partnership with our allies." +Criminal Investigations +Judge Denies Ghislaine Maxwell's Bid To Keep Records Sealed. +McClatchy (7/29, Hall, Wieder, 19K) +reports, "A federal judge late Wednesday rejected an attempt by lawyers for Ghislaine Maxwell, the British +socialite accused of being a sex trafficker and alleged madam for Jeffrey Epstein, to block the unsealing and +release of potentially embarrassing documents from a settled defamation suit." The Herald adds, "Hours before +the start of their scheduled unsealing on Thursday morning, Maxwell's lawyers filed a motion to reconsider +before U.S. District Judge Loretta Preska, challenging her July 23 decision to order the unsealing and release of +documents in a 2015 civil lawsuit that included a deposition given by Maxwell in the case brought by Epstein +accuser Virginia Giuffre. Less than three hours later, Preska denied it, citing 'eleventh-hour request for +reconsideration.' She allowed Maxwell's attorneys two days to seek a stay from an appeals court on two key +depositions but otherwise ordered the unsealing of other documents to begin Thursday." +The Washington Post (7/29, Jacobs, 14.2M) +reports that Maxwell's attorneys "asked a federal judge Wednesday to block the planned unsealing of depositions +she gave as part of a lawsuit, alleging the transcripts were leaked illegally to prosecutors seeking her conviction." +Judge Preska "gave Maxwell's lawyers until Friday to appeal" her Wednesday ruling. The Post adds, 'In his +letter to Preska, Maxwell's lawyer Ty Gee argued that a protective order prevented the deposition transcripts +from being made available to anyone, including law enforcement, and that releasing the documents could +jeopardize Maxwell's ability to have a fair trial. Preska said the potential for Maxwell to be indicted has been +looming throughout discussions as to what to unseal, and was considered in her rulings. It was not a new issue +requiring additional litigation, the judge wrote." +Mississippi Man Charged With Shooting Federal Agent Appears In Court. +WDBD-TV Jackson, MS (7/29, Knowles) reports from Gulfport, Mississippi, "Wearing a red and white +striped jumpsuit, the man accused of shooting a task force agent last week in Gautier appeared in federal court +Wednesday morning." WDBD-TV adds, "Before the preliminary hearing began, Joseph Sonnier could be seen +whispering to his mom, telling her he loved her. Only one witness took the stand during the hearing, a FBI agent +who recounted the events of July 21, 2020, when Sonnier allegedly fired two shots at U.S. marshals who were +attempting to arrest him." Sonnier "admitted to authorities that he knew there were multiple officers outside the +hotel room at the Siegel Select in Gautier when he fired his weapon towards them, said the FBI agent. The +remaining officers then returned fire. According to the affidavit, Sonnier said he was trying to commit suicide +and hoped the officers would kill him." +US Probing Shipments Of Mysterious Seeds. + + +VTDigger (VT) (7/29, 4K) reports, "State and federal authorities are investigating 'hundreds' of complaints from +Vermonters who have received mysterious seeds from China without asking for them." Cary Giguere, "the +agricultural resource management section chief for the Vermont Agency of Agriculture, said this mysterious seed +spreading is not unique to Vermont, as people in at least 30 states have reported similar occurrences," but +"recently, the agency has received hundreds of complaints from Vermonters through its online system. "Over the +last few months and more so in the last week, folks all over the country have been receiving packages unsolicited +originating from China,' Giguere said. 'Now in Vermont, there are hundreds of reports of folks being sent seeds +unsolicited."" Giguere "said that he's been working primarily with the USDA as well as Customs and Border +Protection, the FBI and the Department of Homeland Security." +Suspected Illinois Serial Killer Charged In Connection To 1997 Murder. +The Lake County (IL) News-Sun (7/30, Olson, 1.75M) reports +suspected senal Killer Samuel Wilham Legg Ill, who was arrested in January 2019, has been charged in +connection to the death of Julie A Konkol, whose body was found in Lake County in 1997. The FBI CODIS +database "linked DNA collected from Konkol's homicide" to other murders connected to Legg. +WLS-TV Chicago +(7/29, 391K) reports Legg "is charged with two counts of first-degree murder for the death of 39-year-old Julie +A. Konkol." +Also reporting are Deerfield (IL) Patch (7/29, 1.03M)Chicago (IL) Sun-Times + (7/29, 875K), and Lake County (IL) News-Sun + (7/29, 1.75M). +Reputed Leader Of Chicago Gang Among Several Charged In Gun, Drug Probe. +Fox News (7/29, Casiano, 27.59M) reports, "The alleged leader of a Chicago street +gang whose nickname is 'Murder" is among 23 suspects charged with federal gun and drug offenses after a +years-long investigation, authorities said Wednesday." Darnell "Murder" McMiller, 34, "is described as the +leader of the Black Disciples, one of the city's largest gangs. Several other alleged high-ranking members were +also charged, including members of the gang's 'Dog Pound' faction." Clarence January, 27, "allegedly leads the +subset. He is charged with trafficking three handguns." Kenneth Brown, 59, "supplied the gang drugs to be +distributed throughout the city and Charles Knight supplied drugs to McMiller's crew, the Justice Department +said. Brown is charged with conspiring with Terrence Morris, 48, to distribute heroin in March 2019, according +to a criminal complaint." +New York Pastor Arrested For Minor Solicitation. +The New York Daily News (7/29, Feuerherd, 4.57M) reports Hughes "was busted after the FBI executed a search warrant on the +teen's phone and found the texts." It is unknown how the agents "were first tipped off." +Massachusetts Men Charged In Connection To Shooting. +The Springfield (MA) Republican (7/29, 395K) reports that Holyoke police +"arrested two men who were on probation for other crimes and confiscated two unlawful guns after a shooting +where gunfire went through windows of at least three apartments." Jose Cruz "was charged with assault and +battery with a handgun; receiving stolen property, a handgun; possession of a firearm and ammunition without a +permit; discharging a firearm within 500 feet of a dwelling and on two warrants," while Hector Diaz-Torres "was +charged with possession of ammunition without a permit and on a warrant. A 15-year-old was also arrested in the +shooting and charged with possession of ammunition without a permit and on two warrants." +FBI Agents Searching Boston's North End Neighborhood. +The Boston Globe (7/29, 972K) reports that FBI agents searched Wednesday the North End apartment of Trevor Lucas, +who "spent years in prison for seeking revenge on a Wisconsin teenager he met through the online video game +*World of Warcraft.*" FBI spokeswoman Kristen Setera said, "The FBI's Violent Crimes Task Force and our +Evidence Response Team, along with the Boston Police Department are conducting court-authorized activity in +connection with an ongoing federal investigation." She continued, "There is no threat to public safety. Due to the +ongoing investigation, we're going to decline further comment." +Also reporting are the Boston Herald (7/29, 410K) and WBZ-TV Boston (7/29, 92K). +FBI Investigating New Mexico Cold Case. +KOB-TV Albuquerque, NM (7/29, 51K) reports that the Sandoval County Sheriff's +Office and the FBI "are asking for help in solving a 45-year-old cold case," which dates back to 1975. The +victim, Mary Sparks, "was found dead in a drainage ditch." Investigators seek to leverage FBI DNA tools to +solve the case. +KRQE-TV Albuquerque, NM (7/29, 35K) reports FBI agent Jim Langenberg said, "We're going to work +together to develop leads, follow up on tips, use the new technology to our disposal and hopefully as the sheriff +said, bring closure to the family and the individual responsible for this to justice." +KOAT-TV +Albuquerque, NM (7/29, Laflin, 81K) also reports. + + +FBI Investigating Serial Bank Robber In Illinois. +The Niles-Morton Grove (IL) Patch (7/29, 1.03M) reports that the FBI is investigating a series of bank robberies in Illinois. The agency +"released video images from several of the robberies," and they said that the suspect "is described as 5-foot, 11- +inches, thin build, with black hair, a light complexion, and between the ages of 40 and 50." +Continuing Coverage: Missouri Men Charged In Connection To Kidnapping. +KSNF-TV Joplin, MO (7/29) reports Freddie Tilton and Alvin Dale Boyer "were +charged in federal court [Wednesday] for kidnapping a woman who was rescued from her attackers at a Neosho, +Missouri, hotel room." The criminal complaint "alleges that Tilton and Boyer kidnapped the victim, identified in +court documents as "S.T.," on July 19, 2020." +Alabama Pair Indicted In Connection To Murder Of Child. +Birmingham (AL) News (7/29, 894K) reports that the Northern District of +Alabama U.S. Attorney's Office and the FBI on Wednesday "announced the indictments against Patrick +Stallworth, 40, and Derick Irisha Brown, 29," who "are each charged with count of kidnapping and one count of +conspiracy to kidnap a minor." They "are charged with capital murder of a child under the age of 14 in state +court for the 2019 slaying of 3-year-old Kamille 'Cupcake' McKinney and, if convicted, could face the death +penalty." +New York Man Charged With Sex Trafficking Of A Minor. +The Glens Falls (NY) Post-Star (7/29, +114K) reports Timothy J. Bush "is accused of offering to pay a woman $100 to have sex with her 11-year-old +daughter," but the woman was an undercover FBI agent. He "faces a maximum sentence of life in prison, a +mandatory minimum sentence of 15 years, and at least 5 years of supervised release." +Florida Judge Announces Delay In Bribery Trial. +The Tallahassee (FL) Democrat < https://www.tallahassee.com/story/news/local/fbi/2020/07/29/judge-hinklepushes-back-tentative-j-t-burnette-trial-date-2021/5534715002/> (7/29, 180K) reports US District Judge Robert +Hinkle "decided to push back the tentative trial date for J.T. Burnette, one of ex-City Commissioner Scott +Maddox's co-defendants, until early next year." Burnette "was indicted for the FBI's long-running public +corruption probe." +Reputed Nevada Boogaloo Faces New Child Sex Charge. + + +The Las Vegas Review-Journal (7/29, Kane, 345K) reports, "Suspected boogaloo member +Stephen Parshall has been aceused of sexually exploiting his teenage stepdaughter in a new federal criminal +complaint filed Wednesday." Parshall, 36, "who has been indicted in an alleged right-wing conspiracy to commit +violence in Black Lives Matter protests, was charged with one felony count of sexual exploitation of children. +The federal complaint, filed by the Nevada U.S attorney's office, alleges the abuse began on an unknown date +and continued until May 30, 2020, the day Parshall was arrested by FBI agents in the alleged extremist terror +plot. This follows a state sex abuse case filed against Parshall earlier this month related to the stepdaughter." +KTNV-TV Las Vegas (7/30, Gartner, 78K) reports, "Parshall was charged last month with violations of +federal and state law for conspiracy to cause destruction during protests in Las Vegas, and possession of an +unregistered destructive device (specifically, an improvised incendiary device known as a Molotov cocktail). +Wednesday's charge was announced by U.S. Attorney Nicholas A. Trutanich for the District of Nevada, Special +Agent in Charge Aaron C. Rouse of the FBI, and Sheriff Joseph Lombardo of the Las Vegas Metropolitan Police +Department." +Financial Crime & Corporate Scandals +California Financier Sentenced In College Admissions Probe. +The Los Angeles Times (7/29, Ormseth, 4.64M) reports, "Manuel +Henriquez, who led a venture capital firm before being charged with paying $450,000 to rig his daughters' +college entrance exams and bribe a coach at Georgetown University, was sentenced Wednesday to six months in +prison." US District Judge Nathaniel M. Gorton, "ruling from Boston in a video conference, went beyond the +five-month sentence requested by prosecutors, saying Henriquez's "despicable' crimes made the financier, whose +lawyers had lauded his support of children's charities, 'not only a felon, but a hypocrite."" Judge Gorton "had +previously sentenced Henriquez's wife, Elizabeth, to seven months in prison. In court papers filed before Manuel +Henriquez was sentenced, prosecutors said he was a 'less active participant in the mechanics of the fraud' than +his wife, who 'gloated' after a Harvard-educated conspirator supplied her daughter with the answers to her SAT +exam." +Tennessee Lawmaker Charged With Stealing Federal Funds. +The AP (7/29, Sainz) reports, "A Tennessee state +senator has been charged with stealing more than $600,000 federal funds received by a health care company she +directed and using the money to pay for her wedding and other personal expenses, federal prosecutors said +Wednesday." State Sen. Katrina Robinson faces charges of "theft and embezzlement involving government +programs and wire fraud, U.S. Attorney D. Michael Dunavant said in a news release." Robinson is also the +director of The Healthcare Institute, which "received more than $2.2 million in federal grants from the U.S. +Department of Health and Human Services." +The Memphis (TN) Commercial Appeal + (7/29, Kennedy, 338K) reports, "A criminal complaint filed in U.S. +District Court alleges Robinson used federal grant money issued to her for-profit nursing college to buy a vehicle + + +for her daughter, expenses related to her wedding and honeymoon, and legal fees for her divorce. She is also +accused of using the grant money to pay off credit cards and student loan payments, purchase beauty products +and fund a campaign event." WHBQ-TV Memphis, +TN (7/29, 23K) also reports. +Texas Bank Reports $13.2M "Ponzi-Style Fraud." +The San Antonio Express-News (7/29, Danner, 762K) reports, "The Bank of San Antonio disclosed" on +Wednesday "that it uncovered a $13.2 million 'Ponzi-style fraud scheme" involving a former employee of a +subsidiary who induced the bank to purchase worthless accounts receivable from various businesses." The +Express-News adds, "Bank officials alerted the FBI in May and said in a statement they expect to recoup all +losses from the alleged scheme. The bank and its subsidiary, Texas Express Funding LLC, Tuesday sued the +former employee, five other individuals and four entities for fraud, civil conspiracy and other claims. The suit, +filed in Comal County, seeks unspecified punitive damages." +US Charges New Jersey Family With Contracting Fraud. +Jersey Shore Online (NJ) (7/29, Lundy) reports from Jackson, New Jersey, "The family who own Monmouth Marine +has been charged with selling cheap substitutions to the Navy while billing the federal government for the more +expensive parts." Linda Mika, 69, and Paul Mika, 73, both of Jackson, New Jersey, and Kenneth Mika, 49, of +Ewing, New Jersey "were arrested on July 29, U.S. Attorney Craig Carpenito announced. They allegedly ran a +years-long scheme to defraud the U.S. Department of Defense, the charge stated." The family "allegedly lied to +the government, saying they would be able to provide exact products made by authorized manufacturers. Instead, +they sourced non-conforming substitute parts at a significantly reduced cost to themselves, while still billing the +government for the better quality items." +Former Ohio Public Official Sentenced For Bribery. +Dayton 24/7 Now (7/29, Richardson) reports former Dayton Minority Business Assistance Center director +RoShawn Winburn "was sentenced [Wednesday] to six months in prison for a conviction related to a 2019 +bribery investigation." He "took cash payments of more than $6,500 in exchange for city documents that were +restricted to the public." +WDTN-TV Dayton, OH (7/29, 15K) reports Winburn will "report to prison once the Ohio +Department of Rehabilitation and Corrections determines they have enough space to safely hold him." +Federal Prosecutors: Former Uber Engineer Should Get 27 Months In Prison. +Bloomberg (7/28, Rosenblatt, 4.73M) reports federal prosecutors told a judge that "Anthony Levandowski, the +autonomous-driving engineer who agreed to plead guilty to stealing trade secrets from Google, should spend 27 + + +months in prison, prosecutors say" and that his "punishment is an important lesson for Silicon Valley." The +article explains that Uber "recruited Levandowski from Google to run its self-driving project, and later fired him +while the company was fighting a lawsuit by Alphabet Inc.'s Waymo over allegations similar to those in the +criminal case." +Avenatti Cannot Afford To Pay Lawyer. +The Washington Times (7/29, Dinan, 492K) reports attorney Michael Avenatti, "who used to dominate cable +news shows with his threats to take down President Trump, is now so poor that he was awarded a courtappointed lawyer Wednesday. A federal judge overseeing one of three federal criminal cases against him said he +has established his "current indigency,'" so his lawyer will be paid for by the public. +Former Maryland Lawmaker Sentenced To Two Years In Prison For Bribery. +The AP (7/29, Kunzelman) reports from Silver Spring, Maryland, "A former state lawmaker who helped +create Maryland's medical marijuana industry was sentenced on Wednesday to two years in prison for taking +bribes for legislative favors, including votes to benefit a medical marijuana company." Cheryl Glenn (D), "who +represented parts of Baltimore as a state delegate, told U.S. District Judge Catherine Blake that she is +"profoundly remorseful' and hopes other public officials can learn from her mistakes." Judge Blake "The judge +said Glenn, 69, sold her office to pay her bills and tried to cover up her corruption. "This was not a one-time +lapse. It was not a momentary giving in to temptation. It was a deliberate scheme to take advantage of her +political power and misuse her influence and to break the public trust in exchange for money,' Blake said. Glenn +must report to prison by Sept. 21. The judge also ordered her to pay $18,750 in restitution." +Cyber Division +Cybersecurity Firm: Chinese State-Backed Hackers Infiltrated Vatican. +The Washington Post +(7129, Harlan, Pitrelli, 14.2M) reports cybersecurity firm Recorded Future said that Chinese state-backed hacking +group RedDelta "targeted and infiltrated the Vatican this year" in a move "likely aimed at gaining an advantage +in diplomatic negotiations" as the Vatican and Beijing are considering extending "a controversial agreement on +the process of appointing Catholic bishops in China." The Post casts the intrusion as part of a pattern of Chinese +hackers monitoring the activities of religious groups. The Wall Street Journal + (7/29, Rocca, Xiao, Subscription Publication, 7.57M) reports a US cybersecurity firm determined +a Chinese group backed by the government hacked into Vatican computers prior to key negotiations with +Beijing. The alleged breaches occurred as the Holy See and Beijing began to negotiate the renewal of deal +regarding the appointment of Catholic bishops in China. Originally reached in 2018, the agreement was the most +significant rapprochement between Beijing and the Holy See diplomatic relations were cut in 1951. +TikTok Dismisses Senate Concerns Over Chinese Threat To Election Security. + + +The Washington Times (7/29, Lovelace, 492K) reports seven Republican senators "wrote to the heads of the FBI, +DHS, and ODNI to determine whether China is using TikTok to interfere in the 2020 election." TikTok "says +nobody needs to worry." Sens. Tom Cotton (R-AR), Ted Cruz (R-TX), Kevin Cramer (R-ND), Joni Ernst (R-IA), +Marco Rubio (R-FL), Rick Scott (R-FL) and Thom Tillis (R-NC) "want the federal government to determine +whether the Chinese-owned TikTok is enabling Chinese government influence operations and censorship of US +political content." The senators wrote on Tuesday, "TikTok has become a popular forum for Americansparticularly younger Americans-to engage in political conversations. We are greatly concerned that the [Chinese +Communist Party] could use its control over TikTok to distort or manipulate these conversations to sow discord +among Americans and to achieve its preferred political outcomes." +Mnuchin: TikTok Under CFIUS Review. On Wednesday, Reuters (7/29, Alper, Chiacu) reports, Treasury Secretary Mnuchin said that Tik Tok was under a +security review "and that his agency would make a recommendation to the president about the popular Chineseowned video-sharing app this week." Acknowledging for the first time that TikTok was under review, Mnuchin +said, "TikTok is under CFIUS review. We will be making a recommendation to the president this week so we +have lots of alternatives." +CNBC (7/29, Feiner, +Macias, 3.62M) reports that Mnuchin made the remarks at a White House event with President Trump. The +President commented, "We are looking at TikTok. We are thinking about making a decision." +Cybercrime Ramps Up Amid Coronavirus Chaos, Costing Companies Billions. +CNBC (7/29, Sheng, 3.62M) reports data breaches are "always costly but have become even more of an +issue in recent months as cybercriminals ramped up to take advantage of coronavirus confusion." According to a +new study from cloud computing company Tomart, "large-scale breaches are growing in intensity and frequency +in 2020, with the number of breaches increasing 273% in the first quarter, compared to the same time last year." +CISA Announces Second President's Cup Cybersecurity Competition. +MeriTalk (7/29, Polit) reports the Cybersecurity and Infrastructure Security Agency (CISA) announced July +28 "the second annual President's Cup Cybersecurity Competition." Registration is open to any Federal +Executive branch employee, includingDOD and uniformed service members, with a knack for cybersecurity." +CISA Director Chris Krebs said, "The Federal cybersecurity workforce is a strategic asset that protects our +citizens, homeland, and the American way of life. CISA is proud and excited to lead the second annual +President's Cup Cybersecurity Competition to measure the knowledge, skills, and abilities of the diverse +cybersecurity talent within government." The competition was "born out of a May 2019 Executive Order, which +called for an annual interagency effort to 'identify, challenge, and reward the government's best personnel +supporting cybersecurity and cyber excellence."" +Experts Warn Medical Devices May Create Additional Opportunities For Hackers To Target Hospitals. +Modern Healthcare (7/29, Cohen, Subscription Publication, 214K) reports, "As COVID-19 swept the US, +providers rapidly added web-connected equipment to increase patient data collection while minimizing touch +points." However, "the technology may open hospitals up new vulnerabilities." Although "data breaches often +stem from hacks on email accounts, electronic medical records and other digital repositories," cybersecurity +experts warn that "medical devices create additional access points that hackers could target to enter a hospital's +network and steal data." +International Relations +China Denies Harboring 1MDB Fugitive. +Reuters (7/29) reports, "China on Wednesday denied protecting fugitive financier Low Taek +Jho, being sought by global investigators over his role in the multi-billion dollar 1MDB scandal." Low, +"popularly known as Jho Low, has been charged in Malaysia and the United States over allegations that he +orchestrated the theft of $4.5 billion from state fund Malaysia Development Berhad (IMDB), co-founded by +former prime minister Najib Razak. Low has consistently denied wrongdoing." Reuters adds, "Malaysia's +national police chief Abdul Hamid Bador was reported by newspaper Utusan Malaysia as saying Low was hiding +in Macau and that attempts to extradite him had failed as Chinese authorities 'appeared insincere' in their efforts +to cooperate. Chinese authorities rejected the accusations as 'groundless and unacceptable', saying that police +had investigated all possible leads but were unable to trace Low." +Other FBI News +Trump Defends Use Of COVID-19 Bill To Fund New FBI HQ. +Reuters (7/29) reports that President Trump on Wednesday +"defended his push to use a coronavirus relief package to fund a new FBI headquarters near his Washington hotel +despite opposition from fellow Republicans, citing his background as a real estate developer." The bill, "facing +tense negotiations in the Senate before multiple provisions aimed at helping Americans stave off financial losses +amid the coronavirus pandemic expire on Friday, is on shaky ground with the White House at odds with both +Democrats and Trump's own Republicans, who control the chamber." Trump "at first did not directly answer a +question about whether he would drop his demand for $1.8 billion to fund a new FBI headquarters in downtown +Washington one block from Trump International Hotel. He later said the provision "should stay.' 'Republicans +should go back to school and learn,' he told reporters at the White House. 'I'm very good at real estate." +The Hill (7/29, +Klein, 83.16M) reports, "White House press secretary Kayleigh McEnany was pressed Wednesday on why a +coronavirus stimulus bill includes $1.75 billion for a new FBI building. "So, this was part of the President's +priority of updating the FBI building, keeping it in DC, and it's been one of the things that's been mentioned +that's in this bill and it's a part of one of the President's priorities and it's been a priority for several months, she +said during an appearance on CBS News. Asked again what that provision was doing in the coronavirus bill, +McEnany couldn't say, but said it is 'not a dealbreaker." Trump "said later Wednesday" that "he thought it was +"crazy' that they would consider moving it to the suburbs of Virginia or Maryland." +The Hill (7/29, Chalfant, 2.98M) reports, +"Trump said proposals to move the FBI building to +Maryland or Virginia would have taken the bureau too far away from the Justice Department in downtown +Washington, D.C." +Fox News (7/29, Phillips, 27.59M) quotes Trump as saying, "I said, +'Let's build a new FBI building, either a renovation of the existing or. even better, let's build a new building.' So, +we have that in the bill. It should stay, people have wanted a new FBI building now for 15-20 years." ''But +Republicans don't want it in the bill,' a reporter informed Trump. "Then Republicans should go back to school +and learn you need a new building,' the president said. 'It's a bad building, it's a dangerous building, you have +slabs falling off. It's not a good building from the inside. It's a very expensive building, they need a new building +and we can do it very easily."** +Puerto Rico Power Company Says "Sabotage" May Have Caused Blackout. +Bloomberg (7/29, Wyss, 4.73M) reports, "The head of Puerto Rico's power company said a blackout +Tuesday that affected more than 400,000 customers was a 'man-made event that could have been act of +'sabotage."" Bloomberg adds, Speaking to WKAQ radio Wednesday, Puerto Rico Electric Power Authority +CEO Jose Ortiz said that he will be asking the U.S. Department of Homeland Security and the Federal Bureau of +Investigation to examine the incident that knocked out power to a large swath of the island for several hours +Tuesday. 'What I can tell you is that there was manipulation,' he said of the blackout. 'Either this was an +oversight on someone's part or it was an act of sabotage."*' +Other Washington News +US COVID Fatality Rate Down Significantly From April And May. +The Washington Times (7/29, Howell, 492K) reports that according to pandemic trackers "the share of U.S. residents +who test positive" for COVID-19 "and then die [is] 3.4%, far better than the 15% in the United Kingdom and +roughly 14% in France and Italy, or 7.6% in Canada." The fatality rate "is down from closer to 6% in late April +and early May, when states such as New York and New Jersey reported eye-popping numbers." The 3.4% rate "is +based on known cases. But with so many asymptomatic carriers going untested, the real number is probably +closer to 0.6%, according to experts who have offered their best estimates." The Times adds that the "economic +fallout from springtime lockdowns raises questions about whether they were worth it at all, given the seemingly +low rate." White House Counselor Kellyanne Conway said on KTRK-TV + Houston (7/29, +92K), "The message from the White House is simple. The President delivered it last week. This will get worse + + +before it gets better in some places, and as our case numbers rise, thankfully, the mortality rate is much lower +than it was at it its peak." +Word of the declining fatality rate comes as US deaths from coronavirus "surpassed 150,000 on Wednesday, a +number higher than in any other country and nearly a quarter of the world's total," Reuters + (7/29, Shumaker, McKay) reports. Reuters adds, "Of the 20 +countries with the biggest outbreaks, the United States ranks sixth in deaths per capita, at 4.5 fatalities per 10,000 +people. Only the United Kingdom, Spain, Italy, Peru and Chile have a higher per capita rate, the tally shows, +with U.S. deaths making up nearly 23% of the global total of just over 661,000." In the lead story on ABC World +News Tonight +(7/29, lead story, 4:35, Muir, 7.22M), Victor Oquendo called the death toll "unimaginable," and in its lead story, +the CBS Evening News (7/29, lead story, 4:45, O'Donnell, 4.28M) called it "stunning" and reported that "deaths across the +country have recently surged by more than 30%." +The New York Times (7/29, 18.61M) +reports that "an average of about 1,000 virus-related deaths a day have been reported over the past week, the +worst rate since early June, when the number of people dying seemed to be falling. Now, daily death counts are +rising in 23 states and Puerto Rico." +USA Today (7/29, Flores, Schoolman, 10.31M) says "there is not much relief in sight. The three most +populous states - California, Texas and Florida - were among several that set seven-day records for virus deaths +this week. Others set records for new cases. Tennessee and Arkansas set records for both." NBC Nightly News + (7/29, lead story, +2:50, Holt, 5.97M) reported in its lead story that "new states in the middle of the country now seeing fresh hot +spots." NBC's Miguel Almaguer added that NIAID Director Fauci is "warning several American cities who have +mostly avoided COVID's crippling crush are now on the verge of being hit hard." Fauci: "If you are not getting +your arms around and suppressing that surge that's coming up two to three weeks down the pike, you're in +trouble." +White House Coronavirus Task Force Response Coordinator Deborah Birx said in an interview with Sinclair +Broadcasting Group (7/29, story 2, +1:20, Muir, 7.22M), Mary Bruce said Trump "doubled down on his support for a fringe doctor who is spreading +lies about the coronavirus, even after learning she claims demons and witches cause illnesses." The CBS +Evening News +(7/29, story 3, 0:35, O'Donnell, 4.28M) reported that Trump "doubled down on hydroxychloroquine, requiring +his own health experts to once again remind Americans it doesn't actually work." CNBC + (7/29, Lovelace, 3.62M) reports on its website that NIAID Director Fauci +"said Wednesday that all the 'valid' scientific data shows...hydroxychloroquine isn't effective in treating the +coronavirus." Appearing on MSNBC's Andrea Mitchell Reports +https://playvideo.bulletinintelligence.com/aee0f28fd9674elda7cбeе09c5f221be?pubid=fbi> (7/29, 1.09M), +Fauci said, "You look at the scientific data and the evidence. And the scientific data...on trials that are valid, that +were randomized and controlled in the proper way, all of those trials show consistently that hydroxychloroquine +is not effective in the treatment of coronavirus disease or COVID-19." +Navarro: Hydroxychloroquine Can "Save Lives" And Should Be Prescribed More Frequently. Politico + +(7/29, Forgey, 4.29M) says the White House has "aggressively renewed their promotion of hydroxychloroquine." +Politico says Director of Trade and Manufacturing Policy Navarro "led the charge Wednesday...in defiance of +scientific evidence. But he declined to address the president's praise for a Houston-area physician who falsely +claimed the drug was a coronavirus cure and has promoted other conspiracy theories." Navarro is quoted as +saying, "I'm pleading with you...to look at this drug again. ... Because I literally have tens of millions of tablets +sitting in the Strategic National Stockpile that - if we were allowed under the doctors" advice to get this stuff to +people at the first sign of their symptoms - I guarantee you it would cut the amount of time of the symptoms, +reduce the duration of the symptoms and save lives." +Fauci, Birx, Carson Advocate Use Of Face Masks. +NIAID Director Fauci said on MSNBC's Andrea Mitchell Reports + (7/29, 1.09M), +"I'm not totally against mandating, but I don't want to step on the toes of people in the independent way they run +their states and cities. But clearly the bottom line, without any distraction, is that it is very important for people +to universally wear masks and there's no ambiguity about that statement. They just have got to do it." Fauci +added, "I think right now you're seeing the situation has changed. Vice President Pence wears a mask now. +We've seen the President wear a mask. And the President even has been recommending wearing of masks. He +said that publicly, and I'm very pleased, and those of us on the Coronavirus Task Force are very pleased to see +him having done that." +White House Coronavirus Task Force Response Coordinator Deborah Birx said in an interview with Sinclair +Broadcasting Group (7/29, 22K), "I think every public health official would love it if every single American wore a mask +every single day anytime they were in public and frankly what I told young people and others, protect your +family. If you had one of these indiscretions and been out in a large gathering, you should wear a mask at home." +HUD Secretary Carson said on WEWS-TV + Cleveland (7/29, +106K) that if people wear masks, perform social distancing, have good hygiene, and assume they are +symptomatic carriers "we would depress this thing so quickly your head would spin." + + +NY Times Endorses Sanders Bill Mandating That Three Masks Be Sent To Every Person In US. In an editorial, +the New York Times < https://www.nytimes.com/2020/07/29/opinion/us-coronavirus-masks.html> (7/29, +18.61M) recounts that Sen. Bernie Sanders (I-VT) "introduced legislation this week that directs the Trump +administration to send three 'high-quality, reusable' masks to every person in the United States, and would +provide $5 billion to increase mask production. This is a good idea." While "a national campaign to encourage +people to wear masks, including the distribution of free masks, is not sufficient to confront the pandemic...masks +would help," and "right now, Americans need all the help they can get." +Pelosi To Institute Mandatory Mask Policy For House After Gohmert Tests Positive. +CNBC (7/29, Breuninger, 3.62M) reports on its website that House Speaker Pelosi said Wednesday that "she +will soon be announcing a mandatory mask policy for the floor of the House," a development that "comes just +hours" after Rep. Louie Gohmert (R-TX) "announced that he had tested positive for the coronavirus." Politico + (7/29, Caygle, Ferris, +4.29M) recounts "lawmakers are currently encouraged to wear masks in the chamber and required to wear them +in committee rooms - although some Republicans openly defy that rule and have yet to be punished." Pelosi +said, "Members and staff will be required to wear masks at all times in the hall of the House. Except that +members may remove their masks, temporarily, when recognized." The Hill + (7/29, Marcos, 2.98M) +also reports the story under the headline "Pelosi To Require Masks On House Floor." +The Houston Chronicle (7/29, Rosenthal, 730K) points out "Gohmert used a widelycondemned phrase when referring to the virus in his video statement." Kristen Welker of NBC Nightly News +https://playvideo.bulletinintelligence.com/937789c7a1124f0ebd673966aebf6b7d?pubid-fbi> (7/29, story 2, +1:00, Holt, Welker, 5.97M) showed the congressman saying, "I'm asymptomatic, but apparently I have the +Wuhan virus." +The AP (7/29, Fram, Jalonick) indicates that +Gohmert's positive test forced him "to abruptly cancel his plan to travel to his home state with President Donald +Trump aboard Air Force One." Mary Bruce of ABC World News Tonight +(7/29, story 3, +1:10, Muir, 7.22M) reported Gohmert "has frequently been spotted on the Hill without a mask," and "sources tell +us his staff has even been scolded for wearing them." The Washington Examiner + (7/29, Ferrechio, 448K) reports, however, that "a top staffer in +the office of...Gohmert denied an anonymous claim that employees in the lawmaker's DC office were berated for +wearing masks and forced to work in dangerous conditions." Said Chief of Staff Connie Hair, "We have never +discouraged anyone from wearing a mask." +Gohmert said on Fox News' Hannity (7/29, 535K), "The +left went nuts. They are saying, 'Oh, I contaminate the gym.' I haven't been to the gym in months. They said I +berated staff for wearing masks and that is a lie." +Reuters (7/29, Cowan) also reports Gohmert +"steadfastly refused to wear a mask during the coronavirus pandemic," and USA Today + (7/29, Lalljee, Johnson, 10.31M) recalls "Gohmert told CNN in June he would only wear +a mask if he contracted the virus." Said Gohmert, 'I don't have the coronavirus, turns out as of yesterday I've + + +never had it. But if I get it, you'll never see me without a mask. ... But I keep being tested and I don't have it. So +I'm not afraid of you, but if I get it I'll wear a mask." Axios < https://www.axios.com/louie-gohmert-maskwearing-coronavirus-5a241b3c-8fa3-4835-a15f-779d5c891290.html> (7/29, Perano, 521K), CQ Roll Call + (7/29, Marquette, 154K) and The +Hill (7/29, Marcos, 2.98M), among other news outlets, also report the story. +Gohmert Wonders Whether Wearing Mask Led To Infection. The Texas Tribune + (7/29, Samuels, 23K) reports Gohmert +said in an interview Wednesday, "I can't help but wonder...if I injected the virus into my mask when I was +moving" it. USA Today < https://www.usatoday.com/story/news/polities/2020/07/29/rep-gohmert-attributescovid-19-diagnosis-wearing-mask/5536431002/> (7/29, Santucci, 10.31M) points out the congressman made his +comment in an interview with Texas station KETK +The New York Times (7/29, Fandos, 18.61M) also points out that "the Texas congressman, who frequently refused to wear +a mask, said he had probably contracted the coronavirus because he did so," and the Washington Post + (7/29, Sonmez, +Dawsey, Kane, 14.2M) that Gohmert "went on to make several statements filled with misinformation about the +virus, such as suggesting that wearing a face mask increased his chances of contracting it... 'It is interesting, +and I don't know about everybody, but when I have a mask on, I'm moving it to make it comfortable, and I can't +help but wonder if that puts some germs in the mask,' Gohmert said" in the video he released. +After Coming Into Contact With Gohmert, Barr Tests Negative. Ben Tracy of the CBS Evening News + (7/29, Sherman, 4.29M) points out that "footage from before the hearing shows Gohmert +and Barr walking together in close contact, with neither wearing a mask." +USA Today (7/29, Lalljee, Johnson, 10.31M) reports that according to DOJ, "Barr tested +negative for the coronavirus" Wednesday, following Gohmert's announcement. +Officials Identifying Priority Groups For Initial COVID Vaccinations. +The Washington Post (7/29, Sun, 14.2M) reports that with some coronavirus vaccine trials in the final stage, +"officials and experts are wrestling with one of the most difficult issues facing the country: Who should be first +to get limited doses of a vaccine during one of the worst public health crises in a century?" Discussions +"involving federal health officials and outside experts" have "begun to identify priority groups for initial +vaccination against covid-19." The talks "are based on planning developed during the 2009 H1N1 influenza +pandemic. Highest priority would go to health-care and essential workers and high-risk populations. This +proposed group would also include older adults, residents of long-term-care facilities and people with underlying +medical conditions." +NIAID Director Fauci said on MSNBC's Andrea Mitchell Reports + (7/29, 1.09M), +that "the federal government has invested hundreds of millions if not billions of dollars into getting production at +risk," and companies "are beginning to produce a lot of doses and what's going to happen is that they've + + +promised, and this is more than one company, is that as we get into 2021, they will have hundreds of millions of +doses available and at the end of the year, likely up to a billion doses." +Lancet Editor Tells WPost Why He Thinks US, Europe Mishandled Outbreak. +The Washington Post (7/29, Booth, 14.2M) reports on a +Zoom interview with Lancet editor Richard Horton in which he explains "why he thinks politicians and scientific +advisers in the United States and Europe got so much so wrong" about the novel coronavirus. Horton "is out +with a new book, 'The Covid-19 Catastrophe: What's Gone Wrong and How to Stop it Happening Again."" It "is +an angry work, thrumming with righteous disbelief over mistakes made in the past six months." +In North Carolina, Pence And DeVos Promote Reopening Of Schools. +The AP (7/29, Anderson) reports that in North +Carolina on Wednesday, Vice President Pence "vowed...that schools around the country will have the resources +they need to reopen for in-person learning as he visited a classroom of masked fourth graders at a...private +school." President Trump and Education Secretary DeVos "have threatened to withhold federal funding from K- +12 schools that don't allow all of their students to return to physical classrooms." Pence, who appeared with +DeVos, "visited a Raleigh-area campus of Thales Academy as part of a push to encourage more schools to reopen +with in-person instruction." Pence is quoted as saying, "We're all gonna make sure schools across America have +the support to open up and stay open." Later, Pence said, "Online learning is no substitute for in-person +learning." +Administration officials made a similar cases in media appearances on Wednesday. Surgeon General Adams said +on Mornings On The Mall (7/29), "It is important we understand there are health impacts for shutting down. There are 4.2 million +children behind on their vaccinations. Kids out of school are more likely to be obese... It is important that we +understand there are health harms to staying shut down." +HUD Secretary Carson said on WEWS-TV + Cleveland (7/29, +106K), "Let's determine the risk based on science, not on hysteria." He added, "The likelihood of children being +affected by this is very small. The number of children who have died from COVID is much smaller than the +number who die from regular flu." +Doctors Make Recommendations For Reopening Schools Safely. In an op-ed for the New York Times + (7/29, 18.61M), physicians +Ezekiel J. Emanuel, James Phillips, and Saskia Popescu write that to reopen schools safely, "we must ensure that +all five of the core school-based activities - transportation, time in the classroom, mealtimes, gym and +extracurricular activities - are safe." They write that they have "created a school risk index to assess the dangers +and offer recommendations to reduce the chance of spreading the virus, not only among students but also among +teachers and other employees. " The doctors go on to outline a series of measures that they say "will permit +relatively safe schools and allow in-person education and as much socializing as possible." +Weingarten: Florida, Arizona, Texas Teachers Could Strike Over Unsafe Working Conditions. +Politico (7/29, + + +Perez, 4.29M) reports American Federation of Teachers President Randi Weingarten "warned" Wednesday that +teachers in Florida, Arizona and Texas are most likely to strike over unsafe working conditions due to the +pandemic. Weingarten told Politico that is governors and local officials reopen schools while cases are spiking +without addressing demands for safety measures, teachers cannot give acquiesce in negotiations ahead of the +school year. He said, "You can't say, at the end, 'Okay, I just give up.' You have to actually be true to your +convictions... And if that means a safety strike as a last resort, that's what it means. If you believe that the safety +and health of people are really sacrosanct, then you've got to be able to sacrifice for it." +The New York Times (7/29, Goldstein, Shapiro, 18.61M) reports that on Tuesday, the AFT "raised the stakes +dramatically by authorizing its local and state chapters to strike if their districts do not take sufficient precautions +- such as requiring masks and updating ventilation systems - before reopening classrooms." The Times adds that +"many unions, while concerned about the safety of classrooms, are also fighting to limit the amount of time that +teachers are required to be on video over the course of a day." the Times adds that critics "see teachers' unions as +trying to have it both ways: reluctant to return to classrooms, but also resistant in some districts to providing a +full day of remote school via tools like live video - the kind of interactive, online instruction that many parents +say their children need after watching them flounder in the spring." +In an op-ed for the Wall Street Journal (7/29, Subscription Publication, 7.57M), David R. Henderson, a research fellow at Stanford +University's Hoover Institution, writes that the pandemic may result in more parents realizing the poor job public +schools are doing and choose home-schooling, private schools, or charter schools. +Florida Schools Announce Remote Classes As DeSantis Says State Will Have In-Person Learning. +Politico (7/29, Atterbury, 4.29M) reports that as Florida Gov. Ron +DeSantis (R) "insists" his state will have in-person learning this fall, Florida's largest school district will begin +the year "with remote classes, joining others that are keeping campuses closed." Miami Dade County schools +Superintendent Alberto Carvalho "announced the move Wednesday, a day after nearby Monroe County said it +would rely on digital instruction for the immediate future." Schools in Broward and Palm Beach counties "also +intend to start the school year with online courses." Nonetheless, DeSantis and state Education Commissioner +Richard Corcoran "were unwavering in their confidence that brick-and-mortar schools will reopen their doors +this fall." +DHS Draws Judicial Rebuke Over False Statements In New York Travel Case. +Politico New York (7/29, Durkin) reports US District +Judge Jesse Furman "rebuked the Department of Homeland Security for making statements it has admitted were +false in seeking to ban New York state from travel programs." But last week, DHS officials "admitted in court +papers they had made false statements in an effort to push the ban, which New York was suing to overturn." The +officials "had said that New York placed restrictions unlike any other state on the access immigration authorities +have to Department of Motor Vehicles records. In fact, they later acknowledged, several other states have the +same restrictions but have never faced attempts to block them from travel programs." Furman called the +admissions "deeply troubling revelations." He demanded that the federal government provide "a comprehensive +record of any and all 'inaccurate' or "misleading' statements in their prior submissions" by Aug. 12. +Cuecinelli Defends Administration's Actions On DACA. + + +Acting Deputy DHS Secretary Cuccinelli said on NPR's Morning Edition + (7/29, 7.5M), +"The Supreme Court said overwhelmingly the Trump Administration can move forward to rescind DACA but +that you haven't done it the right way. .. The Maryland ruling was last Friday and then following that Maryland +ruling, we took interim action.... We frequently undertake interim actions to give direction to our employees as +to how to proceed in any particular area. This sort of interim guidance, I will call it, is entirely common. It is +entirely within the legal authority of the Department of Homeland Security to do that and to set a system in place +and the system does not allow new applicants." +Trump Says He Will Act Against Big Tech If Congress Does Not. +President Trump tweeted Wednesday +around noon, "If Congress doesn't bring fairness to Big Tech, which they should have done years ago, I will do it +myself with Executive Orders. In Washington, it has been ALL TALK and NO ACTION for years, and the +people of our Country are sick and tired of it!" Reuters (7/29) covers the +tweet. The Washington Times (7/29, Sherfinski, 492K) reports the White House said Wednesday that the +Administration "is moving forward to implement a recent presidential executive order on social media, ahead of +testimony from top tech company executives on Capitol Hill. The Commerce Department this week filed a +petition to clarify that social media companies can be held liable if they 'alter or editorialize users" speech,' +according to the White House." +Four Big Tech CEOs Appear At Contentious House Hearing. The CBS Evening News +https://playvideo.bulletinintelligence.com/07aef3de740a4778623ebe9b0b33fd9?pubid=fbi> (7/29, story 8, +1:20, O'Donnell, 4.28M) reported that on Wednesday, "for the first time, the titans of tech testified together +before Congress. Amazon's Jeff Bezos, Apple's Tim Cook, Facebook's Mark Zuckerberg, and Google's Sundar +Pichai were confronted with charges of stifling competition and political bias." Jo Ling Kent reported on NBC +Nightly News (7/29, Gordon) reports, "Fending off' +accusations of stifling competition," the CEOs "are answering for their companies' practices before Congress as +a House panel caps its yearlong investigation of market dominance in the industry." The Washington Post + +(7/29, Romm, Zakrzewski, Lerman, 14.2M) reports, "The rare interrogation played out over the course of a +nearly six-hour hearing, with lawmakers on the House's top antitrust subcommittee coming armed with millions +of documents, hundreds of hours of interviews and in some cases the once-private messages of Silicon Valley's +elite chiefs. They said it showed some in the tech sector had become too big and powerful, threatening rivals, +consumers and, in some cases, even democracy itself." +The New York Times +(7/29, McCabe, 18.61M) reports subcommittee chair Rep. David Cicilline (D-RI) "opened the hearing with a +broadside against the companies, saying their dominance harms the economy and leaves consumers with no +choice but to use their products." Politico < https://www.politico.com/news/2020/07/29/tech-antitrust-hearinglive-highlights-and-updates-380487> (7/29, Nylen, Scola, Hendel, 4.29M) says panel members "hammered" +Pichai about Google's "relations with China and whether it steals ideas from other businesses," Zuckerberg +"about a blizzard of disinformation plaguing" Facebook, and Cook "on whether his iPhone-maker strong-arms + + +developers on its App Store." Reuters (7/29, Bose, Bartz) reports Cicilline +"accused Google of stealing reviews from the company Yelp Inc and said that Google threatened to delist the +company from search results if it objected." +Bloomberg (7/29, Newcomer, Brody, 4.73M) reports Republicans took +a different tack, with GP leadership "preparing lawmakers for the hearing labels bias as the top concern, while +conceding it is not an issue that can be solved through antitrust enforcement." Axios + (7/29, Fischer, 521K) reports Reps. Jim Jordan (R-OH) and James +Sensenbrenner (R-WI) "used their first few minutes during their opening statements at the hearing...to call out +tech companies for unproven allegations of political bias against conservatives," while Rep. Kelly Armstrong (R- +ND), "in his first line of questioning, referenced reports that by Google had warned The Federalist, a +conservative website, about being demonetized for violating its rules." +The New York Post (7/29, Vega, Feis, 4.57M) reports Jordan said "in a fiery opening remark," "T'll just cut to the chase. +Big Tech is out to get conservatives. That's not a suspicion, that's not a hunch - that's a fact." The Hill + +(7/29, Rodrigo, 2,98M) reports Jordan "listed a series of instances where social media companies have removed +certain content - including misinformation about the coronavirus pandemic that is contradicted by the World +Health Organization - in arguing that there is active, systemic censorship. He pointed to allegations that Google +was censoring the right-wing site Breitbart News and that Amazon's Twitch banned President Trump's channel." +The Washington Times (7/29, Sherfinski, Lovelace, 492K) runs a brief report under the headline "Rep. Jim Jordan: 'Big +Tech' Is Out To Get Conservatives." Jordan said on Fox News" Tucker Carlson Tonight + (7/29), "You may have the Justice +Department looking at current antitrust laws to go after these companies right now, and frankly we may have to +change the law." +The Wall Street Journal (7/29, +Subscription Publication, 7.57M) says in an editorial that while politicians of both parties seem to despise Big +Tech, the companies' products and services remain popular with hundreds of millions of users, and legislators +must take care to not overlook consumer benefit in their policy conclusions. +WPost Analysis: Tata Nomination Appears "To Be In Trouble." +The Washington Post (7/29, +Lamothe, Kim, 14.2M) reports, "President Trump's nomination of a retired Army general for a senior Pentagon +position appeared to be in trouble Wednesday, with Republicans and Democrats alike expressing concern about +his inflammatory comments about Islam, partisan attacks and infidelity." Anthony J. Tata, "a military officer +turned novelist and Fox News commentator, faces mounting opposition from Democrats on the Senate Armed +Services Committee because of his past remarks, which include falsely calling former president Barack Obama a +'terrorist leader."" To the Post, "the contested nomination for undersecretary of defense for policy is emblematic +of the Trump administration's difficulty in finding qualified nominees and getting them confirmed," and +"highlights anew" Defense Secretary Esper's "struggles to shield the Pentagon from partisanship." +Reuters (7/29, Stewart, Ali) reports, meanwhile, that Tata, +"Trump's most divisive nominee for a senior Pentagon post to date is expected to face a contentious Senate + + +nomination hearing on Thursday, with Democratic lawmakers likely to grill him over remarks they deem +Islamophobic." The White House "said it stands by Tata's nomination to fill the position of undersecretary of +defense for policy." +Senate Democrats Criticize Pompeo For Reducing State Department Staff. +The New York Post (7/29, Jacobs, 4.57M) reports, "Senate Democrats have released a report blasting Secretary of +State Mike Pompeo's management of the State Department, criticizing the fact that he has thinned out the +amount of staff at the bureau." The report, "released Tuesday, comes two days before Pompeo's scheduled +testimony before the Senate Foreign Relations Committee Thursday, where he is expected to face considerable +scrutiny from Democratic senators." Says the report, "Over the last three and a half years, the Department has +been plagued by a hiring freeze, a bungled 'reform' effort, proposals to slash its funding by one-third, and +persistent vacancies, all of which have hampered its effectiveness." +Pompeo Appoints DeHart As Coordinator For Aretic Region. The Washington Times + +(7/29, Meier, 492K) reports "Pompeo on Wednesday announced the appointment of Jim DeHart to be the next +US coordinator for the Arctic region." In a statement, Pompeo "explained that Mr. DeHart will serve as the +principal adviser on all Aretic matters and will coordinate the department's policy-making and diplomatic +engagement on Arctic-related issues." +Trump Touts Move To Stave Off "Low Income Housing" In Suburbs. +President Trump took to Twitter < https://twitter.com/realDonaldTrump/status/1288509568578777088> +Wednesday to write, "I am happy to inform all of the people living their Suburban Lifestyle Dream that you will +no longer be bothered or financially hurt by having low income housing built in your neighborhood.... Your +housing prices will go up based on the market, and crime will go down. I have rescinded the Obama-Biden +AFFH Rule. Enjoy!" +A number of media reports cast Trump's effort as rooted in racism. In particular, the New York Times + (7/29, 18.61M) says Trump is +"continuing his efforts to shore up the support of white suburban voters by stirring racist fears about affordable +housing," and "his remarks on Wednesday were further evidence that he is deploying a strategy rooted in racism, +classism and fear-mongering as he courts white suburban voters, particularly white suburban women, who were +the key to his victory in 2016 but are slipping away from him." The President "made similar remarks last week +when he first announced his administration's plans to eliminate the Obama-era rule." +Politico (7/29, +Choi, 4.29M) reports that "when the Trump administration rescinded an Obama-era fair housing rule last week, it +justified the move as alleviating undue burdens on local governments. But on Wednesday...Trump gave a much +more stark reasoning: Keep low-income housing out of the suburbs." Politico adds that "the 2015 Affirmatively +Furthering Fair Housing rule requires local governments to proactively ensure fair housing in order to receive +federal housing funding," and "was designed to give more teeth to the Fair Housing Act in combating +segregation." +USA Today (7/29, Fritze, Jackson, 10.31M) reports Trump drew "a quick +rebuke from critics who pointed out the provision was an attempt to address racial segregation," and adds +"Democrats - including the party's presumptive presidential nominee, Joe Biden - have accused Trump of race + + +baiting." +Reuters (7/29, Brice) also says +it was Trump's "latest bid to boost his support in the suburbs as he seeks re-election," and the Fox News + (7/29, Phillips, 27.59M) website that +the President "has sought to pit...Biden against suburban voters, last month saying Biden wants to make suburbs +'much worse."" CNBC < https://www.enbc.com/2020/07/29/trump-suburban-voters-will-no-longer-be-botheredby-low-income-housing.html> (7/29, Wilkie, 3.62M) says on its website, "Trump's tweets mark an escalation of +his campaign strategy of trying to stoke fear in suburban voters that poor urban residents, who are +overwhelmingly people of color, will move to their suburbs if low-income housing is permitted to be built in +single-family home neighborhoods." Rolling Stone < https://www.rollingstone.com/polities/polities-news/trumpsuburban-voters-suburban-fair-housing-act-1032625/> (7/29, Stuart, 12.8M), meanwhile, headlines its story +"Trump Is Happy To Inform Suburban Voters That He Is Still A Racist." +Epshteyn: Trump "Just Saved The American Suburb." Writing for Newsweek + (7/29, +1.53M) under the headline "The Trump Administration Just Saved The American Suburb," Boris Epshteyn, +"strategic advisor for coalitions on the Trump 2020 campaign," calls Trump's move "a massive victory for +Americans' constitutional rights to local control and self-government, as well as a recognition that the federal +government's duty to prevent discrimination in housing does not supersede its obligation to protect the rights of +millions of Americans who abide by race-neutral zoning laws to create beautiful, vibrant, family-friendly +suburban communities." +Treasury To Loan Postal Service $10B In Return For "Last-Mile" Contract Details. +The Washington Post +(7/29, Bogage, 14.2M) reports that on Wednesday, the Treasury Department "agreed to loan the U.S. Postal +Service $10 billion in emergency coronavirus relief funding... in exchange for proprietary information about the +mail service's most lucrative private-sector contracts." The Postal Service "will provide Treasury copies of its 10 +largest 'negotiated service agreements,' or contracts with high-volume third-party shippers such as Amazon, +FedEx and UPS, and receive a crucial injection of cash that postal officials say will keep the debt-laden agency +solvent for at least another year." The Postal Service "contracts with private-sector shippers for "last-mile" +delivery from distribution centers to consumers' homes, and it offers those companies small discounts because of +the volume of packages they provide." +Reuters (7/29, Lambert, Heavey) says +President Trump nominated Postmaster General Louis DeJoy "to bring the service's finances in line and he is +pushing to cut costs even if it means delaying deliveries." According to Reuters, the Postal Service "does not +need to borrow at the moment, but the money will now be available should the financially strained agency have +to access it." Treasury Secretary Mnuchin said in a statement, "While the USPS is able to fund its operating +expenses without additional borrowing at this time, we are pleased to have reached an agreement on the material +terms and conditions of a loan, should the need arise." +Ginsburg Undergoes Nonsurgical Medical Procedure. +The AP < https://www.politico.com/news/2020/07/29/ruth-bader-ginsburg-undergoes-medical-procedure-athospital-387588> (7/29) reports that the Supreme Court said Wednesday that Justice Ruth Bader Ginsburg +underwent "a nonsurgical medical procedure in New York City and expects to be released from a hospital there +by the end of the week." A statement from the Court said Ginsburg that the minimally invasive procedure was to + + +"revise a bile duet stent" at Memorial Sloan Kettering Cancer Center. Citing Ginsburg's doctors, the statement +said that "stent revisions are common occurrences and the procedure, performed using endoscopy and medical +imaging guidance, was done to minimize the risk of future infection. +Obama To Deliver Eulogy At Lewis' Funeral. +NBC Nightly News (7/29, story 7, 1:45, Holt, 5.97M) reported that "a long line of mourners paying respects to +Congressman John Lewis" as he arrived back in the Atlanta district "he represented for more than three +decades." NBC (Alexander) added, "One final trip home for Congressman John Lewis. His procession weaving +its way through Atlanta, pausing at the walls bearing his image, the street bearing his name, and the final resting +place of Dr. Martin Luther King Jr., who helped inspire Lewis' lifelong fight for civil rights." NBC added that +former President Barack Obama will deliver the eulogy at Lewis' funeral on Thursday. In addition to Obama, the +CBS Evening News (7/29, story 10, 2:00, O'Donnell, 4.28M) reported, former Presidents George W. Bush and Bill +Clinton "will travel to Atlanta for [Thursday's] funeral." Axios < https://www.axios.com/obama-bush-clintonlewis-funeral-8b70fbaf-e220-4999-8d47-3046c1cf3e54.html> (7/29, Nichols, 521K) reports that Obama, Bush, +and Clinton's attendance "lend[s] presidential prestige to the civil rights icon's funeral that the current occupant +of the White House, Donald Trump, seems determined to withhold." ABC World News Tonight + (7/29, story 11, +0:15, Muir, 7.22M) provided similar coverage. +Navy's First Black Female Fighter Pilot To Get Her Wings Friday. +The CBS Evening News (7129, Sly, Denyer, Eglash, 14.2M) +reports, "An unforeseen summer surge of coronavirus cases in countries that had seemingly quelled their +outbreaks is helping to drive the unrelenting growth of the global pandemic, undercutting predictions that a +'second wave" would not occur until the fall." Hong Kong, Israel, Japan, and Lebanon "are among dozens of +places reporting record numbers of new cases in recent days, many weeks after they had crushed the curve of +infections, reopened their economies and moved on." Furthermore, "in some countries that had brought numbers +down, notably in Europe, the reopening of borders, bars and nightclubs is being blamed for a small but +noticeable increase in cases." +New Outbreak Spreading In Vietnam. The New York Times + (7/29, Beech, Doan, 18.61M) +reports, "After months without a single coronavirus death, or even a confirmed case of local transmission, a new +outbreak has struck Vietnam," and it's now spreading. Initially, "a 57-year-old man from Danang tested positive + + +for the virus and is now on life support.," and "then clusters quickly emerged in five hospitals." As of +"Wednesday, the virus had spread north to Hanoi, the capital, south to Ho Chi Minh City and afflicted two +provinces in central Vietnam, as well as the remote Central Highlands." +UN Agencies Predict Mass Starvation Due To Pandemic. +NBC Nightly News (7/29, story 11, 1:40, Holt, 5.97M) reported that there is "a dire warning about the pandemic's +levastating impact on children worldwide." NBC (Engel) added, "The World Food Programme and three other +JN agencies predict mass starvation because of COVID's disastrous economic impact. The UN agencies say the +140 million people around the world on the brink of starvation now could rise to a staggering 270 million this +year." +NYTimes Analysis: Pandemic Further Undermining Democratic Norms In Latin America. +The New York Times (7/29, Kurmanaev, 18.61M) reports the pandemic is "undermining democratic norms" in several +Latin American countries "that were already under strain." This "gradual undermining of democratic rules during +an economic crisis and public health catastrophe could leave Latin America primed for slower growth and an +increase in corruption and human rights abuses, experts warned." Notably, this year "was the first time that the +Organization of American States, a regional group that promotes democracy, had its invitation to observe +elections withdrawn by a host country in recent history." +Iran Launches Underground Ballistic Missiles During Exercise. +The AP (7/29, Vahdat, Gambrell) reports Iran's +Revolutionary Guard "launched underground ballistic missiles as part of an exercise involving a fake aircraft +carrier in the Strait of Hormuz, state television reported Wednesday." The TV "did not immediately air footage of +the launches," nor did it identify the missiles used in the drill. +Israel Criticizes Twitter For Allowing Khamenei's Anti-Semitic Tweets. +The Washington Free Beacon (7/29, Beyrer, 78K) reports Twitter "came under fire" Wednesday during a meeting of Israel's +Knesset "for allowing Iran's Supreme Leader to post anti-Semitic tweets promoting genocide." The Free Beacon +writes that Twitter has "refused to apply the same standards to Iranian Supreme Leader Ayatollah Ali Khamenei +that it holds President Donald Trump to." It notes that "many of the president's tweets have been taken down for +"glorifying violence," while the Ayatollah's tweets - some of which advocate for the genocide of Israeli Jews +remain untouched." +US Sanctions Syrian Officials, Entities In Push To End War. +Reuters (7/29, Psaledakis, Landay) reports the US on Wednesday imposed new + + +sanctions "aimed at cutting off funds for Syrian President Bashar al-Assad's government and warned that anyone +doing business with Damascus was also at risk of being blacklisted." Assad's son, Hafez, was "among four +people and 10 entities, including a Syrian army unit, targeted by Washington over accusations they either aided +government funding through luxury real estate construction - sometimes on land belonging to displaced civilians +- or prolonged the nearly decade-long war." In a statement, the White House said, "More sanctions will follow +as part of a sustained campaign of economic and political pressure to deny the Assad regime the resources it uses +to wage war against the Syrian people." +Following Trump's Direction, Pentagon Plans To Remove Some Troops From Germany. +Terry Moran reported on ABC World News Tonight +(7/29, story 5, +2:20, Muir, 7.22M) reported the Pentagon is transferring 12,000 US troops "from Germany, a key US ally." +President Trump cited "his longstanding gripe that Germany doesn't pay its fair share for defense in Europe." He +said, "We don't want to be suckers any more." Moran added, "President Trump made crystal clear, this is lot +more about punishing Germany than deterring Russia." Meanwhile, "There was bipartisan condemnation of the +move. " +In a tweet , President Trump said, +"Germany is very delinquent in their 2% fee to NATO. We are therefore moving some troops out of Germany!" +He also said, "Germany pays Russia billions of dollars a year for Energy, and we are supposed to protect +Germany from Russia. What's that all about?" +The Wall Street Journal (7/29, Gordon, Youssef, Subscription Publication, 7.57M) reports Defense Secretary Esper said +the billion-dollar move was to better deter Russia, but Trump told reporters that it could change it could change +if Germany spends more on defense. Esper said, "They're delinquent. So we're reducing the force. Now if they +start paying their bills...I would think about it." +The AP (7/29, Baldor) reports, "Spurred on by +[Trump's] demand to pull troops out of Germany, the U.S. will bring about 6,400 forces home and shift about +5,600 to other countries in Europe." According to the AP, "The decision fulfills Trump's announced desire to +withdraw troops from Germany, largely due to its failure to spend enough on defense." The AP says "a number +of forces will go to Italy, and a major move would shift U.S. European Command headquarters and Special +Operations Command Europe from Stuttgart, Germany, to Belgium." However, the AP adds that "the future of +the plan is uncertain, at best, since it relies on support and funding from Congress, and a number of members +have voiced opposition. And it may not survive at all if Trump isn't re-elected." +Reuters (7/29, Stewart, Ali) reports that in June, +Trump "announced his intention...to cut by about a third the 36,000-strong U.S. troop contingent in Germany, +faulting" Germany "for failing to meet NATO's defense spending target." On Wednesday, Trump said, "We don't +want to be the suckers any more. We're reducing the force because they're not paying their bills; it's very +simple." However, according to Reuters, Esper "has not portrayed the pullout in those terms and said the +military's plan would prevent the troop movements from undermining NATO and its efforts to deter Russian +intervention, following Moscow's 2014 annexation of the Crimean Peninsula." Reuters says that "in remarks +likely to irk Moscow, Esper said some U.S. troops would reposition to the Black Sea region and some could +temporarily deploy in waves to the Baltics." +The New York Times (7/29, +Gibbons-Neff, 18.61M) quotes Esper as saying, "I am confident that the alliance will be all the better and +stronger for it." Nevertheless, the Times reports that "the move is certain to rankle European leaders and anger + + +both Democratic and Republican lawmakers who see the United States troop presence on the continent, +especially in Germany, as a cornerstone of post-World War Il order. ... "This is so clearly a punitive move against +Germany that its hard to see any benefit from this, said Rachel Rizzo, the director of programs at the Truman +Center for National Policy." +The Washington Post (7/29, Ryan, Deyoung, Morris, +14.2M) also reports that "the plan already has received considerable opposition from politicians of both parties, +who fear it will weaken deterrence against Russia and heighten strains with NATO allies." The Post also reports +that Esper's announcement "brought immediate criticism from German lawmakers. By withdrawing troops, +Washington is achieving 'exactly the opposite' of what it says it wants, said Norbert Röttgen, chairman of the +German parliament's committee for foreign affairs." +Politico < https://www.politico.com/news/2020/07/29/us-to-pull-12-000-troops-from-germany-after-trump-callscountry-delinquent-386136> (7/29, Seligman, 4.29M) reports that at a news conference on Wednesday, Esper +"stressed that the plan will enhance NATO's ability to deter Russian aggression and strengthen U.S. alliances in +Europe, yet also reiterated the president's criticism of Germany." Esper said, "Let's be clear: I think Germany is +the wealthiest country in Europe, Germany can and should pay more to its defense, It should certainly meet the +2% standard and I would argue go above and beyond that." Politico notes that NATO Secretary-General Jens +Stoltenberg "said the plan 'underlines the continued commitment by the United States to NATO and to European +security,' and noted that the U.S. consulted 'closely' with all NATO allies ahead of the announcement." +The Washington Times (7/29, Meier, 492K) reports that Democrats say "the move will do the opposite and +will weaken U.S. efforts to counter Russian aggression in the region." Sen. Robert Menendez (D-NJ) said, +"Champagne must be flowing freely this evening at the Kremlin." He added, "Germany is an essential platform +for life-saving medical care for our troops at Landstuhl hospital, for the Enhanced Forward Presence effort in +Eastern Europe to counter Russia and for US security interests across the Middle East and Africa." Sen. Jack +Reed (D-RI) called the plan "self-inflicted wound by President Trump against American interests." He added, +"The Administration's moves outlined today lack a strategic rationale, weaken our allies' confidence in the +reliability of US defense commitments, and serve to embolden Putin's efforts to divide the Alliance." +In an editorial, the Wall Street Journal +(7/29, Subscription Publication, 7.57M) condemns the plan to remove US troops from Germany, arguing it will +hurt US interests while not saving money. While the Journal says Trump has legitimate concerns about Germany +on NATO, China, and Russia's gas pipeline, he is undermining American interests out of spite. The Journal links +the Russian invasion of Ukraine to previous troop withdrawal from Germany and predicts a similar response. +Space Force: Russia Testing Anti-Satellite Weapons. +Fox News (7/29, McKay, +27.59M) reports on its website that the Space Force cautioned that Russia recently undertook at least two antisatellite weapon tests, although Russia's Defense Ministry dismissed the allegation. Gen. John W. "Jay" +Raymond, Commander of US Space Command and US Space Force Chief of Space Operations, called the tests +"further evidence of Russia's continuing efforts to develop and test space-based systems, and consistent with the +Kremlin's published military doctrine to employ weapons that hold the US and allied space assets at risk." +Senate Report: Evading US Sanctions, Putin-Linked Oligarchs Bought Art. The New York Times + +(7/29, Bowley, 18.61M) reports the US Senate's Permanent Subcommittee on Investigations published a report +saying that companies linked to two Russian oligarchs, brother Arkady and Boris Rotenberg, "who are close to +President Vladimir P. Putin of Russia," were able to bypass US sanctions and buy $18.4 million in high-value art + + +by hiding behind an intermediary, who made the purchases. According to the report, "the financial transactions +were enabled by the secrecy and anonymity with which the art market operates and it called for tighter rules to +force greater transparency." Sen. Rob Portman (R-OH) said in a statement, "It is shocking that US banking +regulations don't currently apply to multimillion-dollar art transactions, and we cannot let that continue." +Additional coverage includes the Wall Street Journal (7/29, Crow, Subscription Publication, 7.57M). +Activity Suggests Ongoing Operations At North Korean Nuclear Complex. +38 North (7/29, Williams, Makowsky) reports activity +"throughout North Korea's Yongbyon Nuclear Scientific Research Center goes beyond a caretaker status," +according to satellite imagery, with details "suggest[ing] continued enrichment operations." However, "there has +been no evidence to suggest either the 5 MWe Reactor or the Experimental Light Water Reactor (ELWR) have +been operating." +Four Arrested In Hong Kong Under Security Law. +The Washington Post (7/29, O'Grady, 14.2M) reports that in "some of the most high-profile +detentions" in Hong Kong since Beijing imposed "a controversial national security law late last month restricting +many of the city's previous freedoms," police arrested four people between the ages of 16 and 21 on suspicion of +inciting secession. They could face life sentences. +Former US Ambassador: Administration Has Been "Hypercritical Of China." The Washington Free Beacon + (7/29, +Beyrer, 78K) reports former Ambassador to China Max Baucus told Chinese state outlet CGTN during a July 15 +interview that "the U.S. has been hypercritical of China ... sometimes without any proof." He blamed the "toxic" +political environment and said that the November elections would need to pass before "meaningful" policy +decisions could be made. +China Targeting Expatriates Through US Civil Suits. The Wall Street Journal + (7/29, Viswanatha, O'Keeffe, Subscription Publication, 7.57M) reports China is, in +addition to strong arm tactics - such as imprisoning family - using civil suits in American courts to try to force +expatriates to return to the country and face corruption charges. Some US government officials are alarmed at +China using civil lawsuits to target political fugitives on matters normally handled through diplomatic and lawenforcement channels. The Journal focuses on the case of Peng Xufeng, who says he is being targeted for not +testifying against Communist Party leader Xi Jinping's rivals. +Americans Receiving Mysterious Packages Of Seeds From China. The CBS Evening News + (7/29, story 9, +1:10, O'Donnell, 4.28M) reported on "mysterious packets of seeds that appear to come from China" people in all +50 states received through the mail. "Officials are scrambling to figure out if it's just a scam, or if they're +intended to be seeds of destruction." CBS' Janet Shamlian added, "State agriculture offices, flooded with calls, +are urging people not to plant them." The USDA, which is testing the mystery seeds, "believes it may be part of +what's called a brushing scam, where a seller sends unsolicited packages and posts fake reviews to boost sales." +Turkey Passes Law Imposing Government Control Over Social Media. + + +The New York Times +(7/29, Santora, 18.61M) reports, "Turkish lawmakers passed legislation on Wednesday that would give the +government sweeping new powers to regulate social media content." Under the bill, social media platforms with +over one million daily users - such as Facebook, Twitter, and You Tube must open offices in Turkey, which will +block or remove content at the direction of the government, as well as "store user data inside Turkey, raising +privacy concerns." Those that don't comply face "stiff penalties," including being made "largely inaccessible" +due to slowed bandwidth. Crities cast the law as "part of a broader effort to control the flow of information in the +country and stifle dissent." +WPost Blasts Azerbaijani President For Imprisoning Opposition. +In an editorial, the Washington Post (7/29, 14.2M) writes that Azerbaijani President Iham Aliyev "has blown a gasket," +imprisoning his political opposition in a "tantrum...threatening to obliterate what remains of independent +political forces in Azerbaijan." The Post concludes, "Aliyev's use of the iron fist to destroy his critics is the +opposite of democracy and why everyone should worry about this intemperate tyrant." +The Big Picture +Headlines From Today's Front Pages. +Wall Street Journal: +Big Tech's Power Comes Under Fire At Congressional Antitrust Hearing +Fed Maintains Stimulus Commitment As Economic Outlook Dims +Trump Administration, Oregon Agree To Reduce Federal Agents In Portland + +Boeing Plans Deeper Job, Production Cuts +Covid Spoiled Your Plans? Get A Planner, Say Devotees +China's New Tool To Chase Down Fugitives: American Courts +New York Times: +Lawmakers, United In Their Ire, Lash Out At Big Tech's Leaders + +A Viral Epidemic Splintering Into Deadly Pieces +Teachers Are Wary Of Returning To Class, And Online Instruction Too + +Federal Agencies Agree To Withdraw From Portland, With Conditions + + + +An Extra $600 A Week Kept Many Jobless Workers Afloat. Now What Will They Do? + +In Russia's Far East, A New Face Of Resistance To Putin's Reign + +Washington Post: +Trends Show Young Adults Exposing Elders To The Virus +"Too Many": US Toll Nears 150,000 +Lawmakers Grill Tech Execs Over Market Might + +Pact Aimed At Lowering Tensions In Portland +Latinos Changed Ariz. Do Campaigns See Them? +Financial Times: +Big Tech Bosses Told They Have "Too Much Power" +US To Pull Almost 12,000 Troops Out Of Germany +Kodak Shares Rise Nearly 1,500% On Covid Drug Loan Deal +Washington Times: +Declining Coronavirus Case Fatality Rate In US Renews Questions On Merits Of Lockdown + +Oregon Governor Blinks In Portland Protest Standoff With Feds + +Pentagon Advances Historic Reshuffling Of Forces In Europe, Redraws NATO's Defense Lines + +EPA Speeds Up Colorado Cleanup As Climate Change Takes Back Seat To Superfund + +Trump Campaign Convinced Undercount, Hidden Support Skewing Polls + +Lawmakers Rips Big Tech CEOs Over Accusations Of Bias, Antitrust Violations + +Story Lineup From Last Night's Network News: +ABC: Coronavirus-Rising Cases; Trump-Hydroxychloroquine; Rep. Gohmert-Tests Positive; Biden-VP +Speculation; Trump-Putin; Arizona-Union Pacific Freighter Derailed; Minneapolis-Search for Man Who Incited +Violent Protests; NYC-Unmarked Car Arrest; East Coast-Shark Sightings; Severe Weather; John Lewis-Funeral; +Michigan-Woman's Biscuit Recipe Goes Viral. +CBS: Coronavirus-Rising Cases; Rep. Gohmert-Tests Positive; Trump-Hydroxychloroquine; Trump-Putin; +Biden-Trump; NYC-Unmarked Car Arrest; Arizona-Union Pacific Freighter Derailed; Congress-Tech +Companies; USDA-China Seed Packets; John Lewis-Funeral; Severe Weather; Georgia-Inmates Hailed As +Heroes; Navy-First Black Female Fighter Pilot. +NBC: Coronavirus-Rising Cases; Rep. Gohmert-Tests Positive; Trump-Hydroxychloroquine; Gohmert-Reaction; + + +NYC-Unmarked Car Arrest; Congress-Tech Companies; John Lewis-Funeral; Arizona-Union Pacific Freighter +Derailed; Severe Weather; Biden-VP Speculation; Coronavirus-Hunger & Children; Michael Phelps-HBO +Documentary; NASA-Mars Mission. +Network TV At A Glance: +Coronavirus - 13 minutes, 50 seconds +NYC-Unmarked Car Arrest - 4 minutes, 25 seconds +John Lewis-Funeral - 4 minutes, O seconds +Rep. Gohmert-Tests Positive - 3 minutes, 45 seconds +Trump-Hydroxychloroquine - 3 minutes, O seconds +Arizona-Union Pacific Freighter Derailed - 2 minutes, 15 seconds +Story Lineup From This Morning's Radio News Broadcasts: +ABC: Coronavirus-Rising Cases; Trump-Texas Visit; Florida-Testing Sites Closing Due To Tropical Storm; +SCOTUS-RBG Hospitalized; New Orleans-Collapsed Hard Rock Hotel. +CBS: Powell-Economic Downturn; Mnuchin-Relief Bill; SCOTUS-RBG Hospitalized; Congress-Tech +Companies; Detroit-Federal Agents; USDA-China Seed Packets; Stocks. +FOX: Congress-Tech Companies; Rep. Gohmert-Tests Positive; Coronavirus-Rising Cases. +NPR: Congress-Tech Companies; Rep. Gohmert-Tests Positive; Coronavirus-Rising Cases; Cleveland-Federal +Agents; NYC-Unmarked Car Arrest; Stocks. +Washington's Schedule +Today's Events In Washington. +White House: +* President Trump — Tours the American Red Cross National Headquarters; participates in a roundtable on +donating plasma +* Vice President Pence — Visits Pennsylvania for a bus tour, with agenda including touring Guy Chemical +Company and delivering remarks, 'applauding the efforts of Pennsylvanians who have worked to slow the spread +of coronavirus (COVID-19) and safely reopen the state'; participates in 'Cops for Trump event' in Greensburg, +US Senate: +* Senate Foreign Relations Committee Business Meeting - Senate Committee on Foreign Relations Business +Meeting +Location: Rm 106, Dirksen Senate Office Building, Washington, DC; 8:30 AM +* Secretary of State Pompeo testifies to Senate Foreign Relations Committee on FY'21 budget - Hearing on +'Review of the FY 2021 State Department Budget Request', with testimony from Secretary of State Mike +Pompeo * Committee follows guidelines developed to protect the health of members, witnesses, staff, and the +public, including maintaining six-foot social distance spacing in the hearing room and not accommodating inperson visitors +Location: Rm 106, Dirksen Senate Office Building, Washington, DC; 8:45 AM + + +* Senate Finance Committee second hearing on protecting the reliability of the medical supply chain during +coronavirus - Hearing on 'Part 2: Protecting the Reliability of the U.S. Medical Supply Chain During the +COVID-19 Pandemic', with testimony from Vizient Group Senior Vice President Cathy Denning; UC Health +Senior Vice President and Chief Supply Chain and Logistics Officer Rob Wiehe; International Safety Equipment +Association President Charles Johnson; and American Nurses Association President Dr Ernest Grant +Location: Rm 215, Dirksen Senate Office Building, Washington, DC; 9:30 AM +* Senate Armed Services Committee nominations hearing - Nominations hearing considers Anthony Tata to be +Under Secretary of Defense for Policy * Tata's nomination has faced criticism over reports that he has previously +advocated conspiracy theories and made anti-Muslim comments on social media, including claiming that former +CIA Director John Brennan sent a coded Tweet ordering the assassination of President Donald Trump and saying +that former President Barack Obama was a Muslim +Location: Rm G50, Dirksen Senate Office Building, Washington, DC; 9:30 AM +* Senate Judiciary Committee Executive Business Meeting - Executive Business Meeting, with agenda +including 'S. 4212, Civil Justice for Victims of COVID Act', and nominations of David Dugan and Stephen +McGlynn to be U.S. District Judges for the Southern District of Illinois; Hala Jarbou to be U.S. District Judge for +the Western District of Michigan; Jain Johnston and Franklin Ulyses Valderrama to be U.S. District Judges for +the Northern District of Illinois; and Roderick Young to be U.S. District Judge for the Eastern District of Virginia +Location: Rm 325, Russell Senate Office Building, Washington, DC; 10:00 AM +* Senate Commerce subcommittee hearing on 'The China Challenge' - Security Subcommittee hearing on 'The +China Challenge: Realignment of U.S. Economic Policies to Build Resiliency and Competitiveness', with +testimony from Brookings Institution Chinese Strategy Initiative Director Dr Rush Doshi; U.S.-China Economic +and Security Review Commission Commissioner Michael Wessel; Under Secretary of State for Economic +Growth, Energy, and the Environment Keith Krach; and Assistant Secretary of Commerce for Industry and +Analysis Nazak Nikakhtar +Location: Rm 253, Russell Senate Office Building, Washington, DC; 10:00 AM +* USS Indianapolis crew honored with Congressional Gold Medal, virtually - Congressional Gold Medal +Ceremony honoring the crew of the USS Indianapolis - which earned 10 battle stars, including the Battle of Iwo +Jima and the Battle of Okinawa, before sinking and killing 879 of its 1,195 crewmen - with participants +including House Speaker Nancy Pelosi, Senate Majority Leader Mitch McConnell and Minority Leader Chuck +chumer, Republican Sen. Todd Young, bipartisan Reps. Andre Carson and Larry Bueshon, Indiana Governo +Eric Holcomb, and Secretary of the Navy Kenneth Braithwaite * Medal is the highest honor Congress car +bestow; 11:00 AM +US House: +* Tom Lantos Human Rights Commission hearing on religious freedom in China - Tom Lantos Human Rights +discussing the religious freedom implications for China of the case of Bishop Su - the Catholic bishop of +Baoding, who has been under arrest for the past 17 years +Location: Rm 2172, Rayburn House Office Building, Washington, DC; 9:00 AM +* House Committee on Veterans' Affairs markup hearing + + +Location: HVC-210, U.S. Capitol Visitor Center, Washington, DC; 10:00 AM +* House meets for legislative business - House of Representatives meets for legislative business, with agenda for +the week including completion of consideration of 'H.R. 7027 - Child Care Is Essential Act' and 'H.R. 7327 - +Child Care for Economic Recovery Act', consideration of 'H.R. 7617 - Defense, Commerce, Justice, Science, +Energy and Water Development, Financial Services and General Government, Homeland Security, Labor, Health +and Human Services, Education, Transportation, Housing, and Urban Development Appropriations Act, 2021', +and consideration of 'H.R. 4686 - Sami's Law" +, as amended, and 'H.R. 7575 - Water Resources Development +Act of 2020', as amended, under suspension of the rules +Location: U.S. Capitol, Washington, DC; 10:00 AM +* USS Indianapolis crew honored with Congressional Gold Medal, virtually - Congressional Gold Medal +Ceremony honoring the crew of the USS Indianapolis - which earned 10 battle stars, including the Battle of Iwo +Jima and the Battle of Okinawa, before sinking and killing 879 of its 1,195 crewmen - with participants +including House Speaker Nancy Pelosi, Senate Majority Leader Mitch McConnell and Minority Leader Chuck +Schumer, Republican Sen. Todd Young, bipartisan Reps. Andre Carson and Larry Bueshon, Indiana Governor +Eric Holcomb, and Secretary of the Navy Kenneth Braithwaite * Medal is the highest honor Congress can +bestow; 11:00 AM +* House Financial Services Committee hybrid hearing on the CFPB during coronavirus - Hybrid hearing on +'Protecting Consumers During the Pandemic? An Examination of the Consumer Financial Protection Bureau' +with testimony from CFPB Director Kathleen Kraninger, held virtually via WebEx and in-person in Rm 2128, +Rayburn House Office Building; 12:30 PM +* House Armed Services subcommittee hearing on Cyberspace Solarium Commission recommendations - +Intelligence and Emerging Threats and Capabilities Subcommittee hearing on 'Review of the Recommendations +of the Cyberspace Solarium Commission', +' with testimony from Commission Chairmen Independent Sen. Angus +King and Republican Rep. Mike Gallagher, and Commissioners Patrick Murphy and Frank Ciffullo * Held +virtually via WebEx and in-person in Rm 2118, Rayburn House Office Building; 1:00 PM +* House Foreign Affairs subcommittee hearing on coronavirus response in Africa - Africa, Global Health, +Global Human Rights and International Organizations Subcommittee hearing on 'Update on the COVID-19 +Pandemic Response in Africa' +, with testimony from Assistant Secretary of State for African Affairs Tibor Nagy +Jr.; and USAID Acting Assistant Administrator for Africa Christopher Maloney * Held virtually via Cisco +WebEx and in-person in Rm 2172, Rayburn House Office Building; 1:00 PM +Cabinet Officers: +* Secretary of State Pompeo testifies to Senate Foreign Relations Committee on FY*21 budget - Hearing on +'Review of the FY 2021 State Department Budget Request', with testimony from Secretary of State Mike +Pompeo * Committee follows guidelines developed to protect the health of members, witnesses, staff, and the +public, including maintaining six-foot social distance spacing in the hearing room and not accommodating inperson visitors +Location: Rm 106, Dirksen Senate Office Building, Washington, DC; 8:45 AM +* Transportation Secretary Chao leads virtual event celebrating the 1990 passage of the Americans with +Disabilities Act - Secretary of Transportation Elaine Chao leads 'Breaking Down Barriers' - a virtual +Department of Transportation event celebrating the passage of the Americans with Disabilities Act (ADA) in +1990. She and other leaders from across govt to 'acknowledge the accomplishments in transportation that have +resulted from this landmark civil rights legislation' and discuss 'actions that can help ensure an accessible +transportation future for all Americans'; 2:00 PM +Visitors: + + +* No visitors scheduled +This Town: +* Annual Congressional Clean Energy Expo and Policy Forum held online - 23rd Annual Congressional +Renewable Energy and Energy Efficiency EXPO and Policy Forum, hosted by Environmental and Energy Study +Institute in cooperation with members of the House Renewable Energy & Energy Efficiency Caucus, bringing +together businesses, trade associations, and govt agencies to showcase renewable energy and energy efficiency +technologies. Includes prerecorded remarks from Republican Sens. Susan Collins and Mike Crapo and +Democratic Sens. Chris Van Hollen, Jack Reed and Rep. Dave Loebsack, with other speakers including +American Public Power Association President and CEO Joy Ditto, National Association of Energy Service +Companies Executive Director Timothy Unruh, American Association of Blacks in Energy President and CEO +Paula Glober, Solar Energy Industries Association President and CEO Abby Ross Hopper and Energy Storage +Association President and CEO Kelly Speakes-Backman; 10:00 AM +* National Whistleblower Day celebration - National Whistleblower Day celebration, with this year's event held +as an interactive virtual conference. Speakers include keynote Republican Sen. Chuck Grassley; 12:00 PM +* Summit for Civil Rights - Summit for Civil Rights, hosted online by The Workers' Rights Institute at +Georgetown University Law School and the University of Minnesota Law School in Minneapolis, with Building +One America. Speakers include Democratic Rep. Hakeem Jeffries, Minnesota Attorney General Keith Ellison, +Rockefeller Foundation President Rajiv Shah, Spencer Foundation President Na'ilah Suad Nasir, Ford +Foundation President Darren Walker, AFL-CIO President Richard Trumka, American Postal Workers Union +Secretary-Treasurer Elizabeth Powell, Communications Workers of America President Christopher Shelton; 1:00 +PM +* GOP Rep. Greg Walden speaks at launch of BPC Energy Project Farm and Forest Carbon Solutions Initiative - +'Building a Bipartisan Agenda for Farm and Forest Carbon Solutions' Bipartisan Policy Center online +discussion, to launch the BPC Energy Project Farm and Forest Carbon Solutions Initiative and release their new +policy options synthesis report. Includes keynote from Republican Rep. Greg Walden, with other speakers +including BPC Farm and Forest Initiative Director Robert Bonnie, California Secretary of Agriculture Karen +Ross, and National Alliance of Forest Owners President and CEO Dave Tenny; 2:00 PM +* Health Affairs online briefing on 'NQF and 20 Years of Quality' - Health Affairs hosts The Care We Need: +NOF and 20 Years of Quality' online briefing, discussing 20 years of the National Quality Forum; a new report +from the National Quality Task Force, 'They Care We Need: Driving Better Health Outcomes for People and +Communities"; and its recommendations for improving the health and safety of all Americans. Speakers include +National Quality Forum President and CEO Shantanu Agrawal; Deputy Under Secretary of Veterans Affairs for +Discovery, Education and Affiliate Networks Carolyn Clancy; NQF founding President and CEO Kenneth Kizer; +Georgetown University Practice of Health Care Visiting Distinguished Professor Mary Wakefield; and Health +Affairs Editor-in-Chief Alan Weil; 2:00 PM +* EPA presidential environmental awards winners honored - Environmental Protection Agency honor 2020 +Presidential Environmental Youth Awards and Presidential Innovation Awards for Environmental Educators +winners, who present their work in a poster session. Former recognizes outstanding environmental stewardship +projects from kindergarten to 12th grade, while latter recognizes outstanding K-12 grade educators * Winners +will be invited to Washington, DC, in mid-2020 to be honored by the agency and present their work in a poster +session +Location: Washington, DC +Copyright 2020 by Bulletin Intelligence LLC Reproduction or redistribution without permission prohibited. +Content is drawn from thousands of newspapers, national magazines, national and local television programs, +radio broadcasts, social-media platforms and additional forms of open-source data. Sources for Bulletin +Intelligence audience-size estimates include Scarborough, GfK MRI, comScore, Nielsen, and the Audit Bureau +of Circulation. Data from and access to third party social media platforms, including but not limited to Facebook, + + +Twitter, Instagram and others, is subject to the respective platform's terms of use. Services that include Factiva +content are governed by Factiva's terms of use +Services including embedded Tweets are also subject to Twitter for Website's information and privacy policies +. The FBI News Briefing is published five days a week by +Bulletin Intelligence, which creates custom briefings for government and corporate leaders. We can be found on +the Web at BulletinIntelligence.com, or called at (703) 483-6100. diff --git a/vision-fixhub/ds9-parsed-01/2b4c5c7993beb3ab3f36c195968a5c512a39c52325d4444e5ce2a32a7bc6b347.receipt.json b/vision-fixhub/ds9-parsed-01/2b4c5c7993beb3ab3f36c195968a5c512a39c52325d4444e5ce2a32a7bc6b347.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..6458f61adb086cd04a65e1b966e8ef3eb9f9d6a3 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2b4c5c7993beb3ab3f36c195968a5c512a39c52325d4444e5ce2a32a7bc6b347.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -942, + "dataset": "marble-joined", + "doc_id": "2b4c5c7993beb3ab3f36c195968a5c512a39c52325d4444e5ce2a32a7bc6b347", + "engine": "marble-apple-vision", + "event_count": 216, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "83a6ec4cbf03ae4fc16d9934cffa872525662d4f7bb1a21b3d3cf3d5d15b33c5", + "output_sha256": "d671025447c11bab9f1223cfa4d39972a1d12800ae599ca96811497f51796219", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2b7f6ca2787d092e4f7c45c2a5f0017d2d6a0a67ccf75c9dac29989bc4318a23.md b/vision-fixhub/ds9-parsed-01/2b7f6ca2787d092e4f7c45c2a5f0017d2d6a0a67ccf75c9dac29989bc4318a23.md new file mode 100644 index 0000000000000000000000000000000000000000..03112c0280d9f7452700a15cc394d36363deb011 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2b7f6ca2787d092e4f7c45c2a5f0017d2d6a0a67ccf75c9dac29989bc4318a23.md @@ -0,0 +1,1194 @@ +CAPTAIN +CAPTAIN SEC +OPS LT +ACT LT +SHU LT +SIS LT +SIS LT #2 +SIA +SIS TECH*1 +PHONE MONITOR +SEC OFFICER #1 +SEC OFFICER #2 +TOOL ROOM +SEARCH OFFICER +2 SALLY OFF +3 SALLY OFF +LOBBY +Split Shift 2 00:00 - 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The Court Should Admit the Testimony of Dr. +A. Applicable Law +B. +Discussion +1. Dr. +2. Dr. +...3 +...4 +4 +5 +..9 +.10 +Opinions on Coercion and Attachment are Admissible +Opinion on the Relationship Between Trust and Victim Awareness of Their +Abuse is Admissible... +22 +3. Dr. +Opinion on the Long-Term Consequences of Abuse is Admissible +23 +4. Dr: +Opinion About the Significance of the Presence of Third Parties is Admissible +25 +5. Dr. +Opinion on Delayed Disclosure is Admissible +27 +II. The Evidence Contained in the Government's October 11, 2021 Letter is Admissible. +A. +Applicable Law +B. +Discussion +32 +. 33 +35 +1. The Evidence is Admissible As Direct Evidence, or in the Alternative, Under Rule 404(b).. 35 +2. The Government Has Met and Exceeded Its Notice Obligations... +.39 +III. The Testimony of Minor Victim-3 is Admissible. +A. +C. +A. +Background +B. Applicable Law +Discussion +41 +44 +45 +54 +IV. There is No Basis to Preclude Co-Conspirator Statements at Trial +Background +B. +Discussion. +.55 +58 + + +V. There is No Basis to Suppress Minor Victim-4's Identification of the Defendant +A. +B. +C. +A. +Background +Applicable Law. +Discussion +63 +63 +65 +67 +VI. The Court Should Deny the Defense Motions to Preclude the Government's Exhibits. +Applicable Law +B. +Discussion +VII. There is No Basis to Preclude Discussion of "Victims" or Rape +A. +References to Victims ... +71 +.72 +.76 +.76 +B. +VIII. +Evidence of Rape.. +The Remaining Defense Motions are Aimed at Evidence the Government Does Not Plan to Elicit +..79 +..81 +CONCLUSION +...83 +2 + + +PRELIMINARY STATEMENT +The Government respectfully submits this memorandum in opposition to the defendant's +thirteen motions in limine, dated October 18, 2021. For the reasons that follow, the defendant's +motions should be denied +First, the Government has given notice of a qualified expert who will provide reliable and +relevant opinions, as required by Federal Rule of Evidence 702 and Daubert v. Merrell Dow +Pharmaceuticals, Inc., 509 U.S. 579 (1993). (See Def. Mot. 3). Second, evidence relating to +Minor Vietim-3 is admissible both as direct evidence of the charged crimes, and admissible in the +alternative under Rule 404(b). (See Def. Mot. 4). Third, the Government has provided adequate +notice pursuant to Rule 404(b), and in any event, all evidence for which it has provided such notice +is also admissible as direct evidence of the charged crimes. (See Def. Mot. 2). Fourth, there is no +basis to preclude the introduction of co-conspirator statements under Fed. R. Evid. 801(d)(2)(E). +(See Def. Mot. 1). Fifth, Minor Victim-4's confirmatory identification of the defendant was not +unduly suggestive, and it should not be suppressed. (See Def. Mot. 9). Sixth, the Government's +various exhibits are relevant, and the Government will authenticate them at trial. (See Def. Mots. +7, 8, 13). Seventh, it is entirely proper for the word "victim" and for discussion of rape to be used +in a trial about the sexual exploitation of minor victims. (See Def. Mots. 11, 12). Eighth, and +finally, the Government does not intend to offer evidence of the defendant's flight, her false +exculpatory statements, or law enforcement expert testimony in its case in chief, unless the +defendant opens the door or otherwise puts this evidence in issue. (See Def. Mots. 5, 6, 10). +3 + + +ARGUMENT +The Court Should Admit the Testimony of Dr. +The Government intends to call Dr. +as an expert witness. Dr. +is the +President-Elect of the Division of Trauma Psychology at the American Psychological Association. +She is currently a clinical instructor at the Alpert Medical School of Brown University, and she +has practiced psychology for approximately 25 years, specializing in treating patients with trauma, +including sexual trauma in childhood and adolescence. Dr. +has treated hundreds of +victims of trauma, including many victims of child sexual abuse, and she has written, presented, +and taught about the assessment and treatment of trauma. She has also received continuing +education on trauma and the treatment of trauma in a clinical setting. (See generally Curriculum +Vitae, Def. Mot. 3 Ex. 2). +On April 23, 2021, the Government timely notified the defendant of its intent to call Dr. +in its case-in-chief. As the notice explains, Dr. +is expected to testify, based on +her relevant education, training, experience, and research, and offer the following opinions: +Individuals with particular vulnerabilities are often targeted by +perpetrators of sexual abuse. Sexual abuse of minors frequently +occurs through the use of manipulation or coercion in the context of +an established relationship that is developed over time, rather than +through the use of forcible rape. Minor victims are often subject to +a strategic pattern of behaviors, often called grooming, that can take +a variety of forms and function to render the victims vulnerable to +abuse, to obscure the nature of the abuse, and to build trust and +attachment with their abuser. The relationship of trust and +ttachment can prevent victims from being aware that what they ar +xperiencing is abuse and can prevent disclosure. Minor victim +therefore may not identify themselves as victims of abuse while it is +ongoing, and may not recognize the consequences of that abuse unti +adulthood. Repeated exploitation and abuse can increase the +likelihood of victimization later in life and can result in long-term +4 + + +traumatic and psychological consequences, especially when it +occurs in the context of complex trauma. The presence of othe +individuals can facilitate the sexual abuse of minors. Dr. | +also expected to testify that nondisclosure, incremental disclosure, +and secrecy are common among victims of sexual abuse for a variety +of reasons, and that memory and disclosure of traumatic or abusive +events is impacted by a number of factors, including the +circumstances surrounding the trauma. +(Expert Notice, Def. Mot. 3 Ex. 1 at 2). As the notice also explained, Dr. +has not evaluated +any of the victims in this case, and the Government does not currently intend to offer Dr. +testimony regarding any specific victim. (See id.). +There is nothing controversial about this testimony. It is well supported by established +scientific principles, and it is the kind of testimony frequently admitted in cases involving sexual +abuse. This Court should do the same. +A. Applicable Law +District courts have a "gatekeeper function" in analyzing the admissibility of expert +testimony. Phelps v. CBS Corp., No. 17 Civ. 8361 (AJN), 2020 WL 7028954, at *3 (S.D.N.Y. +Nov. 30, 2020) (quoting Restivo v. Hessemann, 846 F.3d 547, 575 (2d Cir. 2017)). Although +the proponent of the evidence carries a burden of proof to establish its admissibility by a +preponderance of the evidence, see, e.g., United States v. Jones, 965 F.3d 149, 161 (2d Cir. +2020), courts apply a "presumption of admissibility of evidence." Felix v. City of New York, +No. 16 Civ. 5845 (AJN), 2020 WL 6048153, at *6 (S.D.N.Y. Oct. 13, 2020) (quoting Borawick +v. Shay, 68 F.3d 597, 610 (2d Cir. 1995)). Accordingly, the relevant rule of evidence, Rule 702, +reflects "the "liberal thrust' of the Federal Rules and their "general approach of relaxing the +traditional barriers to 'opinion' testimony." Daubert v. Merrell Dow Pharms., Inc., 509 U.S. +5 + + +579, 588 (1993) (quoting Beech Aircraft Corp. v. Rainey, 488 U.S. 153, 169 (1988)). +Under Daubert, a district court must first determine whether an expert is qualified. See +Fed. R. Evid. 702 ("A witness who is qualified as an expert by knowledge, skill, experience, +training, or education may testify in the form of an opinion or otherwise ...."); United States v. +Kidd, 385 F. Supp. 3d 259, 263 (S.D.N.Y. 2019) ("At the first step of the Daubert inquiry, courts +are instructed to consider the expert's qualifications."). Courts then must determine whether the +testimony "will be not only relevant, but reliable." United States v. Romano, 794 F.3d 317, 330 +(2d Cir. 2015); see Daubert, 509 U.S. at 597 (explaining that courts must ensure "that an expert's +testimony both rests on a reliable foundation and is relevant to the task at hand"). On reliability, +Rule 702 identifies three "indicia of reliability": (1) "that the testimony is grounded on sufficient +facts or data; (2) that the testimony is the product of reliable principles and methods; and (3) that +the witness has applied the principles and methods reliably to the facts of the case." United +States v. Williams, 506 F.3d 151, 160 (2d Cir. 2007) (quoting Amorgianos v. Nat'l R.R. +Passenger Corp., 303 F.3d 256, 265 (2d Cir. 2002)). "[T]hese criteria," however, "are not +exhaustive." Id. Daubert itself, which "dealt with a scientific theory," offered additional factors, +such as whether the theory has been subjected to peer review and publication," and the +""known or potential rate of error."" Romano, 794 F.3d at 330 (quoting Daubert, 509 U.S. at +593-94). And "there are many different kinds of experts, and many different kinds of expertise." +Kumho Tire Co. v. Carmichael, 526 U.S. 137, 150 (1999). "[W]hether the specific expert +testimony focuses +upon specialized observations, the specialized translation of those +observations into theory, a specialized theory itself, or the application of such a theory in a +6 + + +particular case, the expert's testimony will often rest upon an experience confessedly foreign in +kind to the jury's own." Id. at 149 (alterations and internal quotation marks omitted); see United +States v. Felder, 993 F.3d 57, 71-72 (2d Cir. 2021) ("Such specialized knowledge can be +grounded in scientific or other particularized training, but it can also derive from personal +observations or experience, see id., so long as those observations or experience are outside the +ken of the average person." (internal quotation marks and citations omitted)); Fed. R. Evid. 702, +Advisory Committee's Note (2000) (explaining that expert testimony may be based on +"experience alone or experience in conjunction with other knowledge, skill, training or +education"). +The key question is whether "an expert, whether basing testimony upon professional +studies or personal experience, employs in the courtroom the same level of intellectual rigor that +characterizes the practice of an expert in the relevant field." Kumho Tire, 526 U.S. at 152; see +Williams, 506 F.3d at 160 (explaining that the Daubert test is "flexible"). In particular, if an +expert's testimony is within "the range where the experts might reasonably differ," the jury, not +the trial court, should be the one to decide among the conflicting views of different experts. +Kumho Tire, 526 U.S. at 153. So long as the testimony is not "speculative or conjectural or +based on assumptions that are so unrealistic and contradictory as to suggest bad faith or to be in +essence an apples and oranges comparison... any other contentions that the assumptions are +unfounded go to the weight, not the admissibility of the testimony." Phelps, 2020 WL 7028954, +at *3 (citations and internal quotation marks omitted). Thus, ""the rejection of expert testimony +is the exception rather than the rule." Floyd v. City of New York, 861 F. Supp. 2d 274, 287 +7 + + +(S.D.N.Y. 2012) (citing Fed. R. Evid. 702 Advisory Committee's Notes (2000 Amendments)). +"IT]he law grants a district court the same broad latitude when it decides how to determine +reliability as it enjoys in respect to its ultimate reliability determination." Kumho Tire, 526 U.S. +at 142 (emphasis in original); see United States v. Requena, 980 F.3d 30, 47 (2d Cir. 2020). Thus +a district court may properly exercise its gatekeeping function without the "formality of a separate +hearing[.]" Williams, 506 F.3d at 161; see also United States v. Barnes, 411 F. App'x 365, 370 +(2d Cir. 2011) (summary order). "This is particularly true if, at the time that the expert testimony +is presented to the jury, a sufficient basis for allowing the testimony is on the record." Williams, +506 F.3d at 161 (citing 4 Weinstein's Federal Evidence § 702.02 [2] (2d ed. 2006)). +Finally, even if the expert testimony is reliable, it must also be relevant. See, e.g., United +States v. Torres, No. 20 Cr. 608 (DLC), 2021 WL 1947503, at *6 (S.D.N.Y. May 13, 2021). In +this context, +, the testimony must "concern matters that the average juror is not capable of +understanding on his or her own." United States v. Mejia, 545 F.3d 179, 194 (2d Cir. 2008); see +Faulkner v. Arista Records LLC, 46 F. Sup. 3d 365, 375 (S.D.N. Y. 2014) ("Weighing whether the +expert testimony assists the trier of fact goes primarily to relevance."). +Courts have frequently admitted expert testimony on the psychological relationship +between perpetrators and victims of sex crimes. For instance, in United States v. Kidd, 385 F. +Supp. 3d 259 (S.D.N.Y. 2019), the Government gave notice of expert testimony on "the +psychology of the pimp-prostitute relationship," including concepts such as "trauma bonding." Id. +at 263. The defendant interposed a Daubert challenge, arguing that the expert's testimony was not +based on "studies or empirical data" and so could not "be assessed for reliability." Id. (internal +8 + + +quotation marks omitted). The district court rejected that argument, explaining that "case law quite +commonly upholds this type of testimony against Daubert challenges," and that the expert's +experience writing about, treating, and speaking to prostitutes was sufficiently reliable. Id. at 263- +64; see also, e.g., Letter, United States v. Kelly, No. 19 Cr. 286 (AMD) (E.D.N.Y. July 23, 2021) +(Dkt. No. 134); United States v. Torres, No. 20 Cr. 608 (DLC), 2021 WL 1947503, at *6 (S.D.N.Y. +May 13, 2021) (permitting expert testimony on "domestic abuse and coercive control"); Feb. 25, +2020 Tr. at 24:1-40:15, United States v. Randall, 19 Cr. 131 (PAE) (S.D.N.Y.), Dkt. No. 335 +(permitting expert testimony on "[t]rauma and coercive control in the context of sex trafficking, +including the psychological relationship between pimps and the women prostituted by them"); +Notice and Oct. 17, 2019 Tr. at 27:1-12, United States v. Dupigny, No. 18 Cr. 528 (JMF) +(S.D.N.Y.), Dkt. Nos. 180-1, 198 (permitting expert testimony on "the psychological relationship +between a pimp and the woman prostituted by him" and "why prostituted women do not leave +their pimp"). +B. Discussion +The defendant does not contest that Dr. +is a qualified expert. Nor could she: Dr. +is a leader in her field, teaching others as a professor at Brown University, and she has +approximately twenty-five years of clinical experience. She is testifying in general about core +concepts in her field, based on her "extensive study of the relevant data and literature and her +clinical experience treating hundreds of trauma and abuse patients over the past twenty years." +9 + + +United States v. Raniere, No. 18 Cr. 204 (NGG), 2019 WL 2212639, at *7 (E.D.N.Y. May 22, +2019). +Instead, the defendant suggests that Dr. +opinions are unreliable, irrelevant, or +prejudicial. To the contrary, and as explained in greater detail below, each of the Dr. +five challenged opinions is well supported and would aid the jury in understanding the evidence +at trial. The Court should permit Dr. +to testify. +1. D. Relanity +As described in the expert notice, Dr. +Opinions on Coercion and Attachment are Admissible +will testify about the role that trust and +attachment play in relationships between a victim and an abuser: +Sexual abuse of minors frequently occurs through the use of +manipulation +coercion in the context of an established +relationship that is developed over time, rather than through the use +of forcible rape. Minor victims are often subject to a strategic pattern +of behaviors, often called grooming, that can take a variety of forms +and function to render the victims vulnerable to abuse, to obscure +the nature of the abuse, and to build trust and attachment with their +abuser. The relationship of trust and attachment can prevent victims +from being aware that what they are experiencing is abuse and can +prevent disclosure. +(Expert Notice, Def. Mot. 3 Ex. 1 at 2). Dr. +will opine that victims are often abused in +the context of a coercive and manipulative relationship which develops over time through the +building of victims" trust and attachment. +One aspect of this relationship is "often called +grooming." (Def. Mot. 3 Ex. 1 at 2). However, the concepts of attachment and coercion go beyond +grooming, and encompass both the trust-building aspect of the relationship and the ways in which +10 + + +that bonds vietims to their abusers and prevents victims from disclosing that they have been +abused.' +These opinions stem in part from Dr. +personal familiarity and experience +treating victims of sexual abuse for decades. She is trained in trauma psychology, she has expertise +in treating victims of sexual abuse who have been subject to this pattern of behavior, and she +teaches residents about trauma psychology. Cf. Bosco v. United States, No. 14 Civ. 3525 (JFK), +2016 WL 5376205, at *11 (S.D.N. Y. Sept. 26, 2016) (expert testimony about "common knowledge +among urologists" require the expert to "draw upon the defining characteristics that make him a +member of that community: his training as a urological surgeon, his practical experience +performing several hundred ureteroscopies, and his knowledge as a clinical instructor of surgery"). +These opinions also stem from the relevant literature. This pattern of coercive attachment +is not a novel or outlier concept in the literature of trauma psychology. For instance, attached as +Exhibit A are some of the articles that have been provided by Dr. +and inform her +testimony. See Dietz, "Grooming and Seduction," 33 J. of Interpersonal Violence 28, 34 (2018) +' The concepts of attachment and grooming encompass a variety of established techniques, +including: (1) the use of attention, love, and affection; (2) using bribery and gift giving; (3) sexual +desensitization that is, talking to children about sex and engaging in touching; (4) isolating the +victim; and (5) engaging in emotional manipulation. Grooming efforts can also extend to +"grooming the environment." Craven et al., "Sexual grooming of children: Review of literature +and theoretical considerations," 3 J. of Sexual Aggression 287, 292-93 (2006) ("Some offenders +groom the environment by targeting single-parent families to gain [a position of trust].] Offenders +may do this because they believe that these children are more vulnerable and because they believe +it will be easier to create opportunities to be alone with the child. Alternatively, offenders may +target children or young people who have absent parents, and hence have less protection." (citation +omitted)). +11 + + +("Since its introduction to the peer-reviewed professional literature in 1984, the term 'grooming' +has become so widely adopted that it will remain in widespread use for decades to come."); +Bennett & O'Donohue, "The Construct of Grooming in Child Sexual Abuse: Conceptual and +Measurement Issues," 23 J. Child Sexual Abuse 957, 964-68 (2014) (reviewing the literature on +the prevalence of various grooming techniques); Craven et al., "Sexual grooming of children: +Review of literature and theoretical considerations," 3 J. of Sexual Aggression 287, 292-93 (2006) +("[R]etrospective identification of sexual grooming, i.e. after a sexual offence has been committed, +is much easier than prospective identification, i.e. before a sexual offence"). To be clear, however, +her review of the literature-and therefore the basis of her testimony extends beyond these +articles. +Accordingly, Dr. +came to her opinions through her clinical experience on this +specific issue, as informed by her education and study of the relevant literature. That is a sufficient +demonstration of "how the expert came to [her] conclusion and what methodologies or evidence +substantiate that conclusion." Riegel v. Medtronic Inc., 451 F.3d 104, 127 (2d Cir. 2006); see Feb. +25, 2020 Tr. at 24:1-40:15, United States v. Randall, 19 Cr. 131 (PAE) (S.D.N.Y.), Dkt. No. 335 +(rejecting the notion that "the many studies that have validated trauma bonding and coercive +controls as established phenomena are unreliable for want of laboratory-like statistical vetting"); +Oct. 17, 2019 Tr. at 27:1-12, United States v. Dupigny, No. 18 Cr. 528 (JMF) (S.D.N.Y.), Dkt. +Nos. 180-1, 198 (explaining that "the basis for the testimony—namely, the witness's training and +experience +—is not such that it would be subject to exclusion on the grounds that it's not based on +12 + + +some sort of empirical scientific testing," and that "those arguments go to the weight, not the +admissibility, of her proposed testimony"). +As noted above, courts have frequently admitted testimony about the psychological +relationship between victims of sexual abuse and their perpetrators. See supra pp. 7-8. Courts +have also specifically authorized expert testimony on the subject of grooming. See, e.g., United +States v. Telles, 6 F.4th 1086, 1097-1098 (9th Cir. 2021) (holding that admission of expert +testimony on grooming did not violate Federal Rules of Evidence 702 or 403 nor violate due +process and finding that the expert ** merely gave a straightforward account of relevant background +information based on [the expert's] own knowledge and experience'" (quoting United States v. +Johnson, 860 F.3d 1133, 1141 (8th Cir. 2017)); United States v. Halamek, 5 F.4th 1081, 1087-89 +(9th Cir. 2021) (holding that expert testimony on grooming was "relevant, reliable, and properly +admitted"); United States v. Isabella, 918 F.3d 816, 833 n. 15 (10th Cir, 2019) ("Grooming can be +established by use of an expert witness who testifies about psychological tactics that are common +in cases of child sex abuse."); United States v. Hitt, 473 F.3d 146, 158 (5th Cir. 2006) (affirming +expert testimony on the "grooming process"); Morris v. State, 361 S.W.3d 649, 656-69 (Tx. Ct. +Crim. App. 2011) (collecting cases showing that "grooming evidence has been received by courts +from numerous types of experts"); see also United States v. Brand, 467 F.3d 179, 203 (2d Cir. +2006), abrogated on other grounds by United States v. Cabrera, 13 F.4th 140 (2d Cir. 2021) +(noting that evidence of grooming supported the jury's verdict). +Against this weight of authority, the defendant relies principally on one case from the +District of Maine. United States v. Raymond, 700 F. Supp. 2d 142 (D. Me. 2010). The proposed +13 + + +testimony in this case is readily distinguishable from that in Raymond. There, the government +gave notice of expert testimony about the "behavior of child molesters" from a veteran FBI agent +who had reviewed case studies of child abuse and had written one book and one article. Id. at 143, +145, 147. The purported expert's book, in turn, merely made assertions about the "profile" of child +molesters, with no information about how his experiences reliably led to his conclusions. Id. at +147-48. In the same breath, however, the book "disavow[ed] [its] reliability ... for legal use," and +his article similarly offered generalized views on what "many" offenders were "more likely or less +likely to do." Id. at 148 (emphasis omitted). Accordingly, at bottom, the purported expert's +testimony was based only on his subjective conclusions after reviewing case studies. See id. at +147 n.5 (explaining that the expert "troubling[ly]" wrote that "data is not the plural of anecdote," +but "the information and opinions are based primarily on the totality of my acquired knowledge +and expertise"). +The situation here is quite different. Dr. +conclusions are not anecdotal; they are +grounded in the academic literature and her formal and informal education. Moreover, she will be +testifying about concepts she regularly employs as a practicing clinician. Again, the defense does +not contest that Dr. +is qualified to be an expert on this subject. And Dr. +opinions are not an attempt to offer a "profile" of perpetrators of child sexual abuse or their +activities. +Instead, Dr. +will testify about the psychological underpinnings of an +14 + + +established pattern of victimization +-attachment and coercion-experienced by victims of sexual +abuse. +The defense would read Raymond to stand for the proposition that expert testimony is +unreliable if it does not explain "what testing was involved, what data she considered, or how her +conclusions can be verified." (Def. Mot. 3 at 8). For instance, the defense criticizes Dr. +for opining that sexual abuse of minors occurs "frequently," without specifying whether it occurs +"half the time" or "two-thirds of the time." (Id. at 7; see id. at 8 (quoting Raymond, 700 F. Supp. +2d at 148-49)). That is not what is required by Daubert in the context of qualitative social science, +and it is not what many courts have held in the context of precisely this form of testimony, as +explained above. To the extent Raymond stands for such a broad proposition, it is contrary to the +law of this Circuit. See United States v. Joseph, 542 F.3d 13, 21-22 (2d Cir. 2008), abrogated on +other grounds as recognized by United States v. Ferguson, 676 F.3d 260, 276 n.14 (2d Cir. 2011) +(recognizing that social +science research "cannot have the exactness of hard science +methodologies, and expert testimony need not be based on statistical analysis in order to be +probative" (citation and internal quotation marks omitted)).Z +The defendant's remaining critiques of Dr. +opinion miss the mark. First, the +defendant asserts that Dr. +patients are uncorroborated, and she "simply assumes her +- Even in Raymond, the Court left open the possibility that the Government could call the expert +it should similarly revisit permitting Dr. +attacks victim credibility. +15 + + +patients are telling the truth." (Def. Mot. 3 at 6). The defendant claims that this "fatally +undermines the reliability of her opinion" because her conclusion has "no known or identified rate +of error... nor is there a reliable method or a series of factors guiding +conclusion as to +whether an individual victim is fabricating her abuse." (Id. (alterations and quotation marks +omitted)). Clinical psychologists are not so +credulous. As part of Dr. +work as a +practicing clinician, she examines consistencies and inconsistencies in the information provided +by patients and assesses patient self-reporting in the context of literature and knowledge that she +has developed in her years of practice. As the Government's expert notice makes clear, Dr. +has treated hundreds and hundreds of patients in her decades of experience, and her +opinions are based in part on the significant patterns she has observed among the patients she has +treated. The Court should reject the defendant's speculative claim that Dr. +has been +misled by hundreds of patients who sought professional treatment for traumatic events that did not +occur. +In any event, the defendant's argument about error rates misunderstands the nature of a +Daubert inquiry. An error rate is but one of the Daubert factors that may or may not be applicable +in every case. See Romano, 794 F.3d at 330. And in cases such as this, where a social science +expert is testifying based on qualitative methodology, that factor is inapplicable. See Torres, 2021 +WL 1947503, at *6 n.8. As the Second Circuit has explained, "Peer review, publication, potential +error rate, etc.... are not applicable to this kind of testimony, whose reliability depends heavily +on the knowledge and experience of the expert, rather than the methodology or theory behind it. In +such cases, the place to quibble with [an expert's] academic training is on cross-examination ... +16 + + +" Joseph, 542 F.3d at 21-22 (first and second alterations in original) (citations and internal +quotation marks omitted). +That point is particularly true in sex trafficking cases. As Judge Engelmayer explained +when evaluating the testimony of a similar expert in a sex trafficking case, analyzing error rates is +an "unusually poor fit" in this area: +[S]tudying the circumstances and psychological drivers of trafficked +women is not like studying diseases or potential cures in laboratory +animals. ... Given the necessarily retrospective nature of such a +study, given the small size of the populations under review, and +given the inherently individualized circumstances presented by +different perpetrators, victims, and contexts in this tumultuous and +emotionally fraught area of criminal conduct, the vocabulary of +error rates ... is an unusually poor fit.... The testing that has been +done as to trauma bonding and coercive control, instead, necessarily +uses more qualitative research methodologies. These involve +interviews and case studies and clinical examinations conducted +over time." +Feb. 25, 2020 Tr. at 29:4-30:20, United States v. Randall, 19 Cr. 131 (PAE) (S.D.N.Y.), Dkt. No. +335. Because statistical rigor is not a useful method for evaluating the reliability of qualitative +research like Dr. +statistical tools like error rates are irrelevant to the Daubert analysis. +Contrary to the defendant's next claim, these opinions are not "impregnable for purposes +of cross examination." (Def. Mot. 3 at 7 (citation and internal quotation marks omitted)). The +defendant is free to cross Dr. +on how frequently she sees grooming in her patients and +how she evaluates whether they are telling the truth. The defendant is also free to explore, in cross +examination, the difficulties in assessing whether a patient has been groomed. The defense can +also make arguments—in cross examination and in jury addresses —about the lack of quantitative +rigor in this qualitative area of science. That is the point: it is for the jury, after hearing the +17 + + +evidence, to evaluate what weight to give it. But that does not change whether Dr. +opinions are squarely within the mainstream of psychological practice. +The defendant next argues that Dr. +patients are "self-selected," and she has not +established the "representativeness of her patients as typical victims of so-called grooming +behavior." (Def. Mot. 3 at 7). But the defendant makes no argument that the minor victims in this +case are distinctive in some way such that general principles of psychology may diverge as to +them. And in any event, that argument is for the jury to evaluate, and not a basis to preclude Dr. +testimony. See Feb. 25, 2020 Tr. at 36:13-37:5, United States v. Randall, 19 Cr. 131 +(PAE) (S.D.N.Y.), Dkt. No. 335 (rejecting a defense attempt to distinguish between native-born +and domestic-born women because, "while a court is to be a gatekeeper as to reliability so as to +keep "junk science' away from juries, the Court must not overstep that role. Whether or not the +Court would be persuaded that adult native-born women can be subject to trauma bonding, the +Court is not to arrogate to itself that judgment.") +Finally, the defendant argues that Dr. +has no experience treating perpetrators of +sexual assault, so she cannot testify as to the psychology of perpetrators and their "so-called +'grooming' techniques." (Def. Mot. 3 at 7-8). Many of the opinions the defendant challenges +concern the experiences of victims, not perpetrators. Dr. +will testify about the pattern to +which "minor victims are often subject," which makes "victims vulnerable to abuse," and builds +their "trust and attachment with their abuser." (Expert Notice, Def. Mot. 3 Ex. 1 at 2 (emphasis +added)). Grooming creates in the victims "a relationship of trust and attachment" that "can prevent +victims from being aware that what they are experiencing is abuse and can prevent disclosure. (Id. +18 + + +(emphasis added)). Dr. +testimony will also include discussion of techniques used by +perpetrators. Dr. Rocchio's testimony regarding such techniques is supported by Dr. +review of the relevant literature, see Exhibit A, and through her clinical work. By virtue of her +experience treating victims, Dr. +is necessarily informed about perpetrators' actions. See +Halamek, 5 F.4th at 1088 ("Extensive experience interviewing victims can qualify a person to +testify about the relationships those victims tend to have with their abusers."). Dr. +testify squarely within her expertise and experience.? +will +b. Relevance and Rule 403 +Dr. +opinions will assist the trier of fact in understanding the evidence at trial. +This case concerns an "unusual area of human interaction." See Feb. 25, 2020 Tr. at 39:8-9, United +States v. Randall, 19 Cr. 131 (PAE) (S.D.N.Y.), Dkt. No. 335. The Minor Victims in this case +were trafficked over many years, and none were physically restrained. An average juror, with no +experience with sexual abuse vietims, may not understand why the Minor Victims continued to +3 In United States v. Raniere, No. 18 Cr. 204 (NGG), 2019 WL 2212639 (E.D.N.Y. May 22, 2019), +Judge Garaufis questioned whether an expert on grooming with experience focused on victims +may have been able to testify reliably about how "perpetrators often use "grooming' techniques on +adult and child victims ...." Id. at *7. Even then, he did not exclude the testimony— he simply +ordered a Daubert hearing. Id. at *8. The Government ultimately declined to proceed with that +testimony rather than conduct a mid-trial Daubert hearing. Here, and as noted above, Dr. +Is proposed testimony concerns the experience of manipulated and coerced victims, rather +than the intentions of perpetrators. +19 + + +return to Epstein's home for sexual abuse, or why some occasionally expressed affection for the +defendant and Epstein. +Although Dr. +will not testify about these specific Minor Victims, her testimony +will help the jurors understand the "psychological dynamic often seen in abusive relationships that +leads an abuse victim to behave in counterintuitive ways, such as by declining to take opportunities +to leave an abusive situation or by expressing gratitude to an abuser." Torres, 2021 WL 1947503, +at *7. This psychological dynamic between a victim of child sexual abuse and her abusers is +"beyond the knowledge of the average juror and would or could plainly be helpful in understanding +the psychological dynamics at play." Oct. 17, 2019 Tr. at 27:3-7, United States v. Dupigny, No. +18 Cr. 528 (JMF) (S.D.N.Y.), Dkt. No. 198; cf. See Feb. 25, 2020 Tr. at 38:13-20, United States +v. Randall, 19 Cr. 131 (PAE) (S.D.N.Y.), Dkt. No. 335 ("[B]y and large the relationship between +prostitutes and pimps is not the subject of common knowledge. Jurors are not apt to intuitively +understand the mechanisms that may lead a woman who is not physically restrained or confined +to heed the demands of a pimp to traffic herself."). Accordingly, Dr. +testimony will +help the jury understand and contextualize the other testimony it will hear.* +The defendant expresses concern that a lay jury will be unable to apply Dr. +analyses to the facts of this case, stating "[t]hat is not how Rule 702 works." (Def. Mot. at 10). +* Relying again on Raymond, the District of Maine case, the defendant argues that expert testimony +about "general principles is helpful only when it 'describes widely recognized and highly +predictable and verifiable phenomena."" (Def. Mot. 10 (quoting Raymond, 700 F. Supp. 2d at 150 +n. 12 (alterations omitted)). That proposition comes from footnote 12 of Raymond, which +attempted to distinguish that expert's "profile" testimony from the Federal Rules Advisory +Committee's observation that the 2000 amendment "does not alter the venerable practice of using +20 + + +That is precisely how Rule 702 works in cases where experts testify about general principles, which +the Rule contemplates. See Fed. R. Evid. 702 Advisory Committee note ("I]t might also be +important in some cases for an expert to educate the factfinder about general principles, without +ever attempting to apply these principles to the specific facts of the case."). Dr. +will +provide reliable opinions about principles of coercion and attachment in abusive relationships that +will help the jury understand the psychological factors underlying the relationships that the jury +will learn about at trial. +Finally, the defendant argues that the Court should preclude Dr. +testimony under +Rule 403. In so arguing, she expresses concern that Dr. +testimony will "radically +simplify' an otherwise complex case" by 'foist[ing] a damning teleology on a series of actions +each of which might have been motivated by a variety of ends or no ends at all. (Def. Mot. at +11 (quoting United States v. Burns, No. 07 Cr. 556, 2009 WL 3617448, at *5 (N.D. III. Oct. 27, +2009)).S There is nothing prejudicial or simple about Dr. +testimony. The jury will not +conclude that the defendant is guilty because Dr. +explains that acts which "might have +been motivated by a variety of ends" are sometimes part of the process of sexual abuse. Whether +expert testimony to educate the factfinder on general principles." Raymond, 700 F. Supp. 2d at +150 n. 12 (quoting Fed. R. Evid. 702 Advisory Committee note). The defendant cites no place +containing this limitation in the text of the Rule, its advisory committee notes, Daubert, or the law +of this Circuit or District. Nor does it make sense on its own terms: "how financial markets respond +to corporate reports" or the "principles of thermodynamics" are sometimes highly predictable, but +not always, depending on the context. +› Burns, a case about a district court's application at sentencing of a Guidelines enhancement, says +nothing about whether the jury would be confused by learning about grooming. +21 + + +they were in this case will depend on the other evidence. That is not a prejudicial simplificationthat is the trial. +There is nothing unreliable, irrelevant, or unusual about Dr +opinion on coercion +and attachment. +• Drawing on her decades of clinical experience and her familiarity with the +relevant literature, Dr. +will give opinion testimony that will help the jury understand +witness testimony. That is all Rule 702's gatekeeping requirements demand. +2. Dr. +Opinion on the Relationship Between Trust and Victim Awareness +of Their Abuse is Admissible +At trial, the Government intends to offer Dr. +testimony about how victims +process their abuse and how that can prevent or delay disclosure. As the Government set forth in +its expert notice, Dr. +will testify that: +The relationship of trust and attachment can prevent victims from +being aware that what they are experiencing is abuse and can prevent +disclosure. Minor victims therefore may not identify themselves as +victims of abuse while it is ongoing, and may not recognize the +consequences of that abuse until adulthood. +(Def. Mot. 3 Ex. 1 at 2). This opinion is part and parcel of Dr. +other opinions about the +relationship between attachment and coercion. Specifically, and as noted above, victims develop +relationships of trust and attachment with their abusers that leave victims vulnerable to coercion. +This opinion adds that, as part of this relationship, victims may not recognize that they are +experiencing abuse and may not see themselves as victims while they are in this relationship, and +therefore may not disclose their abuse or recognize the consequences of their abuse until later in +life. As the defense correctly observes, this opinion is intertwined with Dr. +opinions +about coercion and attachment. (Def. Mo. 3 at 12). Just as those are reliable, so is this one. +22 + + +The defense argues that this opinion is outside Dr. +expertise because she has "no +experience treating alleged perpetrators," so "her view ... is entirely one-sided." (Id.). As is clear +from the above excerpt, her testimony is about largely about trust and attachment built in victims, +and the resultant ways in which victims process abuse. But she is also an expert in the actions and +techniques of perpetrators through her review of the literature and the lens of what she has learned +through victims. This opinion is therefore squarely within Dr. +expertise. +Finally, the defendant argues that this testimony violates Rule 704, because it is an "opinion +that the alleged victims in this case are testifying truthfully," and 403, because it "risks jurors +accepting her 'expert' opinion as gospel at the expense of their duty to evaluate the evidence." +(Def. Mot. 3 at 13). Dr. +nas not evaluated the victims in this case and will not express an +opinion as to whether they are testifying truthfully. And the defense motion is entirely unclear on +the features of this expert opinion that create risk that the jurors would abdicate their +responsibilities. To the contrary, the defense concerns underscore how relevant this opinion will +be in aiding the jurors in understanding the testimony at trial. +3. Dr. +Dr. +Opinion on the Long-Term Consequences of Abuse is Admissible +will also testify that "[repeated exploitation and abuse can increase the +likelihood of victimization later in life and can result in long-term traumatic and psychological +consequences, especially when it occurs in the context of complex trauma." (Def. Mot. 3 Ex. 1 at +2). As Dr. +will explain, and as is detailed in her Jencks Act material", experiencing child +• The Government produced Dr. +Jencks Act material to the defense at the time of the +expert notice. (See Def. Mot. 3 Ex. I at 2 ("The Government is producing notes from the +Government's interviews with Dr. +today as well.")). +23 + + +sexual abuse can lead to a variety of psychological difficulties, including substance use and +participation in risky sexual behavior. Complex trauma—trauma involving repetitive or prolonged +exposure to or experiences of multiple traumatic stressors, involving harm or abandonment by +trusted adults, and occurring at developmentally vulnerable times can lead to various +psychological consequences, including dysregulation in emotional control, difficulties in +relationships or with behavioral control, and distorted perceptions of the self and others. +This opinion is highly relevant. It is likely that jurors will not be intimately familiar with +the consequences of child sexual abuse. Accordingly, the causal connection between these +psychological problems and child sexual abuse is outside the experience of the average juror. Yet +that information will aid the jury in two respects: First, it will help jurors assess the credibility of +Minor Victims, to the extent they have had some of these psychological symptoms or had other +difficulties described by Dr. +in the years since their abuse. For instance, the Government +expects the defense to attack the credibility of a Minor Victim by cross0-examining her about her +substance abuse. Dr. +testimony will provide the jury with a fuller picture by showing +that substance abuse can be a consequence of sexual trauma. Second, experiencing certain +psychological difficulties is consistent with past child sexual abuse and complex trauma. It is +evidence that Minor Victims in fact experienced child sexual abuse that they suffered known +consequences of such abuse. +See Raniere, 2019 WL 2212639, at *3, *7 (admitting expert +24 + + +testimony that "sexual assault can result in severe, long-lasting and wide-ranging psychological +consequences and related difficulties"). +The defendant argues that this evidence is nonetheless prejudicial because it will inflame +the passions and emotions of the jury. (Def. Mot. 3 at 14). The Minor Victims, however, will be +the ones testifying about the abuse they experienced and observed, and-whether on direct or +cross +about the psychological consequences of their experiences. The question is only whether +the jury will hear from an expert about the causal connection between those two conceptstestimony about concepts not specifically applied to any victim, and testimony about a causal +connection whose reliability the defense does not challenge. There is nothing inflammatory about +this expert testimony, much less something sufficiently prejudicial to substantially outweigh the +probative value of the testimony. See Fed. R. Evid. 403. +4. Dr. +Opinion About the Significance of the Presence of Third Parties is +Admissible +As noted above, Dr. +will opine that "It]he presence of other individuals can +facilitate the sexual abuse of minors." (Def. Mot. 3 Ex. 1 at 2). For instance, and as Dr. +will explain, the presence of a third party can disarm an intended victim and make perpetrators +appear safe and trustworthy, or can create a false sense of security on the part of a minor victim +that sexualized situations are normal and acceptable. Based on her experience as a clinician, Dr. +will testify that young children in particular often feel more comfortable in the presence +of a woman. +The defendant objects to this testimony on the grounds that it concerns a lay matter "which +a jury is capable of understanding and deciding without the expert's help." (Def. Mot. 3 at 14 +25 + + +(citation and internal quotation marks omitted)). Dr. +however, is not testifying about +common experience or from common experience. +Her testimony stems from her clinical +experience, and it concerns the psychological experiences of victims when a third person is present +during parts of their sexual abuse, as part of her broader opinion on attachment and coercion. The +average juror will not have knowledge of or experience in the psychology of abuse victims, and +Dr. +testimony will aid their understanding. +The defendant relatedly seeks to preclude Dr. +from testifying about "groomingby-proxy," a term which appears nowhere in the Government's expert notice. (Def. Mot. 3 at 9). +By that term, the defendant appears to argue that Dr. +will opine that an individual can +groom a victim for abuse by another perpetrator, and that such an opinion is unreliable and +"prejudicial speculation." (Id.). This argument misses the mark in three respects. First, Dr. +testimony primarily concerns the experience of victims, not perpetrators, as explained +above. If the vietim experienced attachment and grooming, it makes no analytical difference +whether the perpetrator intends to engage in sexual contact with the victim or, instead, is preparing +the victim for abuse by a third party. See Feb. 25, 2020 Tr. at 31:1-34:12, United States v. Randall, +19 Cr. 131 (PAE) (S.D.N.Y.), Dkt. No. 335 (explaining that, where there is a "reliable basis for +....testi[mony] about trauma bonding and coercive control as phenomena that exist more broadly," +the expert may testify, and defendants "are at liberty to vigorously cross-examine [the expert] to +attempt to cabin or limit trauma bonding and coercive control to populations predominately outside +of the alleged victims in this case"). Indeed, expert testimony is commonly offered in sex +trafficking cases on the pimp-prostitute relationship, which is specifically designed to permit the +26 + + +pimp to arrange sex acts for third parties. See, e.g., Kidd, 385 F. Supp. 3d at 263; Oct. 17, 2019 +Tr. at 27:1-12, United States v. Dupigny, No. 18 Cr. 528 (JMF) (S.D.N.Y.), Dkt. No. 198. Second, +in any event, the Government did not provide expert notice on "grooming by proxy." Dr. +will give an opinion on grooming, and she will discuss how "It ]he presence of other individuals +can facilitate the sexual abuse of minors." (Expert Notice, Def. Mot. 3 Ex. 1 at 2). The former is +a reliable opinion, as explained above, and the defendant does not challenge the reliability of the +latter opinion. (See Def. Mot. 3 at 14). Third, trial testimony will show that the defendant (1) in +fact participated in sexual abuse of minors, (2) facilitated that abuse through her presence, and (3) +conspired with a predator who groomed and sexually abused minors. None of that involves +"grooming by proxy." +5. Dr. +Finally, Dr. +Opinion on Delayed Disclosure is Admissible +will offer the opinion that "nondisclosure, incremental disclosure, and +secrecy are common among victims of sexual abuse for a variety of reasons, and that memory and +disclosure of traumatic or abusive events is impacted by a number of factors, including the +circumstances surrounding the trauma." (Def. Mot. 3 Ex. 1 at 2). +Much of the basis for this opinion is set forth in Dr. +Jencks Act material. For +instance, extensive psychological literature supports the idea that individuals who are harmed as +children may come to disclose their experiences incrementally or not until much later, as they may +only realize that their experiences were abusive later in life, among other reasons. Selected articles +from that literature are attached as Exhibit B. See Alaggia et al., "Facilitators and Barriers to Child +Sexual Abuse (CSA) Disclosures: A Research Update (2000-2016)," 20 Trauma, Violence & +Abuse 260, 276 (2016) ("Disclosure is now generally accepted as a complex and lifelong process, +27 + + +with current trends showing that CSA disclosures are too often delayed until adulthood"); +McElvaney, "Disclosure of Child Sexual Abuse: Delays, Non-disclosure, and Partial Disclosure," +24 Child Abuse Rev. 159, 160 (2015) (There is consensus in the research literature that most people +who experience sexual abuse in childhood do not disclose this abuse until adulthood, and when +disclosure does occur in childhood, significant delays are common."); Bicanic et al., "Predictors +of delayed disclosure of rape in female adolescents and young adults," 6 Euro. J. of +Psychotraumatology 25883 (2015) (listing among the predictors of delayed disclosure "age +category 12-17 years"). Children who do disclose may choose to share information with a peer, +but are less likely to go to an adult. Especially where a child has been groomed, the perpetrator +has become a trusted adult for a child, reducing the likelihood of the child's disclosure. +Incremental disclosure depends on a variety of factors, including how safe the victim feels with +the recipient of the disclosure, how voluntary the disclosure is, and psychological factors that may +prevent the victim from accessing their full memories. Vietims may also experience significant +shame or self-blame that prevents them from sharing certain information, and they may still be +attached to the perpetrators, such that they try to protect the perpetrators. +Sexual abuse also impacts the way memory is encoded. In traumatic circumstances, often +only the most salient details are encoded, and over time, specific details may be lost. With +traumatic memory in particular, adrenaline and cortisol responses in the context of fear and trauma +cause people to narrow their focus to the most salient and relevant details. If someone is abused +multiple times or by multiple people, it is very common for memories of similar occurrences to +28 + + +jumble together, although the victim can remember the perpetrator and maybe some of the +locations where the abuse occurred. +Taken together, Dr. +_expert testimony explains why victims of child sexual +abuse and especially repeated sexual abuse may disclose their abuse in a delayed and +incremental fashion, and why their memories may lack some level of detail when the disclosure +finally occurs. +The defendant argues that testimony about delayed disclosure is unreliable, repeating some +of the defendant's earlier arguments about whether the testimony is "based entirely on her +treatment of a self-selected group of individuals she assumes are telling the truth" and how the +opinion lacks an error rate. (Def. Mot. 3 at 15). Here, as with her opinions on attachment and +coercion, Dr. +is testifying based on her training, clinical experience, and the academic +literature. See Exhibit B. That victims of childhood sexual abuse delay disclosure is a wellestablished phenomenon the fact of which though not the underlying psychological +explanation +-is readily visible in the news. See also 2 Mod. Sci. Evid. § 19:15 (explaining that +"a large literature over the years has demonstrated that individuals frequently fail to disclose +autobiographical information in numerous different settings," including disclosure of "episodes of +sexual abuse"). +Courts have specifically authorized experts to provide testimony on delayed disclosure. +See, e.g., United States v. Gaudet, 933 F.3d 11, 15-16 (1st Cir. 2019) ("Moreover, the government +provided expert testimony from Dr. Ann Burgess ... in which she testified that delayed disclosures +are "[vlery common' in abuse victims and stem from the way the brain processes, stores, and recalls +29 + + +traumatic experiences" (second alteration in original); Raniere, 2019 WL 2212639, at *3, *7 +(admitting expert testimony that "disclosure by sexual assault victims often unfolds over time, and +the process of disclosure is influenced by multiple and changing factors including, but not limited +to, the specific characteristics of the experience, the victim's psychological vulnerabilities, the +victim's relationship to her perpetrator and her pattern of recovery and coping"); United States v. +Young, 623 F. App'x 863, 865-66 (9th Cir. 2015) ("[The expert] testified that ... delayed +disclosures, piecemeal disclosures and/or even recanted disclosures are coping mechanisms. ... +[The expert]'s testimony was helpful and probative because [the defendant] had attacked the +victims' credibility based on their delayed and incomplete reports of abuse." (citations and internal +quotation marks omitted)); United States v. Betcher, 534 F.3d 820, 826 (8th Cir. 2008) ("In this +case, Dr. Levitt's testimony as to delayed disclosure helped the jury understand why the girls did +not reveal they had been photographed until they were confronted with the images."). +The defendant suggests that Dr. +opinions on delayed disclosure are not helpful +to the jury because they are too generic. As set forth here and more fully in Dr. +Jencks +Act material, Dr. +has elaborated on her opinions about the relationship between child +sexual abuse and traumatic memory.? The defendant adds that, because Dr. +opinion is +that delayed disclosure is consistent with sexual abuse but not a necessary consequence of sexual +abuse, jurors have no means to determine whether a Minor Victim is lying or telling the truth. +' The defendant also argues that Dr. | +generally" (Def. Mot. 3 at 17). The Government agrees. But Dr. +is not an expert in "the human brain or memory +is an expert in trauma +psychology, which includes related issues of memory. +30 + + +(Def. Mot. 3 at 16). This argument misunderstands the role of the jury. Jurors are not tasked +merely with applying Dr. +expertise to facts. The jury will hear testimony that some +Minor Victims did not immediately disclose their sexual abuse. When evaluating the credibility +of those delayed disclosures, they will have the benefit of observing the Minor Victims' testimony, +including their cross-examination which is sure to address their delayed disclosure, and the Minor +Victims' explanation for those delays. The jury will also hear general testimony from Dr. +about various circumstances that may lead victims of sexual abuse to delay disclosure. In the +totality of the circumstances, the jury can then decide who it finds credible. +The defendant also argues it is prejudicial to her that Dr. +suggests "that delayed +reporting is more consistent with truthfulness than fabrication, a determination which the jury must +make for itself." (Def. Mot. 3 at 17). It is unclear how the defendant can simultaneously argue +that (1) Dr. +testimony improperly assumes the role of the jury by suggesting that delayed +reporting is "more consistent" with child sexual abuse (id.); and (2) Dr. +testimony would +only help the jury if she resolved any ambiguity by saying that delayed reporting is a necessary +consequence of child sexual abuse (id. at 15-16). +Finally, according to the defendant, Dr. +arguments will only prejudice the +defendant, because it will serve to bolster the witnesses' credibility. As the defense acknowledges, +however, Dr. +will not offer an opinion regarding any specific victim, and she has not +evaluated any victims in this case. (Cf. Def. Mot. 3 at 16 (citing United States v. Charley, 189 +F.3d 1251, 1266-67 (10th Cir. 1999), in which the expert opined that the victims were in fact +abused based "largely on crediting the girls' account," thereby "vouching for their truthfulness"). +31 + + +Instead, the Government will seek to offer Dr. +testimony as background in this case. +"Daubert instructs that vigorous cross-examination and the presentation of contrary evidence are +the central tools available to an adversary who wishes to debunk an expert's testimony." Randall, +19 Cr. 131 (PAE), Dkt. No. 335 at 37 (internal quotation marks omitted) (citing Daubert, 509 U.S. +at 594-595). Thus, to the extent the defendant wishes to cast doubt on the applicability of Dr. +background testimony, she is free to do so through cross-examination or by offering +contrary evidence. As discussed above, Dr. +testimony is relevant to helping the jury +understand key issues in the case, like why the Minor Victims may have returned to the defendant +and Epstein without being physically forced to do so, and why they delayed disclosure. +*** +The parties agree that Dr. +is a qualified expert. Her opinions are well within the +range of reasonable expert opinions, and so are sufficiently reliable to go to the jury. And they +will aid the jury in evaluating other testimony in this case. That is enough for the Court to admit +Dr. Rocchio's testimony. +II. The Evidence Contained in the Government's October 11, 2021 Letter is +Admissible +On October 11, 2021, the Government notified the defense of certain evidence it may offer +at trial. In particular, the letter addressed +and the expected testimony of one potential +witness. (See October 11, 2021 Letter, Def. Mot. 2 Ex. A). As the Government explained in its +letter to the defense, the evidence constitutes direct evidence of the charged offenses, but the +Government provided notice under Rule 404(b) in the alternative. That same day, the Government +provided the defense with +along with copies of all other marked Government +32 + + +exhibits, all of which were in the Government's discovery productions. The Government also +provided the defense with Jencks Act materials for all trial witnesses that same day, including +detailed notes and reports of the Government's interviews of the witness referenced in the letter. +The defendant now moves to exclude this evidence, arguing, among other things, that the +Government has not provided sufficient notice of the evidence it intends to offer at trial under Rule +404(b). For the reasons set forth below, the defendant's motion lacks merit, and should be denied. +The Government has provided detailed notice, well in advance of trial. This evidence is admissible +on multiple grounds, and the jury should be permitted to consider it. +A. Applicable Law +Relevant evidence is "not confined to that which directly establishes an element of the +crime." United States v. Gonzalez, 110 F.3d 941, 942 (2d Cir. 1997). As the Second Circuit has +explained, "[t]o be relevant, evidence need only tend to prove the government's case, and evidence +that adds context and dimension to the government's proof of the charges can have that tendency." +Id.; accord United States v. Coonan, 938 F.2d 1553, 1561 (2d Cir. 1991). The Second Circuit has +repeatedly held that actions and statements are admissible as direct evidence of the crimes charged, +and are "not considered other crimes evidence under" Federal Rule of Evidence 404(b), if (a) they +"arose out of the same transaction or series of transactions as the charged offense," (b) they are +"inextricably intertwined with the evidence regarding the charged offense," or (c) they are +"necessary to complete the story of the crime on trial." Carboni, 204 F.3d at 44; see also United +States v. Quinones, 511 F.3d 289, 309 (2d Cir. 2007); United States v. Baez, 349 F.3d 90, 93-94 +(2d Cir. 2003). In those circumstances, the uncharged crimes evidence is "appropriately treated +33 + + +as part of the very act charged, or, at least, proof of that act." Quinones, 511 F.3d at 309 (internal +citations and quotations marks omitted). +Federal Rule of Evidence 404(b) allows for the admission of uncharged crimes, wrongs, or +other acts for purposes other than proving criminal propensity, "such as proving motive, +opportunity, intent, preparation, plan, knowledge, identity, absence of mistake, or lack of +accident." Fed. R. Evid. 404(b). The Second Circuit "has long adopted an 'inclusionary" approach +to the admission of uncharged crime evidence, under which evidence of prior crimes, wrongs, or +acts is admissible for any purpose other than to show a defendant's criminal propensity." United +States v. Paulino, 445 F.3d 211, 221 (2d Cir. 2006) (internal quotation marks omitted). Where the +defendant claims her conduct has an innocent explanation, the admission of such evidence of other +acts is particularly appropriate. See, e.g.. United States v. Zackson, 12 F.3d 1178, 1182 (2d Cir. +1993) ("Where a defendant claims that his conduct has an innocent explanation, prior act evidence +is generally admissible to prove that the defendant acted with the state of mind necessary to commit +the offense charged."). Where evidence is offered for a proper purpose under Rule 404(b), it may +only be excluded if the probative value of the evidence is "substantially outweighed" by the danger +of unfair prejudice. Id. at 1182; see Fed. R. Evid. 403. +Until December 1, 2020, the Government was required to provide "reasonable notice of +the general nature of any such evidence that the prosecutor intends to offer at trial." Fed. R. Evid. +404(b)(2)(A) (2011). On December 1, 2020, the rule was amended (the "2020 Amendments") to +require the Government to also "articulate in the notice the permitted purpose for which the +prosecutor intends to offer the evidence and the reasoning that supports the purpose." Fed. R. +34 + + +Evid. 404(b)(3)(B) (2020). The 2020 Amendments also removed language permitting notice of +the "general nature" of the evidence. +These amendments are "relatively modest." Wright & Miller, "2020 Amendments to Rule +404(b)," 22B Fed. Prac. & Proc. Evid. § 5242.1 (2d ed.). They simply require the prosecutor to +"articulate a non-propensity purpose for which the evidence is offered and the basis for concluding +that the evidence is relevant in light of this purpose." Id. (quoting Fed. R. Evid. 404(b) Advisory +Committee note). The other act evidence should also be "described with helpful specificity." Id. +B. Discussion +To be clear, in the Government's view, the exhibits and testimony discussed in the +Government's October 11, 2021 letter are direct evidence of the offenses charged, such that they +do not need to be admitted pursuant to Rule 404(b). And although notice was not required under +Rule 404(b), the Government has provided the defense with notice substantially in advance of trial. +The Court should admit this evidence, regardless of whether Rule 404(b) applies. +1. The Evidence is Admissible As Direct Evidence, or in the Alternative, Under Rule +404(b) +The Government's October 11 letter identified seven exhibits and one witness whose +statements are admissible as direct evidence, or in the alternative under Rule 404(b). (See October +11, 2021 Letter, Def. Mot. 2 Ex. A at 1). More specifically, the letter explained that the +Government may offer at trial +marked as Government Exhibits 401 through 404, +409 through 410, and 413. In addition, the Government notified the defense that it may call as a +witness an individual ("Employee-1") who worked for Jeffrey Epstein +immediately +35 + + +following the charged conduct. Both categories of evidence are admissible as direct evidence of +the charged conduct, or in the alternative under Rule 404(b). +a. Government Exhibits 401 through 404, 409 through 410, and 413 +Turning first to the exhibits, the Government has notified the defense that it intends to offer +(October 11, 2021 Letter, Def. Mot. 2 Ex. A at 1). +36 + + +But the jury could easily draw different inferences from these exhibits. The +exhibits go directly to the defendant's intent and motive, because they show +Accordingly, these exhibits are probative of the issues the jury will be asked to resolve at +trial and should be admitted as direct evidence of the charged crimes.? In the alternative, this +evidence is probative of the defendant's motive, intent, plan, and knowledge, and should be +admitted pursuant to Rule 404(b)(2). +8 The remaining exhibits identified in the Government's October 11, 2021 letter are necessary to +identify the parties to the emails. +" This evidence would also be admissible to rebut defense arguments concerning similar topics, +and in cross-examination of the defendant. +37 + + +only highlights that this evidence does "not involve conduct any more +sensational or disturbing than the crimes with which [the defendant] was charged," which weighs +in favor of admitting these exhibits under Rule 404(b)(2). United States v. Roldan-Zapata, 916 +F.2d 795, 804 (2d Cir. 1990). +b. Testimony of Employee-l +Employee-1 worked as a personal assistant for Epstein for approximatelyl +(October 11, 2021 Letter, Def. Mot. 2 Ex. A at 1). During that time, Employee-1 +reported directly to another employee ("Employee-2"), who worked for Epstein during the +timeframe of the charged conspiracy, and who is referenced in the Second Superseding Indictment +(the Indictment"). (ECF No. 187, 111 6, 7(b)). The Government expects that Employee-1 will +testify about Employee-l's observations of the close relationship between the defendant and +Epstein. Indeed, Employee-1 will testify that Employee-1 worked out of the defendant's +townhouse in Manhattan during the weeks that Employee-1 worked in New York City. The +Government also expects Employee-1 to testify about her observations at Epstein's properties, +including observations of minor girls at the properties, as well as her knowledge of Epstein's +practice to arrange multiple sexualized massages per day. In addition, although Employee-l's +employment post-dates the defendant's conduct with the victims in this case, Employee-1 became +familiar with certain items in Epstein's residences during her tenure there, and thus Employee-1 +will authenticate certain exhibits relating to the Minor Victims. Finally, the Government expects +38 + + +Employee-1 to testify that in or about October 2005, Epstein and her supervisor directed her to +gather the computers and contact books in the house and hand them over to a specified individual. +Employee-I's testimony is admissible for multiple permissible purposes. Her testimony +shows the relationship between Epstein and the defendant +shortly after the end of the +conspiracy period, including the defendant's role in Epstein's affairs. Similarly, it provides +background information about the operation of Epstein's homes and lifestyle. Employee-l's +testimony will also show the defendant and Epstein's plan and preparation, because it will describe +the process and frequency of obtaining masseuses, including the fact that the masseuses were often +underage girls, and that some of the massages developed into sexual abuse. And Employee-l's +testimony tends to show the defendant's knowledge, because it describes the visibility of Epstein's +abuse to individuals at his properties. Finally, Employee-1's testimony will authenticate exhibits +that are direct evidence of the charged crimes. Accordingly, Employee-I's testimony is direct +evidence of the crimes charged. +. Moreover, this evidence is admissible in the alternative under +Rule 404(b), for substantially the same reasons. +2. The Government Has Met and Exceeded Its Notice Obligations +Even if Rule 404(b) applies here, the Government's October 11, 2021 letter-and the +corresponding Jencks Act disclosures have satisfied any notice obligations that apply here. +The defense claims that the Government's October 11, 2021 notice was inadequate in light +of the 2020 amendments to Rule 404(b). The Government provided the defense with a letter, and +corresponding disclosures, seven weeks before trial. In fact, the defense has had the seven exhibits +for much longer, since they were part of the Government's Rule 16 discovery productions. The +defense now also has this briefing, five weeks before trial. Thus, any alleged gap in the +39 + + +Government's notice is remediated by this brief. This is ample notice of the possible Rule 404(b) +evidence in this case. Indeed, the Rule only requires that the defense receive notice "before trial," +or even "during trial ... for good cause." Fed. R. Evid. 404(b)(3)(C). +The defense claims, without supporting authority, that Rule 404(b) requires heightened +notice that cannot be satisfied here without, essentially, a script of all of the proposed testimony at +trial accompanied by detailed expositions of the Government's case-in-chief. (Def. Mot. 2 at 4- +5). But the Government has provided the defense with marked exhibits and comprehensive Jencks +Act materials of the single witness subject to this motion (approximately 400 pages) "unusually +early" (Endorsed Letter at 3, Dkt. No. 353), along with a letter specifically highlighting the +proffered evidence at trial. That is all that is required, and the defendant cannot leverage the notice +requirements of Rule 404(b) to preclude this evidence at trial. Indeed, the "Second Circuit +generally disfavors the exclusion of otherwise relevant evidence on technical grounds." Hart v. +BHH, LLC, No. 15 Civ. 4804 (WHP), 2019 WL 1494027, at *3 (S.D.N.Y. Apr. 4, 2019) (citing +Rodriguez v. Vill. Green Realty, Inc., 788 F.3d 31, 47 (2d Cir. 2015)). Accordingly, the only judge +in this District to consider a similar situation concluded that the Government's Rule 404(b) notice +was sufficient in combination with the Government's motion papers. See United States v. +Chandler, No. 19 Cr. 867 (PKC), 2021 WL 1851996, at *2 n.2 (S.D.N.Y. May 10, 2021). +The defense vaguely asserts that it cannot perform an independent investigation into the +Rule 404(b) evidence due to the inadequacy of the Government's notice. (Def. Mot. 2 at 5-6). +That conclusory assertion cannot support a motion to preclude the jury from hearing evidence of +the defendant's guilt. The defense has not identified any specific way that they have been hampered +40 + + +in their ability to investigate or move in limine. The Government's Rule 404(b) notice-and this +briefhave been provided far in advance of trial. In many cases, the Government gives Rule +404(b) notice two weeks before trial, and here the Government's notice concerns a small number +of exhibits and only one witness. See, e.g., United States v. Tranquillo, 606 F. Supp. 2d 370, 383 +(S.D.N.Y. 2009) ("The Government has indicated that it will make the required disclosure two +weeks prior to trial, a practice that typically comports with Rule 404(b)."); United States v. Fennell, +496 F. Supp. 2d 279, 284 (S.D.N.Y. 2007) ("The government has in good faith noted its obligations +under Rule 404(b), and indicated that it intends to provide notice of the 404(b) evidence it intends +to introduce two weeks before the beginning of trial. There is therefore no need to issue the order +Defendant seeks."). The Government has identified the specific evidence it will seek to admitnot just the types of evidence—-and has explained the connection between that evidence and nonpropensity purposes for which it will be offered. That is all Rule 404(b) requires. +III. The Testimony of Minor Victim-3 is Admissible +The defendant has moved to exclude evidence related to Minor Victim-3. This is nothing +more than an attempt to seek reconsideration of the Court's pretrial order denying the defense's +motion to strike Minor Victim-3 from the Indictment. Evidence of the defendant and Jeffrey +Epstein's abuse of Minor Victim-3 is direct evidence of the offense charged in the Indictment, +including the overt acts in the Indictment that pertain to Minor Victim-3. And in any event, her +testimony would easily satisfy the requirements of Rule 404(b). +A. Background +Both the first and second superseding indictments described the defendant and Epstein's +sexual abuse of Minor Victim-3. As set forth in the Indictment, the defendant "groomed and +41 + + +befriended Minor Victim-3 in London, England between approximately 1994 and 1995, including +during a period of time in which [the defendant] knew that Minor Victim-3 was under the age of +18." (Indictment 9| 9(c)). The defendant "introduced Minor Victim-3 to Epstein and arranged for +multiple interactions between Minor Vietim-3 and Epstein," during which the defendant +"encouraged Minor Victim-3 to massage Epstein, knowing that Epstein would engage in sex acts +with Minor Victim-3 during those massages." (Id.) Minor Victim-3 provided those massages, +during which Epstein sexually abused Minor Victim-3. (Id.) Two overt acts in those Indictments +concerned the defendant and Epstein's sexual abuse of Minor Victim-3 in London. (Id. 19 13(d), +19(d)). +The defendant moved to strike the portions of the S1 Indictment involving Minor Victim- +3, arguing that the events involving Minor Victim-3 were unrelated to the conspiracies charged in +Count One and Count Three. (See generally Mem. of Law, Dkt. No. 146). In response, the +Government explained that the defendant and Epstein's "interactions with Minor Victim-3 were +part of a broader scheme and agreement to entice and transport minor victims with the intent to +commit illegal sex acts," and in any event, admissible under Rule 404(b) as evidence of the +defendant's knowledge, intent, and modus operandi. (Gov't Opp. at 157-169, Dkt. No. 204). The +Government expects Minor Victim-3 to testify, in substance and in part, that she met the defendant +when she was +The defendant befriended Minor Vietim-3 by, among other things, +discussing Minor Victim-3's life and family with Minor Victim-3. +42 + + +The Court denied the defendant's prior motion to strike portions of the Indictment related +to Minor Victim-3 (Op. & Order at 33, Dkt. No. 207), explaining that it was premature to strike +any language from the Indictment, because Minor Victim-3's allegations "may reflect conduct +43 + + +undertaken in furtherance of the charged conspiracy or be relevant to prove facts such as +Maxwell's state of mind." (id. at 26-27). +B. Applicable Law +It is axiomatic that the Government may offer proof of acts included within the indictment. +Those are the very acts the Government seeks to prove at trial. See United States v. Dugue, 763 +F. App'x 93, 94 (2d Cir. 2019) (summary order) ("[A]n act that is alleged to have been done in +furtherance of the alleged conspiracy is not an 'other" act within the meaning of Rule 404(b); +rather, it is part of the very act charged." (alterations and citation omitted); Quinones, 511 F.3d at +308 ("While Rule 404(b) identifies various rationales ... for which evidence of bad acts other than +those charged in the indictment may be admitted at trial, the rule has no bearing on the admissibility +of acts that are part of the charged crime." (emphasis in original) (footnote omitted)). +As discussed above, see supra Section II, direct evidence is "not confined to that which +directly establishes an element of the crime." Gonzalez, 110 F.3d at 942, see id. at 942 (rejecting +a claim that the evidence fell under Rule 404(b)). It also includes actions or statements that (a) +"arose out of the same transaction or series of transactions as the charged offense," (b) are +"inextricably intertwined with the evidence regarding the charged offense," or (c) are "necessary +to complete the story of the crime on trial." Carboni, 204 F.3d at 44. +In addition, in a conspiracy case, +, "the Government need not set out with precision each and +every act in furtherance of the conspiracy." United States v. LaSpina, 299 F.3d 165, 182 (2d Cir. +2002) (citation, +alterations, and internal quotation marks omitted). +Instead, "where the +Government must prove a conspiracy existed, evidence of acts committed in furtherance of the +conspiracy is ... direct evidence of the acts charged in the Indictment." United States v. Townsend, + + +No. S1 06 Cr. 34 (JFK), 2007 WL 1288597, at *1 (S.D.N.Y. May 1, 2007) (citing United States v. +Concepcion, 983 F.2d 369, 392 (2d Cir. 1992)); United States v. Van Putten, No. 04 Cr. 803 (PKL), +2005 WL 612723, at *3 (S.D.N.Y. Mar. 15, 2005) (similar). +As also discussed in Section II, supra, evidence of "other acts" is admissible under Rule +404(b) if it is (1) advanced for a proper purpose, such as to prove "motive, opportunity, intent, +preparation, plan, knowledge, identity, absence of mistake, or lack of accident"; (2) relevant to the +crimes for which the defendant is on trial; and (3) has probative value which is not substantially +outweighed by any unfair prejudicial effect. See Zackson, 12 F.3d at 1182. If requested, such +evidence must be admitted with limiting instructions to the jury. See United States v. Edwards, +342 F.3d 168, 176 (2d Cir. 2003). The Second Circuit "ha[s] adopted an inclusionary approach to +evaluating Rule 404(b) evidence, which allows evidence to be received at trial for any purpose +other than to attempt to demonstrate the defendant's criminal propensity." Id. (internal quotation +marks and citations omitted). +C. Discussion +Minor Vietim-3's testimony is direct evidence of the charged criminal conductspecifically, the conspiracies in Counts One and Three of the Indictment. +The Government expects that Minor Vietim-3's testimony, which concerns a +period of time overlapping with or in close proximity to other Minor Victims' experiences with +the defendant and Epstein and concerns teenagers of similar ages, will significantly overlap with +the testimony of those other Minor Victims. +Put simply, Minor Victim-3's account is +45 + + +corroborative of the accounts of the other Minor Victims. It is also direct evidence of the operation +of the conspiracy that is probative of the defendant's intent at the time of the offense. See Op. & +Order at 10, Dkt. No. 106 ("[!]t is anticipated that the three witnesses will provide detailed and +corroborating accounts of the Defendant's alleged role in enticing minors to engage in sex acts."); +see also United States v. Curley, 639 F.3d 50, 59 (2d Cir. 2011) (explaining in an interstate stalking +case that evidence of earlier abuse that was "similar in nature and severity" demonstrated a "pattern +of activity that was probative of [the defendant's] intent"). +Minor Victim-3's testimony is also direct evidence of the offense because it concerns acts +taken by the defendant in furtherance of the conspiracies. In particular, +Indeed, at a minimum, the defense motion should be denied because the Government's +proffered evidence relating to Minor Victim-3 is admissible to prove the overt acts involving +Minor Victim-3 contained in the Indictment. (Indictment 11 13(d), 19(d)). Evidence proving overt +acts in the Indictment is direct evidence of the offense, and not other-acts evidence. See United +States v. James, 520 F. App'x 41,45 (2d Cir. 2013) (summary order) ("James's possession of five +pounds of marijuana on December 22, 2005, and December 2, 2010, were charged as overt acts in +the indictment. Accordingly, evidence of James's possession of marijuana on these occasions was +not subject to the structures of Rule 404(b)."). The Court previously denied the defense's motion +to strike the overt acts involving Minor Vietim-3 as surplusage, explaining that it "may reflect +conduct undertaken in furtherance of the charged conspiracy or be relevant to prove facts such as +46 + + +Maxwell's state of mind." (Op. & Order at 26-27, Dkt. No. 207 ("Courts in this district generally +delay ruling on any motion to strike until after the presentation of the Government's evidence at +trial, because that evidence may affect how specific allegations relate to the overall charges.")). +Having concluded that it should delay striking these overt acts until after presentation of the +Government's evidence, the Court should not now effectively reverse its decision by precluding +that very evidence. If the Government's proof at trial does not establish the relevance of Minor +Victim-3's testimony, if anything, the proper course is for the defense to move to strike the relevant +overt acts and Minor Victim-3's testimony at that time. +Even if evidence of Minor Victim-3 were uncharged criminal activity, it would still be +necessary to understand the other aspects of the charged conspiracies. +Minor Victim-3 +experienced the pattern of abuse in close temporal proximity to the other Minor Victims: the +conduct involving Minor Victim-1 spans 1994 to 1997, the conduct involving Minor Victim-3 +spans 1994 to 1995, and the conduct involving Minor Vietim-2 occurred in 1996. The defendant's +acts toward Minor Victim-3 show (1) the defendant's relationship with Epstein, including her +willingness to procure teenagers to give Epstein massages, (2) the defendant's knowledge of both +the sexual nature of those massages and the need to procure additional victims, and (3) her +willingness to transport minors to further their abuse. This evidence is therefore direct proof of +the defendant's state of mind and agreement to participate in a conspiracy with Epstein. Moreover, +her relationship with Minor Victim-3 was "part of [her] continued effort" to commit the offenses +charged in Counts One and Three. Carboni, 204 F.3d at 44; see United States v. Romero-Padilla, +583 F.3d 126, 130 (2d Cir. 2009) ("We reject Romero-Padilla's contention that evidence of his +47 + + +previous plans with Ferro to import narcoties +….. was evidence of 'other crimes' .... I]t +corroborated the charge that Ferro and Romero-Padilla were partners during the charged +conspiracy and established that Romero-Padilla's participation in the charged conspiracy was at +least in part motivated by his desire to acquire [certain] funds ...")." +Minor Victim-3's testimony is also necessary to complete the story of the offense conduct +in light of expected defenses at trial. To the extent that the defense argues, for instance, that the +defendant played no role in obtaining girls to massage Epstein or was unaware that Epstein's +I' The cases the defendant cites (Def. Mot. 4 at 8-9) conclude that the admission of evidence about +distinct criminal incidents are not direct evidence of the conspiracy. See United States V. +Cummings, 60 F. Supp. 3d 434, 438 (S.D.N.Y. 2014), vacated on other grounds, 858 F.3d 763 (2d +Cir. 2017) (evidence of prior narcotics arrest and firearms conviction in narcotics and firearms +case "could be +• connected to the charged conspiracy, but the Government has not provided +enough detail"); Townsend, 2007 WL 1288597, at *2 (stating that the Government did not show +that uncharged firearm and drug transactions involving the same confidential informant outside +the time period of the charged conspiracy, described "rather generically" as a sale of firearms and +"narcotics transactions," are "part and parcel of" the charged conduct or sufficiently similar to +them); United States v. Mahaffy, 477 F. Supp. 2d 560, 566 (E.D.N.Y. 2007) (stating that, although +the facts between two fraud schemes were "quite similar," the other acts were "a separate, discrete +offense that may be conceptually segregated from the charged offenses without impairing the +jury's ability to understand the facts underlying the schemes alleged in the indictment"), vacated +in part on other grounds 285 F. App'x 797 (2d Cir. 2008); United States v. Nektalov, 325 F. Supp. +2d 367, 370 (S.D.N.Y. 2004) ("IT]he transactions took place as early as three years prior to the +charged conspiracy and appear to involve a series of distinct cash for gold transactions...."). +That is not the case here, where the abuse of Minor Vietim-3 occurred during the charged +conspiracy period, overlaps temporally with the testimony of other Minor Victims, whose +admissibility the defendant does not contest, and is direct proof of the operation of the conspiracy. +But in any event, in each case, the Court admitted at least some evidence under Rule 404(b). See +Cummings, 60 F. Supp. 3d at 438 (evidence admissible under Rule 404(b)); Townsend, 2007 WL +1288597, at *5-6 (some evidence admissible under Rule 404(b), some evidence "far too vague" +for the Court to resolve, evidence of later marijuana possession irrelevant); Mahaffy, 477 F. Supp. +2d at 566 (evidence admissible under Rule 404(b)); Nektalov, 325 F. Supp. 2d at 372 (evidence +admissible under Rule 404(b)). +48 + + +massages were sexualized, evidence that she did so in the case of Minor Vietim-3——at roughly the +same time as Epstein was abusing Minor Victim-1 and Minor Vietim-2—is "necessary to complete +the story of the crime on trial." United States v. Robinson, 702 F.3d 22, 37 (2d Cir. 2012) +("Robinson argued at trial that Jane Doe was his "girlfriend' and that he had no control over her +prostitution activities. Evidence that Robinson was in the prostitution business and controlled +prostitutes other than Jane Doe was therefore "necessary to complete the story of the crime on +trial."*). +The defense focuses on allegations involving Minor Victim-3 in isolation. In its attempt +to confuse the issues, the defense argues that the defendant's conduct with Minor Victim-3 was +lawful in the United Kingdom, and that Minor Vietim-3 was an adult when she ultimately traveled +to the United States and was abused by Epstein. The defense states that "[a]s to [Minor Victim- +3], the completed endeavor—i.e., her alleged sex acts with Epstein — was not a substantive criminal +offense." (Def. Mot. 4 at 8 (emphasis in original)). The defense then claims —without any basis +that the allegations relating to Minor Vietim-3 in the Indictment are "of no consequence," because +"the government evidently charged the conduct under the mistaken belief that [Minor Victim-3] +was a minor when she engaged in sex acts with Epstein." (Id. at 9-10). According to the defense, +the government "did not know that [Minor Victim-3] was above the [age] of consent in the U.K. +The government presented [Minor Victim-3]'s allegations to the grand jury incorrectly assuming +that she was a minor and that the alleged sex acts between Epstein and [Minor Victim-3] were +illegal." (Id. at 1-2). +49 + + +Not so. The defendant's argument entirely misunderstands the charges in the Indictment +and the jury's task at trial. The defendant is charged with conspiring to transport and entice minors +for the purpose of sexual abuse. The question at trial will be whether the defendant took steps to +provide Jeffrey Epstein with access to girls under the age of 18, knowing that Epstein intended to +have sexual contact with those girls. The defendant's acts involving Minor Victim-3 were part of +that scheme and are highly relevant to demonstrating the existence of the conspiracy and the +defendant's role in the scheme. That is all that is required for evidence relating to the defendant's +exploitation of Minor Victim-3 to be direct evidence of the charged offenses. The defendant is not +charged with an offense under United Kingdom law, and the age of consent in the United Kingdom +is irrelevant. The defendant is also not charged with any substantive offenses with respect to Minor +Victim-3, and thus it makes no difference whether the defendant could have, attempted to, or did +successfully transport Minor Victim-3 in violation of those statutes. ' +In any event, this evidence is all admissible under Rule 404(b). '3 Testimony regarding the +defendant's efforts to recruit and encourage Minor Victim-3 to engage in sex acts with Epstein in +the context of massages establishes that the defendant knew of Epstein's attraction to minor girls +12 Indeed, there is no risk at trial that the jury will convict the defendant based on the testimony of +Minor Victim-3 alone. As the Government has made clear, the jury may not convict the defendant +of the conspiracy offense solely based on Minor Victim-3 due to the statute of limitations. (Gov't +Opp. at 157-58, 163, Dkt. No. 204). The jury should be appropriately instructed at the conclusion +of the trial. +13 To the extent this evidence is properly admissible under Rule 404(b) rather than as direct +vidence, the Government's detailed memorandum in opposition to the defense pretrial motions +hich described theories of 404(b) admissibility (Gov't Opp. at 165-69, Dkt. No. 204), and th +memorandum, filed five weeks before trial, is more than sufficient notice for the defense. +50 + + +and knew that Epstein used massage to initiate sexual contact with minor girls. Minor Victim-3's +testimony shows the defendant's intent, through her acts befriending Minor Victim-3, encouraging +Minor Victim-3 to provide Epstein massages, and asking Minor Victim-3 to find other girls. And +it shows the defendant's specific modus operandi of the conspiracies in the Indictment. For these +and the other reasons described above, Minor Vietim-3's testimony easily satisfies Rule 404(b)'s +requirements. Evidence of other acts involving the grooming or abuse of minor victims is regularly +admitted for similar purposes in cases where charges allege sexual activity with minors. See, e.g., +United States v. Vickers, 708 F. App'x 732, 737 (2d Cir. 2017) ("As to the testimony concerning +Vickers" 'grooming' of his victims, we conclude that such evidence was admissible even under +Rule 404(b), because it was probative of Vickers' knowledge of how to secure adolescent boys' +trust so that he could sexually abuse them. We identify no abuse of discretion in the district court's +decision to admit all of the challenged testimony [regarding uncharged acts of sexual abuse] under +Rule 403."); United States v. McDarrah, 351 F. App'x 558, 563 (2d Cir. 2009) (affirming +admission pursuant to Rule 404(b) of defendant's "e-mail responses to the Craigslist +advertisements" for erotic services because the e-mails "were relevant to his knowledge and intent, +because he wrote those emails to girls he knew could be minors (he enthusiastically indicated that +girls younger than 18 are acceptable) and his e-mails showed his interest in actual sexual +conduct"); United States v. Brand, No. 04 Cr. 194 (PKL), 2005 WL 77055, at *5 (S.D.N.Y. Jan. +12, 2005) (admitting "evidence that Brand exhibited an interest in child erotica and child +pornography on the internet in the period leading up to the charged conduct" under Rule 404(b) +51 + + +because evidence was "pertinent to whether he used the internet in an attempt to engage in sexual +conduct with" putative victim). +The defense argues that this testimony will be unfairly prejudicial to the defendant. See +Fed. R. Evid. 403. According to the defense, if Minor Vietim-3 testifies that she had sex with a +"much older man when she was 17 years old" or that she was sexually abused, the jury will assume +that Epstein engaged in illegal conduct, which will somehow prejudice the defendant. (Def. Mot. +4 at 13). The Court should not assume that the jury will speculate about principles of United +Kingdom law and apply them to this case. The Court will properly instruct the jury on the elements +of the offenses charged in the Indictment and the evidence that the jury can—and cannotconsider. Those instructions will not ask the jury to consider or pass upon any aspect of United +Kingdom law, which will not be in evidence at trial. And in any event, as discussed in the +Government's opposition to the defendant's pretrial motion to strike references to Minor Victim- +3 in the Indictment, evidence regarding Minor Victim-3's experiences with the defendant and +Epstein are no more inflammatory or upsetting than those of Minor Victim-1 and Minor Victim- +2. The risk of unfair prejudice is therefore minimal. +In the alternative, the defense seeks three rulings: (1) precluding the Government from +referring to Minor Victim-3 as a "minor," (2) precluding the Government and Minor Victim-3 +from representing that she was "sexually abused" by Epstein, and (3) giving a limiting instruction +about United Kingdom law. The defense's requested rulings are not grounded in law or reason. +First, the defense claims that Minor Vietim-3 should not be referred to as a "minor" because +she was above the age of consent in the relevant jurisdictions at the times she had sexual contact +52 + + +with Epstein. When Minor Victim-3 began having sexual contact with Epstein, she was +The +issue at trial will be the defendant's knowledge of Epstein's preference for girls under the age of +18. Under federal law, there is a term for individuals under the age of 18: minors. There is nothing +inappropriate about using that term at trial. +Similarly, the phrase "sexual abuse" is accurate, and the Government should be permitted +to use it. Minor Victim-3 is expected to testify about her experiences with the defendant and +Epstein, including that she was sexually abused by Epstein numerous times. Regardless of whether +she uses the term "sexual abuse," her testimony will capture her experience that she was +exploited sexually. And it is fair for the Government to argue that those acts were sexual abuse. +The defense argues that the phrase "sexual abuse" is misleading because it suggests to the jury that +Epstein engaged in "criminal sexual activity" with Minor Victim-3. (Def. Mot. 4 at 14-15). To +justify that proposition, the defense cites a single Supreme Court case in which (1) the parties were +engaged in the task of statutory interpretation, not argument in a jury address or description of a +victim's lived experience, and (2) the Court rejected that proposed definition of "sexual abuse of +a minor" as "flatly inconsistent with the definition of sexual abuse contained in th[at] very +dietionary." Esquivel-Quintana v. Sessions, 137 S. Ct. 1562, 1569 (2017). Again, the Government +is confident that the Court will properly instruct the jury regarding the elements of the crimes in +the Indictment. +Finally, there is no basis for an instruction about United Kingdom law. The defense has +demonstrated no unfair prejudice that might warrant a limiting instruction, and the defense's +proposed instructions would only confuse the jury. The jury will be instructed to consider only +53 + + +the elements of the crimes the Court provides them, so any assumptions the jury might make about +United Kingdom law are irrelevant. '4 See United States v. Vasquez, 82 F.3d 574, 577 (2d Cir. +1996) (appropriate to reject defense request for an instruction if it does not "represent[] a theory +of the defense with a basis in the record that would lead to acquittal"'). And the proposed jury +instruction that the sexual activity involving Minor Victim-3 "cannot be considered 'illegal' or +"criminal' or 'unlawful' for purposes of the crimes charged in the indictment" (Def. Mot. 4 at 15), +is wrong on the law. The sexual activity involving Minor Vietim-3 can be considered criminal for +purposes of the crimes charged in the Indictment, because it is probative proof of the defendant's +guilt of those crimes. The instruction the defense proposes, in contrast, creates serious risk that +the jury will think the Court is telling them that the conduct is lawful and therefore irrelevant to +the case. It is not irrelevant: it is direct evidence of the crimes charged, and it should be put before +the jury. +IV. There is No Basis to Preclude Co-Conspirator Statements at Trial +On October 11, the Government provided the defense with comprehensive Jencks Act +material for trial witnesses and its exhibits, along with a letter telling the defense, consistent with +the Court's order, the identities of the individuals the Government intends to argue are coconspirators at trial. The defense nonetheless asks the Court to enter an order precluding the +Government from introducing any co-conspirator statements under Federal Rule of Evidence +14 In the event the Court instructs the jury on the age of consent in the United Kingdom, the +Government requests that the Court also instruct the jury that the United Kingdom's age of consent +is irrelevant and they should not consider it. +54 + + +802(d)(2)(E) because it claims the Government failed to comply with the Court's September 3, +2021 Order. (Def. Mot. 1 at 1). The defense misreads this Court's September 3, 2021 Order to +require the Government to do something unprecedented: identify and itemize for the defense each +and every co-conspirator statement it plans to use at trial, seven weeks in advance of trial. Then, +complaining that the Government has not complied with the defense's peculiar reading, the +defense +seeks an extraordinary remedy: precluding the Government from offering any coconspirator statements at trial. Each step of this analysis is erroneous, and the Court should deny +the motion. +A. Background +The defendant first sought to compel the Government to identify the co-conspirator +statements it plans to use at trial in its initial round of pretrial motions. There, the defendant argued +that the Second Circuit's practice of conditional admission of co-conspirator statements at trial +would prejudice her because "any cautionary instruction would be of doubtful utility." (Mem. of +Law at 13, Dkt. No. 148). She therefore asked the Court to order a "proffer from the government +or conduct a pretrial hearing to determine if the statements are admissible." (Id. at 13-14). +In response, the Government observed that the practice of conditional admission of coconspirator statements is the law of the Circuit, notwithstanding the defense's preference to the +contrary. (Gov't Opp. at 192, Dkt. No. 204). The Government also explained that "the Second +Circuit has rejected the suggestion that non-exculpatory co-conspirator statements are discoverable +under Rule 16 or by any means other than the Jencks Act." (Id.). See In re U.S., 834 F.2d 283, +284-87 (2d Cir. 1987) (issuing a writ of mandamus reversing District Court's order directing the +Government to "produce all oral statements made by the defendants and coconspirators that the + + +Government planned to offer at trial as admissions of a defendant" under Fed. R. Evid. 801). +Accordingly, the Government argued that "the defense will receive notice of any co-conspirator +statements that the Government may seek to introduce through witness statements" in its Jencks +Act production. (Gov't Opp. at 192, Dkt. No. 204). +The Court denied the motion, explaining that the Court lacked the power to order pretrial +disclosure of non-exculpatory co-conspirator statements. (Op. & Order at 30, Dkt. No. 207). The +Court also explained that the "[clo-conspirator statements may often be admitted at trial on a +conditional basis," and to the extent that "can pose a problem, a pretrial hearing is unnecessary +here because the Government has committed to producing co-conspirator statements at least six +weeks in advance of trial to allow Maxwell to raise any objections." (Id. at 30-31). +The defendant's second bite at the apple came in the parties' joint scheduling letter. (Letter, +Dkt. No. 291). There, the defense requested that the Government "identify any co-conspirator's +names and statements (whether via witness testimony or documentary evidence) at the same time +as it discloses []3500 material," so it could "litigate their admissibility before trial." (Id. at 11-12). +The Government responded that it is "entirely appropriate for defense counsel to receive notice of +any co-conspirator statements through Jencks Act materials and marked exhibits," because any coconspirator statements will be contained therein. (Id. at 5). The Government also noted that the +defendant cited no cases "directing separate notice of coconspirator statements that the +Government may introduce at trial." (Id.) +On June 2, 2021, the Court adopted the "Government's proposal" and set a deadline of +October 11, 2021, for the "disclosure of Jencks Act and Giglio material, Rule 404(b) evidence and +56 + + +notice, co-conspirator statements, and Government witness list," as well as the "Defendant's +proposal" that the Government disclose its proposed exhibit list that same day. (Order at 1, Dkt. +No. 297). This order did not expressly require the Government to specifically identify coconspirator statements within its other productions. +In the defendant's second round of pretrial motions, she asked the Court to order the +Government to disclose a series of information about the Indictment. That list contained a renewed +request for the Government to identify uncharged co-conspirators, but it did not contain a new +request for the Government to separately identify co-conspirator statements within its discovery +production. (Mem. of Law at 23-24, Dkt. No. 293). On August 13, 2021, the Court denied the +defense's motion, but in a footnote, explained that it "presume[d] the Government intends to +disclose" the "identi[ties of] the unnamed co-conspirators who allegedly participated in the +conspiracies charged in the S2 Indictment," since the Government had not previously opposed that +request. (Op. & Order, Dkt. No. 317 at 12 n. 1). The order said nothing about identifying coconspirator's statements. (Id.). +The Government filed a letter opposing the request for the Government to "identify [the +defendant]'s unnamed co-conspirators." (Letter at 1, Dkt. No. 320). The defendant filed a new +letter in response, raising "two issues." (Letter at 1, Dkt. No. 331). First, the defendant sought the +identities of co-conspirators. (Id. at 1-2). Second, the defendant took a third bite at the apple, once +again seeking "disclosure of the purported co-conspirator statements [the Government] intends to +offer at trial." (Id. at 3). The defendant also argued that the Court's scheduling order had already +required the Government to specifically identify co-conspirator statements. (Id. at 3-4). +57 + + +On September 3, 2021, the Court ordered the Government to "disclose to the Defendant +the identities of all unnamed co-conspirators alleged in the S2 indictment to whom it will refer at +trial." +(Order at 1, Dkt. No. 335). The Court further ordered the Government to "disclose all coconspirator statements it intends to offer at trial no later than October 11, as consistent with this +Court's scheduling order." (Id. at 2) +Accordingly, on October 11, 2021, the Government produced its exhibit list and Jencks +Act material to the defendant. The Jencks Act materials and exhibits contained the only coconspirator statements in the Government's possession that will be offered at trial. It also disclosed +the identities of the individuals to whom it may refer at trial as co-conspirators and informed the +defendant that it "has produced all co-conspirator statements which it intends to offer at trial ... +in the Government's production [that day] or in its previous productions." (Def. Mot. 1 Ex. 1 at +1). The Government further noted that "[t]o the extent the Government learns of additional coconspirator statements as it continues to prepare for trial, it will produce those statements in +connection with its ongoing obligation to produce Jencks Act material." (Id.). +B. Discussion +The Government has complied with its pre-trial disclosure obligations, consistent with the +Court's orders and on a schedule with deadlines well in advance of trial. As of October 11, the +Government produced all co-conspirator statements in its possession that it intends to offer at trial. +To the extent that the Government learns of additional co-conspirator statements as it prepares for +trial-such as in a session preparing a witness for trial—it will produce those statements as part of +its ongoing Jencks Act obligations. +58 + + +The defense errs when it suggests that the Court ordered the Government to specifically +itemize any co-conspirator statements contained in its disclosures. When the Court first set a +disclosure schedule for Jencks Act material, it adopted the "Government's proposal," which +opposed any requirement that the Government isolate co-conspirator statements from other witness +statements. (Order at 1, Dkt. No. 297). When the Court ordered the Government to produce the +identities of co-conspirators, it again ordered the Government to "disclose" all co-conspirator +statements, citing the Court's earlier order. (Order at 2, Dkt. No. 335). Neither order expressly +directed the Government to produce a set of co-conspirator statements it would offer at trial +separately from the other evidence it would offer at trial. +A requirement to "disclose statements" is not a requirement to isolate statements. For one, +the Court denied the defense request for effectively that relief in the first round of pretrial motions. +(Op. & Order at 30-31, Dkt. No. 207). For another, in the defense's many rounds of briefing on +this issue, it has cited no case— not from this District, nor any other—in which a Court ordered the +Government to segregate and itemize co-conspirator statements from other statements for the +convenience of the defense. +The Government is aware of no such case likely because such an +order would be in considerable tension with Circuit precedent, see In re U.S., 834 F.2d at 286. For +a third, the guiding principle of the defense's justification for its request is to facilitate litigation +of those statements' admissibility pre-trial. +But the law of the Second Circuit is that such +statements can be conditionally admitted during the trial, and their admissibility litigated +thereafter. See, e.g., United States v. Ferguson, 676 F.3d 260, 273 n.8 (2d Cir. 2011) (citing United +States v. Geaney, 417 F.2d 1116, 1120 (2d Cir. 1969)); Op. & Order at 30, Dkt. No. 207. As much +59 + + +as the defense might like the Government to create such an index, that is simply not how the +litigation of co-conspirator statements is handled. And it is not what the Court's order, requiring +"disclos[ur]e" of co-conspirator statements, required. +The Government's obligation is to make disclosures. The Government is not obligated to +serve as members of the defense team, reviewing Jencks Act materials for the defense and +itemizing and indexing disclosures for them. The Government is no more obligated to itemize +Jencks Act materials containing co-conspirator statements than it is obligated to exhaustively detail +for the defense the basis for offering any other type of witness statement contained in the Jencks +Act material it has produced. Such an obligation would extremely burdensome and is both without +precedent and entirely unnecessary. The defense team has ample resources to review the +Government's disclosures and file any motions they wish to make regarding the admission of +certain testimony. And there is ample time before trial for the defense to do so, and no basis in the +record to believe the defense will be unable to raise these issues and seek a ruling before trial. +The defense argues that the Court did order the Government to itemize co-conspirator +statements contained in its Jencks Act production. In support, however, the defense cites to orders +relating to the disclosure of the identities of co-conspirators. (Compare Def. Mot. 1 at 2 (citing +Dkt. No. 317 at 12 n. 1) and Def. Mot. 1 at 3 (citing Dkt. No. 335 at 3) (stating that the Court +rejected the defendant's arguments "because of ' the need for the parties to litigate co-conspirator +issues in advance of trial'" (emphasis in Def. Mot. I)), with Op. & Order at 12 n.1, Dkt. No. 317 +("Additionally, Maxwell includes in her motion for a bill of particulars a request to require the +government to identify the unnamed co-conspirators who allegedly participated in the conspiracies +60 + + +charged in the S2 indictment."), and Order at 3, Dkt. No. 335 (following the above sentence with +"In light of the interests discussed above ... the Court will require the Government to disclose the +identities of any unnamed co-conspirators .…."). +The defense also argues that failure to provide an index of co-conspirator statements +permits "the presentation of false testimony" and is "an invitation to manufacture evidence," +because a witness will offer a co-conspirator statement for the first time. (Def. Mot. 1 at 4). This +argument is nonsensical and offensive. It is deeply unfortunate that defense counsel would so +casually resort to baseless allegations that the Government would manufacture evidence and +present false testimony at trial. And in any event, the Government produced to the defense Jencks +Act material containing co-conspirator statements in its possession on October 11 and will +continue to make Jencks Act productions as it prepares for trial. To the extent the defense is +concerned that a witness will say something on the stand for the first time, the Government cannot +disclose that in advance because no lawyer can know a witness's verbatim answer in advance. But +were that to occur, the defense would be well positioned to cross-examine the witness. '5 +15 The defendant's motion also makes the puzzling argument that co-conspirator statements are +problematic in this case because the defense is limited in its ability to call co-conspirators to testify +as defense witnesses. (Def. Mot. 1 at 4). That is true in essentially every criminal case, as the +Court has previously noted. (See Op. & Order at 17-18, Dkt. No. 207 ("There are also serious +doubts under all of the relevant circumstances that a jury would have found testimony from Epstein +credible even if he had waived his right against self-incrimination and testified on her behalf.")). +In any event, to the extent the defense takes issue with the rule that co-conspirator statements can +be admitted without requiring the declarant to testify, that complaint is properly directed to the +drafters of the Federal Rules of Evidence. +61 + + +Even if the Government has misread the Court's order, the defense's claims of prejudice +are exaggerated. Although the defense complains that the Government seized "multiple electronic +devices" containing "hundreds of thousands of statements spanning decades" (Def. Mot. 1 at 3), +any statements contained in emails or other documents that the Government plans to use at trial +have been marked as Government exhibits and produced to the defense. The defense need look +no further than the Government's exhibit list to discover what documents will be offered at trial. +Similarly, although the defense complains of "document dumps" (id. at 2) and the need to review +"thousands of pages of newly provided discovery material" (id. at 7), any witness testimony +containing co-conspirator statements is contained in the Government's Jencks Act production +and specifically, the Government's production of material for testifying witnesses. Although the +Government produced as a courtesy prior statements of non-testifying witnesses, by definition the +Government does not plan to call those individuals at trial. And the Government has informed the +defense of the limited number of co-conspirators to whom it may refer at trial, so the defense +knows exactly which declarants' statements are possibly subject to the co-conspirator exception. +See Fed. R. Evid. 801(d)(2)(E). ' +Finally, and in any event, suppression is not a proper remedy. The defense relies +principally on Taylor v. Illinois, 484 U.S. 400 (1988), in which the Supreme Court upheld an order +16 To be clear, the defendant's motion concerns the admission of statements under Rule +801(d)(2)(E). The majority of the statements made by co-conspirators that will be offered at trial +lave other bases for admissibilit +naste then, and diratimistil . Fived frome, stin ese testify regarding patmas oriens +subject to hearsay rules. Rather, they are offered for the effect on the listener, among other reasons. +62 + + +excluding the testimony of a defense witness as a sanction for counsel's (i) noncompliance with a +discovery rule that required notice of intention to call the witness, and (ii) misleading the court +concerning his knowledge of the witness's whereabouts. The Supreme Court found the discovery +violation was "both willful and blatant." Id. at 416. Taylor does not support the defense's position. +The defense, citing Taylor, accuses the Government of willfully violating the Court's September +3, 2021 Order. (See Def. Mot. 1 at 6-7; see id. at 3 (accusing the Government of "attempting to +overstuff an already full sandbag")). The Government did no such thing. The Government has +simply read the word "disclose" to mean "disclose," consistent with the uniform practice in this +District. The defense's accusations are baseless and offensive. +The defense has all of the co-conspirator statements the Government plans to use at trial. +They have these records "unusually early"— seven weeks before trial. (Endorsed Letter at 3, Dkt. +No. 353). The defense also knows the identities of the limited number of co-conspirators to whom +the Government may refer at trial, a highly unusual circumstance that makes the defense's task +even easier. And they are free to litigate the admissibility of any such statement during trial. The +Government has complied with its obligations, and the defense is fully equipped to prepare for +trial. The Court should deny the motion. +V. +There is No Basis to Suppress Minor Victim-4's Identification of the Defendant +The defendant claims that Minor Victim-4's identification of her was unduly suggestive +and should be suppressed. (Def. Mot. 9). That argument finds support in neither fact nor law. +Minor Victim-4 knew the defendant personally, and she has consistently described the defendant +for decades. The identification was not suggestive, and the motion should be denied. +A. Background +63 + + +As set forth in Counts Five and Six of the Indictment, Minor Victim-4 was trafficked by +the defendant and Jeffrey Epstein from approximately 2001 to 2004. (Indictment M1 22-27). +During that time, Minor Victim-4 personally interacted with the defendant for instance, the +defendant paid Minor Victim-4 following Minor Victim-4's sexual encounters with Epstein. (Id. +25(a)). +In 2007, Minor Victim-4 was interviewed by the Federal Bureau of Investigation. In that +interview, she described meeting "an older lady with short black hair and an unknown accent" —a +description that is consistent with the defendant's appearance—at her first meeting with Epstein. +In +Minor Victim-4 was deposed, during which she explained that she sometimes called the +house to get work, and she would talk to an employee or "Maxwell." Later in the deposition, she +added that the same employee or "Maxwell" would contact her when Epstein wanted her to come. +This Office first interviewed Minor Vietim-4 in July 2020. During that meeting, Minor +Victim-4 spoke about her many interactions with the defendant. She did so again at the +Government's meetings with her in August 2020, and at multiple meetings in January 2021. +The Government met Minor Victim-4 again in June 2021 for several meetings. During one +of those meetings, the Government showed Minor Victim-4 a photo book containing 20 photos. +The Government asked Minor Victim-4 to review each photograph in the book and to indicate +whether she recognized anyone in the book. The Government explained that just because someone +is in the book, it does not mean that Minor Victim-4 knowns that person or that the person is in +trouble. The Government instructed Minor Victim-4 just to let the Government know if she +recognized anyone. +64 + + +Minor Victim-4 identified photo as possibly depicting the defendant, but indicated that +she was not sure. When she reached photo +Minor Victim-4 said it depicted the defendant. +After completing her review of the book, Minor Victim-4 returned to compare photos +and she confirmed that she believed photo +was a photo of the defendant, and she was not sure +whether she knew the person in photo_ +B. Applicable Law +As a general matter, the Constitution "protects a defendant against a conviction based on +evidence of questionable reliability, not by prohibiting introduction of the evidence, but by +affording the defendant means to persuade the jury that the evidence should be discounted as +unworthy of credit." Perry v. New Hampshire, 565 U.S. 228, 237 (2012). Eyewitness +identifications should therefore be excluded only where "improper police conduct" occurred that +was "so unnecessarily suggestive as to give rise to a very substantial likelihood of irreparable +misidentification." Id. at 238-39; see Manson v. Brathwaite, 432 U.S. 98, 112-14 (1977); Simmons +v. United States, 390 U.S. 377, 384 (1968). +Federal courts follow a two-step analysis in ruling on the admissibility of identification +evidence. Perry, 565 U.S. at 238-40; Brisco v. Ercole, 565 F.3d 80, 88 (2d Cir. 2009). First, the +defendant must show that the identification was "so unnecessarily suggestive and conducive to +irreparable mistaken identification that [the defendant] was denied due process of law." United +States v. DiTommaso, 817 F.2d 201, 213 (2d Cir. 1987) (citation and internal quotation marks +omitted); see Raheem v. Kelly, 257 F.3d 122, 134 (2d Cir. 2001). This is a high threshold to meet, +as the defendant must show that, under the totality of the circumstances, there is "a very substantial + + +likelihood of irreparable misidentification." United States v. Maldonado-Rivera, 922 F.2d 934, +973 (2d Cir. 1990). If the defendant cannot make such a showing, "the trial identification +testimony is generally admissible without further inquiry into the reliability of the pretrial +identification. +In that circumstance, any question as to the reliability of the witness's +identifications goes to the weight of the evidence, not its admissibility." Id. +Second, an unduly suggestive identification procedure does not alone require suppression +of the identification evidence. See Brathwaite, 432 U.S. at 110-14. Instead, the court must then +determine whether the identification evidence is nevertheless "independently reliable" based on +the totality of the circumstances. Brisco, 565 F.3d at 89; United States v. Simmons, 923 F.2d 934, +950 (2d Cir. 1991) ("[E]ven a suggestive out-of-court identification will be admissible if, when +viewed in the totality of the circumstances, it possesses sufficient indicia of reliability."). Among +the factors to be considered are: "the opportunity of the witness to view the criminal at the time of +the crime, the witness' degree of attention, the accuracy of the witness' prior description of the +criminal, the level of certainty demonstrated by the witness at the confrontation, and the length of +time between the crime and the confrontation." Neil v. Biggers, 409 U.S. 188, 199-200 (1972). +No single factor is dispositive. See Kelly, 257 F.3d at 135. +66 + + +C. Discussion +There was nothing unduly suggestive about the identification procedure used here. +Accordingly, there is no basis to suppress Minor Vietim-4's identification of the defendant, and +Minor Victim-4 should be permitted to identify the defendant at trial.'? +First, +the identification procedure was not suggestive because it was merely a +"confirmatory identification" of a person Minor Victim-4 had known and identified by name over +the years. +There is no "improper police conduet" creating a "substantial likelihood of +identification" by showing a person in that position even a single photograph, much less a photo +array or photo book. See, e.g., United States v. Hardy, No. 10 Cr. 1123 (JSR), 2011 WL 7782582 +(S.D.N.Y. Jan. 25, 2011) ("Displaying a confirmatory photograph of a person the witness has +indicated that he already knows is perfectly acceptable."); Gilbert v. Sup't of Collins Corr. Fac., +No. 03 Civ. 3866 (LBS), 2004 WL 287683, at *8 (S.D.N.Y. Feb. 11, 2004) (upholding +confirmatory identification following street canvass on the grounds that "police suggestiveness +does not require suppression of an identification if the witness was not thereby influenced, as, for +example, when the witness's identification was already positive."" (quoting Jarrett v. Headley, +802 F.2d 34, 41-42 (2d Cir. 1986))); see also, e.g., Franco v. Lee, No. 12 Civ. 1210 (SJF), 2013 +WL 704655, at *10 (E.D.N.Y. Feb. 26, 2013) ('In cases in which the defendant's identity is not in +issue, or those in which the protagonists are known to one another, suggestiveness is not a concern +1 Even if the Minor Vietim-4's identification of the defendant were suppressed, that would not +preclude Minor Victim-4 from testifying about her abuse and the name and physical description +of the person involved. +67 + + +and the identification is merely confirmatory." (citation and internal quotation marks omitted)); +Stallings v. Wood, No. 04 Civ. 4714 (RLM), 2006 WL 842380, at *11 (E.D.N.Y. Mar. 27, 2006) +(collecting cases). +Minor Victim-4's personal knowledge of the defendant is well established. The defendant +and Minor Vietim-4 met in person and interacted multiple times between 2001 and 2004. Minor +Victim-4 then mentioned the defendant by description or by name in 2007, 2009, 2020, and 2021, +all prior to being shown the photo book. And the circumstances of the identification were not +suggestive. Minor Victim-4 was shown 20 photos_ +She was not asked to locate the defendant, or asked whether a particular photo +depicted the defendant, but just whether she recognized anyone, although she was told that she +was not expected to recognize someone just because their photo was in the book. And, indeed, +Minor Victim-4 said she did not recognize some photos in the book. Regarding the defendant +specifically, Minor Vietim-4 carefully considered whether a different photo depicted the person +she believed to be the defendant before seeing and selecting a photo of the defendant. This +procedure was cautious and not suggestive- much less unduly suggestive. +The reality is straightforward: Minor Victim-4 knows exactly who the defendant is and +confirmed that the person in the photograph was the defendant. In response, the defense argues +that the photo "looks like a mug shot" and "is different than the others." (Def. Mot. 9 at 3). Of +course, as is often the case with photo arrays or photo books, all of the photos generally resemble +mug shots, so there is nothing suggestive about the fact that the defendant's photo does. And it is +not in fact different from the others: While the defendant's photo is lower resolution than some, +68 + + +there are several similar quality photos in the book. (See Ex. A, photos +In any event, +these highly conclusory statements fall well short of transforming the careful confirmatory +identification used in this case into an unduly suggestive procedure. The motion to suppress should +be denied on this basis, and the identification should be admitted at trial, where the defendant will +have a full opportunity to contest the persuasiveness of that evidence through cross-examination +and attorney argument. See Maldonado-Rivera, 922 F.2d at 973 (where there has been no showing +of suggestiveness, "any question as to the reliability of the [identification] goes to the weight of +the evidence, not its admissibility"). +Even if the "confirmatory identification" procedure was impermissibly suggestive as the +defendant claims, which it was not, Minor Victim-4's identification had clear independent +reliability because Minor Victim-4 stated that she knew the defendant by name from previous +interactions. For example, in Wiggins v. Greiner, the Second Circuit declined to address a disputed +question about a confirmatory identification's suggestiveness because the independent basis for +the in-court identification was so clear. See Wiggins, 132 F. App'x 861, 864-66 (2d Cir. 2005) +(witness saw defendant at distance of 50 feet under "streetlight illumination" but was familiar with +defendant from seeing him previously in neighborhood); accord United States v. Lumpkin, 192 +F.3d 280, 288 (2d Cir. 1999) (officers" in-court identifications reliable where officers had +unobstructed views of the defendant selling narcotics on two occasions, one of which was during +daylight at close range); United States v. Crumble, No. 18 Cr. 32 (ARR), 2018 WL 1737642, at *2 +(E.D.N.Y. Apr. 11, 2018) (collecting cases finding that "in-court identification is [] admissible, +despite an improper pre-trial identification procedure, if the witness is familiar with the defendant +69 + + +prior to the incident," or alternatively, if "if a witness gets a good look at the defendant during the +course of a crime"); United States v. Reed, No. 11 Cr. 487 (RJS), 2012 WL 2053758, at *5 +(S.D.N.Y. June 6, 2012) (noting that a "witness's familiarity with a suspect may establish that the +identification ……. is independently reliable"). +This is not a crime in which a victim captures a fleeting glance of the perpetrator. Minor +Victim-4 interacted with the defendant personally on multiple occasions between 2001 and 2004. +She knew the defendant by name and gave a description. In the totality of the circumstances, it is +plain that Minor Victim-4's identification of the defendant is sufficiently independently reliable to +permit the jury to decide its persuasiveness. +The defense merely replies, again in conclusory fashion, that Minor Victim-4 (1) never +identified the defendant as an abuser, (2) did not have an opportunity to view her during the crime +because the defendant was not involved in a crime, (3) never described the defendant, and (4) the +time between the abuse and the identification was extraordinarily long. (Def. Mot. 9 at 4). The +first three of these points are inaccurate, as set forth above. And the delay in time is untroubling +given Minor Victim-4's contacts with the defendant and consistent references in the intervening +time. The defense is free to attempt to argue these points to the jury, but none of these arguments +supports a motion to suppress Minor Victim-4's identification of the defendant. +Minor Victim-4 knows who participated in the sexual abuse she experienced, as she has +for the decades since it happened. This Court should deny the motion. +70 + + +VI. The Court Should Deny the Defense Motions to Preclude the Government's +Exhibits +The defense has filed several motions to preclude certain Government exhibits. (Def. +Mots. 7, 8, and 13). The Court should deny the defense authentication arguments without prejudice +because the Government expects its witnesses will be able to authenticate the exhibits at trial +before it offers them. The defendant's arguments regarding relevance and Rule 403, however, are +meritless, and the Court should deny them. +A. Applicable Law +In general, "[to satisfy the requirement of authenticating or identifying an item of +evidence, the proponent must produce evidence sufficient to support a finding that the item is what +the proponent claims it is." Fed. R. Evid. 901(a). The Second Circuit has made clear that "the bar +for authentication of evidence is not particularly high." United States v. El Gammal, 831 F. App'x +539, 542 (2d Cir. 2020) (summary order) (quoting United States v. Gagliardi, 506 F.3d 140, 151 +(2d Cir. 2007)). Rule 901 is "satisfied if sufficient proof has been introduced so that a reasonable +juror could find in favor of authenticity or identification," El Gammal, 831 F. App'x at 542 +(quoting United States v. Tin Yat Chin, 371 F.3d 31, 38 (2d Cir. 2004)), and such "proof of +authentication may be direct or circumstantial," United States v. Al-Moayad, 545 F.3d 139, 172 +(2d Cir. 2008) (citations and internal quotation marks omitted). +For instance, in United States v. Al Farekh, 810 F. App'x 21 (2d Cir. 2020) (summary +order), the defendant challenged the authenticity of "handwritten letters that were found in a USB +drive that was handed to an agent of the Federal Bureau of Investigation in Afghanistan." Id. at +24. The Second Circuit rejected the challenge. "Although the Government did not present +71 + + +evidence regarding the circumstances surrounding the seizure of the USB drive, Federal Rule of +Evidence 901(b)(4) permits authentication based on '[t]he appearance, contents, substance, +internal patterns, or other distinctive characteristics of the item, taken together with all the +circumstances." Id. (alteration in original) (quoting Fed. R. Evid 901(b)(4)). Witness testimony +about the content of the letters was "sufficient to pass the relatively low bar for authentication of +evidence," and "any remaining questions as to the reliability of the letters go to their evidentiary +weight, not their admissibility." Id. at 24-25. +Similarly, although physical evidence may be authenticated through a chain of custody, +"any flaws in the chain of custody bear only on the weight of the evidence, and not on its +admissibility." United States v. Stuckey, No. 06 Cr. 339 (RPP), 2007 WL 2962594, at *7 (S.D.N.Y. +2007) (citing United States v. Morrison, 153 F.3d 34, 57 (2d Cir. 1998)); see also United States v. +Hemmings, 482 F. App'x 640, 643 (2d Cir. 2012) (summary order) (similar). "Evidence should +be excluded on a motion in limine only when the evidence is clearly inadmissible on all potential +grounds." United States v. Cilins, No. 13 CR. 315 (WHP), 2014 WL 173414, at *2 (S.D.N.Y. Jan. +15, 2014) (citation and internal quotation marks omitted). +B. Discussion +The defense's challenges to the Government's exhibits largely turn on the Government's +ability to authenticate them. Those arguments are premature. At trial, the Government expects +that witnesses familiar with the exhibits will testify that the items are what the Government claims +they are. +The defendant is not entitled to a preview of the Government's case-in-chief at this +juncture. +72 + + +First, the defendant moves to exclude Government Exhibit 52, which it says was obtained +by the Government "as part of discovery in +v. Maxwell civil litigation ... with no +explanation about its origin." +(Def. Mot. 7 at 1). The defendant misidentifies the exhibit. +Government Exhibit 52 is a physical contact book belonging to the defendant. The records +attached by the defense as Exhibit 1 appear to be a scan of Government Exhibit 52 that was +produced in discovery in +v. Maxwell. But the Government will not offer that scan at trial. +It will offer the physical book itself, along with scans taken by the Government of the physical +book. A witness with personal knowledge of the physical book is expected to testify to its +authenticity. +The defendant takes issue with the history of the Government's acquisition of Government +Exhibit 52. The defendant is correct that the Government came into custody of this exhibit after a +former employee of Jeffrey Epstein attempted to sell it to a civil lawyer suing Epstein. (Id.). The +defense calls this "particularly troubling" (Def. Mot. 7 at 2), but that argument is misplaced. How +the Government acquired the exhibit goes, if anything, to its weight and not its admissibility. If a +witness can identify the exhibit based on its contents, that is sufficient to pass the relatively low +bar for authentication of evidence." See Al Farekh, 810 F. App'x at 24-25. +Finally, the defendant argues that the contents of Government Exhibit 52 are hearsay +because they are not a business record. (Def. Mot. 7 at 4-6). The exhibit is separately admissible +not for the truth of the matters asserted therein (such as the accuracy of the contact information for +victims), but to establish that the defendant kept contact information for relevant individuals at +trial, including victims. +The exhibit has evidentiary value in showing that the defendant +73 + + +maintained a contact book containing what purports to be this list of names and associated contact +information. +Second, the defendant moves to preclude any items seized during the 2005 search of +Epstein's home in Palm Beach, Florida. The defense claims, in a conclusory fashion, that "no +witness has +sufficient personal knowledge about the proposed exhibits" to demonstrate +authenticity, because "the evidence collection and retention in this matter is an unreliable mess." +(Def. Mot. 8 at 3-5). The defense further speculates that the Government intends to offer these +exhibits without any testimony about their authenticity, in part because the original custodian- +Detective +is dead. (Id. at 4-5). The defense is mistaken. The Government intends to +call live witnesses to establish the authenticity of the evidence at trial. 18 +Third, the defendant argues that the photographs in Government Exhibit 251 and 288 are +irrelevant. (Def. Mot. 13 at 2). +18 As to Government Exhibit 295 specifically, that exhibit was written by both Detective I +and another witness who is expected to testify at trial. The exhibit is primarily marked for +identification, although portions of that document may be offered as a past recollection recorded +by that other witness. See Fed. R. Evid. 803(5). The Government will not offer statements from +Detective +74 + + +Fourth, the defendant argues that Government Exhibit 294 is irrelevant. (Def. Mot. 13 at +2-3). Government Exhibit 294 displays a box containing "Twin Torpedos"— sex toys seized +during the search of Epstein's Palm Beach house. This photograph is corroborative of witness +testimony, which is expected to describe the presence of sex toys and that the defendant and +Epstein used sex toys during their abuse. +Fifth, the defendant argues that Government Exhibit 313 is irrelevant. (Def. Mot. 13 at 2- +3). Government Exhibit 313 is a photograph of the defendant and Epstein swimming together +while nude. This evidence corroborates witness testimony expected at trial, which will describe +topless swimming in the pool at Epstein's Palm Beach House. It is also relevant to the relationship +between the defendant and Epstein. For instance, to the extent the defense at trial argues that the +defendant was merely an employee of Epstein's, this photograph is evidence to the contrary. +Sixth, the defense argues that Government Exhibit 606 lacks evidentiary foundation, is +hearsay, and is irrelevant because it was created after the events alleged in the Indictment. (Def. +Mot. 13 at 2-3). Government Exhibit 606 is a manual governing the operations of the Palm Beach +house. A witness at trial is expected to authenticate this document and explain that it was the +version in effect at the house in 2005. Another witness is expected to testify about the rules in +effect in the Palm Beach household during the time period of the charged conduct; those rules are +75 + + +consistent with the rules in this exhibit.' The relevance of the document is self-evident: among +other things, it directs employees to "see nothing, hear nothing, say nothing." (GX 606 at 4). It is +not prejudicial as to her "lifestyle" (Def. Mot. 13 at 3), because the jury will already hear testimony +about her and Epstein's various properties, private jet, and employees. And the document is not +hearsay, because the statements are being offered as instructions to staff, not for the truth of the +matter asserted. +As described above, each of these exhibits is highly relevant, not hearsay or subject to a +hearsay exception, and can be authenticated at trial. The Court should deny the defense's motion +regarding relevance and Rule 403, and deny the motion regarding authentication with leave to +renew it at trial. +VII. There is No Basis to Preclude Discussion of "Victims" or Rape +Citing no case in the federal system, the defendant moves to preclude any trial participants +from referring to the Minor Victims as Victims. The defendant also moves to preclude testimony +concerning a rape committed by Jeffrey Epstein against one of the Minor Victims. Both of these +motions lack merit, and they should be denied. +A. References to Victims +19 Here and elsewhere (see, e.g. Def. Mot. 2 at 3-4), the defense argues that evidence that postdates the time period of the conspiracy is irrelevant. That is incorrect. What matters is whether +the evidence tends to make a fact of consequence more or less probable. If, for instance, there is +evidence showing that Epstein and the defendant were extremely close partners in 2005, that tends +to make it more probable that they had such a relationship in 2004, during the time period of the +conspiracy. It is therefore highly relevant. +76 + + +The defendant moves to preclude any trial participants from using the word "victim" to +refer to any of the Minor Victims. The Government expects that it will use the word "victim," +particularly in jury addresses, but such use is not improper vouching or prejudicial to the defense. +The Government also expects its expert to use the word "victim," but she will testify about victims +generally and not any victims in this case specifically. The Government does not otherwise expect +its witnesses to use the word "victim." To the extent they do, however, it is not prejudicial to the +defense.20 +The defendant cites no federal case that has accepted its argument. Nor does this argument +make sense. The erroneous premise in the defense argument is that referring to someone as a +"victim" "necessarily conveys the speaker's opinion that a crime in fact occurred and that the +accusers are credible." (Def. Mot. 12 at 1). That is incorrect. The Government's references to +"victims" are part of its theory of the case. Use of that term in a jury address is not an expression +of counsel's opinion; it is the Government's litigating position, just like referencing someone as +the "shooter" in a shooting case or the "dealer" in a narcoties case. See United States v. Arias- +Javier, 392 F. App'x 896, 898 (2d Cir. 2010) (summary order) (The prosecutor is permitted +vigorously to argue for the jury to find its witnesses credible as long as it does not link its own +credibility to that of the witness or imply the existence of extraneous proof supporting the witness's +' Notably, the defense motion is entirely premised on the notion that the parties disagree about +nether the Minor Victims are in fact victims of any crime. If the defense concedes at any poir +nat the Minor Victims are victims of any crime—for example, if the defendant concedes th +victims were abused by Epstein but disclaims knowledge or involvement their argument in +support of this motion collapses entirely. (Def. Mot. 12 at 1 (contrasting this case with cases in +which "there is no dispute that the person was a victim of something"). +77 + + +credibility."). Prosecutors are simply using a term that is consistent with the Government's theory +of the case. See United States v. Edwards, No. CR 16-103-BLG-SPW-1, 2017 WL 4159365, at +*1 (D. Mont. Sept. +. 19, 2017) (explaining that "use of the term 'victim' is not prejudicial to the +defendant's rights when the presentation of evidence taken as a whole clarifies the government's +burden of proving all of the elements of the crime" and finding that the "jury will not be unduly +prejudiced against [the defendant] if the government refers to certain witnesses as victims"); (citing +United States v. Washburn, 444 F.3d 1007, 1013 (8th Cir. 2006) ("[A] number of courts have +determined that the use of the term "victim" in jury instructions is not prejudicial to a defendant's +rights when, as is the case here, the instructions taken as a whole clarify the government's burden +of proving all elements of the crime")); Server v. Mizell, 902 F.2d 611, 615 (7th Cir. 1990) ("No +logical argument can be made that the mere use of the term 'victim' [in jury instructions] somehow +shifted the burden of proof."). In addition, "It]he term 'victim' is not inherently prejudicial. It is +a term commonly used in the English language that does not by its nature connote guilt." United +States v. Lussier, No. 18-CR-281 (NEB), 2019 WL 2489906, at *5 (D. Minn. June 15, 2019).21 +And just as the defense may make arguments attacking the credibility of victims, the Government +is free to argue that these witnesses are, in fact, victims of a crime. Cf. United States v. Thai, 29 +F.3d 785, 807 (2d Cir. 1994) (explaining that prosecutors may also "respond to an argument that +impugns its integrity or the integrity of its case"). +21 The same is true with references by the Government to "minor victims." (CY. Def. Mot. 12 at 4- +5). The Government does not expect any other trial participant to use the phrase "minor victims." +78 + + +Witnesses may also reference "victims." But the only witness the Government expects to +use the term "victim" is its expert, Dr. +And Dr. +will not be testifying about the +defendant or the Minor Victims in this case, but about victims of sexual abuse generally. +Accordingly, she is not vouching for the credibility of anyone in this case, or presuming anything +about the truth or falsity of any accusations. +To the extent other Government witnesses use the term "victim," however, it would not be +prejudicial to the defense. The limitation on improper vouching applies to the prosecutor, not to +Government witnesses, as even one of the defendant's cases acknowledges. See Jackson v. State, +600 A.2d 21,25 (De. 1991) ("The opinion does not state, nor does it imply, that the use of the term +'victim' by witnesses, as a term of art or in common parlance, is a basis for objection."). In +particular, some of the witnesses who may use the word "victim" are the Minor Victims +themselves, who are testifying about their subjective experiences. It is not prejudicial to the +defense for someone who considers herself a victim to testify as much.? +Here, as with other motions, the defendant requests an extraordinary order not seen in other +cases in this District. That request lacks merit, and the Court should deny it. +B. Evidence of Rape +The Government expects that at least one minor victim may describe being raped by Jeffrey +Epstein. If that testimony is offered, it is directly relevant to issues before the jury. The defendant +and Epstein are charged with transporting minors, enticing minors, or trafficking minors with the +22 The Government defers to the Court on how it would like to refer to the Minor Victims. It notes, +however, that "Accuser" is an alternative that is prejudicial to the Government. +79 + + +intention that they would engage in illegal or commercial sex acts, and conspiring to do, and aiding +and abetting, the same. These events occurred during an ongoing course of conduct, in some +instances during multi-year relationships. The ongoing relationships between the defendant, +Epstein, and the victims is directly relevant, and the victims' accounts of these events are necessary +to complete the story of the crime on trial. Indeed, given the complex relationships between +victims and their abusers, these events are integral to the relationships that will be at the heart of +the trial. The defendant repeatedly claims that there is no evidence she participated in or was +aware of a rape specifically (Def. Mot. 11 at 1-2), but defense arguments about her knowledge and +involvement are for the jury. +The defense argues that the Indietment does not allege that Epstein raped anyone, and so +the rape is irrelevant. (Def. Mot. 11 at 2). That is a non sequitur. Indictments are not documents +that contain all of the Government's evidence, and the defense cites no authority for the puzzling +argument that witnesses cannot testifying using words that are not contained in an indictment. To +the extent the defense understands the Indictment to allege only conspiracies to arrange for +sexualized massages for Epstein (id. at 3), the defense is mistaken. The Indictment charges the +defendant with conspiracies to arrange for "sexual activity" (Indictment 19 12, 18) and "a +commercial sex act" (Id. 9 24). +The defense also argues that evidence of a rape does not satisfy Rule 403 balancing, +because evidence of a rape is "highly emotional and inflammatory." (Def. Mot. 11 at 3). This +conclusory claim is insufficient to show prejudice to the defense. Testimony from victims in sex +crimes trials can be very emotional when describing their abuse and the perpetrator. But that +80 + + +evidence- +-including evidence of rape, where it occursis the core conduct in the case. See, e.g., +United States v. English, No. 18 Cr. 492 (PGG), 2020 WL 7773606, at *10 (S.D.N.Y. Dec. 30, +2020) (describing evidence of rape in a trial for sex trafficking of minors); United States v. +Graham, No. 14 Cr. 500 (NSR), 2015 WL 6161292, at *8 (S.D.N.Y. Oct. 20, 2015) (concluding, +in response to the argument that "rape" is a legal term, "there is a "critical distinction between a +patient telling a physician that she 'had intercourse with three men' and a patient telling the +physician that she was "raped' by three men."). Its probative value is certainly not outweighed by +any unfair prejudice. Nor is it the case that evidence of a rape especially at the level of +abstraction described by the defense is significantly more inflammatory than the charged crime: +the sexual abuse of minors. +In the event that a Minor Victim testifies that Epstein raped them, it is part of the charged +conspiracy in this case, and it should be admitted. +VIII. The Remaining Defense Motions are Aimed at Evidence the Government Does +Not Plan to Elicit +Three of the defense motions are aimed at precluding the Government from offering +evidence it does not intend to offer at trial. +First, the defense seeks to preclude the Government from arguing that the defendant was +hiding from, evading, or fleeing from law enforcement between Epstein's arrest and her own. +(Def. Mot. 5 at 1). The Government's view remains that such conduct reflects the defendant's +consciousness of her guilt (see id. at 2 (citing multiple Government filings)), and the Government +does not agree that such evidence lacks an adequate factual basis or is inadmissible under Rule +403. (See id. at 6-9). However, the Government does not intend-and so will agree not to offer- +81 + + +such evidence in its case-in-chief, unless the defendant opens the door to this evidence or otherwise +puts it at issue at trial. Furthermore, if the defendant testifies, the Government may cross-examine +the defendant about this conduct, depending on the scope of her direct examination. But the +Government will not affirmatively offer this evidence in its case-in-chief. +The same is true for the defense motion to exclude evidence of the defendant's false +statements in her 2016 depositions. (Def. Mot. 6 at I). Although false exculpatory statements are +admissible as proof of a defendant's consciousness of guilt (see Gov't Opp. at 142-43, Dkt. No. +204 (citing, e.g., United States v. Anderson, 747 F.3d 51, 60 (2d Cir. 2014), the Government does +not intend—and so will agree-not to offer this information as part of its case-in-chief, unless the +defense opens the door or otherwise puts these statements at issue. However, the Government may +offer these statements in rebuttal to defense arguments. Moreover, the defendant's prior statements +are of course appropriate material for cross-examination of the defendant. The Government also +consents to the defense request to redact the perjury counts from the Indictment. (Def. Mot. 6 at +6). +Finally, the defense seeks to preclude the Government's law enforcement witnesses from +offering expert testimony. (Def. Mot. 10 at 5). The defense appears to take an improperly broad +view of the scope of expert testimony." However, the Government has not noticed the three law +23 For instance, the defense, citing United States v. Garcia, 413 F.3d 201 (2d Cir. 2005), makes +the sweeping claim that "any opinion testimony" based on those three law enforcement witnesses' +"specialized "training and experience" is expert opinion testimony subject to Rule 702 and Rule +16(1)(G) and is inadmissible at trial." (Def. Mot. 10 at 4 (emphasis in original)). But in Garcia, +the Second Circuit simply held that an undercover law enforcement agent could not testify as lay +opinion that, based on his knowledge from other drug interdiction cases, the defendant was a + + +enforcement officers identified by the defense as experts and will not elicit expert testimony from +them. Those witnesses are being called as fact witnesses to describe, for instance, the execution +of a search and evidence seized during that search.24 +CONCLUSION +For the reasons set forth above, the Government respectfully requests that the Court deny the +defendant's motions in limine. +Dated: October 25, 2021 +New York, New York +Respectfully submitted, +DAMIAN WILLIAMS +United States Attorney for the +Southern District of New York +By: +/s/ +Assistant United States Attorneys +partner in the narcotics distribution conspiracy. Garcia, 413 F.3d at 216. That is distinguishable +from cases where, as expected here, witnesses testify based on their personal involvement in +certain investigative steps. +24 It bears noting that the defense's motion is expressly concerned about testimony from case +agents (Def. Mot. 10 at 5 n.2), and testimony about "the case, its origins, and the investigation" +(id. at 3), which it considers to be improper expert testimony. The Government has moved to +preclude the defense from offering such evidence, including by calling the case agents identified +in its Touhy notice. (See Gov't Motions in Limine Section Ill). Accordingly, if the defense plans +to call case agents for such testimony—which the Court should preclude the defense must +provide expert notice of such testimony. +83 diff --git a/vision-fixhub/ds9-parsed-01/2be8ffa2c63f8e8e26dde5b005c81389099e5c3b9fc79b0140ce4d1ed90bdf72.receipt.json b/vision-fixhub/ds9-parsed-01/2be8ffa2c63f8e8e26dde5b005c81389099e5c3b9fc79b0140ce4d1ed90bdf72.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..66bf7c7d460bf76d6c08163e090b7d9344509210 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2be8ffa2c63f8e8e26dde5b005c81389099e5c3b9fc79b0140ce4d1ed90bdf72.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -1044, + "dataset": "marble-joined", + "doc_id": "2be8ffa2c63f8e8e26dde5b005c81389099e5c3b9fc79b0140ce4d1ed90bdf72", + "engine": "marble-apple-vision", + "event_count": 102, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "82116c059ecba141ac3ca0fb331a6ad702920d3407db8b45586bfd7f5cb47450", + "output_sha256": "461655127bdb9ace08f88de897b52f01c2208d94c29247b583275e4265b90471", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2bf67af645cf4485b0f72d9a5e1c984b853a163ac6680c88962281dda8c87c23.md b/vision-fixhub/ds9-parsed-01/2bf67af645cf4485b0f72d9a5e1c984b853a163ac6680c88962281dda8c87c23.md new file mode 100644 index 0000000000000000000000000000000000000000..36b3102f536ae47b1e5cfe8792039d70e721afae --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2bf67af645cf4485b0f72d9a5e1c984b853a163ac6680c88962281dda8c87c23.md @@ -0,0 +1,58 @@ +Grand Jury Subpoena +United States District Court +SOUTHERN DISTRICT OF NEW YORK +TO: +GREETINGS: +Appearance Date: +July 24, 2019 +Appearance Time: 10:00 a.m. +to testify and give evidence in regard to an alleged violation of : +18 U.S.C. §§ 1591, 2421, 2422, 2423, 371 +and not to depart the Grand Jury without leave thereof, or of the United States Attorney, and that you bring +with you and produce at the above time and place the following: +See attached Advice of Rights +Failure to attend and produce any items hereby demanded will constitute contempt of court and will +subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law. +DATED: New York, New York +GSB- +July 5, 2019 +GEOFFREY S. BERMAN +United States Attorney for the +Southern District of New York +Assistant United States Attorneys +Telephone: +rev. 02.01.12 + + +Advice of Rights +1. You may refuse to answer any question if a truthful answer to the question would tend to +incriminate you +2. Anything that you do say may be used against you by the grand jury or in a subsequent legal +proceeding +3. If you have a lawyer, the grand jury will permit you a reasonable opportunity to step outside the +grand jury room to consult with your lawyer if you so desire. +4. If you would like a lawyer but do not have funds to retain one, you may make an application to +the United States Magistrate Judge who will decide whether to appoint a lawyer to represent you. + + +U.S. Department of Justice +United States Attorney +Southern District of New York +The Silvin I. Mollo Building +New Sain, New bors 020 T +July 5, 2019 +Re: Grand Jury Subpoena +Please be advised that the accompanying grand jury subpoena has been issued in connection with +an official criminal investigation of a suspected felony being conducted by a federal grand jury. The +Government hereby requests that you voluntarily refrain from disclosing the existence of the subpoena to +any third party. While you are under no obligation to comply with our request, we are requesting you not +to make any disclosure in order to preserve the confidentiality of the investigation and because disclosure +of the existence of this investigation might interfere with and impede the investigation. +Moreover, if you intend to disclose the existence of this subpoena to a third party, please let me +know before making any such disclosure. +Thank you for your cooperation in this matter. +Very truly yours, +GEOFFREY S. BERMAN +United States Attorney +By: +Assistant United States Attorneys diff --git a/vision-fixhub/ds9-parsed-01/2bf67af645cf4485b0f72d9a5e1c984b853a163ac6680c88962281dda8c87c23.receipt.json b/vision-fixhub/ds9-parsed-01/2bf67af645cf4485b0f72d9a5e1c984b853a163ac6680c88962281dda8c87c23.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..3e0cece3e38b466b3a3234475af226b97bee2718 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2bf67af645cf4485b0f72d9a5e1c984b853a163ac6680c88962281dda8c87c23.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -36, + "dataset": "marble-joined", + "doc_id": "2bf67af645cf4485b0f72d9a5e1c984b853a163ac6680c88962281dda8c87c23", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "73b42d215f6f4f241c92d884253d9fccfda6d3c7988f217a83039795911bb972", + "output_sha256": "a7e1a28c50fd7b08c24785cdad46118c3a11063eab531c7715acd0d29efc1b94", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2c4ec76d57912f3840082dae1633ee4098a09d459723e0a4f63670ea270e37fa.md b/vision-fixhub/ds9-parsed-01/2c4ec76d57912f3840082dae1633ee4098a09d459723e0a4f63670ea270e37fa.md new file mode 100644 index 0000000000000000000000000000000000000000..a82456112ce70bf5b8c379805b126ee6b04d399c --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2c4ec76d57912f3840082dae1633ee4098a09d459723e0a4f63670ea270e37fa.md @@ -0,0 +1,42 @@ +From: +To: " +Subject: FW: Subpoena - JP Morgan Chase Re +Date: Tue, 08 Oct 2019 15:09:54 +0000 +I know we're just sort of deferring to +on whatever projects he's working on, but do you guys think we want +to have any kind of conversation / oversight with him on any of this? It occurs to me in particular for entities he's +subpoenaing where we already have ongoing interactions with counsel, for example. I don't have super strong +feelings either way but wanted to check in on it. +----Original Message--. +From: +Sent: Tuesdav. October 08. 2019 U:07 +To: +Subject: RE: Subpoena - JP Morgan Chase Re +Subpoena attached, thanks. +Assistant United States Attorney +Southern District of New York +1 St. Andrew's Plaza +New York. NY 10007 +-----Original Message----- +From +Sent: Tuesday, October 8, 2019 8:10 AM +To: +Subject: Subpoena - JP Morgan Chase Ro +Please prepare and return to me a subpoena for JP Morgan Chase regarding +rider for the subpoena. I will serve the subpoena. +Additionally, please utilize the following text in the subpoena: +If you have any questions, please contact Forensic Accountan +I have attached the + + +or Special Agent +Please forward the results in an electronic format to Special Agent +Investigation, 26 Federal Plaza, New York, NY 10278, telephone +If you have any questions or comments, please contact me. +Thanks +Mark +Forensic Accountant +FBI New York Field Office +26 Federal Plaza +NYC, NY 10278 +Office: diff --git a/vision-fixhub/ds9-parsed-01/2c4ec76d57912f3840082dae1633ee4098a09d459723e0a4f63670ea270e37fa.receipt.json b/vision-fixhub/ds9-parsed-01/2c4ec76d57912f3840082dae1633ee4098a09d459723e0a4f63670ea270e37fa.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..ccf3539c3b1e7ce64f0cb5a82bfd14173bab8a39 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2c4ec76d57912f3840082dae1633ee4098a09d459723e0a4f63670ea270e37fa.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "2c4ec76d57912f3840082dae1633ee4098a09d459723e0a4f63670ea270e37fa", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "9407ee7121489b4f1b46ad0fcc533ddc40c5371f2fdb6f47e8c56e50f7d14ec1", + "output_sha256": "dbe982a0d34f08b0e9db0f95041ef0f982dd798428e44f5e19200820efa22870", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2c58ecde73ad4f3e31f68d500da4363d163503a84770ed7132ccf4f13c140f39.md b/vision-fixhub/ds9-parsed-01/2c58ecde73ad4f3e31f68d500da4363d163503a84770ed7132ccf4f13c140f39.md new file mode 100644 index 0000000000000000000000000000000000000000..b4764fb5fde9efd7b8209febf5b46ffd94169f09 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2c58ecde73ad4f3e31f68d500da4363d163503a84770ed7132ccf4f13c140f39.md @@ -0,0 +1 @@ +No Images Produced diff --git a/vision-fixhub/ds9-parsed-01/2c58ecde73ad4f3e31f68d500da4363d163503a84770ed7132ccf4f13c140f39.receipt.json b/vision-fixhub/ds9-parsed-01/2c58ecde73ad4f3e31f68d500da4363d163503a84770ed7132ccf4f13c140f39.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..219bb653cc62f0d71b830d5bde9959c5cbd34e23 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2c58ecde73ad4f3e31f68d500da4363d163503a84770ed7132ccf4f13c140f39.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "2c58ecde73ad4f3e31f68d500da4363d163503a84770ed7132ccf4f13c140f39", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "667095973927545203db69829e3ee7cccd86d518483f46a7b73f0a6f2edd87bc", + "output_sha256": "3874328764c818fba06683a6d5ddc2edc2d7850aaf4ba18646f81d3f8420a729", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2c7cadb1664d5b64e5e75d931ef289fa9652d63371c7739000eb16588c6aa50e.md b/vision-fixhub/ds9-parsed-01/2c7cadb1664d5b64e5e75d931ef289fa9652d63371c7739000eb16588c6aa50e.md new file mode 100644 index 0000000000000000000000000000000000000000..1c415479404f9b01cd3eb72ed4cc77fe6723633e --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2c7cadb1664d5b64e5e75d931ef289fa9652d63371c7739000eb16588c6aa50e.md @@ -0,0 +1,86 @@ +To: +From: +OFFICE OF THE GENERAL COUNSEL +Sent: +Wed 8/14/20193:08:00 PM +Subject: BOP OFFICIAL - LEGAL HOLD NOTICE for (INMATE DEATHI +CustodianDocSearchCheckList_LHN-CIV-2019-00204 +itt +Subject: BOP OFFICIAL - LEGAL HOLD NOTICE for (INMATE DEATH) +Legal Hold Notice: Record Custodians + +U.S. Department of Justice +Federal Bureau of Prisons +Aug 14 2019 +NOTIFICATION FOR: MICHAEL ALBERT THOMAS, TOVA A NOEL, + +SDNY_00009827 + + +FROM: +The Office of the General Counsel, Federal Bureau of Prisons +Supervisory CLC Attorney +EMAIL: +ADDRESS: +RE: +NEW YORK NY 10007 +obligation to Preserve Records and Electronically Stored Information in +INMATE DEATH, LHN-CIV-2019-00204 +The BOP and its employees are required to preserve any potentially relevant +information pertaining to +On Saturday, August 10, 2019, at around 6:30 am, EPSTEIN, Jeffrey, reg. no. 76318 +054, was found unresponsive in his cell in conjunction with an apparent suicide, and, +subsequently, pronounced dead at the local hospital. No lawsuit has been filed yet, +but one is anticipated. +In this case, relevant information includes, but is not limited to: +Please preserve all electronic files (e.g. emails, Word documents, TRUSCOPE +entries, videos, BEMR records) and all handwritten or other physical documents +pertaining to inmate Epstein. +You have been identified as an individual likely to have information relevant to +this matter. Therefore, you must take appropriate steps to preserve any such +information in your possession, custody, or control even if it otherwise would be +destroyed, deleted or overwritten, in the normal course of Agency operations. +Knowingly altering, editing, or deleting potentially relevant information could +result in court-ordered sanctions against the BOP and/or employment action +against staff. +Electronically stored information (ESI) includes all information stored in any +digital medium, including the BOP s computer network, any PCs, laptop computers, +all back-up media, email, calendars, word processing documents, scanned documents, +spreadsheets, photos and drafts. +DO NOT DISCARD OR DESTROY ANY RECORDS (ELECTRONICALLY STORED OR OTHERWISE) +RELATING TO THIS MATTER. +Action Required: +1. Complete the attached Custodian Document Search Checklist and return to +by 08/21/2019. +2. Preserve Relevant Information +a. Do not alter, edit, delete, or otherwise destroy potentially relevant +information in either paper or digital documents. All auto-deletion +functions should be turned off and any retention policy should be +suspended if execution would cause the loss of potentially relevant +information. Do not move or alter electronic documents as this will + +SDNY_00009828 + + +modify the metadata. Should you need to work on a relevant document, +please save it as a new version and edit the new version. +b. Do not transfer any potentially relevant information to a +Federal Records Center (FRC) or any other location. +c. Notify me of any potentially relevant information that is in the +process of being or has been sent to an offsite storage facility +(FRC or any other offsite facility) . +3. Contact me if there are any staffing changes in your office that affect +this matter (e.g., retirement, transfer, etc.). +4. If you are aware of the loss of any potentially relevant ESI, notify me +immediately. +5. This document is privileged and confidential. +DO NOT FORWARD OR SHARE THIS NOTICE WITH ANYONE. +PLEASE SEND ANY QUESTIONS OR COMMENTS TO +CERTIFICATION +I certify that I have read the above, and I am complying with my preservation obligations. +(PLEASE CERTIFY BY CLICKING "CONFIRMATION LINK" below.) +Confirmation Link +NOTE: PLEASE DO NOT REPLY TO THIS EMAIL DIRECTLY. THIS IS A SERVICE +MACHINE FOR OUTBOUND MESSAGES ONLY. + +SDNY_00009829 \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/2c7cadb1664d5b64e5e75d931ef289fa9652d63371c7739000eb16588c6aa50e.receipt.json b/vision-fixhub/ds9-parsed-01/2c7cadb1664d5b64e5e75d931ef289fa9652d63371c7739000eb16588c6aa50e.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..2b7b9193b6a6b9c32923ff47fb54c6bba7ca068f --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2c7cadb1664d5b64e5e75d931ef289fa9652d63371c7739000eb16588c6aa50e.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -87, + "dataset": "marble-joined", + "doc_id": "2c7cadb1664d5b64e5e75d931ef289fa9652d63371c7739000eb16588c6aa50e", + "engine": "marble-apple-vision", + "event_count": 6, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.privileged-attorney-work-product\"]", + "idempotent": true, + "input_sha256": "a069a395fd8d0b452b35ba15a8d3e81c60cf5b9e71c396fabbf56026354aa076", + "output_sha256": "ffc98c81ceba50dfaa475bed447d61909c44eb57dd99b7e4ba1e90e1aeb169f4", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2c899e372686cb0450b49932b6cae30a8469def498a70d9886535611613fc5a6.md b/vision-fixhub/ds9-parsed-01/2c899e372686cb0450b49932b6cae30a8469def498a70d9886535611613fc5a6.md new file mode 100644 index 0000000000000000000000000000000000000000..e69de29bb2d1d6434b8b29ae775ad8c2e48c5391 diff --git a/vision-fixhub/ds9-parsed-01/2c899e372686cb0450b49932b6cae30a8469def498a70d9886535611613fc5a6.receipt.json b/vision-fixhub/ds9-parsed-01/2c899e372686cb0450b49932b6cae30a8469def498a70d9886535611613fc5a6.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..cf5d5d9c0d3cf116052b2b55b708c4da390db102 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2c899e372686cb0450b49932b6cae30a8469def498a70d9886535611613fc5a6.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "2c899e372686cb0450b49932b6cae30a8469def498a70d9886535611613fc5a6", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "447a7aa89278feb16cac109878b5559ceb4ba25544bc46838e50c45005eeb369", + "output_sha256": "e3b0c44298fc1c149afbf4c8996fb92427ae41e4649b934ca495991b7852b855", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2cd3d7f137ea74938f9a275db57ea5ca0c23894c4ff0a2fe1345cb163dcfddf1.md b/vision-fixhub/ds9-parsed-01/2cd3d7f137ea74938f9a275db57ea5ca0c23894c4ff0a2fe1345cb163dcfddf1.md new file mode 100644 index 0000000000000000000000000000000000000000..ee2a84ef1ad3ec85b2cf65c195e3af1922127708 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2cd3d7f137ea74938f9a275db57ea5ca0c23894c4ff0a2fe1345cb163dcfddf1.md @@ -0,0 +1,44 @@ +From: ' +To: +Cc: +Subject: RE: 302s / interview notes +Date: Thu, 14 May 2020 18:00:06 +0000 +Attachments:| +Thanks very much, that's great. And the +• and bu +notes are attached. +From: +To: +Cc: +Sent: Thursday, May 14, 2020 13:47 +Subject: RE: 302s / interview notes +Hi all, +l've attached the notes you've requested. I've also attached +302 and notes; that interview was not in +the batch we gave you. You'll see below where I've typed "attached" to reflect what notes we have. Interviews where +this is not written simply meant there were no notes to attach likely because the interview/contact was brief (I double +checked all to be sure). Let me know if there is anything else you come across that we've missed sending. +Also, could you send over the notes from the last two phone interviews with +we have them on our end. +and +? Just want to make sure +Thanks, +From: +To: +Cci +Sent: Friday, May 08, 2020 6:52 PM +Subject: RE: 302s / interview notes +Thanks very much again for getting us so many 302s recently, we really appreciate it. Collectively, there have been more +than 120 interviews in this case, which is incredible. We've now completed a full review and cross-reference of all our +materials, so wanted to address a handful of loose ends. In terms of reports, I think currently we're down to only missing +three, all of which we have interview notes for but no 302s: + + +And then there are a larger number of interviews where we have a 302 but not hand-written notes. My guess is that for +some of these, and possibly most, there aren't notes because the "interviews" were so short that they just got typed up, +but we wanted to check. Also most of them were interviews conducted by other agents (where it was agents other than +one or both of you, I've indicated below). But if you could please double check to see if there are interview notes for the +following, and in particular the few that are in bold? And let us know if any questions or issues. They are: +Thanks again! +Assistant U.S. Attorney +Southern District of New York diff --git a/vision-fixhub/ds9-parsed-01/2cd3d7f137ea74938f9a275db57ea5ca0c23894c4ff0a2fe1345cb163dcfddf1.receipt.json b/vision-fixhub/ds9-parsed-01/2cd3d7f137ea74938f9a275db57ea5ca0c23894c4ff0a2fe1345cb163dcfddf1.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..aa89affb094fe1355d9ae39ed45a62d7c1837138 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2cd3d7f137ea74938f9a275db57ea5ca0c23894c4ff0a2fe1345cb163dcfddf1.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "2cd3d7f137ea74938f9a275db57ea5ca0c23894c4ff0a2fe1345cb163dcfddf1", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "6d2ba6701ff8edc636b1ef3c556da3a1dd3d1eba27d80e46578a193cceb1891d", + "output_sha256": "3994c8eedc7400179eb62d3fb2889c5b8e17d7e065e92b75b576460efb96e0b2", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2d192e06f75963e465bb35f767e034364e30fee6c8726e6cb4e6482ba45f4a03.md b/vision-fixhub/ds9-parsed-01/2d192e06f75963e465bb35f767e034364e30fee6c8726e6cb4e6482ba45f4a03.md new file mode 100644 index 0000000000000000000000000000000000000000..480e3e2544e9a123aecc3cb8d13b7b22c53fb466 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2d192e06f75963e465bb35f767e034364e30fee6c8726e6cb4e6482ba45f4a03.md @@ -0,0 +1,3046 @@ +To: + + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +Date: Tue, 22 Jun 2021 11:31:14 +0000 +Attachments: KCG_Appendix_3-20_13_penultimate.docx; KCG_TCR_3-20-13-penultimate_draft.pdf; +KCG_TCR_3-20-13-penultimate_draft.docx; KCG_Appendix_3-20_ +_ 13_penultimate.pdf; +kcglq2015.pdf +SDNY Judges: which one of you will be the lucky recipient of still MORE SEC fraud on your courts? +Complaint - OFER ABARBANEL (sec.gov). +As is SOP for the SEC +More OMMISSIONS than submissions +per the Welshans et al SEC "complaint" +"NALR is a shell company...." +Full stop. NALR/Alaska/New York/State was at ALL times a FULLY REPORTING SEC company +Are we clear? +Further: +"From March 2019 through November 2020, Abarbanel and the (FULLY SEC REPORTING SHELL) Fund +transferred approximately $102,000,000 of the funds invested by investor Group A into NARL ACCOUNTS" +the COO of State Funds/New York Alaska is Nicholas Abbate +A former "independent" Market Maker at Knight Capital +UNITED STATES (sec.gov). +Guess who controlled (for others) 40% of the State Fund receiving the $102,000,000 investor Funds? +"Note 9. Control and Ownership" +Brown Brothers Harriman +The penny stock money launderer FINRA/Dick Best all entities un named +Guess who controlled (for others) 57% of the State Fund/NARL receiving the $102,000,000 investor funds? +Bahamas/Toronto based Old Fort/Mosaic Ltd +Mosaic Financial (mosaic-financial.com). + + +Mosaic Financial +For more than 50 years, our team has built on expertise in private +banking for UHNW individuals and families to serve larger and +more complex accounts in financial technology. To serve our +clients better, we provide a turnkey asset management platform +that simplifies custody, execution, accounting, reporting, research, +mosaic-financial.com +Yet, somehow/ some way: no mention of COO Abbate, BBH, OR Mosaic/Old Fort +AND +Of course: absolutely ZERO reference to AML. +ANOTHER fraud SEC complaint coming to the SDNY Courts +The SEC is a grossly corrupt, criminal organization bought and paid for by criminals ACTIVELY facilitating +multiple, massive, ongoing frauds on the public while screwing the whistleblower who caught them: ME +Sent: Friday, June 11, 2021 5:59 AM + + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +SDNY,NY Supreme Court, NJ Judges et al +to say the SEC is a grossly corrupt, criminal enterprise ACTIVELY facilitating multiple, massive, ongoing frauds on +the public to the benefit of the criminals who own them while screwing the whistleblower who caught them: +me. The real world implications of this irrefutable FACT are staggering. REAL lives changed/ruined. Staggering +losses for "main street investors" as Clayton referred to them. Because, for ANYONE spending more than an +hour or 2 on a trading desk: Gordon Gekko was right: "It's a zero sum game. Somebody wins, somebody loses". +The Grossly corrupt SEC has rigged the game in favor of the criminals over the public it is mandated to protect. +Mr Paley, did your Micro Cap Fraud Task Force actually accomplish ANYTHING? How did 4+ +TRILLION shares of OTCM money laundering shells trade in 1Q, 2021? Are prolific Bag Men like Kramer and +Honig etc etc etc actually "out of business"? +HELL NO! +Mr Gensler, Chair Waters/Congress made repealing the grossly corrupt Clayton, Peirce, Roisman Rule in the +summer of 2020 that exempts 90% of current 13 F filers a priority. Will you execute the stated will of Congress? +As the Corrupt POS Paley et al know: NONE OF THESE CRIMINALS are out of business in 2021. In Fact, business +is BOOMING +SEC.gov | SEC Proposes Amendments to Update Form 13F for Institutional Investment Managers; Amend +Reporting Threshold to Reflect Today's Equities Markets +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. +Speaking of Prolific Bag Man Honig: As you are all aware, I made the connection between Honig, Russian +entities, Signature Bank: SBNY, and the criminal law firm of Sichenzia Ross. Mr Gottschall: Have you been able +to locate Castle Rock on a map yet? +Here are just a few of the recently filed RIOT Blockchain filings with the SEC + + +Detailing a few "transactions" +With the likes of The Bejing China Bitcoin mining company Bitmain where RIOT bought the "mining machines" +at the Rockdale Texas 1gigt "HPC" data center. It doesn't look like Bitmain has much of a future in China. But +Rockdale Texas is a growth market for sure. +https://www.sec.gov/Archives/edgar/data/1167419/000107997321000272/ex99x1.htm +SEC.gov| HOME +Hash Rate Growth . By Q4 2022, Riot expects a total hash rate capacity of 7.7 EH/s with a fleet of +approximately 81,146 Antminers, 95% of which will be the latest generation S19 series model. +Another "transaction" involves the RIOT acquisition of a Data Center in Rockdale Texas owned by a German +entity called Northern Data/Northern Bitcoin/Whinstone +Northern Data AG successfully closed the sale of its Texas data center to Riot Blockchain, Inc. - Northern Data +AG +Northern Data AG successtully closed the sale of its Texas data center to +Riot Blockchain, Inc. - Northern Data AG +Frankfurt am Main - May 27, 2021 - Northern Data AG (XETRA: NB2, ISIN: DE000AOSMU87) a leading +infrastructure supplier for Bitcoin mining and other HPC infrastructure solutions, successfully completed the +sale of its U.S. subsidiary Whinstone US, Inc., which operates a high-performance data center facility based +in Rockdale, Texas, to Riot Blockchain, Inc. (NASDAQ: "RIOT"). The ..... +northerndata.de +Northern Data is a publicly traded company with ADR's trading OTCM Pinks. +US Jurisdiction established +Half-Year-Report_2019.pdf (northerndata.de) +HALF-YEAR REPORT 2019 - Northern Data +PAGE 4 NORTHERN BITCOIN AG | HALF YEAR REPORT 2019 BITCOIN IS CHANGING THE WORLD Bitcoin is a +digital finance system that cannot be manipulated. +northerndata.de + + +Investor Relations - Northern Data AG +Investor Relations - Northern Data AG +Northern Data AG develops and operates global infrastructure +solutions in the field of High-Performance Computing (HPC). +With its customer-specific solutions, the company provides the +infrastructure for various HPC applications in areas such as bitcoin +mining, blockchain, artificial intelligence, big data analytics, IoT or +northerndata.de +OTC Markets NDTAE| Company Profile OTC Markets +Northern Data is now a 12% holder of RIOT +Inline XBRL Viewer (sec.gov) +EDGAR Filing Documents for 0001140361-21-019019 (sec.gov). +Northern Data/Bitcoin Frankfurt came into existence in 2015. +The founder is a guy named Mathis Schultz. Mr Schultz previously was a Private Banker at Julius Baer, LGT, +and Elan Capital Management +Mining Like a Viking: How the Ejords of Norway Offer a Greener Alternative - Bitcoin Magazine: Bitcoin +News, Articles, Charts, and Guides +Mining Like a Viking: How the Fjords of +Norway Offer a Greener Alternative - Bitcoin +Magazine: Bitcoin News, Articles, Charts, and +Guides +Northern Bitcoin's energy costs are lowered still by the climate +control measures Lefdal mine features by design. As if the +Norwegian climate wasn't cool enough, the data center is +situated some 656 feet below ground, so it maintains a constant +temperature of 55 degrees Fahrenheit (~12.5 degrees Celsius). +bitcoinmagazine.com +Schultz picked a very interesting nobody from New Orleans to build his 1Gig+ "HPC" data center in Rockdale +Texas: Chad Everett Harris +qualifications? +The Year of Chad Everett Harris - Chad Everett Harris + + +The Year of Chad Everett Harris - Chad Everett +Harris +2020 will be the Year of Chad Everett Harris. This will be the year +that the last 1642 days of work pays off and things get back to +my normal chaotic life that I love. This year will be filled with +achievement, challenges, and excitement. It will also be a year of +living in the [...] +www.chadeverettharris.com +Chad Everett Harris | Meet New Orleans Entrepreneur +Chad Everett Harris | Meet New Orleans +entrepreneur +Chad Everett Harris realized his passion for entrepreneurship very +early on in his childhood. Born in Palos Verdes, California in 1969, +he spent much of his young life moving between cities across the +US.In his early years alone, he spent considerable time in Georgia, +Michigan, and Louisiana. +www.chadeverettharris.com +Chad Everett Harris Archives - Page 2 of 4 - Chad Everett Harris +Northern Data/ Northern Bitcoin bought Whinstone in 2019. +Whinstone was building its Rockdale Texas 1 gigt "HPC" data center in 2020 supervised by Chad Everett Harris +Northern Data/ Northern Bitcoin sells Whinstone Texas "Data center" in April 2021 +Northern Data founded in 2015 by former Private Banker Mathis Schultz +RIOT has no office at SEC filings address. +RIOT is Honig/Russian money laundering shell +RIOT does "offering" with SBNY as escrow agent and the criminal law firm Sichenzia Ross. +Northern Data trades OTCM Pinks: no info +Northern Data now owns 12% of RIOT +RIOT is a "customer" of Beijing based Bitmain which has been effectively shut down by the PRC +Bitmain filed a "secret ipo" with Clayton/SEC +RIOT is a National security risk and ONGOING fraud on the public kept up and running by the grossly corrupt +SEC: Gottschall et al +Bitmain +funny. +Mr Gottschall: And to think ALL of this is happening 15 from my home in Castle Rock Colorado. Too fucking + + +Sent: Tuesday, June 1, 2021 6:31 AM + + +subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +SDNY, NY Supreme Courts/NJ Courts grossly corrupt SEC et al, +Let's break down VIRT CEO Dougie "Mr Transparency" Cifu comments to Sell Side analists on the NITE/VIRT 10. +2021 earnings call in May 2021: +Per below: +"Yes, Dan, obviously you look at the same metrics I do, just to give you a little commentary on them,l mean +April volumes were a hair under 10 billion shares per day which is down 32 odd percent from the first +quarter....." +Meaning: 1Q, 2021 equity market making volumes at NITE were roughly 13 billion shares per day. +Let's compare the last KCG stand alone quarter: 102017 (below) where total equity market making share +volumes were "a hair OVER 10 billion shares per day": 10.082 billion shares per day to be exact. +KCG 1Q2017: 154 mil trading revenue +93.589 mil commissions/fees +eps .05/ 67 mil shares outstanding +Since Dougie "Mr Transparency" Cifu won't actually disclose 102021 metrics, let's do some simple math and +solve for "X" shall we? +NITE/VIRT COMBINED 1Q2021 +Remember: "April volumes were down approximately 32% from 1Q, 2021 volumes " +April volumes were a "Hair under 10 billion shares pe day" +Therefore: Cifu says to Sell Side analysts on May4 2021 earnings call: 102021 share volumes were roughly 13 +billion shares per day +The 1q2021 NITE/VIRT combined SEC reviewed 10Q. +Document (sec.gov) +trading income: 812.743 mil +net commissions: 191.64 mil +eps 1.91/sh on 123.4 mil shares out +Again: 1Q, 2017 OTCM Pink money laundering shell volumes: 90%+ of total equity MM volumes +OVERALL OTCM Volumes: 100-300 billion shares/month +in 102021 OVERALL OTCM Money laundering share volumes were 4+ TRILLION shares +a 10-30x+ INCREASE 2021 vs 2017 in OTCM Money laundering shell volumes +YET TOTAL equity market making share volumes were up just 30+% 102021 vs KCG stand alone 1020177??? +How much market share did NITE/VIRT LOSE since 2017: 90+%???? +NITE/VIRT 1Q2021 share volumes were MULTIPLES of 13 billion shares/day. Cifu is KNOWINGLY LYING +Further: +Recall: ANOTHER example of SEC corruption: the KCG 1Q2014 "astronomical" OTCM share volume metrics +expunged by McKessy, Norberg, Pasquinelli, et al from the 102014 10Q: +The KCG stand alone 1Q2014 10Q: the basis of my March 2014 letter to McKessy with Berger Montague : I have +attached the KCG 1Q2015 SEC reviewed 10Q, above +Year over year numbers: The corrupt SEC failed to expunge +Pg 53 +1Q2014 KCG STAND ALONE OTCM share volumes +14.045 BILLION shares/day (My Letter to McKessy) + + +NYSE/NASDAQ volumes: 862 MILLION shares/day +So according to Dougie "Mr Transparency" Cifu" +1Q,2021 average daily share volumes were roughly 13 billion shares per day: This number is LESS than KCG stand +alone 102014 share volumes of almost 15 billion shares/day: 7 FUCKING YEARS AGO +In 1Q2014 KCG trading revenue was 254.6 million and eps was .30/share +This is blatant, egregious Cifu/SEC facilitated fraud on the public the SEC is mandated to protect. +WHY is Cifu hiding this from the investing public and as important: WHY is the grossly corrupt SEC letting him? +Read my TCR. In furtherance of the conspiracy: the CORE business at Knight/KCG/VIRT: NITE is and always has +been Illegal naked shorting OTCM shells to facilitate money laundering. +Further: Clayton et all CORRUPTLY gave NITE and CDEL their own exchange: MEMX: in 2020 for this EXACT +reason +The FINRA OTCM share volume discrepancies explained: NITE/VIRT is NOT reporting the vast amount of illegal +naked shorting OTCM share volumes. Recall my correspondence to the grossly corrupt SEC when MEMX was +announced: "Just between us criminals" +Once again, my allegations are irrefutably accurate. The SEC has AGAIN doubled down and taken the side of the +criminal entity NITE. As a result: the SEC ACTIVELY facilitates multiple, ongoing frauds on the public to the +benefit of the criminals who own them while screwing the whistleblower who caught them: ME. +Whistleblower extraordinaire +Sent: Friday, May 28, 2021 8:58 AM + + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +SDNY/NY Supreme Court/NJ judges: My apologies. I think I typed too fast for many on this email. Let me state +plainly what | allege: For that, I turn directly to UBS Sell Side Analyst Alex Kramm who had quite the exchange +with Cifu on the 1Q, 2021 earnings call earlier this month. +Mr Kramm: based on my analysis below, tell everyone WHY you think Cifu chose to be "Less transparent" with +regards to 1Q,2021 share volumes? +l'll type slower this time: +1Q, 2021 OTCM total reported share volumes: 4+ TRILLION +Cifu on the call! have electronic version should you prefer) +"Yes Dan (Jefferies analyst Fannon), obviously, you look at the same metrics I do, just to give you a little +commentary on them (without actually disclosing them), I mean April volumes were a hair under 10 billion +shares per day......' +Mr Kramm: this is a knowingly, blatantly false and misleading statement. Accurately: a bald face lie. This is why +Cifu won't disclose the actual share volumes. +Per below: in 1Q, 2017: the last stand alone KCG quarter: OTCM share volumes were reported in SEC reviewed +10Q at 9+ billion shares/day. Back when OTCM TOTAL SHARE VOLUMES were reported in the 100-300 billion +shares per month. +Yet, in 1Q 2021 when total reported OTCM share volumes were more than 1 TRILLION shares per month, hitting +almost 2 TRILLION shares in Feb 2021, Cifu would have us believe NITE Equity market making share volumes +were a "hair under 10 billion shares per day". +A blatant LIE. The SEC knows EXACTLY what the NITE equity share volumes were in 102021. And it was a LOT +MORE than "a hair under 10 billion shares/day". Driven of course by OTCM Money laundering shells Trading +profits: illegal naked shorting. Exploding balance sheet. Insolvent still/again. +Once again, the SEC facilitating/covering up a MASSIVE ongoing fraud on the public to the benefit of the +criminals who own them while screwing the whistleblower who caught them: ME + + +Have a GREAT long weekend! +Whistleblower Extraordinaire +From: Chris Dilorio «| +Sent: Friday, May 28, 2021 7:25 AM +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +Ms Pasqinelli, + + +There have been 3 (THREE) SEC actions CLEARLY based on my information that also CLEARLY qualify for OWB +Award eligibility. +Sason/Keener/Salviola et al: NewLead +Joshua Sason, et al. (Release No. LR-24403; Feb. 15, 2019) (sec.gov). +Joshua Sason, et al. (Release No. LR-24403; Feb. 15, 2019) +SEC Files Charges in Elaborate Microcap Stock Fraud Litigation Release No. 24403 / February 15, 2019 +Securities and Exchange Commission v. Joshua Sason, et al. +John Fife +John M. Fife, Chicago Venture Partners, L.P., Iliad Research and Trading, St. George Investments LLC, Tonaquint, +Inc., and Typenex Co-Investment, LLC (Release No. LR-24886; Sep. 3, 2020) (sec.gov) +John M. Fife, Chicago Venture Partners, L.P., Iliad Research and Trading, St. +George Investments LLC, Tonaquint, Inc., and Typenex Co-Investment, LLC +(Release No. LR-24886; Sep. 3, 2020) - SEC.gov +The Securities and Exchange Commission today filed charges against John M. Fife of Chicago and +companies he controls for acquiring and selling more than 21 billion shares of penny stock without +registering as a securities dealer with the SEC. +Justin Keener/JMJ +Justin W. Keener d/b/a JMJ Financial (Release No. LR-24779; Mar. 24, 2020) (sec.gov). +Justin W. Keener d/b/a JMJ Financial (Release No. LR-24779; Mar. 24, 2020) +- SEC.gov | HOME +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) +ALL: My information. +Yet NONE of these actions have been posted to the OWB Award Eligible website +SEC.gov | Office of the Whistleblower +SEC.gov | Office of the Whistleblower + + +NOTICE: Until further notice, any Whistleblower Award Applications submitted by mail should be sent to +the following address due to the mandatory telework posture at the SEC's Washington, DC headquarters: +14420 Albemarle Point Place, Suite 102, Chantilly, VA 20151-1750. +SEC IG Hoecker: HOW IS THIS REMOTELY PLAUSIBLE?? +There is only 1 explanation: SEC criminal obstruction and corruption. +Like the Dick Best/FINRA BBH complaint: also my information. No mention of executing broker dealers/MM's. +OR as the SEC would like us to believe: "Penny stock trading fairies" +NO! +The SEC in ALL of these actions is protecting the criminal enterprise which has been bailed out on multiple +ocassions: Knight/KCG/VIRT:NITE +Automatically placing this criminal enterprise on the SEC "Do not investigate list". +As a result, the SEC has KNOWINGLY, ACTIVELY facilitated countless, ongoing frauds on the public it is mandated +to protect. ALL of the ilegal activity I have detailed is ongoing in May 2021. NITE is again/still insolvent. Cifu in +the latest attempt to conceal this massive ilegal activity has once again limited transparency for the investing +public. The NITE Q1 earnings call: May 4, 2021 +Virtu Financial Inc (VIRT) Q1 2021 Earnings Call Transcript | The Motley Fool +Virtu Financial Inc (VIRT) Q1 2021 Earnings +Call Transcript | The Motley Fool +Virtu Financial Inc (NASDAQ:VIRT) Q1 2021 Earnings Call May 4, +2021, 8:30 a.m. ET. Contents: Prepared Remarks; Questions and +Answers; Call Participants; Prepared Remarks: Operator. Good day, +and... +www.fool.com +Cifu: "April volumes were a hair under 10 billion shares per day…...." +So, the last 10Q, filed by KCG/Knight as a stand alone company was 10, 2017. The VIRT acquisition closed on July +31, 2017. Cifu won't disclose and the SEC let him KCG 2Q2017 financials. BLATANT fraud. Cifu/ the SEC wrote +down more than $4 billion in fails. +The 1Q2017 KCG 10Q +Document (sec.gov) +Market Making stats. Cifu no longer discloses in SEC reviewed filings +Avg daily OTC BB and OTC Market shares traded (millions) 9,096 +Avg daily NYSE AND NASDAQ shares traded (millions) 986 +Per my consistent correspondence with the SEC: Knight/KCG:NITE derived 80-90%+ of their equity Market +making share volumes from OTCM. This is why VIRT acquired KCG/Knight. This is and always has been the core +business at NITE. This is what Cifu conceals from the investing public. In May 2021. + + +As I have also detailed over the last several years: FINRA share stats data is complete fraud. This ALSO continues +in May 2021 +Market Statistics - Equity Trading Data Monthly_(finra.org). +At the top of the page: "Last month statistics: April-2021 Share volume 44+BILLION shares" +Yet below that under April share volumes:TOTAL SHARES: 928+BILLION +The Knight/KCG/VIRT: NITE balance sheet in 10, 2021 filed with the SEC in May 2021 +The balance sheet is AGAIN exploding +Inline XBRL Viewer (sec.gov). +NOT HFT related where holding time is seconds +Tangible book after properly classifying naked short fails: booked as an asset: receivable due to self clearing: +insolvent. By a VERY wide margin. +ALL as a direct result of ONGOING SEC criminal obstruction and corruption. +So, Ms Pasquinelli: who was the executing BD/MM converting all of these fraud notes into worthless certs and +dumped on the investing public where they are converted to real money? WHY would ANY BD/MM execute +these trades? HOW do OTCM money laundering shells trade to trip zeroes? More buyers than sellers? NOPE: +ilegal naked shorting to facilitate money laundering. That is why none of these actions have been posted to the +OWB website. Even though they CLEARLY are eligible actions: My information. +Sent: Thursday, May 27, 2021 5:49 AM + + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +More Honig/Stetson et al SEC facilitated ONGOING fraud on the public +David Urban: Trump PA Campaign Manager and NITE Not So Independent Board Member and his own money +laundering shell: FSD Pharma: HUGE with Pakistani's +Had a BINDING LOI to acquire Israeli Therapix. +FSD Pharma Responds to Therapix Termination of Binding LOL | Business Wire +Not so binding. I caught them. Plan B +Therapix: An Israeli money laundering shell where Stetson was "investor" +EDGAR Filing Documents for 0001493152-17-003810 (sec.gov) +and never shut down by the SEC as is typical of many Honig money laundering shells +Today, Therapix is now Sci Sparc Ltd +SEC approved offerings done By Aegis +SEC FORM D +Yes: that Aegis: also very much up and running in May 2021. New York: SDNY jurisdiction +We don't need no stinkin' SAR's. Aegis prolific OTCM/NASDAQ shell money launderer +Aegis Capital Corporation (sec.gov) +UNITED STATES OF AMERICA Before the SECURITIES AND EXCHANGE +COMMISSION ADMINISTRATIVE PROCEEDING File No. 3-18412 ORDER +INSTITUTING ADMINISTRATIVE PURSUANT TO SECTIONS 15(b) AND 21C + + +OF THE SECURITIES EXCHANGE ACT OF 1934 AND SECTION 203(e) OF +THE INVESTMENT ADVISERS ACT OF 1940, - SEC.gov | HOME +3 As a result of the foregoing, Aegis willfully 2 violated Exchange Act Section 17(a) and Rule 17a-8 +thereunder. RESPONDENT Aegis is a dually-registered investment adviser and broker-dealer with multiple +branches +Well known to the SEC/FINRA: WHO were the customers? +Who were the executing BD/MM's? MORE SEC "penny stock trading fairies" of course. NOPE: NITE. +WHY are all entities once again UN Named? +Robert_Eide.pdf (finra.org). +FINANCIAL INDUSTRY REGULATORY AUTHORITY OFFICE OF HEARING +OFFICERS - FINRA.org +FINANCIAL INDUSTRY REGULATORY AUTHORITY OFFICE OF HEARING OFFICERS DISCIPLINARY +PROCEEDING NO. 2011026386002 HEARING OFFICER: MJD ORDER ACCEPTING OFFER OF SETTLEMENT +August 3, 2015 INTRODUCTION Disciplinary Proceeding No. 2011026386002 was filed on October 21, +2014, by the +www.finra.org +Orders Accepting Offers of Settlement - Aegis Capital Corp., Charles Smulevitz, Kevin McKenna (finra.org) +Complainant, Hearing Officer Rochelle S. Hall Department ofEnforcement, +Disciplinary Proceeding ORDER ACCEPTING OFFER OF OFFICE OF +HEARING OFFICERS INDUSTRY REGULATORY AUTHORITY FINANCIAL +Aegis Capital Corp. SETTLEMENT Date: August 3, 2015 Respondents. +INTRODUCTION - FINRA.org +another F11"4RA member and registered with FINRA, through the firm, in several capacities, including as a +GSR and GSP. Under Article V ofthe FINRA By-Laws,FINRA possesses +www.finra.org +Kevin Mckenna and Robert Eide (sec.gov) +Kevin Mckenna and Robert Eide - SEC.gov | HOME +3 As a result of the foregoing, McKenna willfully 2 aided and abetted and caused Aegis' violations of +Exchange Act Section 17(a) and Rule 17a-8 thereunder and Eide was a cause of Aegis' violations. + + +Stetson: Honig side kick. Therapix now SciSparc. Still Israel +Beginning on pg 10 of the SciSparc SEC approved and reviewed registration +https://www.sec.gov/Archives/edgar/data/1611746/000121390021022427/ea139707- +f1_scisparcltd.htm#a_009 +20 Raul Wallenberg Street, Tower A, Tel Aviv 6971916, Israel. Tel: (+972) (3) 610-3100 : Puglisi & Associates. +850 Library Ave., Suite 204. Newark, DE 19711 +Sellers include: +Aegis CEO Robert Eide Pension Plan: NOW that is f'n funny +Hoboken restraunteur Rohit Bawa +NYC Restaurateur Revamping Former Liberty Bar Site | Jersey Digs +NYC Restaurateur Revamping Former Liberty +Bar Site | Jersey Digs +The building itself was designed by Minervini Vandermark and +will be four stories of concrete construction. The residential +component will consist of three separate 3-bedroom, 2-bathroom +units, each occupying one floor. +jerseydigs.com +Connecticuit distributor Michael Bozzuto +Contact | Bozzutos.com +Contact Bozzutos.com +Connect With One of Our Teams. We value your feedback. Let us know what's on your mind and how we +can serve you better. Please select a department on the left to send a message directly to the team you +would like to reach. +www.bozzutos.com +and, prolific Bag Man Michael Bigger +Bigger Capital +AND many more +More on New York based Bigger Capital coming +Of course, Aegis has a BOOMING wealth Management business + + +How many related party transactions in this SEC reviewed Therapix F1? +https://www.sec.gov/Archives/edgar/data/1611746/000121390016017994/ff12016_therapixbio.htm#a_017 +Next up: SciSparc +Aegis "Investment banking" has ties to Israeli military +Isaac Livni-EIDE: related? +Investment Banking Team - Aegis Capital Corp. (aegiscapcorp.com). +Aegis just did an SEC approved offering for Meten Edtech Education Group +China +Brought to the US public/NASDAQ, by the same Bag Man who brought Hwang/Archegos money laundering shell +GSX to the US/NASDAQ +Puglisi and Associates:Delaware +https://www.sec.gov/Archives/edgar/data/1796514/000121390020018525/ea124386-f1_metenedtech.htm +Form F-1 (sec.gov) +Some reports I've read suggest the SEC won't investigate Archegos/Hwang because it lacks "jurisdiction". +Perhaps Ms Hodgman/Strzok can clarify for us. +Recall: Honig, Stetson/Frost/Alpha Cap (my TCR). As | REPEATEDLY told the SEC: multi BILLIONAIRE Frost didn't +risk it all to make a few million. He/they were laundering +8 (EIGHT) YEARS after submitting my NITE/UBS TCR with the SEC, Alpha Capital Anstalt is very much up and +running in 2021 +For His part: Frost bought Ladenberg from Icahn/Lorber/ et al: Vector/New Valley AFTER Ladenberg had bought +Icahn's former firm Gruntal. Gruntal: SAC,Sater,Feinberg, Icahn: MILKEN +Archegos and Greensill: Credit Suisse. +Credit Suisse is controlled by Milken flunkies. Including the Risk Officer who quietly stepped down. +Greensill: Jim Justice: Magna/Sason/Saviola/Sichenzia: SDNY/NY Supreme Court +I suspect there will be no SEC investigation of Credit Suisse. Ms Hodgman Strzok is an expert at criminal +obstruction. +Pretty good, eh? +It's a gift really +Whistleblower Extraordinaire + + +Sent: Monday, May 24, 2021 5:47 AM +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +Judge Engelmayer: +Simply put: RIOT exists in SEC filings only. Multiple Honig money laundering shells: Aspenbio/Venaxis/Bioptix +involving Russian Government entity: Rusnano +RIOT world HQ in Castle Rock is 15 minutes from my home. Apparently Mr Gottschall can't seem to find Castle +Rock on a map. There is no RIOT at SEC filling address. +An ISP: Clear Connect and a Pakistani BPO entity: NASDAQ traded IBEX. +Who did Mr Gottschall deliver his "no further investigation" letter to exactly? It sure as hell wasn't RIOT. +BTW: as a result of said Gottschall letter/determination as result of his incredibly THOROUGH investigation, the +SEC chose not to review a RIOT offering in December 2020 +Riot Blockchain, Inc. S-3 Letter.pdf (sec.gov) +UNITED STATES SECURITIES AND EXCHANGE COMMISSION +WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE - +SEC.gov +United States securities and exchange commission logo December 11, 2020 Jeffrey McGonegal Chief +Executive Officer Riot Blockchain, Inc. 202 6th Street, Suite 401 +and resulted in Susquehanna/CVI pump and dump +EDGAR Filing Documents for 0001104659-21-023563 (sec.gov) + + +EDGAR Filing Documents for 0001104659-21-023563 +Riot Blockchain, Inc. (Subject) CIK: 0001167419 (see all company filings) IRS No.: 841553387 | State of +Incorp.:NV | Fiscal Year End: 1231 Type: SC 13G | Act: 34.. +Judge Engelmayer, other SDNY/NY Supreme Court Judges: I implore you to send me a subpoena +Sent: Tuesday, May 18, 2021 6:07 AM + + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +Well well well. Mr Gottschall ended his "thorough investigation" into RIOT/Honig et al on 1/29/2020 +Riot Blockchain SEC Ends Investigation Letter 1.29.20 | U.S. Securities And Exchange Commission | Common +Law (scribd.com) +Riot Blockchain SEC Ends Investigation Letter +1.29.20 | U.S. Securities And Exchange +Commission | Common Law | Free 30-day +Trial | Scribd +Riot Blockchain SEC Ends Investigation Letter 1.29.20 - Free +download as PDF File (.pdf), Text File (.txt) or read online for free. +Included a letter from the Denver office of the SEC telling Riot +Blockchain that the investigation by the securities regulator is +over and at this time no enforcement action is recommended. +www.scribd.com +without EVER visiting the RIOT world HQ in Castle Rock. SHOCKING! +Curious Mr Gottschall: who recieved/signed for your "termination of investigation" into RIOT: The ISP +ClearConnect or the Pakistani BPO entity IBEX? +Judge Ramos, other SDNY judges, NY Supreme Court, and NJ Judge Quraishi: you have been played for fools +once again by the grossly corrupt SEC. ALL of your courts have jurisdiction over the SEC NY. +Let's give NJ Judge Quraishi a primer on prolific Bag Man Barry Honig shall we? +As detailed by me in my extensive correspondence: the record. +ANOTHER Honig money laundering shell: Inergetics fka Millenium Biotech +Based in Newark NJ +Is everyone familiar with Healthcare fraud felon Brian Colleran? +Three Companies and Their Executives Pay $19.5 Million to Resolve False Claims Act Allegations Pertaining to +Rehabilitation Therapy and Hospice Services | OPA | Department of Justice +Three Companies and Their Executives Pay $19.5 +Million to Resolve False Claims Act Allegations +Pertaining to Rehabilitation Therapy and Hospice +Services | OPA | Department of Justice +Ohio based Foundations Health Solutions Inc. (FHS), Olympia Therapy Inc. +(Olympia), and Tridia Hospice Care Inc. (Tridia), and their executives, Brian + + +Colleran (Colleran) and Daniel Parker (Parker), have agreed to pay +approximately $19.5 million to resolve allegations pertaining to the submission +www.justice.gov +Somehow, the DoJ didn't believe this was a criminal case. The "prosecutor" on the case was Chad Readler. Now: +JUDGE Chad Readler. Made so by Trump. +Colleran entered into a fraud $20 million purchase order with Millenium Biotech in 2007 +Millennium Biotechnologies, Inc. Signs Five Year $20,000,000 Purchase Agreement with Provider Services Inc. I. +BioSpace +Millennium Biotechnologies, Inc. Signs Five Year $20,000,000 Purchase +Agreement with Provider Services Inc. - BioSpace +Millennium Biotechnologies, Inc. Signs Five Year $20,000,000 Purchase Agreement with Provider Services +Inc. - read this article along with other careers information, tips and advice on BioSpace +www.biospace.com +Colleran then became a large shareholder in Millenium +EDGAR Filing Documents for 0001144204-08-023159 (sec.gov) +Guess who controlled the money laundering shell Millenium/Inergetics? +Prolific Bag Man Barry Honig +EDGAR Filing Documents for 0001144204-10-011488 (sec.gov) +But, it gets better still: Somehow, some way Prolific Bag Man Josh Sason/Hanover/Magna: MULTIPLE TCR's filed +by me and a massive SEC fraud on the SDNY and NY Supreme Courts: NewLead/FreeSeas et al: showed up as a +very large holder of Millenium successor Inergetics +EDGAR Filing Documents for 0001144204-15-034843 (sec.gov) +https://www.sec.gov/Archives/edgar/data/72170/000114420414046310/v385056_s1.htm#s1_007 +The SEC revoked the Inergetics/Millenium registration only AFTER this massive fraud on the public was +committed +I can't seem to find any reference to this money laundering shell in the DoJ/Readler CIVIL not criminal +complaint. You won't find any SEC complaint implicating Colleran/ Honig /Sason either +Millenium/Inergetics: New Jersey: SEC NY +OTHER Sason entities list offices at 40 Wall Street: Trump +So, Judge Ramos: HOW did prolific Bag Man Honig become involved in the Honig money laundering shell MGT +Capital which ALSO did a "pivot" to crypto mining? +EDGAR Search Results (sec.gov). + + +Venaxis/Aspenbio/Bioptix: now RIOT. Which only exists in SEC filings. Thanks in large part to the well +orchestrated SEC NY/ SEC Denver criminal obstruction/corruption. +EDGAR Filing Documents for 0001493152-16-013083 (sec.gov) +That was 1 thorough "investigation Mr Gottschall. I see great things at the SEC for you +AND guess who ELSE was involved in MGT in 2019 just before the SEC revoked the registration: +Chicago Bag Man Fife/Iliad +6 years after I filed my TCR with the grossly corrupt SEC +EDGAR Filing Documents for 0001567619-19-008772 (sec.gov) +AND the Scumbags at Sichenzia Ross:MULTIPLE frauds on SDNY/NY Supreme Courts with Sason et al +https://www.sec.gov/Archives/edgar/data/1001601/000114420415063432/v423506_s-1.htm +The interconnectedness of my claims on display yet again. OR: The record +to be continued... +From: Chris Dilorio I +Sent: Monday, May 17, 2021 5:28 AM + + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +Oh, +But it gets MUCH better Mr Gottschall et al: +Ibex Digital: 202 6th St suite 401 +Bermuda based/Pakistani controlled Ibex Ltd +NASDAQ: IBEX +EDGAR Search Results (sec.gov). +60+% controlled by Pakastani entities: The Resource Group: TRGI +and TRG Pakastan Ltd: TRGP +BPO takes on a WHOLE different meaning. +Which explains the co location with Local ISP ClearConnect. +Riot Blockchain is just a front. +RIOT crypto mining contract with Massena NY Coinmint +New York Crypto Mining Farm Coinmint Set to Dissolve? - MinerUpdate +New York Crypto Mining Farm Coinmint Set to +Dissolve? - MinerUpdate +An ongoing dispute between the two partners who hold equal +shares in multi-cryptocurrency mining company Coinmint has +resulted in one of the partners filing to dissolve the company. +www.minerupdate.com +is on verge of dissolution +RIOT/Aspenbio/Bioptix/Venaxis is and always has been a Prolific Bag Man Honig money laundering shell. +Because: say it with me: the only difference between a NASDAQ money laundering shell and an OTCM money +laundering shell is the amount being laundered. +I've read that somewhere before. Hey, I'm the 1 who said it. +Give me a call Mr Gottschall. After I help you find Castle Rock on a map, lIl walk you through it. I'I type/talk +slowly for you. Because, if you can't find Castle Rock on a map you don't have a chance in hell of finding + + +Pakistan on a map. And, after you're able to find Castle Rock on a map, I'll take you to Vista Gold :VGZ "world +HQ" at 7961 Shaffer Parkway Suite 5 Littleton CO +The money laundering shell cited in my TCR and kept up and running by the grossly corrupt SEC for the last 8+ +years and with SEC approved offering after offering. +Sent: Friday, May 14, 2021 6:34 AM +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +In addition to NeoPhotonix and Bioptix +BiOptix Diagnostics, Inc. - Portfolio company - RUSNANO Group + + +BiOptix Diagnostics, Inc. - Portfolio company - +RUSNANO Group +RUSNANO was founded in March 2011 as an open joint stock +company through reorganization of state corporation Russian +Corporation of Nanotechnologies. RUSNANO's mission is to +develop the Russian nanotechnology industry through coinvestment in nanotechnology projects with substantial economic +en.rusnano.com +Rusanano/Akhanov invested in Quantenna +Now On Semiconductor which supplies chips to Apple +EDGAR Filing Documents for 0001628280-17-001249 (sec.gov) +as well as chip company Aquantia +EDGAR Filing Documents for 0001387131-18-000659 (sec.gov) +Aquantia was acquired by giant chip company Marvell +Company - Newsroom - Marvell Completes Acquisition of Aquantia - Marvell +Company - Newsroom - Marvell Completes +Acquisition of Aquantia - Marvell +Marvell Completes Acquisition of Aquantia Accelerating Multi- +Gig Ethernet Technology Leadership. Santa Clara, California +(September 19, 2019) - Marvell (NASDAQ: MRVL) today +announced that it has completed its acquisition of Aquantia, +Corp. (NYSE: AQ).. Aquantia pioneered Multi-Gig technology - +www.marvell.com +The SEC massive frauds on the SNY and NY Supreme Courts continues +Sichenzia Ross: Sason/Crede/ Jim Justice et al NewLead and FreaSeas +As well as WNW and others. +Now RiotBlockchain. +So, Sichenzia facilitated a fraud "acquisition" of certain Futures Commission Broker now Introducing Broker +trading platform from Mark B Fisher of "Miami" +https://www.sec.gov/Archives/edgar/data/1167419/000107997318000207/riot_8k-03272018.htm + + +SEC.gov | HOME +Check the appropriate box below if the Form 8-K filing is intended to simultaneously satisfy the filing +obligation of the registrant under any of the following provisions (see General Instruction A.2. below): +Mark B Fisher has owned MBF Clearing +MBF Clearing Corp (mbfcc.com) +MBF Clearing Corp. +Welcome to MBF Clearing Corp website About MBF Clearing Corp Founded in 1987, MBF Clearing Corp. is +widely-recognized for our preeminent role within the global futures markets. +www.mbfcc.com +As well as MBF Capital +mbf online | management (mbfcapital.com). +mbf online | management +Mark Fisher is the President of MBF Capital Corporation, Inc. He is a founder of Vela Pharmaceuticals, +Inc., ExSAR Corporation, and Kimeragen, Inc., which merged into Valigen, Inc. Prior to the formation of +MBF, Mr. Fisher was a Principal of Alex Brown where he was employed from 1990-1996. +www.mbfcapital.com +for quite some time. BOTH New York based. +Not even sure if there is a Miami Office for eithe Fisher entities. So WHY "Miami"? +Part of that question can be answered by ANYONE receiving my extensive and irrefutable evidence of SEC +criminal obstruction and corruption: +Miami SEC Director Eric Bustilloe. A grossly corrupt Piece of Shit on par with Gottschall and Best. Did Fisher +have outside investors in his firmS based in Miami? +MBF /Fisher CLEARLY fall under SDNY/NY Supreme Courts jurisdiction. As does Sichenzia Ross +As I have said repeatedly: the national security implications of these massive, multiple SEC facilitated frauds are +staggering. + + +From: Chris Dilorio ‹| +Sent: Thursday, May 13, 2021 9:49 AM +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +"Mr Dilorio, do you have any MORE irrefutable evidence of SEC gross criminal obstruction and corruption while +screwing you the whistleblower who caught them?" +Yes SDNY/NY Supreme Courts, SEC IG Hoecker, L +FBI, IRS CI etc etc etc: It just so happens I took a +field trip to try and find the longstanding address of the Castle Rock CO money laundering shell +Riot Blockchain fka Aspen Bio, Venaxis, Bioptix +EDGAR Search Results (sec.gov). +Enlightening! Kept up and running by the grossly corrupt SEC and pumped by Najarian(NetElement) on CNBC, +Riot Blockchain is a Honig/Grousman/Stetson/GRQ et al money laundering shell which somehow escaped +(along with many others) the SEC scrutiny in its Honig/Stetson/Frost/Jaclin/Alpha Cap et al complaint +https://www.sec.gov/Archives/edgar/data/1167419/000107997317000238/bioptix_s3.htm +But WAIT. There's MORE! +The Honig/Stetson Bioptix money laundering shell is ALSO a Colorado entity: Boulder + + +Bioptix was just a vehicle to get Honig/Stetson et al into RIOT. Gee, I wonder what they saw in Bioptix that +caused them to "invest" when it was around less than 2 years before "pivoting" to blockchain/crypto???? +let's ask the scumbags at Sichenzia Ross who advised on the Bioptix money laundering offering which gave +Honig et al ownership in RIOT +https://www.sec.gov/Archives/edgar/data/1167419/000107997317000154/ex10x5.htm +SEC +WHEREAS, subject to the terms and conditions set forth in this Agreement and pursuant to Section 4(a)(2) +of the Securities Act of 1933, as amended (the "Securities Act"), and Rule 506 promulgated thereunder, the +Company desires to issue and sell to each Purchaser, and each Purchaser, severally and not jointly, desires +to purchase from the Company, securities of the Company as more fully .... +Then, we can ask the Bioptix offering Escrow agent: New York licensed Signature Bank:SBNY. You know the 1: +the once and always Private Banking arm of Hapoalim where Strauss/Berman criminally obstructed a thorough +investigation of Hapoalim tax evasion and money laundering. The same SBNY which boasted Ivanka Trump as a +Board memberand was a "go to lender" for Trump/Kushner and where ALL SEC filings have disappeared. AND +where Chairman Scott Shay is on BoD of CardWorks (Berman) which was go to processor for Net Element: +Merrick Bank UT. Etc etc etc. YES, that SBNY +https://www.sec.gov/Archives/edgar/data/1167419/000107997317000154/ex10x3.htm +SEC.gov| HOME +WHEREAS, pursuant to the terms of the Purchase Agreement the Company desires to sell (the "Offering") a +minimum of $2,000,000 (the "Minimum Amount") and a maximum of $2,250,000 (the "Maximum Amount") +of units of its securities (the "Units")."). Each Unit is being sold at a price of $2.50 per Unit. Each Unit +consists of one (1) share of the Company's common stock, no par value per share (the .... +How much SEC et al criminal obstruction and corruption are we up to so far Mr Gottschall et al? +Wait, there's more! +In 2015, just prior to Honig/Stetson/SBNY/Sichenzia et al fraud offering, Boulder Based Bioptix FKA Alphasniffer +did an SEC approved D offering +SEC FORM D/A +SEC FORM D/A +In submitting this notice, each issuer named above is: Notifying the SEC and/or each State in which this +notice is filed of the offering of securities described and undertaking to furnish them, upon written request, +in the accordance with applicable law, the information furnished to offerees.* + + +Guess who shows up as A Bioptix/Alphasniffer insider? +Dimitry Akhanov +WTAF is Rusnano USA????? AND head of the Russian Federal Energy Agency???? +WHY is he involved in Bioptix now RIOT??? +Dmitry Akhanov, CEO of Rusnano USA, Inc., RUSNANO (topionetworks.com). +Dmitry Akhanov, CEO of Rusnano USA, Inc., RUSNANO +Curated profile of Dmitry Akhanov, CEO of Rusnano USA, Inc., RUSNANO +www.topionetworks.com +Akhanov is also involved in NYSE listed Neophotonics +NeoPhotonics Names Dmitry Akhanov to Board of Directors President and CEO of Rusnano USA Joins +NeoPhotonics Board | NeoPhotonics Corporation +Neophotonics supplies optical chips to some of the biggest optical switching companies in the world like US +based Cisco and Ciena +Recall: Honeg/Stetson/Frost/Alpha Cap +Alpha Cap: my 2013 TCR +Honig/Stetson: Jaclin: Farkas: BLNK. Also CFO New: NETE: Crede/SBNY/CardWorks/ESQ, etc +Honig also Trump fundraiser: Cleveland: Colleran. DoJ "prosecutor" on Colleran massive healthcare fraud: Chad +Readler. Trump made Readler a Federal judge. +SEC left dozens of Jaclin money laundering shells up and running. Including Blink/New Image Concepts, +Intercloud with Sason etc. As well as OZ/Maso/Sculptor NJ deli Hometown International: HWIN. NONE of this is +by accident. SEC gross criminal obstruction and corruption. +Now Honig/Stetson: Bioptix now crypto RIOT. +Right here. 15 minutes from my home. Like CGFIA and VGZ. As well as prolific shell CPA firm BF Borgers. +Give me a call Mr Gottschall. I'll point out Castle Rock to you on a map you grossly corrupt piece of shit! +From: Chris Dilorio / +Sent: Sunday, May 9, 2021 5:06 PM +P; + + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +Per below: +Judge Cote's sentencing of Dan Kamensky is a gross miscarriage of justice. The SDNY, NY Supreme Court, [ +• Mr Kamensky's counsel, FBI, other DoJ attorneys are in possession of information which clearly +indicates a long standing and grossly corrupt relationship between the SEC and Handler/Jefferies. Further, as is +material in the "ongoing" Joshua Sason investigations of massive fraud committed on the SDNY/NY Supreme +Courts and directly related to my multiple claims: AQR and Sason: MI Acquisition with known felon Tom Priore: +ICP: also SDNY and now a direct lending client of Ares Management: Ressler: Drexel with Handler: also Neiman +Marcus. In short: Handler/Ressler set up Mr Kamensky for fucking with their deal. Had Kamensky won his bid, +Ares/Ressler would have been left with a much less valuable asset. AND put them further under water. +AresNeiman.pdf (pecloserlook.org) +Sticker Shock: Can Ares Management Sell Neiman Marcus? + + +2 Ares' Neiman Marcus Gamble In September 2013, Ares Management purchased luxury retailer Neiman +Marcus in a joint venture of Ares Corporate Opportunities Funds III and IV and the Canadian Pension Plan +Investment +www.pecloserlook.org +The SDNY Courts had this information. Kamensky's counsel had this information. Judge Cote should have +declared a mistrial rather than sentence Kamensky. A gross miscarriage of justice. +Now, let's turn to another example where the grossly corrupt SEC is ACTIVELY facilitating multiple frauds on the +investing public while screwing the whistleblower who caught them: ME. +Recall ANOTHER completely fraudulent denial of award : UBS AML. Where Norberg/OWB invoked the ILLEGALLY +enacted Summary Disposition Rule aka Christopher J Dilorio rule. Where the SEC own SEC website clearly +states: ALL tips received are THOROUGHLY reviewed by Enforcement Staff. Meaning: The Summary Disposition +Rule: SEC Staff never saw the information: is a KNOWN fraud. +Follow up for Mr Searles/Banerjee et al: SEC LA where multiple frauds left up and running. Ares also LA and NY. +Milken: Beverly Hills +Recall: UBS San Diego: K2. Where FINRA,FINCEN, and the SEC all confirmed UBS cross border business was +never shut down per the terms of the DoJ dropping it's DPA in 2010. Further, clearly obstructed by SEC IG +Hoecker when I filed a complaint with his office in 2015 after receiving another denial for Award related to the +UBS Reg Sho complaint. ALSO according to the SEC OWB FAQ: Enforcement staff notifies investigating staff of +related tips received AND Whistleblowers are ALSO entitled to awards based on new lines of inquiry. The +Mckessy/Norberg/Hoecker criminal obstruction led to the UBS cross border business never being shut down. +The UBS AML complaint acknowledges this irrefutable fact. +UBS K2: NO individuals were censured/fined by SEC/FINRA. ALL correspondence to UBS Weehawken. SEC +LA:Searles/Banerjee et al had ZERO jurisdiction. +Searles: Anton Chia and related fraud and money laundering. As I have also irrefutably proven: MULTIPLE frauds +Up and running today. +It is no coincidence the SEC LA/ UBS San Diego multiple money laundering frauds. Searles et al are PROTECTING +UBS San Diego. That's why none of these frauds have been shut down. The UBS cross border business is very +much up and running TODAY +MORE.... +Who is San Diego resident Jason Sunstein? CFO of several Once/still SEC reporting money laundering shells +trading OTCM Pinks and no doubt well known to Searles, Banerjee et al in SEC LA. +Viper Networks fka +Tinglefoot Mining +Baja Pacific International +Taig Ventures +EDGAR Search Results (sec.gov). +Microsoft Word - VPER - OTC PInkGuidelines Annual 12.31.20(Feb21 vers)v.3_nowcfo changes - Apollo Smart +Lights-3.docx (otcmarkets.com) +VPER - OTC PInkGuidelines Annual 12.31.20(Feb21 vers)v.3 nowcto changes +- Apollo Smart Lights-3 +27& Odunhwv *urxs ,qf 27& 3lqn %dvlf 'Ivforvxuh *xIgholqhv y )heuxdu\ 3djh ri i wklv Ivvxhu ru da\ ri lwv +suhghfhwvruv kdyh ehhq wkh vxemhfw ri vxfk surfhhglqjv sohdh surylgh dggiwIrqdo ghwdlov lq wkh + + +backend.otcmarkets.com +Santeon Group +fka Air-Q +Air Rover +Covenant Financial +Homegate Corp +Spartan Oil +ubroadcast +Santeon and Viper: African/Egyptian entities/Individuals +Santeon CEO : Ashraf Rofail +International Land Alliance +A San Diego virtual office well known to the SEC in its correspondence +Virtual Office in DiamondView Tower | Regus RU +Virtual Office in DiamondView Tower | Regus RU +Renting a Virtual Office in DiamondView Tower is affordable and easy. Choose a virtual office option and +pay one simple price. Get a quote today. +www.regus.ru +filenamel.pdf (sec.gov) +filename1.pdf (sec.gov) +International Land Alliance +A little California pot +a little "Mexico vacation properties" +Mexico Vacation Property Investment | Baja Mexico Real Estate Investment | International Land Alliance +(ila.company) +Mexico Vacation Property Investment | Baja +Mexico Real Estate Investment - Baja Mexico +Real Estate Investment | International Land +Alliance + + +International Land Alliance is a Mexico vacation property +investment firm based in San Diego, California. The company was +formed for the purpose of developing and selling residential +communities for home buyers, vacation/second home, +retirement, and investors. +ila.company +As of 2017, ILA is a Wyoming LLc +SEC FORM D +SEC FORM D +In submitting this notice, each issuer named above is: Notifying the SEC and/or each State in which this +notice is filed of the offering of securities described and undertaking to furnish them, upon written request, +in the accordance with applicable law, the information furnished to offerees.* +Of course: as has been well documented by ME: ILA currency of choice for these "beautiful Mexico land +ventures" is common stock. +In April 2021 +International Land Alliance Inc. (Form: 8-K, Received: 04/05/2021 14:00:05)_(otcmarkets.com) +OMID Holdings +fka New York Based Avl Group +content (otcmarkets.com) +Disclosure Statement Pursuant to the Pink Basic Disclosure Guidelines - +OTC Markets Group +OTC Markets Group Inc. OTC Pink Basic Disclosure Guidelines (v2.1 December 2019) Page 1 of 23 . +Disclosure Statement Pursuant to the Pink Basic Disclosure Guidelines +backend.otcmarkets.com +Back in 2010, AV1 Group New York was controlled by a Moussa Traore +SEC FORM D +Who happens to have the same name as former Mali Dictator. +Of Course, Jason Sunstein ONLY experience on Linked In is his ILA tenure. ALL of these other ventures have been +ommitted. Gee, I wonder why. +Jason Sunstein - Co-Founder and Vice President - International Land Alliance, Inc. (OTCQB: ILAL)_| Linkedin + + +Jason Sunstein - Co-Founder and Vice President - +International Land Alliance, Inc. (OTCQB: ILAL) | +Linkedin +Jason Sunstein Co-Founder and Vice President at International Land Alliance, +Inc. San Diego, California 500+ connections +www.linkedin.com +Mr Searles, Banerjee, SEC LA have been criminally obstructing a REAL investigation into Sunstein et al. Right +there in San Diego/UBS K2 back yard. So: No individual UBS San Diego K2 complaints, multiple money +laundering shells up and running. +For MANY reasons IG Hoecker: ALL SEC OWB Denials of my award applications are complete fraud. ALL of the +activity continues TODAY as a direct result of your criminal obstruction and corruption. +AND: NITE and CDEL trading all of them. +In furtherance of the conspiracy...... +Sent: Friday, May 7, 2021 4:01 PM +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +Judge Cote, +Your 6 month prison sentence for Dan Kamensky is a gross miscarriage of justice. Your Courts, Ms Strauss, and +Mr Kamensky's counsel are in posession of information that clearly indicates a long standing and corrupt +relationship between the SEC and Handler/Jefferies. Kamensky was set up. I will be contacting Mr Kamensky +directly as his counsel has committed gross negligence in his representation. +Sent: Friday, May 7, 2021 6:28 AM + + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +SDNY/NY Supreme Court Judges et al: +The interconnectedness of my claims on display AGAIN +Per my 2013 TCR criminally obstructed by McKessy/Norberg et al: WHY do $50 billion Swiss banks trade OTCM +Pink penny and fractional penny stocks? The record is irrefutable: FINRA/SEC/FINCEN using my information: +these publicly traded shells are the perfect money laundering vehicle. Absolutely IRREFUTABLE. WHY do firms +like NITE and CDEL trade the same OTCM Pink shells? Abusive, illegal naked shorting to facilitate this illegal +activity. Virtually riskless. VERY profitable. NONE of this happens without a willing executing criminal BD like +NITE converting worthless certs to real money and dumped on the investing public the SEC is MANDATED to +protect. ACTIVELY facilitated and perpetuated by the grossly corrupt SEC: reverse splits, no CAT, Obligation +Warehouse: circumvent close outs of Rule 204, rarely revoked registrations, outsourcing the entire OTCM to the +BD SRO FINRA, etc etc etc. I made the link between the money laundering and the illegal, abusive naked +shorting. This is and always has been the core business at Knight/KCG/VIRT:NITE. ALL money laundering can be +reverse engineered from the executing BD/MM level. The cash register. +What we are seeing in GME is a rounding error compared to the fails and illegal naked shorting in the OTCM. + + +As I have also repeatedly said: the only difference between a money laundering OTCM Pink shell and a NASDAQ +SPAC is the amount of money being laundered. Also on display real time as I have detailed. As with Swiss banks +and penny/fractional penny stocks: WHY do giant Quant Hedge Funds like AQR facilitate so many fraud blank +check shell transactions? CERTAINLY does not fit the investment thesis of a firm run by Phd's. +WHY does giant PE/Real Estate firm Apollo play Fisker SPAC? WHY did Goldman,JPM, Jefferies et al bail out NITE +more than once? WHY has the SEC repeatedly bailed out criminal NITE? +The most recent Earnings call for NITE was remarkable: SELL SIDE is actually doing what it's supposed to do and +questioning NITE/Cifu lack of transparency particularly in the last few years. This has been going on for some +time detailed by me and blessed by the SEC. This lack of transparency is designed to conceal from the public the +true nature of the core NITE business: illegal, abusive naked shorting OTCM publicly traded shells to facilitate +money laundering. Until now, the Sell Side turned a blind eye/ also intentionally misled the public by omitting +these share volumes from their models. These share volumes have been the subject of other SEC/FINRA +actions. But, somehow NITE has avoided such actions. INEXPLICABLE. The SEC/FINRA have done everything in +their power to protect NITE. WHY? Because they bailed out a known criminal entity in 2012 and have been +criminally and corruptly covering up this irrefutable fact ever since. As a result: The illegal activity has continued +un abated. Then in 10,2021, the activity hit a level not even dreamt of. It has been a well orchestrated and +massive SEC facilitated fraud on the public the SEC is mandated to protect. A key player in this massive fraud is +the corrupt SEC IG Carl Hoecker who not only has criminally and corruptly obstructed an investigation of my +extremely serious allegations, Hoecker has also criminally obstructed Congress from executing its oversight of +the SEC. +These corrupt, criminal, ongoing frauds have also found their way into the SDNY and NY Supreme Courts as I +have detailed. Mr Kamensky is most definitely NOT on the SEC/DoJ "Do not investigate list". This can also be +observed in real time. Per my correspondence: MI Acquisition: Magna/Sason: 40 Wall St with AQR/"payment +processing" and felon Tommy Priore: ICP:SDNY. +There is a straight and direct line between ICP/Priore and the Degenerate Milken as well as the corrupt +SEC/SDNY Kamensky "sting" that goes beyond the degenerate Milken flunkie Handler/Jefferies. Where • +Praised the work of the SEC. As I have previously detailed: Ares Management: Neiman Marcus: Tony +Ressler: Milken/ Drexel degenerate flunkie has built quite the monstrosity. A little PE. A little Real estate. But +the 800lb gorilla at Ares: Credit. Ressler's sister is married to Fat Leon Black. Close knit bunch for sure. +Ares: +Massive CLO manager/originator. 1 stop shop. Because as I detailed previously: now a direct lender to fraud +money laundering entities like Priore/Sason/AQR et al: PRTH. +Because securitization drives the lending and is not a biproduct of sound credit analysis: Junk is junk REAL +TIME. +I applaud Chair Waters and her efforts to reign in illegal trading practices detailed in my extensive record. +However: non bank lenders like the massive Ares pose a systemic risk to the US financial system. CLO's are a +massive fraud on the public developed by the Milken degenerates like the sub prime and S&L's. The SEC actually +brought a complaint recently: IIG which described using CLO's as a money laundering vehicle. The Caymans +have recently cracked down also. Greensill: Credit Suisse: Milken: is another example of securitization as money +laundering vehicle in sub prime factoring: Jim Justice. SBNY is also a securitization fraud: SBA. +Chair Waters and her Committees see the Credit Ratings Agency/SEC fraud I have also detailed. +My Coronavirus/repo virus: CLO correspondence: The SEC corruptly didn't downgrade massive CLO debt in +2020. The result: issuance exploded in 2021. Non bank lenders like Ares as well as Apollo,Jefferies, Ted Virtue +etc etc have reaped tens of millions in management fees. Who told the SEC to obstruct the proper role of the + + +Credit Agencies to downgrade massive CLO's in 2020? Mr Clements knows. His garbage CLO "report" late in +2020 set the stage for the "all clear" to the SEC. +Oh Mr Kamensky! I only hope you sue these corrupt scumbags who ruined your life while they are treated with +ZERO implications for their illegal activity by the grossly corrupt SEC/DoJ. +Sent: Tuesday, May 4, 2021 7:15 PM + + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +Mr "Not so Transparent" Dougie Cifu got a little testy on the 1Q2021 earnings call and it abruptly ended. +2 Sell Side Analists: Fannon/Jefferies and Kramm/UBS pressed @dougielarge on his lack of transparency. What +is Dougie Cifu hiding? Something about "what percentage of those 4+ trillion shares of OTCM money laundering +shells did NITE trade?" made Dougie squirm like the snake most already know he is. +Love the parting shot to Kramm/UBS: +"your firm would love to have our business" +Virtu Financial Inc (VIRT) Q1 2021 Earnings Call Transcript | The Motley Fool +Virtu Financial Inc (VIRT) Q1 2021 Earnings +Call Transcript | The Motley Fool +Virtu Financial Inc (NASDAQ:VIRT) Q1 2021 Earnings Call May 4, +2021, 8:30 a.m. ET. Contents: Prepared Remarks; Questions and +Answers; Call Participants; Prepared Remarks: Operator. Good day, +and ... +www.fool.com +I fell off my chair laughing. +Still no questions on the balooning/insolvent balance sheet. But, hey it's a start. +Ms Mehraban, Mr Williams: your former Paul Weiss colleague Dougie Cifu is feeling some heat. I know you will +be gentle with him +Mr Gensler: in case you missed it: Dougie sends his best +Sent: Monday, May 3, 2021 2:03 PM + + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +SDNY/NY Supreme Court Judges. +I once challenge the best and brightest the SEC/DoJ/FBI/IRS CI/FINCEN have to offer. Tear me to shreds. Make +an example. I haven't been wrong about 1 single thing. NOT EVEN 1. +The record is simply irrefutable: +The latest edition of "The SEC is a grossly corrupt, criminal organization actively facilitating +multiple, massive, ongoing frauds on the public it is mandated to protect to the benefit of the criminals who own +them while screwing the whistleblower who caught them:ME" +I refer you to the SEC Office of the Whistleblower FAQ +Of course, I have multiple forms copied should you prefer +SEC.gov | Office of the Whistleblower +SEC.gov | Office of the Whistleblower +3. What information can I submit to the SEC? The SEC conducts investigations into possible violations of +the federal securities laws. In general, the more specific, credible, and timely a whistleblower tip, the more +likely it is that the tip will be forwarded to investigative staff for further follow-up or investigation. + + +AGAIN AGAIN AGAIN IG Hoecker et al: the "summary disposition" aka Christopher J Dilorio rule corruptly +enacted by Norberg/Clayton et al was/is COMPLETE FRAUD +per FAQ #12 from the grossly corrupt SEC/OWB website: +"ALL TIPS, complaints, and referrals received by the SEC are FULLY REVIEWED BY OUR ENFORCEMENT +STAFF........" +FURTHER +"Complaints that relate to an EXISTING INVESTIGATION are FORWARDED TO the STAFF WORKING ON THE +MATTER." +New line of inquiry. +I don't see how it could be ANY MORE CLEAR IG Hoecker et al. +In addition to annual reports to Congress ACKNOWLEDGING the OWB as the primary contact for whistleblowers +to the Commission at large, this is damning. The summary disposition rule aka Christopher J Dilorio Rule: "SEC +staff never saw Mr Dilorio's information" is complete and total FRAUD. Designed to use my information to both +bring and obstruct thorough investigations while screwing me out of rightfull compensation. +IG Hoecker, I'm still looking forward to our first interview given the 3 (THREE) complaints I have filed with your +office. The UBS Reg SHO Denial was complete fraud. The UBS FINRA/FINCEN, SEC AML Denial was complete +fraud. The Opco Denial was complete fraud. ALL must be reversed. The Summary Disposition Rule/aka +Christopher J Dilorio rule must be nullified RETROACTIVE to its passage as it is clearly contrary to the SEC Rules +ITSELF. +1 look forward to speaking with you Carl +Sent Thursday April 22 20215-57 AM +To: +P +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +so sorry for incorrect e mail +Sent: Thursday, April 22, 2021 5:44 AM + + +Subject: FW: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +Judge Buchwald, +I hope your colleagues in the SDNY and NY Supreme Court have forwarded my information. Like your +colleagues, you are the victim of another SEC fraud on the SDNY court. I am an irrefutable expert on SEC +criminal obstruction and corruption. Jay Clayton was NEVER "shocked" by the widespread fraud in the OTCM +and crypto markets. +Widespread Fraud in ICOs and Penny Stocks Shocked SEC's Jay Clayton - Bloomberg +Widespread Fraud in ICOs and Penny Stocks +Shocked SEC's Jay Clayton - Bloomberg +The former Wall Street deals lawyer who leads the U.S. Securities +and Exchange Commission said one of the biggest surprises of +his first year heading the agency has been learning about the +levels ... +www.bloomberg.com +Clayton's firm Sullivan Cromwell/Jared Fishman/Rodgin Cohen et al are EXPERTS on penny stock fraud having +bailed out the criminal enterprise Knight/KCG/VIRT:NITE on more than 1 occassion. OTCM shells and crypto are +complimentary money laundering vehicles. +Clayton and the SEC have obstructed a thorough investigation of my very serious allegations for years. Including +the 2017 merger of Virtu and KCG: NITE. As a direct result multiple, massive SEC facilitated frauds on the public +the SEC is mandated to protect are very much ongoing. In 1Q 2021, more than 4 TRILION shares of OTCM +money laundering shells were traded. Money laundering shells like SEC reporting HWIN and hundreds just like +it. Bitcoin continues to be mined in China, Russia, and Belarus. Bitcoin claims to have a limited supply. But, can +that actually be verified? On his way out the door, Clayton bought the Ripple action. As you have stated: +extremely flawed SEC argument that Ripple IS a security but somehow Bitcoin ISN'T. +In fact: either ALL crypto are securities OR NONE are. The IRS for its part treats cryptos as a capital asset. +Subject to capital gains and losses for tax purposes. As your colleagues can attest, the interconnectedness of my +information is irrefutable. Several entities including Signature Bank/Greenbox are just 1 example of my +"Derivative" information. +Seems to me that Clayton,Hinman, crypto pumper Peirce ALL had KNOWN settled precedent to regulate Bitcoin +and ALL crypto as securities: SEC V SG Ltd. Where appeals Court got it right and where Howey was applied: +Securities & Exchange Commission v. SG Ltd., 265 F.3d 42 | Casetext Search + Citator +Securities & Exchange Commission v. SG Ltd., 265 F.3d 42 | Casetext Search ++ Citator + + +Read Securities & Exchange Commission v. SG Ltd., 265 F.3d 42, see flags on bad law, and search Casetext's +comprehensive legal database +casetext.com +The inconsistency in the SEC approach to regulating ALL crypto as securities has caused great confusion in the +marketplace and has opened the door wide to fraud. +This is just another example of SEC corruption. +Now, the SEC corruption has reached your Courtroom as well +Sent: Tuesday, April 20, 2021 11:39 AM + + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +Several typos omissions corrected below +Judge Ramos: SEC 1 Off's +Sec. & Exch. Comm'n v. Honig, 18 Civ. 8175 (ER) | Casetext Search + Citator +Sec. & Exch. Comm'n v. Honig, 18 Civ. 8175 (ER) | Casetext Search + Citator +Read Sec. & Exch. Comm'n v. Honig, 18 Civ. 8175 (ER), see flags on bad law, and search Casetext's +comprehensive legal database +casetext.com +SEC settled quickly with Honig et al. Also Alpha Capital Anstalt: Liechtenstein: IMDS: Bag Man Schlaff: Bawag: +Refco:Rhino: Sedona: Scan Graphics: Shaye Hirsch: Karfunkel: Kushners: Nordlicht: Englander: et al: Judge Swain +Derivatives. +These SEC 1 off's guarantee the activity continues. It does. +Below: Tri-Mark: Sytner +last 10K filed with the SEC:2010 +form10k5to1holding123110.htm (sec.gov). +Pg 46 Honig owned 2,514,786 shares or 7% +That's STATED control +When did the SEC waive 13D/G filings simply because it was disclosed in an audited/SEC reviewed 10K? +Not 1 off's: guarantee activity continues +Judge Ramos, did you put an end to Honig? +NOPE +Barry C. Honig, et al. (Release No. LR-24262; Sep. Z, 2018) (sec.gov). +Barry C. Honig, et al. (Release No. LR-24262; Sep. 7, 2018) +The Securities and Exchange Commission today charged a group of ten individuals and ten associated +entities for their participation in long-running fraudulent schemes that generated over $27 million from +unlawful stock sales and caused significant harm to retail investors who were left holding virtually worthless +stock. +And, as I proved below: Jaclin/Honig STILL up and running in April 2021 + + +SDNY Judges/NY Supreme Court: The SEC CONTINUES to play you for fools while ACTIVELY facilitating massive, +ongoing frauds on the public it is mandated to protect while screwing the whistleblower who caught them: ME +As I have stated repeatedly in my correspondence: the record +Multi billionaire Frost wasn't trying to MAKE a few million. Frost et al were LAUNDERING. +Frost: bought Ladenburg from Icahn/LeBow/Lorber: Vector /New Valley. AFTER Icahn rolled his former +employer: Gruntal: Sater,Feinberg, SAC et al: MILKEN: into Ladenburg. As MY record also clearly shows: Honig +also Colleran: Trump felon fundraiser. AND: Vector/New Valley also Trump/Russia. +"1 off's"! +Too f'n funny +Sent: Monday, April 19, 2021 4:10 PM + + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +Welcome to Episode number: I lost track: of SEC criminal obstruction/corruption while screwing the public it is +mandated to protect and screwing the whistleblower who caught them: ME. +Give me a call Mr Gensler. Love to catch up. Saw where you did a OTCM esque reverse split in the massive USO +fraud on the public. +SDNY Judges et al, when you read about something as absurd and ridiculous as Hometown International with a +Deli front and New Jersey and entities in Hong Kong and Macau, you're probably thinking what I was thinking +10 years ago when I began researching NITE and the OTCM shells they traded. But, these are NOT 1 offs. This is +VHY the OTCM exists: abusive naked shorting OTCM shells to facilitate money laundering is and always ha +een the core business at NITE et al. This is WHY NITE has been bailed out multiple times by other crimina +entities. There is no such thing as just 1 cock roach. HWIN is no different. It is part of a MUCH MUCH bigger and +well orchestrated scheme. +More on Hometown International: +Hey look, there's a Senegal/Ivory Coast individual named Ibrahima Thiam with a Macau address +OTCQB-Certification.pdf (sec.report) +If the name Thiam is familiar, it should be: Tidjane Thiam the former CEO of Milken controlled Credit Suisse: Jim +Justice: Greensill. +The resemblance is striking. Don't you think? +Ibrahima Thiam - Wetlands International +Ibrahima Thiam - Wetlands International +P.O. Box 471 6700 AL Wageningen The Netherlands. Tel. +31 (0) +318 660 910 E-mail: [email protected] RSIN Number: 806703726 +Reg No: 09099028 +www.wetlands.org +You know the 1 I'm talking about Judge Silver: NITE top traded/multiple SEC/FINRA reverse splits/Jim Justice: 5 +Mile: Perian Salviola/Josh Sason/Sichenzia : NewLead fame? AND sister fraud "Greek Shipper" FreeSeas: also NY +Supreme Court. Also Sason/Sichenzia. But with other Milken flunkie Terren Peizer. Crede. Along with Deutsche +Bank and Credit Suisse. Peizer/Crede also Net Element. Net Element former CFO New: also Blink Charging: with +JMJ/Keener AND Prolific Bag Man Michael Farkas. MORE derivatives + + +More on Farkas later in the e mail. Read on +And, not to get too graphic +But another Hong Kong/Macau HWIN "investor" is Swiss "model" Nathalie Pasyawon +Nathalie Pasyawon - Boobpedia - Encyclopedia of big boobs +Interconnectedness defined. OR as I like to say MORE DERIVATIVES +The 2020 SEC reviewed HWIN 10K filed March 26, 2021 +https://www.sec.gov/Archives/edgar/data/1632081/000121390021018020/f10k2020_hometowninter.htm +UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 . FORM 10-K (Mark +One) IX ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF +1934 For the fiscal year ended: December 31, 2020 or O TRANSITION REPORT PURSUANT TO SECTION 13 +OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934 For the transition period from . +Guess who has been the HWIN auditor since 2015? +Fined/censured by PCAOB Liggett and Webb +James Liggett/Martin Webb +Microsoft Word - 105-2020-010-L.docx (azureedge.net) +Not the ONLY money laundering shells L/W CPA are involved in either +Directory - Service Provider Directory_| OTC Markets +OTC Markets | Official site of OTCQX, OTCQB and Pink Markets +Get Stock &. Bond Quotes, Trade Prices, Charts, Financials and Company News & Information for OTCQX, +OTCQB and Pink Securities. +www.otcmarkets.com +Several SEC reporting +AND a few more with up and running TODAY +NASDAQ listed Orbital Energy Group OEG +Aqua Power Systems APSI. That's Aqa Power systems fka NC Solar: a Jaclin money laundering shell +https://www.sec.gov/Archives/edgar/data/1553264/000114420412044855/v321146_s1.htm + + +Bang Holdings Corp BXNG: VERY appropriate Name. Read on. Also Jaclin. Also Zenith. AND Platinum +Brownies Marine Group BWMG +CZE Energy Inc OOGI FKA Odyssey Oil and Gas: through 2020: a NY HQ company +https://www.sec.gov/Archives/edgar/data/1160798/000121390021020286/f10k2020_c2eenergyinc.htm +The Company intended to expand the making of bio fuels from algae to other large mining Companies in +South Africa. On May 26, 2009, the Company acquired 51% of H-Power (Pty) Ltd. H-Power (Pty) Limited, a +South African registered company, which owns an exclusive license to develop and market batteries based +on patented Hybrid Battery Technology worldwide. However, on August 27, 2009, the ... +Enviro Technologies US Inc EVTN +Hometown International HWIN +See Below +Ocean Thermal Energy Corp CPWR +Point Of Care Nano-Technology Inc PCNT fka Alternative Energy and Environmental Solutions: Also Jaclin +ts10511_altenergy.htm (sec.gov). +Second Street Capital CTON +content (otcmarkets.com). +Vynleads Inc VYND +PuraDyn Filter Technologies PFTI +A New York Liggett/Webb money laundering shell is CZE Energy Inc + + +Began as an "exercise equipment " shell controlled by Curtis Olschansky +Everyone remember the Better Buns machine? +https://www.sec.gov/Archives/edgar/data/1160798/000114420407015535/v069715_10ksb.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. +Here's ANOTHER lesson in derivatives for the slow on the uptake +New York C2E Energy Inc is now controlled by PROLIFIC Bag Man David Lazar/Zenith Partners/International +/Equity Holdings LLd's and Custodian Ventures. +https://www.sec.gov/Archives/edgar/data/1160798/000121390021020286/f10k2020_c2eenergyinc.htm +The Company intended to expand the making of bio fuels from algae to other large mining Companies in +South Africa. On May 26, 2009, the Company acquired 51% of H-Power (Pty) Ltd. H-Power (Pty) Limited, a +South African registered company, which owns an exclusive license to develop and market batteries based +on patented Hybrid Battery Technology worldwide. However, on August 27, 2009, the ... +Lazar/Zenith following money laundering shells: +Mediashift MSHF +Melt Inc MELT +XXStream XMET +FinotecGroup FTGI +Enabling Asia Inc EAIN +Goff Corp GOFF +NYSE listed SyntheticBiologics SYN +Exobox EXBX +just to name a few +Lazar NY address: 3445 Lawrence Ave +Oceanside, NY +Also SEC NY +Lazar partner in Zenith is Los Angeles/Beverly Hills/Santa Monica based Barry Sytner +also home to Mogilevich Bag Man Milken/Dexel/Boyd Jefferies et al +Sytner was himself in control of Tri - Mark Mfg Inc with guess who? Barry Honig + + +and another money laundering shell up and running today: Chinese S$ laundering shell Worry Free Holdings +Teed up and ready to go with Rent A CFO: CFO NOW +Worry Free is FKA SEC reporting iVoiceldeas Inc +Microsoft Word - WYCC 30 SEPT 2018 OTC FILING.FILED VERSION (otcmarkets.com). +Worry Free not the only Lazar China S$ laundering shell +Hong Kong Winalite Group +Not revoked by the grossly corrupt SEC after 10 years of no financial disclosures. Rather: voluntarily suspended +by Lazar to be re used at a later date. Per my record with the SEC et al: money laundering shells go dark AFTER +the fraud is committed. SEC does nothing to PREVENT the fraud from happening in the first place +https://www.sec.gov/Archives/edgar/data/1059885/000121390020001328/f1515d0120_hongkongwinalite.ht +m +Anyone keeping track of the Jaclin/Honig related money laundering shells we're up to so far? +Again: the Lazar/Sytner/Zenith/Custodian Ventures/Liggett/Webb list is not exhaustive +But in excess of 20 money laundering shells up and running today should be a good start. Don't you think Mr +Gensler? +Of course, the money laundering shell that ties all of these ongoing frauds together is Bang Holdings: BXNG +https://www.sec.gov/Archives/edgar/data/1632323/000161577415000921/s101040_s1.htm#INTEREST +SEC.gov | HOME +(1) This Registration Statement covers the resale by our selling shareholders up to (1) 1,857,050 shares of +common stock previously issued to such selling shareholders and (2) 1,500,000 shares of common stock +issuable upon exercise of outstanding warrants ("Warrants") at an exercise price of $0.35 per share, that +were issued in connection with a Securities Purchase Agreement by and between ... +A Colorado incorporated/Miami based/Jaclin money laundering shell where Liggett/Webb are auditor with +Farkas/Platinum/Zenith Equity Holdings/Michael Bernstein et al +EDGAR Search Results (sec. gov) +Vast majority: SEC reporting. Several Jaclin. BXNG: Farkas/Jaclin. Several with Chinese Nationals. +Zenith/Lazar/Sytner: Jaclin 2.0 like Honig. ABSOLUTELY NOTHING random about this as I have stated repeatedly: +MASSIVE in scope/Brazen/Egregious/ongoing/SEC facilitated/SEC IG complicit frauds on the public the grossly +corrupt SEC is mandated to protect while screwing the whistleblower who caught them: ME. AND NONE OF IT +HAPPENS without well known criminal entities like executing BD/MM's NITE et al. NOT the "penny stock trading +fairies" + + +No, SDNY/NY Supreme Court Judges: Hometown International is NOT a 1 off that slipped through the cracks. At +ALL times Jaclin has been under the jurisdiction of the SEC NY. At ALL times SEC NY ALSO under the jurisdiction +of the SDNY. +From: Chris Dilorio _ +Sent: Saturday, April 17, 2021 10:31 AM + + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +SDNY Judges and SEC IG, +I would like to Re admit the following which is part of my extensive record with the grossly corrupt SEC: Jaclin +Money laundering shells: Honig et al. AND prolific Bag Man Michael Farkas: BLNK,ICLD etc etc +Have you been watching the story about this Deli in New Jersey with a $100 million dollar market cap? +US Financial Markets Have Become A Giant Mirage Built On A Foundation Of Fraud_| ZeroHedge +US Financial Markets Have Become A Giant +Mirage Built On A Foundation Of Fraud +ZeroHedge - On a long enough timeline, the survival rate for +everyone drops to zero +www.zerohedge.com +SDNY judges/ SEC IG: This is what I have been telling the grossly corrupt SEC for more than 8 f'n years now. +ALL of this activity is up and running TODAY: April 2021 thanks to SEC criminal obstruction and corruption. +The SEC is a criminal enterprise ACTIVELY facilitating multiple, ongoing frauds on the public it is mandated to +protect to the benefit of the criminals who own them while screwing the whistleblower who caught them: ME +Say Hi to the OTCM Pink money laundering shell Hometown International +EDGAR Search Results (sec.gov). +pg 22 and following of Selling Shareholders in this 2020 SEC approved S1 +https://www.sec.gov/Archives/edgar/data/1632081/000121390020014269/ea122720-s1_hometown.htm#j_015 +SEC.gov|HOME +(1) Pursuant to Rule 416(a) under the Securities Act of 1933, as amended (the "Securities Act"), there are +also being registered hereby an additional indeterminate number of shares of the Registrant's Common +Stock, $0.0001 par value (the "Common Stock") as may become issuable to the selling stockholders as a +result of stock splits, stock dividends and similar transactions, and, in … +New Jersey Deli with "investors" in Macau, Hong Kong etc +Welcome to my world in dealing with the grossly corrupt SEC +Of course, Hometown International was ANOTHER Jaclin money laundering shell kept up and running by the +grossly corrupt SEC +https://www.sec.gov/Archives/edgar/data/1632081/000114420415059929/v422176_s1.htm +SEC.gov| HOME + + +25 E. Grant Street. Woodstown, NJ 08098 (856)759-9034 (Address, including zip code, and telephone +number, Including area code, of registrant's principal executive offices) +What I have been telling the grossly corrupt SEC for YEARS: This is WHY the OTCM exists. AND, in Q1 2021, more +than 4 TRILLION shares of money laundering shells like Hometown International were traded by NITE, CDEL et +Market Statistics - Equity Trading Data Monthly_(finra.org). +ABSOLUTELY nothing has changed in the last 8 years. Infact, as the grossly corrupt SEC, DoJ et al have been in +possession of my information, this illegal activity has EXPLODED. +SEC IG: DO YOUR FUCKING JOB!!!!! +Hometown International: Woodstown NJ: SEC NY: SDNY jurisdiction +Sent: Monday, April 5, 2021 5:29 AM + + +Subject: FW: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +Judge Swain: still ANOTHER version of A Stroll Down the ABSOLUTELY NOTHING HAS CHANGED Avenue. +This is another version of my extensive correspondence as I wait on the SEC Final Determination. Below, I +detailed the $765 million fraud DFC/taxpayer loan to almost insolvent Kodak to transition from +film/cameras(buggy whips) to hydroxychloriquine. The DFC was run by Jared Kushner's college roommate. +Massive fraud from the outset. The SEC of course never investigated the massive pump and dump related to +this fraud. AND, thanks to the SEC egregious obstruction of Congress: there is STILL no CAT. Of Course the DFC +first appointed IG Zakel (Sep 6 2020) concluded 2 months later that Jared's roommate didn't break any laws. +Further: The Akin Gump internal investigation is ripped to shreds by yours truly below. AGAIN:There was no +Clayton et al/SEC OR DoJ investigation into the egregious Insider Pump and Dump that took place in KODK +related to the fraud DFC taxpayer loan. +The interconnectdness of my claims on display yet again. +Some Interesting entities involved with Blackstone/Schwarzman/New in the almost insolvent at the time/still: +KODK. +Recall from a version I sent last week Judge Swain: +Sedona/Scan Graphics: 1998 +Kushners/Nordlicht/Englander AND +The Karfunkel Family Trust +https://www.sec.gov/Archives/edgar/data/764843/0000943396-98-000012.txt +KODK got some attention when GEORGE KARFUNKEL made a generous donation to a "synagogue" in Brooklyn +called Congregation Chemdas Yisroel +https://www.sec.gov/Archives/edgar/data/31235/000121390020020114/ea124950sc13da2karfunkel_eas.htm +SEC.gov |HOME +This Amendment No. 2 to Schedule 13D ("Amendment No. 2") relates to the common stock, $0.01 par +value per share (the "Common Stock"), of Eastman Kodak Company, a New Jersey corporation (the +"Issuer"), and amends and supplements the initial statement on Schedule 13D filed on May 18, 2017, as +amended and supplemented by the Schedule 13D/A filed on December 6, 2019 (the "Schedule ... +Chemdas Yisroel address: + + +This EXACT address is the home of Roth CPA's etc +Which also has offices in Israel +Roth&Co - We understand that your business is your life's work (rothcocpa.com). +Roth&Co - We understand that your business is your life's work +NEW YORK. 1428 36th Street, Suite 200 Brooklyn, NY 11218 Phone: 718-236-1600 Fax: 718-236-4849 +rothcocpa.com +Important to note here that George Karfunkel founded 1 of the largest Stock transfer companies: American +Stock Transfer. Did I mention there was no Jay Clayton et al/SEC/DoJ Insider trading/P&D investigation into +KODK? +I digress. +See, back in 2004, Barry F'n Honig had a shop called GRQ Consultants +GRQ was involved in 2 money laundering Shells: +Amplidyne yada yada +EDGAR Filing Documents for 0001170022-05-000036 (sec.gov) +AND +Cell Power Technologies +EDGAR Filing Documents for 0001144204-04-007936 (sec.gov) +Everyone catch the address of this Cell Boost "technology" Cell Power? +The SAME address as Chemdas Yisroel and Roth CPA's +but just down the hall: Suite 205 +This is priceless. +An SEC approved offering from 2005 for Cell Power +https://www.sec.gov/Archives/edgar/data/1202034/000114420405030051/v026245_424b3.txt +Who was the law firm on this money laundering shell in 2005??? +Sichenzia Ross. The same law firm responsible for NewLead and FreeSeas: 2 massive frauds perpetrated on the +SDNY Courts as well as NY Supreme Court. Brought to you by the grossly corrupt SEC. +Gets better still.... +The SEC revoked Cell Power Technologies in 2010 +EDGAR Search Results (sec.gov). +Barry Honig/Jaclin: also Blink Charging with prolific Bag Man Michael Farkas, JMJ, Drexel Alum Director, +Jonathan New: NETE CFO up and running in 2021. +And Barry Honig: Frost/Stetson/Colleran/ Alpha Capital et al +Recall the record Janey: "multi billionaire Frost wasn't trying to MAKE a few million. Frost was laundering" +Frost: bought Ladenburg from Icahn/Vector after Ladenburg bought Gruntal: Milken, SAC, Feinberg et al +Colleran: Trump felon fundraiser +Alpha Cap: Schlaff: Bawag/Refco/Sedona/Judge Swain: also my Knight/KCG/VIRT:NITE TCR +2020. TEN YEARS AFTER the SEC revoked the Honig/Sichenzia money laundering shell down the hall from +Chemdas Yisroel/Roth CPA: Garfunkel: Cell Power Technologies + + +Garfunkel: 1998 Sedona/Scan Graphics w/Kushners et al +Karfunkel/Chemdas Yisroel/Roth CPA's weren't the only ones to "get the look" (for those of you with ZERO +trading experience charged with enforcing Securities Laws like insider trading, this is the term used for insider +trading) +Moses Marx also "got the look" +EDGAR Filing Documents for 0001104659-20-089495 (sec.gov) +EDGAR Filing Documents for 0001104659-20-089495 +EASTMAN KODAK CO (Subject) CIK: 0000031235 (see all company filings) IRS No.: 160417150 | State of +Incorp.:NJ | Fiscal Year End: 1231 Type: SC 13D/A | Act: 34 | File … +Marx and Karfunkel go way back and are still in business together +Does United Equities/Commodities ring any bells? +How about Berkshire Bancorp? ANOTHER New York licensed Bank +EDGAR Search Results (sec.gov). +Karfunkel/Marx moved BERK from the NASDAQ to the OTCM Pinks around 2013 +WHY? Less disclosure stupid. +Microsoft Word - (D634DCBC-639A-4A58-8504-3EDC20157A89) (otcmarkets.com) +hey look! Marx, Karfunkel:BERK has the same auditor as Trump: Mazars. Prly just ANOTHER coincidence. For +those of you incapable of following along: The probability that ALL of the Karfunkel illgotten gains in the +SEC/Trump/Kushner/Blackstone/DFC et al facilitated P&D/Insider trading went to Congregation Chemdas +Yisroel is virtually ZERO. +Have I mentioned there was NO :zero,zilch, nada Jay Clayton et al/SEC/DoJ insider trading investigation into +KODK? +OK, good. Got it covered +Maybe, just maybe had the grossly corrupt SEC thoroughly investigated my irrefutably accurate allegations: +Blackstone/Schwarzman: NITE, the massive pump and dump fraud:Blackstone et al: KODK wouldn't have +happened. Which is why there has NEVER been a thorough investigation of my irrefutably accurate allegations. +In fact, the grossly corrupt SEC has criminally obstructed a thorough investigation of my claims SO THAT frauds +like KODK can continue. The SEC is bought and paid for by criminals while actively facilitating MULTIPLE frauds +on the public it is mandated to protect WHILE screwing the whistleblower who caught them:ME. the record +Janey is IRREFUTABLE. +Finally Ms Wing/Strauss: will you be keeping your DoJ e mail address up and running months after you land a +new gig like Geoffrey Berman has? Almost like he never left. +So Judge Swain: What has changed since your Sedona/Badian/Hirsch/Refco/Bawag decision? +ABSOLUTELY NOTHING! +Yes: Blackstone/Schwarzman/Marx/Karfunkel/Kushner/Trump et al are most definitely on the SEC/DoJ "Do not +investigate List" + + +Sent: Wednesday, September 23, 2020 7:18 PM +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +Judges Cave and Nathan, +If there was ANY question as to the veracity of my extremely serious allegations, the SEC put it to rest today +with its "clarification" and new rules governing the Whistleblower program: +My preliminary denial in June for the Opco Award application which was 5 years in the waiting: "SEC staff never +saw Mr Dilorio's information" +I refer you to the ONLY new rule in the "clarifications" in the interest of "transparency" +https://www.sec.gov/rules/final/2020/34-89963.pdf +SECURITIES AND EXCHANGE COMMISSION 17 CFR Parts 240 and 249 RIN +3235-AM11 ACTION SUMMARY +SECURITIES AND EXCHANGE COMMISSION . 17 CFR Parts 240 and 249 [Release No. 34-89963; File No. S7- +16-18] RIN 3235-AM11. Whistleblower Program Rules +New Rule 240.21F-18 Summary Disposition +(3) The information you submitted was never provided to or used by the staff handling the covered action or the +underlying investigation (or examination), and the staff members otherwise had no contact with you. +AKA the Christopher J Dilorio Rule. Created to deny awards of rightful compensation. Per my appeal: a whistleblower CAN +NOT know who at the SEC he/she should contact as investigations are done in strict confidentiality. Further, the OWB itself +is the CENTRAL contact for whistleblowers. It is the EXPLIT and EXCLUSIVE responsibility of the OWB to distribute +whistleblower information within the SEC. This "rule" is FURTHER overwhelming evidence of SEC corruption and +obstruction. +Judges Cave and Nathan: ALL information presented to your Courts must be treated with extreme skepticism if not +outright disdain. IF the SEC is willing to commit massive fraud on whistleblowers who expose their corruption and criminal +activity just imagine the evidence it is willing to fabricate to bring a case like they are in Kamensky. An immediate STAY in +Kamensky is warranted until an independent thorough investigation of my claims can be executed. ALL evidence +presented to your courts by the SEC must be questioned in light of the overwhelming evidence I have provided. Again: this +corruption goes straight to Jay Clayton himself. His former colleague Jared Fishman has played a key role in this massive +fraud. Clayton NEVER disclosed these conflicts. In addition, your Honors are in possession of other Clayton/Sull +Crom/AQR/Girsky facilitated fraud: Nikola. This is what it has come to when you blow the whistle on the grossly corrupt +SEC: They create a completely arbitrary and fraudulent rule to silence you. +Rule 204-21F summary disposition aka Screw the whistleblowers exposing SEC corruption Rule OR + + +The Christopher J Dilorio Rule +Regards, +FROM:Chris Dilorio< +Sent: Wednesday, September 23, 2020 5:27 AM +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +Judges Cave and Nathan, +My allegations are chock full of members of the SEC "Do Not investigate Club". Per my TCR: Key to the Aug 2012 +"glitch/Bailout: Blackstone/Schwarzman. Blackstone had done extensive Due Diligence on Knight prior to the +"glitch" and had considered buying them north of $14/sh. Somehow/some way Blackstone decided not to go +ahead with buying Knight not too long before the "glitch" which took the stock to $3. The ultimate bailout deal +was NOT collateral based. Rather a convert with a %50 discount to $3: $1.50/share. "WHEW". Per my TCR: ALL +2012 "glitch" bailout participants including Blackstone knew EXACTLY the fraud on the Knight balance sheet. +Because of SEC corruption/criminal obstruction, NITE is insolvent TODAY. Absolutely nothing has changed. A +massive ongoing fraud on the public. +As a direct result of the SEC "Do not investigate Club", The KODK/Blackstone fraud on US Taxpayers (see below) +was perpetrated on the public. +Steve Schwarzman/Blackstone are near the top of the SEC "Do not investigate List". +Obviously, Mr Kamensky is not in the Club. +As you can clearly see from my appeal to the OWB: The SEC intended to run out the clock. 5 years in the waiting +in their Preliminary Determination Opco Award Denial for " Investigators never saw my information". Yet, SEC +actions based on my information include: Hanover/Magna, JMJ/Keener, Fife, Southridge/Hicks, Opco, and +UBSS. Missing somehow: NITE, Handler/Jefferies, Blackstone/Schwarzman etc etc. +The last overt act of this massive conspiracy has not yet occurred. +Mr Kamensky and I are BOTH victims of a longstanding and corrupt relationship between the SEC and +Handler/Jefferies et al. Also victim of this corruption: the investing public the SEC is mandated to protect and +the US Taxpayer. +Regards, + + +Sent: Wednesday, September 16, 2020 6:25 AM +Subject: Fw: Formal appealfor denial covered action 2015-016/ Knight Capital TOR & Appendix +Janey, +Schwarzman must be pretty close to the top of the SEC's "do not investigate" list. +The latest Schwarzman/Blackstone orchestrated fraud and cover up: KODK +Today, the KODK Board Member Jason New: Blackstone "independent" outside inquiry by the law firm Akin +Gump is in +https://www.kodak.com/content/products-brochures/Company/Report-to-the-Special-Committee- +09.15.2020.pdf +"gaps" indeed +The flowery New/BX cover up is chock FULL of gaps. +"Introduction to Phlow" +Phlow: the VA consortium receiving $350 mil in Government Covid funding to provide Trump pushed Covid +Cure: hydroxychloroquine +https://www.prnewswire.com/news-releases/phlow-corporation-awarded-354-million-hhsasprbarda-contractto-manufacture-essential-medicines-in-shortage-301061648.html +Phlow Corporation Awarded $354 Million HHS/ASPR/BARDA Contract to +Manufacture Essential Medicines in Shortage - PR Newswire +RICHMOND, Va., May 19, 2020 /PRNewswire/ -- Phlow, a U.S.-based, public benefit drug manufacturing +corporation, has received federal government funding of $354 million for advanced manufacturing ... +www.prnewswire.com +Phlow already has/had a long standing relationship with Ampac Fine Chemicals +https://www.phlow-usa.com/about-us/ +About Us | Phlow Corporation +Robert Mooney is a tireless champion of creativity and business +acumen. As an entrepreneur and co-founder of New Richmond +Ventures (NRV), Bob counseled startups and early stage +companies on accounting and financial reporting, capital + + +strategies, equity raising, project financing, milestones, business +www.phlow-usa.com +In May 2020, Phlow was re starting/building a mfg facility/warehouse with partner Ampac (AFC) to fulfill its +Government contract +https://richmondbizsense.com/2020/05/20/new-richmond-based-pharma-startup-with-350m-in-funding-eyesfacility-in-petersburgL +New Richmond-based pharma startup with +$350M in funding eyes facility in Petersburg - +Richmond Bizsense +Earlier this month BizSense first reported Phlow's initial +government contract for $6 million, but details on the company's +plans remained unclear at the time... Gupton said in an interview +Tuesday the company's plans have been in the works for about 18 +months, well before COVID-19 hit. +richmondbizsense.com +Per the KODK/New/BX/Akin Gump cover up: pg 20 +"On June 15 2020,Kodak signed a Letter of Intent with Phlow in furtherance of its application to the DFC to +show it had a CUSTOMER for its future API's" +Most definitely "DEFINITIVE AND MATERIAL" +So, where is the SEC reviewed/required 8k for this agreement? +https://www.sec.gov/cgi-bin/browse-edgar?CIK=31235 +Meaning: the DFC application was a FRAUD. Fraud on the government. Fraud on American taxpayers. +Further: WHY would the DFC consider "loaning" $765 million to KODK with NO EXISTING API capability when it +already granted LESS money to Phlow/Ampac with proven capabilities? Answer: KODK liquidity issues are +SEVERE +Like Milken: Insider trading is NOT the real issue here. The latest BX orchestrated "glitch": KODK. +I know this information may be more than the SEC/DoJ are capable of comprehending. +Call me and I'll walk you through it SLOWLY. + + +Sent: Tuesday, September 1, 2020 7:40 AM +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +Janey, +MORE on the Blackstone/Trump/Kushner KODK P&D grift. +Again, BX helped orchestrate the Knight "glitch" and bailout. No doubt, the "luckiest" f'ers on the Street. VERY +high on the SEC do not investigate list. So, they can continue to facilitate criminal activity. +See below: Jason New: KODK BoD: BX. In charge of the KODK "internal investigation". Now we read where DE +Shaw has taken a 5% stake in KODK. guess who DE Shaw largest investor is: Blackstone. Corruption cover up. For +the record Janey +https://www.thetrustedinsight.com/investment-news/de-shaw-blackstone-20190325420/ +Sent: Thursday, August 20, 2020 12:04 PM + + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +Mr Best, +Congratulations on your new position as Director of SECNY. +No doubt you have earned the promotion. For those of you who don't know Dick Best from his FINRA days, this +masterpiece is what got him his job at the SEC Atlanta office +https://www.finra.org/media-center/news-releases/2014/finra-fines-brown-brothers-harriman-record-8- +million-substantial-anti +The BBH AML complaint. Truly, fantastic work. +ALL of the entities in the complaint are un named. WHY? +This is my information. +Swiss Banks, FFI's, and of course: penny stock trading fairies aka executing BD's/MM's that made it all possible. +Per Dick's complaint: BBH delivered 80%+ of the trades to executing BD's/MM's. Did Dick Best criminally +obstruct an investigation into my claims? Per my extensive correspondence with Robin Traxler at FINRA AND the +fact that the SEC had my Knight Capital TCR in its possession for almost a year when Dick brought his BBH +complaint. So, did Dick's complaint implicate entities in my TCR and that's why ALL of the entities in Dick's +complaint are un named? Most certainly YES. +Recall, this scheme generated $850 MILLION in proceeds. Dick's $8 mil fine was not a deterrent. Intentionally +SO. +So Congrats Dick on your new position as Director at SECNY. Janey, Hoecker, Dick, the record is extensive of my +correspondence including Dick Best at the Atlanta Office. No doubt he will be recusing himself related to +matters involving the un named entities in his FINRA BBH complaint. OR will he do what is expected at the SEC: +Criminally obstruct investigations while screwing whistleblowers like me? +Sent: Wednesday, August 19, 2020 6:53 AM +P + + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +Further: +Janey, Hoecker, Jay, Mehraban et al +Let me help narrow down the SEC facilitated, ongoing accounting fraud at NITE as I know none of you have ever +spent a day on a trading desk: +IF the avg holding period for VIRT HFT is a matter of seconds AND VIRT goes home flat every night, then what is +the receivable/fails related to? With the core Virtu HFT business eliminated, what that does that leave? The +CASH OTCM business maybe? Should I draw a picture in crayon for you Ms Mehraban? +NITE: 3 different CFO's in the last year. Ms Mehraban, How much is your former Paul Weiss colleague/boss +Dougie Cifu paying you to criminally obstruct an investigation of my allegations? +Janey, Hoecker, Mehraban et al: When it comes to trading fraud/accounting fraud cover ups, SEC attorneys are +CLEARLY not qualified. +The record there is ALSO IRREFUTABLE. +Here glitchy glitchy. +Sent: Tuesday, August 18, 2020 6:37 PM + + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix +Janey, Hoecker, Mehraban, Jay et al, +The massive SEC facilitated fraud on the public known as Knight/KCG/VIRT: NITE is reaching epic proportions in +August 2020. For the new "accounting" hires at the SEC: +In 102020, the receivable at NITE was up 90% or $1.2 BILLION from Dec 2019 to $2.562,721 billion +Per the extensive record Janey: fails: because of self clearing are booked as a receivable. FRAUD. no intention of +delivering. More accurately a liability. AND per my 2013 TCR: a large portion: structural liability as a result of an +open naked short fail position WHEN not if a reverse split is approved by the grossly corrupt SEC/FINRA. There +are some new "buckets" Malusso, loffe, Dougie large have created within the Receivable as well. Creative. The +accounting shell game: moving fraud (abusive naked shorts) from bucket to bucket. +The 1Q2020 10Q +https://www.sec.gov/ix?doc=/Archives/edgar/data/1592386/000159238620000006/virtufinancial03- +31x20.htm +Inline XBRL Viewer - SEC +The Inline XBRL Viewer allows a user to quickly and easily review details of the tagged information in an +Inline document by automatically placing a top and bottom highlight border around each tagged numeric +fact and left and right border for each block tagged fact. +Pg 23. +Buckets total $2.562,721 BILLION +the 2Q2020 10Q +https://www.sec.gov/ix?doc=/Archives/edgar/data/1592386/000159238620000009/virt-20200630.htm +pg 24 +Buckets total $2.441,283 BILLION +The FRAUD (please see the record Janey). +ALL of the receivable items are related to SETTLEMENT. +Certain items within the receivable: buckets: would zero out within days IF VIRT was in compliance with the +Securities LAWS: Close out requirements of Rule 204. So, isn't it beyond amazing THAT: although there was + + +some change in certain buckets AND that the amounts were zeroed out within days of March 31, 2020 ONLY to +end the quarter June 30, 2020 a mere $121.438 MILLION difference from the March 31, 2020 ending +balance?????? +That is absolutely f'n amazing: $2.562,721 BILLION zeroed out from March 30, 2020 THEN a $2.441.283 balance +at June 30,2020. Well, the SEC does believe in "penny stock trading fairies" too. +Nope. Not penny stock trading fairies. AND VIRT didn't zero out :FAILED to SETTLE BILLIONS S$ in transactions. +This massive fraud is due to NEVER closing/covering as is mandated by LAW. SEC, ongoing, massive fraud on the +public. Classic bucket shell game. A la FCM and Reverse mortgages. +NOTHING has changed thanks to SEC corruption and obstruction while screwing whistleblowers like me. +The massive NITE accounting fraud facilitated by the SEC that facilitates the ongoing fraud on the public the SEC +is mandated to protect. +CLEARLY, IRREFUTABLY: NITE is and always has been a criminal entity. ILLEGAL NAKED SHORTING drives trading +profits at NITE. ALWAYS has. Janey, please post Jay Clayton AND Ms Mehraban NITE conflict disclosures. No +doubt, Dougie large will see this e mail the same way the grossly corrupt SEC has disclosed my information to +NITE for the last 10 years. NITE is GROSSLY insolvent TODAY August 18,2020. +From: Chris Dilorio I +Sent: Tuesday, August 11, 2020 6:53 AM +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight TCR & Appendix +Janey, Hoecker et al +SEC criminal obstruction virtually real time. + + +https://www.sec.gov/news/press-release/2020-178 +SEC.gov | SEC Charges Interactive Brokers With Repeatedly Failing to File +Suspicious Activity Reports +The Securities and Exchange Commission today announced that Interactive Brokers LLC will pay an $11.5 +million penalty to settle charges it repeatedly failed to file Suspicious Activity Reports (SARs) for U.S. +microcap securities trades it executed on behalf of its customers. +SECNY: Lara Shalov Mehraban. Ms Mehraban, I've asked this before: Was Dougie "Large" Cifu your boss at Paul +Weiss? The IBKR "complaint" is getting very close to your former boss/colleague isn't it? +Questions Ms Mehraban doesn't want the public to see: +Her former boss/colleague Dougie "Large" Cifu hired Alex loffe as VIRT CFO in 2019. From 2003-2019 loffe was +CFO at IBKR. INCLUDING the period covered in Ms Mehraban's complaint. +Not filing SAR's, Microcap securities, AML red flags. No kidding. WHY are the securities un named? WHO was +ultimate executing BD/MM? +As self clearing Ms Mehraban, isn't Knight/KCG/VIRT (Cifu): NITE the LARGEST clearing agent of microcap +securities? How many SAR's coming out of your former boss executing BD/MM? +Per my TCR: NONE. ZILCH. NADA. How do I know that? +When would the criminal enterprise NITE which is run by Ms Mehraban's former Paul Weiss boss/colleague Cifu +file a SAR: +BEFORE +AFTER trading billions of shares? +Did NITE Compliance rely on IBKR/loffe compliance? That would be a violation wouldn't it? +Ms Mehraban is the poster child of SEC corruption and criminal obstruction while screwing whistleblowers like +me. Virtually real time in August 2020. Very much an ONGOING and massive fraud on the investing public. +Ms Mehraban, please pass along my warmest regards to your former Paul Weiss boss/colleague Dougie "Large". +No doubt you "chat" often. +The record is overwhelming AND irrefutable. +From: Chris Dilorio «I +Sent: Monday, August 10, 2020 8:32 AM + + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight TCR & Appendix +Janey, Hoecker et al +speaking of NO 8K, recall the extensive record for the criminal/insolvent/fraud on the public +Knight/KCG/VIRT:NITE +The record Janey: Clayton/Sull Crom/Fishman "sale" of FCM business to other criminal firm Wedbush with NO +8K +3Q2014 10Q +https://www.sec.gov/Archives/edgar/data/1569391/000156939114000013/kcg2014093010-q.htm +KCG then CFO Bisgay resigned with 2 weeks left in the quarter and didn't certify the financials. WHO certified +along with Coleman? Sean P GALVIN. +Cifu, Viola, Urban, Hutchins et al getting the fraud band back together +https://finance.yahoo.com/news/virtu-financial-announces-changes-finance-105100941.html +WHY would "Cutting edge technology firm" VIRT want to go with a guy who knows how to run the books at low +as low tech gets OTCM cash trading firm Knight/KCG? The core business at Knight/KCG/VIRT: NITE is and always +has been: abusive naked shorting OTCM (and other) publicly traded shells to facilitate money laundering +Here glitchy glitchy +Sent: Friday, August 7, 2020 6:20 AM + + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight TCR & Appendix +The SEC facilitated fraud on the public continues unabated. MORE irrefutable evidence of SEC criminal +obstruction while screwing whistleblowers like me. +A direct result of this ongoing massive fraud on the public. +After NITE reported its 1Q,2020 results | again again, again, like the last 10 years, alerted the grossly corrupt SEC +to the massive accounting fraud at NITE as a direct result of abusive naked shorting. +Per my 2013 TCR Janey, Hoecker, Jay et al: +NITE is in a constant state of insolvency as a result of illegal, criminal, abusive naked shorting OTCM money +laundering shells. This illegal activity drives trading revenue at NITE. This illegal activity is and ALWAYS has been +the core business at NITE. This very profitable albeit illegal activity is WHY Sull Crom client KCG was bought by +Virtu. This illegal activity is WHY NITE has been repeatedly bailed out by GS,B,JEF, JPM and the SEC +The receivable is where NITE books naked short fails as a result of self clearing. NITE has no intention of closing/ +can't close these naked short positions. NOT a legit asset. Further, the receivable isn't a legit asset NITE can +convert to cash for its own use. There are prior commitments on these "assets": SETTLEMENT +In 1Q,2020, the NITE receivable grew to $2.5 BILLION. UP 90% from December 2019 +https://www.sec.gov/Archives/edgar/data/1592386/000110465920057660/tm2018404d1_ex99-1.htm +SEC.gov | HOME +Exhibit 99.1 . Virtu Announces First Quarter 2020 Results . NEW YORK, NY, May 7, 2020 - Virtu Financial, Inc. +(NASDAQ: VIRT), a leading provider of financial services and products that leverages cutting edge +technology to deliver innovative, transparent trading solutions to its clients and liquidity to the global +markets, today reported results for the first quarter ended March 31, 2020. +Per the SEC reviewed 8k filing this am Aug 7, 2020 NITE reported 202020 earnings. showing the receivable +roughly flat with 1Q2020 at 2.44 BILLION +https://www.sec.gov/Archives/edgar/data/1592386/000110465920091707/tm2026789d1_ex99-1.htm +These are NOT "assets". More accurately, these are LIABILITIES. Massive accounting fraud. After moving these +fraud "assets" to the appropriate liability classification, NITE tangible book value is GROSSLY insolvent. The SEC +has obstructed my allegations for several years while allowing NITE to write down this structural liability on + + +more than 1 occasion. Further, sell side analists at the guidance of Cifu et al never question these EGREGIOUS +balance sheet issues. AND, with the grossly corrupt SEC blessing, Cifu et al never disclose insolvency in any SEC +filing OR investor presentation. +After dismal April/May REPORTED OTCM volumes on the FINRA now controlled website, June saw a dramatic +spike in share volumes. +The Top 25 OTCM money laundering shells by share volume in June 2020 and share price +PLYZ .00015 +PVDG .0008 +RTON .00015 +GRST .001 +RNVA .76 (rev split) +OZSC .0049 +EWLL .0002 +VSYM .0012 +OPTI .14755 +AFOM .0001 +SIML .00025 +IGEN +0084 +XMET .0002 +GTEH .0001 +ABCE .0003 +TSOI .007 +NTRR +.0014 +GFTX .0005 +LVXI .0003 +SGMD 0024 +INQD .002765 +RBNW .0005 +TLSS .0238 +TPTW .07215 +HYSR +.0328 +Combined price approximately $1 +How do stocks trade to trip zeroes? More buyers than sellers? +Covering/closing out naked short fails shouldn't be an issue. ONLY explanation: abusive naked shorting: +MANIPULATION. NOT Bona Fide market making. +As a direct result of this massive, ongoing SEC facilitated fraud on the public, ABSOLUTELY NOTHING HAS +CHANGED. +The record is irrefutable: SEC criminal obstruction while screwing whistleblowers like me to facilitae a +MASSIVE, ongoing fraud on the public. Key facilitator: Jay Clayton/Jared Fishman: Sull Crom + + +Sent: Thursday, July 30, 2020 9:31 AM +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight TCR & Appendix +MORE SEC corruption/obstruction/screwing whistleblowers like me. +Per my 2013 TCR attached Janey, we know that Schwarzman/Blackstone has played a key role in perpetuating +the criminal entity Knight, KCG,VIRT:NITEthe Sull Crom client. +We also know Trump and Schwarzy are BFF's. Schwarzy is also connected to Kushner and Epstein. +Schwarzy is most definitely on the SEC's "Do not investigate List" +A stroll down the record Janey: Around the same time as the SEC/BX/JEF/GS et al August 1 2012 NITE "trading +glitch", Schwarzy/BX were key advisers to bondholders of Eastman Kodak and to the company also. Jason New: +Blackstone was re elected to the KODK BoD in May 2020. +https://www.sec.gov/Archives/edgar/data/31235/000156459020027039/kodk-8k_20200520.htm +Then the Pumper/Grifter in Chief Trump goes out wide and far with this absolutely incredible news: +The camera/film company Eastman Kodak is now going to be the US savior in pharma ingredients supply chain. +This is a page out of the penny stock grifter playbook. This is what happens when we have a WH full of money +laundering shell grifters. So, what has been the result of this incredible pump/transformation? KODK has gone +from 2 to 90 back to 40. +As is typical Trump/grifters/ and his criminal Clayton led SEC: the public hasn't seen a 8K filed by KODK to detail +this incredible "transformation". The SEC has given its blessing to yet ANOTHER Trump/Grifter/Bag Men P&D. in +KODK, FBO Trump BFF and Sull Crom client: Knight "savior" Schwarzy/BX. Had the grossly corrupt SEC +investigated my claims instead of obstructing them and screwing me, MAYBE Schwarzy/BX would have thought +twice about their latest grift: KODK. We know that Schwarzy is also a prolific GOP donor. +F'n criminals + + +Sent: Thursday, July 30, 2020 6:33 AM +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight TCR & Appendix +Still MORE IRREFUTABLE evidence of SEC criminal obstruction and corruption while screwing whistleblowers like +me. Per the record Janey: Trump PA campaign Mgr David Urban on the BoD of #1 money laundering shell trader +and Clayton/Sull Crom client NITE. Urban also on the BoD of money laundering shell: Pakastani/Canadian pot +company w/ 200k in revenue FSD Pharma:HUGE. Today HUGE is up more than 100% on "news" it will pivot +away from growing pot in Canada to "developing" a pot based cure for Covid. A money laundering shell. +Of course, the grossly corrupt SEC has approved a $20 million public offering for Urban/Trump: HUGE +SEC facilitated P&D to facilitate money laundering +https://www.sec.gov/Archives/edgar/data/1771885/000106299320003258/formsuppl.htm +AGAIN, the SEC is a criminal organization facilitating criminal activity and protecting criminals at the expense of +the public it is MANDATED to protect while screwing whistleblowers like me. +The record is extensive. + + +Sent: Tuesday, July 28, 2020 7:48 AM +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix +STILL MORE OVERWHELMING evidence to support my extremely serious allegations that the SEC is a criminal +organization, run by criminals, to support criminal activity while screwing whistleblowers like me. +Farkas: Michael: is a prolific Bag Man well known to the SEC. Farkas chose a Jaclin money laundering shell +INTENTIONALLY. Blink Charging (BLNK) is ANOTHER SEC facilitated fraud on the public the SEC is MANDATED to +protect. +Other Farkas money laundering shell: i Incubator +https://www.sec.gov/cgi-bin/browse-edgar?CIK=1044693 +As is SOP for the grossly corrupt SEC: Revoked AFTER this massive fraud on the public was complete +https://www.sec.gov/litigation/admin/2009/34-60013.pdf +ALSO SOP for the corrupt SEC: No mention of Farkas and his controlling i Incubator entities in the complaint +https://www.sec.gov/Archives/edgar/data/1044693/000104653200000261/0001046532-00-000261-index.htm +https://www.sec.gov/Archives/edgar/data/1044693/000104653200000265/0001046532-00-000265-index.htm +https://www.sec.gov/Archives/edgar/data/1044693/000104653200000263/0001046532-00-000263-index.htm +ALSO missing from the i Incubator complaint: Executing BD/MM of the worthless Farkas certs dumped on the +public while the grossly corrupt SEC watched. Those damn "penny stock trading fairies" AGAIN! +NOPE. +BLNK never should have happened. Farkas, his NETE CFO, Keener, Nordlicht, etc etc should have been shut +down LONG AGO + + +Sent: Thursday, July 23, 2020 5:59 AM +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix +The grossly corrupt SEC response to whistleblower OVERWHELMING evidence of money laundering +,manipulation, and fraud: MY INFORMATION has been remarkably consistent over the last 9 yearst+: +Obstruct, cover up, facilitate illegal activity at the expense of the investing public it is sworn to protect while +screwing whistleblowers like me. +BLNK: A KNOWN Jaclin money laundering shell. Rev merger with a KNOWN Bag Man: Michael Farkas who was +the largest shareholder of ANOTHER money laundering shell: SkyWay but somehow escaped the SEC +investigation. With Board members like Engel: Drexel, Scigliano: Acies: NETE a CFO:New from NETE. A known to +the SEC Bag Man: Keener who the SEC has kept up and running for YEARS since being BARRED (Not Exactly) by +Industry SRO FINRA. +In addition to that name Farkas: ANDREW/Jonathan Farkas. Trump fundraiser and Epstein: Jeffrey: business +partner, this fraud has an added element. So, after receiving my overwhelming evidence with AML red flags too +numerous to count, what was the par for the course SEC response: Approved BLNK public offering just several +days ago AND with my overwhelming evidence in hand. But, that's not where the corrupt SEC active facilitation +of this massive fraud on the public ends. Yesterday, 7/22, BLNK put out a PR linking it to a few hundred charging +stations in VA, MD,DC. This pr drove the stock up almost 30% at 1 point and closed 15% higher on almost 8x avg +volume. A most certainly "MATERIAL" event. AND an event that required an SEC 8k filing if "DEFINITIVE" as well. +No such 8K was filed by BLNK for this pr. This pr therefore must be complete FRAUD intended ONLY to facilitate +a massive Pump and Dump on the public. It accomplished its intended fraudulent outcome. +But, back to BLNK fka New Image Concepts: the company +Between Blink and New Image Concepts, BLNK was known as Car Charging Inc + + +https://www.sec.gov/Archives/edgar/data/1429764/000114420414059745/v390669_def14c.htm +This 2014 SEC approved offering also had several red flags of its own. WHOPPERS in fact. +Guess who ELSE was involved in this years in the operating money laundering shell? +Platinum Funds/Nordlicht. With links to Kushner(s) and Trump lawyer Giuliani. Other NY entities, a Columbus +OH entity, a Chicago entity, and a Belize entity. Still counting the AML red flags? +The icing on the top of this massive SEC facilitated fraud: ex NM Governor Bill Richardson. +Who, is also linked to Jeff Epstein and his NM Zorro Ranch. +BLNK: money laundering fraud on the public ACTIVELY facilitated by the SEC in July 2020 despite overwhelming +whistleblower (me) information. Linked to Milken, Russia, Trump, and Epstein. Of course the 7/22 trading +activity NEVER would have happened without willing, executing BD's and MM's like the criminal entity known +as Knight, KCG,VIRT: NITE. Which has also been kept up and running by the grossly corrupt SEC despite +overwhelming evidence of a massive, ongoing, criminal conspiracy detailed by a whistleblower: me. +From: Chris Dilorio 4 +Sent: Wednesday, July 22, 2020 8:44 AM +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix +Greetings grossly corrupt SEC et al +Still MORE SEC facilitated fraud on the public it is mandated to protect: + + +BLNK: Farkas/JMJ/Jaclin/CFO New(NETE) money laundering fraud +today's pr +https://www.globenewswire.com/news-release/2020/07/22/2065815/0/en/Blink-Charging-Awarded-Grantfrom-Virginia-Clean-Cities-to-Place-200-Fast-Level-2-Charging-Stations-Across-the-Mid-Atlantic-Region.html +Of course, BLNK didn't file an SEC reviewed 8K for this material, definitive agreement that has the stock up 27% +on 5x normal volume at 10:30 EST +In fact, the last filing with the SEC by BLNK was actually the SEC declaring effective a public offering of securities +on 7/15/20. 1 week ago today. +MORE SEC facilitated fraud on the public. +Sent: Tuesday, July 14, 2020 3:31 PM +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + + +OH JOHNNY! +https://www.reuters.com/article/bc-finreg-fbi-laundering-private-equity-idUSKCN24F1TP +FBI concerned over laundering risks in private +equity, hedge funds - leaked document - +Reuters +The U.S. Federal Bureau of Investigation believes firms in the +nearly $10-trillion private investment funds industry are being +used as vehicles for laundering money at scale, according to a +leaked ... +www.reuters.com +Janey, +Even though you admit not distributing my information within the SEC, I was busy distributing it myself to +others. +Carl baby, I'm afraid this means your first "investigation" of my complaints to you wasn't exactly "thorough" as +I've been saying for years. +Shall I point out the pages for you? +Blackstone wanted to buy NITE but only AFTER theirSEC/JEF et al orchestrated August 1 2012 "glitch" +"luckiest f'ers" on the Street +https://www.businessinsider.com.au/blackstone-dodged-a-bullet-with-knight-capital-2012-8 +WHEW: Blackstone Almost Bought Knight +Capital Before Its Stock Collapsed +One company is breathing a sigh of relief after a trading glitch +sent shares of Knight Capital Group from more than $10.30 to +nearly $2.50 last week. +www.businessinsider.com.au +From my TCR you admit never distributing Janey +https://www.reuters.com/article/us-wealth-summit-ubs-blackstone-idUSTRE6A055020101101 + + +UBS brokerage's McCann sees more +Blackstone ties - Reuters +UBS, rebuilding a brokerage hard-hit by the financial crisis, lately +has been mingling in some good company: Blackstone Group LLP. +www.reuters.com +The UBS award application I sent to Janey TEN TIMES from a commercial fax machine: +ALSO MY INFORMATION +https://www.sec.gov/enforce/34-84828-s +SEC.gov | SEC Charges UBS Financial Services Inc. with Anti-Money +Laundering Violations +ADMINISTRATIVE PROCEEDING File No. 3-18931. December 17, 2018 - The Securities and Exchange +Commission today announced settled charges against broker-dealer UBS Financial Services Inc. for failing +to report suspicious transactions in customer accounts. UBS agreed to pay a $5 million civil penalty to +resolve the SEC's charges, and separately agreed to pay $10 million to the U.S. Treasury ... +Y'all are gonna be FAMOUS! +Sent: Tuesday, July 14, 2020 12:34 PM + + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix +MORE SEC corruption/obstruction +ANOTHER Jaclin money laundering shell: +https://www.sec.gov/Archives/edgar/data/1449527/000121390008002174/fs1_prcomplete.htm +YESDtc Holdings fka PR Complete +https://www.sec.gov/cgi-bin/browse-edgar?CIK=1449527 +MORE related entities to my claims: +Bill Scigliano: Chairman BoD +Scigliano was also a Director at Oleg Firer's revoked but still very much up and running in MA: Acies Corp. Acies +was incorporated by His Eminence with a NY address of 14 Wall Street: Rovt: Allied Wallet: WireCard. Jaclin and +Oleg related entities/people: Money laundering shells. Is the grossly corrupt SEC regretting their Jaclin +complaint which was a cover up for much larger criminal activity: MY CLAIMS? +But there's more. +The SEC also brought "more coverup than complaint" In Frost,Honig,Alpha,Stetson et al. The SEC Knows who +else was involved in the Jaclin money laundering shell PRComplete/YESDtc: +Barry Honig/GRQ +https://www.sec.gov/Archives/edgar/data/1449527/000152153612000023/0001521536-12-000023-index.htm +So, Jaclin money laundering Shells and Honig too? +Gee, maybe Bag Men Honig, Keener, Scigliano etc KNEW these were money laundering shells? +Who was the executing BD/MM converting all these billions of worthless Jaclin, Ironridge, JMJ, Farkas, Honig etc +etc certs into real money? +The SEC response: "penny stock trading fairies". NOPE: NITE +How is it possible that there is NO reference to AML in ANY of these SEC complaints? +Because the SEC outsourced BD compliance with the BSA to industry advocate FINRA. DUH +Then, there's the Jaclin money laundering shell New Image/BLNK. Gee, wonder if Farkas of money laundering +shell Skyway, JMJ/Keener: money laundering shells in my claims, Engel: Drexel, Jonathan New NETE CFO, etc +knew BLNK was/is a money laundering shell too. +His Eminence Firer is a prolific Bag Man. I've been telling the SEC that for years. +Janey, update my NETE and AQR TCR's. You know, for the record. Several entities in my TCR's linked to Jaclin's +shell factory. Including NITE. +I've asked this many times Janey, Jay, Hoecker et al: + + +WHAT EXACTLY DOES THE NITE COMPLIANCE DEPARTMENT DO EXACTLY? +Other than looking the other way while they naked short publicly traded shells to facilitate money laundering +that is +Sent: Monday, July 13, 2020 10:50 AM +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix +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. +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 +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. +Sent: Wednesday, July 8, 2020 9:35 AM + + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix +Janey, Hoecker et al, +REVOKED +election-1230690 +Is Trump prolific Bag Man Jonathan Farkas related to Bag Man Michael Farkas: Skyway largest shareholder: +https://www.hollywoodreporter.com/rambling-reporter/inside-hamptons-fundraisers-netted-trump-12m- +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? +From: Chris Dilorio J +Sent: Tuesday, July 7, 2020 6:09 AM + + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix +Janey, +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, 1 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 +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. +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 +See ThruEquity 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. 0). 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: | 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 +Not just irony but a massive fraud on the +Sent: Tuesday, June 30, 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, Hoecker, 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 +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-antimoney-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 +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_0_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 ... +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 +1234567891011 12 13 14 15 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 ... +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 +https://www.sec.gov/cgi-bin/browse-edgar? +action=getcompany&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 HQ'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) +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. +From: Chris Dilorio 4/ +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 1Q2014 and 2Q2014 that were expunged from KCG 10Q SEC filings. Not 2Q2014 and 3Q2014 SEC +reviewed 10Q's as I previously stated +corrected below +Sent: Tuesday, June 23, 2020 9:48 AM + + +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 I 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 AMP) where the ultimate +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 JM, 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 +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/BSI/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. +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 +10,2020, 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:Icahn/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 EWW 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 202017 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. +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 10,2014 +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 102014 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: +$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 2Q2017 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 L +/Trump/Barr +don't you think? The SEC needs some fixers. Wonder why. +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. +Wistleblower +Sent: Wednesday, June 10, 2020 2:30 PM +To: +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...... +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 +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. +Sent: Tuesday, May 12, 2020 8:54 AM +To: +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 +Sent: Monday, May 11, 2020 7:16 PM +To: + + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix +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: +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. +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 +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_10g.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. +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.... +Sent: Tuesday, April 28, 2020 7:24 AM +P; + + +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 +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. +https://www.sec.gov/Archives/edgar/data/1322587/000114420413065095/v361773_sc13g.htm +(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. +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. +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 +investigation of the ENTIRETY of the FIRA 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’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. +Sent: Sunday, April 26, 2020 9:36 AM +To: +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix +From: Chris Dilorio 4 +Sent: Friday, 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 +(asComplaint 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 +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. GfiRALTAR 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 +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? +The judge in the Gibraltar case said "the SEC's requested amount CLEARLY UNDERESTIMATES the defendants illgotten 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 +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 +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 +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 ... +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. + + +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 +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. +1 appeal the SEC preliminary determination and wish to file ANOTHER complaint with the SEC IG. +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 + + +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/lг24403.htm +Joshua Sason, et al. (Release No. LR-24403; Feb. 15, 2019) +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. +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. +Christopher Dilorio +Mr Peirce, +Congratulations on your nomination as SEC Commissioner. I have read your paper on FINRA lack of +iccountability, I believe the SEC has abdicated its responsibility to enforce Broker Dealer compliance with the +SA 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 obstructing an investigation, they are aiding and abetting the activity. These are not far flung +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?772? 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 +SEC +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 I contacted Kevin Goodman Dir OCIE for Broker Dealrsat 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 \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/2d192e06f75963e465bb35f767e034364e30fee6c8726e6cb4e6482ba45f4a03.receipt.json b/vision-fixhub/ds9-parsed-01/2d192e06f75963e465bb35f767e034364e30fee6c8726e6cb4e6482ba45f4a03.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..60c1e3811c3f5295bf59b39b1416201b74d09b21 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2d192e06f75963e465bb35f767e034364e30fee6c8726e6cb4e6482ba45f4a03.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -5322, + "dataset": "marble-joined", + "doc_id": "2d192e06f75963e465bb35f767e034364e30fee6c8726e6cb4e6482ba45f4a03", + "engine": "marble-apple-vision", + "event_count": 117, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "7327d63b7989c89c86d96e1f7ec4e798cc1ab104821341a29352348f88eef745", + "output_sha256": "d6221e4becf9379befccea268f50c7b69122be7b168ce35ee0a53f7c5368cee4", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2d20ca1c8de3a110c4e331889a8d15af589b10fc98841d946cd711d0d8d603b2.md b/vision-fixhub/ds9-parsed-01/2d20ca1c8de3a110c4e331889a8d15af589b10fc98841d946cd711d0d8d603b2.md new file mode 100644 index 0000000000000000000000000000000000000000..bda5432acc2c28c55e2792eb341af23533c500f3 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2d20ca1c8de3a110c4e331889a8d15af589b10fc98841d946cd711d0d8d603b2.md @@ -0,0 +1,15 @@ +From: " +To: " +Cc: +Subject: 302s, photos, & +Proffer notes +Date: Wed, 27 Nov 2019 16:45:44 +0000 +Attachments: Proffer of +Interview_231.pdf; +pdf; Photos provided by +Lpdf; | +-pdf +17.31.19.pdf; +Hi all, +See attached. +Thanks, diff --git a/vision-fixhub/ds9-parsed-01/2d20ca1c8de3a110c4e331889a8d15af589b10fc98841d946cd711d0d8d603b2.receipt.json b/vision-fixhub/ds9-parsed-01/2d20ca1c8de3a110c4e331889a8d15af589b10fc98841d946cd711d0d8d603b2.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..a585ce4478bd057ff6057f8a2e75b45d38997f5b --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2d20ca1c8de3a110c4e331889a8d15af589b10fc98841d946cd711d0d8d603b2.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "2d20ca1c8de3a110c4e331889a8d15af589b10fc98841d946cd711d0d8d603b2", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "76045e3c7be6e4bf68d603392a2d760ecf9235a027b84ad60f9d08e3f2983e34", + "output_sha256": "4d8e84e2a7be0a5ca887bd766b365a9b3487d1c518156e4edf4f5413945728ca", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2d37c323b89a142f7172965595cc0731729aea77693591b9fc9610ce4b8f7da3.md b/vision-fixhub/ds9-parsed-01/2d37c323b89a142f7172965595cc0731729aea77693591b9fc9610ce4b8f7da3.md new file mode 100644 index 0000000000000000000000000000000000000000..b4764fb5fde9efd7b8209febf5b46ffd94169f09 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2d37c323b89a142f7172965595cc0731729aea77693591b9fc9610ce4b8f7da3.md @@ -0,0 +1 @@ +No Images Produced diff --git a/vision-fixhub/ds9-parsed-01/2d37c323b89a142f7172965595cc0731729aea77693591b9fc9610ce4b8f7da3.receipt.json b/vision-fixhub/ds9-parsed-01/2d37c323b89a142f7172965595cc0731729aea77693591b9fc9610ce4b8f7da3.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..04c0cc603b97e375f31c39f5a68a97d792c04f26 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2d37c323b89a142f7172965595cc0731729aea77693591b9fc9610ce4b8f7da3.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "2d37c323b89a142f7172965595cc0731729aea77693591b9fc9610ce4b8f7da3", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "2f63098944e346cdbb6ee0bc929909a91cd1d35470f6d772f1c2b939632f1d71", + "output_sha256": "3874328764c818fba06683a6d5ddc2edc2d7850aaf4ba18646f81d3f8420a729", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2d69dc4f329d647a5f2732aafe5c9afe6957fee0c256816fed23c3c62ebb024c.md b/vision-fixhub/ds9-parsed-01/2d69dc4f329d647a5f2732aafe5c9afe6957fee0c256816fed23c3c62ebb024c.md new file mode 100644 index 0000000000000000000000000000000000000000..fae6b8326bc4a530c9abf8ab2f41d9984249b76b --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2d69dc4f329d647a5f2732aafe5c9afe6957fee0c256816fed23c3c62ebb024c.md @@ -0,0 +1,157 @@ +From: +Cc: "l +To: "Pileggi, Patricia Anne" ‹ +Subject: RE: +Date: Tue, 05 Oct 2021 14:12:15 +0000 +Attachments: 2021.10.05_Court_Subpoena_-_Mar_a_Lago.pdf +(USANYS)" +Hi Pat, +Thanks a lot. A trial subpoena is attached. +Thanks, +From: Pileggi, Patricia Anne ‹/ +Sent: Friday, October 1, 2021 9:39 PM +To: | +Cc: +(USANYS) < +Subject: [EXTERNAL] RE: +Hi +I have been authorized to accept a subpoena on behalf of the custodian of records for Mar a Lago. +Thanks - +Pat +From: +I mailto: +Sent: Thursday, September 30, 2021 4:53 PM +To: Pileggi, Patricia Anne ‹ +Cc:| +Subject: [EXT] RE: +PiL +| (USANYS) < +Hi Pat, +Thank a lot. We'd like to serve a subpoena to Mar a Lago for a records custodian and employment records. Please just let +us know if there's a contact we should send it to, or we should serve it on them directly. +Thanks, +From: Pileggi, Patricia Anne < +Sent: Thursday, September 30, 2021 1:56 PM +To: l +Cc:| +Subject: [EXTERNAL] RE: +Hi +(USANYS) < + + +I have been speaking with Compliance Counsel for the Trump Organization who informs me that Mar a Lago +Joes not have in house counsel. She has advised me that there are a number of different attorneys withir +the Trump Organization who are responsible for Mar a Lago. She asked that you let me know what +information you are looking for and she will either give me that information or make sure that it is +forwarded to the appropriate attorney. +Thanks - +Pat +From: +[mailto: +Sent: Thursday, September 30, 2021 1:21 PM +To: Pileggi, Patricia Anne < +Cc: +Subject: [EXT] RE: +Pil +I (USANYS) < +Hi Pat, +I'm just following up on my voicemail yesterday. Can you share with us the contact info for Mar a Lago's in-house +counsel? +Thanks, +From: Pileggi, Patricia Anne < +Sent: Friday, September 24, 2021 3:41 PM +To: 1 +Cc: +Subject: [EXTERNAL] RE: +(USANYS) < +I have been dealing with in house counsel on this, no other outside counsel. I can give you her name, but +let me give her a heads up first that you will be calling. +From: +) Imailto: +Sent: Friday, September 24, 2021 3:25 PM +To: Pileggi, Patricia Anne ‹ +Cc:| +Subject: [EXT] RE: +I (USANYS) < +Thanks for the update, Pat. On our call the other day, you mentioned that there's another lawyer representing Mar a Lago +for this matter. Would you mind sharing his/her contact information? It might help if we talked to them directly. +Thanks, +From: Pileggi, Patricia Anne ‹ +Sent: Friday, September 24, 2021 3:18 PM +To: l +Cc: +Subject: [EXTERNAL] RE: +Hi l +(USANYS) < +So far, no news. The document that +provided does not appear to be a business record - it was +not a record that was prepared on a regular basis and I +doesn't know who prepared it. + + +I have not been able to locate anyone who recalls +working at Mar a Lago in 2000. +Best, +Pat +From: I +1 [mailto: +Sent: Friday, September 24, 2021 2:42 PM +To: Pileggi, Patricia Anne ‹| +Cc: | +Subject: [EXT] RE:| +Hi Pat, +PiL +I (USANYS) < +I hope all's well. I'm checking in to see if you have any news about Mar a Lago. I'm happy to jump on a call if there's an +update. +Thanks, +From: Pileggi, Patricia Anne ‹ +Sent: Wednesday, September 8, 2021 9:48 PM +To: +Cc: +Subject: RE: +Perfect. I'll circulate a calendar invite. +From: [ +| [mailto: +Sent: Wednesday, September 8, 2021 9:38 PM +To: Pileggi, Patricia Anne < +Cc: +Subject: [EXT] RE: +Hi Pat, +No problem at all. How's 3:30 tomorrow? +Thanks, +(USANYS) < +(USANYS) ; Louise Scott < +>; +Subject: RE: Epstein investigation +Jill, +We wanted to quickly follow up since I think you and | last spoke a little over a week ago-understand if you are still +discussing with your client, just wanted to check in, and we're happy to provide any additional information that might be +useful, as always. +thank you, +From: Jill Greenfield <| +Sent: Saturday, February 22, 2020 17:09 +To: +Cc: Kyle Phillips < +Subject: Re: Epstein investigation +Thanks +Understood +I will call tomorrow +Regards +>; Louise Scott < +Jill Greenfield +Partner +D:! +M: +Personal Injury Team of the Year - Solicitors Journal Awards 2017 +Sent from my iPhone +On 22 Feb 2020, at 21:51, +> wrote: +Jill, +No problem at all, we understand this takes time, and we appreciate you getting back to us, and we're very grateful that +your client is open to speaking with us. +On your questions, we are certainly fine with the first two questions / requests - we're happy to meet with you and your +client in an initial conversation, during which we can do the kind of introductions and explanations we've done with you + + +(and that we do with all victim witnesses we meet), including answering any questions to the best of our ability, and +then to take a break and have a more substantive discussion later on. +Regarding the friend, does that individual also represent her as counsel? We aren't normally able to include individuals +in addition to the witness and counsel in an interview—what does sometimes work is for someone who is providing +support (a parent, friend, etc.) to be close by for any discussions, assistance, etc. anytime that a witness wants to speak +with that person, which would of course be totally fine in this instance. Or if he represents her in his capacity as an +attorney then he of course could be in the interview in that role (with the only caveat that we would just want to +confirm that he himself is not separately a witness of some sort in the case). We unfortunately are not able to pay for +third parties (including counsel) to travel in connection with witness interviews, though - if it's preferable, we certainly +could pay for your client's travel to the U.S. for the interview, including airfare and lodging, if that makes it easier for the +friend to be present? And we're happy to discuss any of this further by email or phone if that's useful - I'll be at my +desk for the next several hours and most of tomorrow, at +,, or we could also set a time to chat, whatever +would be helpful. +thank you, +From: Jill Greenfield < +Sent: Saturday, February 22, 2020 13:55 +To: +Cc: Kyle Phillips ‹ +Subject: RE: Epstein investigation +Hello +>; Louise Scott < +Apologies for the slight delay. My client is willing to help but asks the following: +That there be a morning meeting at which introductions with a discussion as to the investigation and my clients +involvement. I appreciate that you have explained this to me but I think further verbal clarification would assist. +• In the afternoon and after a break, my client would be willing to answer questions, in so far as she can. +• That a friend of hers be allowed to be present as well. However that friend is based in the US and would need to +be flown over to London. He is a US lawyer. +Perhaps you could let me know if this is possible? +Kind regards, +Jill +Jill Greenfield +Partner +D: +M: +Personal Injury Team of the Year - Solicitors Journal Awards 2017 +Simage00Ljpg≥ +Sent: Saturday, February 15, 2020 7:08 PM + + +To: Jill Greenfield 4 +Cc: Kyle Phillips < +Subject: RE: Epstein investigation +Understood - thanks very much. +P; Louise Scott < +From: Jill Greenfield ‹| +Sent: Saturday, February 15, 2020 07:22 +To: +Cc: Kyle Phillips < +P; Louise Scott < +Subject: Re: Epstein investigation +Thanks +This is helpful. I've gone back to my client with this. I will be back in touch shortly. +Regards +Jill +Jill Greenfield +Partner +D: +M: +Personal Injury Team of the Year - Solicitors Journal Awards 2017 +Kimage003.jpg≥ +Sent from my iPhone +On 14 Feb 2020, at 21:43, +> wrote: +Jill, +Following up on our phone call, thank you for talking with us again, and we wanted to get back to you regarding some +of the additional follow-up questions you asked, and to describe in more detail for your client how we would expect to +approach any discussion with your client if she were comfortable meeting with us. +The absolute most important thing is that any discussion would be entirely voluntary, and by that we mean the +decision to meet with us but also as to any topic or question —your client would be absolutely free to determine what +topics she felt comfortable discussing. There is absolutely no pressure on victim witnesses to address anything that +would make them uncomfortable at any time, and even if your client was willing to meet with us, we would tell her, as +we do for any witness, that if any topic comes up that she wants to skip, or discuss with you privately, that is no +problem at all. +In fact, if you and she would prefer, we would be happy to have a meeting where we simply introduced ourselves, +explained the status of our investigation, talked about how a discussion would proceed if your client ended up being +comfortable with that, and answered in person any questions she. We have done that previously, where we do the + + +talking rather than asking questions in an initial meeting, and that would of course be without any requirement for +anything additional if she preferred not to. As I mentioned on the phone, we have consistently found that we are able +to reassure individuals when we have the opportunity to meet in person so they can see directly our interest in +approaching these discussions with great sensitivity and care. As I also mentioned on the phone, even if your client +were willing to speak with us, there would be absolutely no need or requirement for her to talk about any assault or +victimization she experienced. We wrote in our first email that we would primarily be interested in talking about +topics such as the general scope of her employment, directions she received from Epstein or Maxwell, etc., and as +always we would be guided by her comfort level. +In terms of who would attend a meeting, we almost always work in pairs, so two prosecutors and two officers, and +that's not to have extra people, but rather because it helps us to be as efficient as we can, and so witnesses can meet +the people on the team. Our team is also majority female, and we always tell witnesses that if topics come up in a +discussion that they would prefer to speak about just with women, that's fine and we can be flexible in the moment +and are always guided by the comfort level of the victim. But I also want to stress that in terms of your client in +particular, we don't expect to initially address issues of a very personal or sexual nature, and we certainly would tell +you in advance if there came a time when we thought that might be important to address, and how we could facilitate +that. Who exactly from our team would be at any meeting would depend on schedules, but we can assure you that +every one of us has now spoken with dozens of victims in this case, and every one of us has extensive experience more +generally working with victims and working on cases involving sex offenses. We are proud of how we have been able +to work with victims in this case especially, given all of the circumstances, and we absolutely would take the same +sensitive approach with your client as we have with the many other victims in this case who have spoken with us. +Again, if it would be helpful even for us to just come to the U.K. and introduce ourselves and explain in person how our +process works, and answer any questions your client has in person, we would absolutely be happy to do that with no +obligation at all from her. We also could do that with the possibility that if she felt comfortable, we could just address +the general subject of her employment, for example. But no obligation and no pressure. We continue to appreciate +your and her willingness to even broach the possibility of a discussion, and we hope this is helpful. +thank you very much, +Assistant U.S. Attorney +Southern District of New York +Sent: Saturday, February 08, 2020 14:25 +To: Jill Greenfield < +Cc: Kyle Phillips < +>; Louise Scott < +Subject: RE: Epstein investigation +Jill, +Thanks for circling back, and we'll do our best to answer these questions. In terms of who would be in the room, the +most likely answer is that it would be two of the prosecutors and the two law enforcement officers on the case. The +only reason I saw "most likely" rather than having a definitive answer is that when we're interviewing in a foreign +country, it sometimes is the case the local law enforcement also insists on having representatives present. I don't +believe that's required in the U.K., but we can check on it and give you a definitive answer in the coming days if that's +useful. (Also, if she preferred to be interviewed in the U.S., we certainly could guarantee that the room would be just +the case team, and we could arrange for travel and lodging for her. Let us know if that's the case, but otherwise we're +of course happy to travel to her.) + + +Regarding access to notes, it would principally be the investigative team—so again, the prosecutors and the FBI team +working on the case. Our respective supervisors also theoretically have access to our files, but the reports are not +generally widely disseminated. The basic logistics are that an agent takes notes during an interview, and then types up +those notes into a formal report (called an FBI Form 302). We don't ordinarily share notes with other entities, but | +can also check on that to see if I can make a more specific representation with respect to your client. +With respect to anonymity, I confess that I'm not familiar with the distinction you're referring to. In terms of our +investigation, we don't publicly disclose the names of individuals we meet with, and we don't disclose to any other +witnesses, for example, the identities of victims or witnesses we are meeting with. (And our policies on that don't +change even for individuals who are in the position of your client, who have been widely publicly reported to have +been connected to Epstein and/or his employees or associates). But if that doesn't answer your question, we're of +course happy to discuss further. Let me know if it might be useful to have a call? Or if not, also happy to address any +follow-up via email. +thanks, +From: Jill Greenfield < +Sent: Saturday, February 08, 2020 13:17 +Cc: Kyle Phillips <| +P; Louise Scott < +P: +Subject: Re: Epstein investigation +Hil +Thanks for this. I've been asked who would be in the room and thereafter who would have access to any +notes made. Would her permission be sought before disclosing to any other parties or officials? +As you know there is a real difficulty in relation to her anonymity in the US versus the UK. Are you able to +provide any comfort on this? +Many thanks +Jill +Jill Greenfield +Partner +D: +M: +Personal Injury Team of the Year - Solicitors Journal Awards 2017 +Simage001 jpg≥ +Sent from my iPhone +On 6 Feb 2020, at 21:53, +Ms. Greenfield, +> wrote: + + +Thank you again for speaking with us earlier today regarding our interest in talking with your client in connection +with our investigation into the conduct of Jeffrey Epstein. +As requested, we wanted to briefly memorialize our current views and understandings of your client, and also to +reiterate our interest in approaching any discussion with great care and sensitivity, particularly to avoid adding to her +trauma or causing re-victimization. +As we mentioned on the phone, your client +As we discussed, our knowledge of your client specifically is somewhat limited, having never +spoken to her-and therefore knowing about her only through other witnesses and records—but it certainly has +been our experience that the overwhelming majority of young women and girls who were in the orbit of Jeffrey +Epstein during the relevant periods were subject to his abuse. It does not surprise us, nor do we have any trouble +believing, that your client was similarly a victim. I hope that is helpful in understanding the capacity in which we +hope to speak with her. +Separately, and as we also discussed, any discussion with our team would be entirely voluntary-and that extends +not just to whether she would be willing to meet with us at all, but also including her ability to decline to discuss +particular topics or even particular questions, and to talk with her counsel at any time, to take any breaks that would +be beneficial while we're meeting, etc. +In terms of topic areas, we would be hoping to learn about the general narrative of her interactions with Epstein and +his other associates and employees, including Ghislaine Maxwell, whom we understand she may have worked +directly for. That would broadly include how she came to be in contact with them, the nature and scope of her +employment, any instructions she was given relating to other women or girls, and just generally her experiences and +observations in interacting with them. We ordinarily would also be interested in understanding the general nature of +the abuse she was subjected to, but I want to emphasize that we would not need to discuss with her the specifics if +she weren't comfortable with that, and in particular we often don't even broach that subject in a first meeting. +Please let us know if you have any additional questions, and in particular whether any other information from us +would be useful, and we look forward to speaking with you again soon. +Regards, +Assistant U.S. Attorney +Southern District of New York +Fieldfisher, Riverbank House, 2 Swan Lane, London EC4R 3TT. +www.fieldfisher.com +We do not intend to change our bank details. If you receive any communication that any of our bank details have changed, telephone us and speak to your +contact at our office before transferring any funds. We do not accept responsibility for monies paid into a wrong bank account in any circumstances. +This email and any attachments are confidential and may also be privileged. If you receive this message in error, please contact the +sender immediately, destroy the email and any attachments and do not use, copy, store or disclose this email and any attachments +for any purpose. Fieldfisher does not accept service of documents by electronic means without express prior agreement. +For details about what personal information we collect and why, please see our Privacy Notice on our website at +www.fieldfisher.com. +eldfisher is the trading name of Fieldfisher LLP, a limited liability partnership registered in England and Wales (registered number OC318472) and is authorised and regulat +the Solicitors' Regulation Authority. A list of its members and their professional qualifications is available at its registered office, Riverbank House, 2 Swan Lane, Lond +EC4R 3TT. We use the term partner to refer to a member of Fieldfisher LLP or an employee or consultant with equivalent standing or qualifications. \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/2d6dd1a513a41cea154c18954ea0f0c5968942913715e6ef4c6e0ee6ef4e9140.receipt.json b/vision-fixhub/ds9-parsed-01/2d6dd1a513a41cea154c18954ea0f0c5968942913715e6ef4c6e0ee6ef4e9140.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..1b641e3b0a3cbfc173df1b94584435bc2ae3bc85 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2d6dd1a513a41cea154c18954ea0f0c5968942913715e6ef4c6e0ee6ef4e9140.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -109, + "dataset": "marble-joined", + "doc_id": "2d6dd1a513a41cea154c18954ea0f0c5968942913715e6ef4c6e0ee6ef4e9140", + "engine": "marble-apple-vision", + "event_count": 8, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "e4e16634737a71bc6ba9e7b4881b17149a44f19e05e1df21bae09d6037e1a74f", + "output_sha256": "bcb59524ad05d5e3ef8a7db1866c2c99e3e349b7a455c136f5be8dcc20c016fb", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2d7d535d82ef14d94fee46c913cb45dd470b7bf248919066255c542f4f951fab.md b/vision-fixhub/ds9-parsed-01/2d7d535d82ef14d94fee46c913cb45dd470b7bf248919066255c542f4f951fab.md new file mode 100644 index 0000000000000000000000000000000000000000..eb86713f8d00ffe1e1214cf453444db24d5701da --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2d7d535d82ef14d94fee46c913cb45dd470b7bf248919066255c542f4f951fab.md @@ -0,0 +1,15 @@ +AP SKULL +CR30 +Se: 21 +Im: 1 +3480x4248 +Sp: 0.100\0.100 +F +NYC OME +Bronx +Epstein Jeffery +M-19-019432 +- +Imgs: 1 +Zoom: 19% +W: 4096 L: 2048 diff --git a/vision-fixhub/ds9-parsed-01/2d7d535d82ef14d94fee46c913cb45dd470b7bf248919066255c542f4f951fab.receipt.json 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a/vision-fixhub/ds9-parsed-01/2d840184b081c549086d09196317f89fd9a19f9e4dcee4f42011adc5dad66ccc.md b/vision-fixhub/ds9-parsed-01/2d840184b081c549086d09196317f89fd9a19f9e4dcee4f42011adc5dad66ccc.md new file mode 100644 index 0000000000000000000000000000000000000000..2a2ac0cb1e642d84d7dbd789c929d7e1a3d6ffe4 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2d840184b081c549086d09196317f89fd9a19f9e4dcee4f42011adc5dad66ccc.md @@ -0,0 +1,29 @@ +29868000V||3 +(x0м0 0 Ź8$İ299[999[99 +(0(v99X +*XX*44Y +X*xxXXxxxxxxxxxxxxxxxxxx*****x****x**x****x********** +*Xxxxxx***************xx**x***xx*********X*********x*********************** +**x*xxxx******** +¢×××¢¢xx××¢***×************************** +apla /. +ki +0000÷ 992001 202007 +0000÷ Z11 +az uelo +00000= 000502 +00000= 000060 + +Dial by your location ++1 669 254 5252 US (San Jose) ++1 646 828 7666 US (New York) +Meeting ID: 160 146 2933 +Password: 182411 +Find your local number: https://nhd-uscourts.zoomgov.com/u/adw03gcw5b +Join by SIP +1601462933@sip.zoomgov.com +Join by H.323 +161.199.138.10 (US West) +161.199.136.10 (US East) +Meeting ID: 160 146 2933 +Password: 182411 diff --git a/vision-fixhub/ds9-parsed-01/2d840184b081c549086d09196317f89fd9a19f9e4dcee4f42011adc5dad66ccc.receipt.json b/vision-fixhub/ds9-parsed-01/2d840184b081c549086d09196317f89fd9a19f9e4dcee4f42011adc5dad66ccc.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..fc97d3c8fd270361ecce2c2ad56abfd48bcc0284 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2d840184b081c549086d09196317f89fd9a19f9e4dcee4f42011adc5dad66ccc.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "2d840184b081c549086d09196317f89fd9a19f9e4dcee4f42011adc5dad66ccc", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "18e6f7dcfc36f2e71f4dfd12677878b69c07762fc2f1c5d5cf168bd7e2b32f1c", + "output_sha256": "4457440d3708c8757729113bfcbc85280ec297c3a9e113d11c5f048f0636c431", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2d9f6a20ff25e3a996881b4c141d8bf8707f76c18bd33ac79a0e96bd7e14f20d.md b/vision-fixhub/ds9-parsed-01/2d9f6a20ff25e3a996881b4c141d8bf8707f76c18bd33ac79a0e96bd7e14f20d.md new file mode 100644 index 0000000000000000000000000000000000000000..e7050552105e015c3af125601c801f9e05edc9fd --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2d9f6a20ff25e3a996881b4c141d8bf8707f76c18bd33ac79a0e96bd7e14f20d.md @@ -0,0 +1,8 @@ +From: +To: +Cci +Subject: United States v. Epstein +Date: Fri, 30 Aug 2019 03:23:51 +0000 +Hi +Thanks! +Did y'all order a transcript of this week's hearing? If not, will you point us in the right direction to order one? diff --git a/vision-fixhub/ds9-parsed-01/2d9f6a20ff25e3a996881b4c141d8bf8707f76c18bd33ac79a0e96bd7e14f20d.receipt.json b/vision-fixhub/ds9-parsed-01/2d9f6a20ff25e3a996881b4c141d8bf8707f76c18bd33ac79a0e96bd7e14f20d.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..a776b63666e61b3bfd477002612fa43c16bc15a6 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2d9f6a20ff25e3a996881b4c141d8bf8707f76c18bd33ac79a0e96bd7e14f20d.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "2d9f6a20ff25e3a996881b4c141d8bf8707f76c18bd33ac79a0e96bd7e14f20d", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "7c1998ffecf11bc356581b48e9a6b8dfe7bdf5389216412ad381ab3dc1c3ec1f", + "output_sha256": "792260d09ee5eea8ef333f6d7211abcf039351822b76bc4ab7e2b7d4ed2698c9", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2dd0a094ce4d258fb7d4775120b44de1b061da640079327d9809e7e990711bcb.md b/vision-fixhub/ds9-parsed-01/2dd0a094ce4d258fb7d4775120b44de1b061da640079327d9809e7e990711bcb.md new file mode 100644 index 0000000000000000000000000000000000000000..35a42c7d953403535a4bf42a6f0120a5ee9475ab --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2dd0a094ce4d258fb7d4775120b44de1b061da640079327d9809e7e990711bcb.md @@ -0,0 +1,8 @@ +Suicide Watch +None +Psych Observation +2. Epstein #76318-054 +Thank you, +(Forensic) + +SDNY_00011722 \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/2dd0a094ce4d258fb7d4775120b44de1b061da640079327d9809e7e990711bcb.receipt.json b/vision-fixhub/ds9-parsed-01/2dd0a094ce4d258fb7d4775120b44de1b061da640079327d9809e7e990711bcb.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..94720f3182eea247d6cd2d6841b9438fd893d500 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2dd0a094ce4d258fb7d4775120b44de1b061da640079327d9809e7e990711bcb.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "2dd0a094ce4d258fb7d4775120b44de1b061da640079327d9809e7e990711bcb", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.stamp-stripping.confidential\"]", + "idempotent": true, + "input_sha256": "85d9e36655c71e945158706e99ff9308b0353dd067b87e47aacddca5cdf0695a", + "output_sha256": "d1931e1015ea17b1df0c275afdee76f26ce28ce283066982ae99f5a4fd998283", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2df50e3cbe07e9e804447dbcccd49bae34b8a68fc40936d16d364562b3041477.md b/vision-fixhub/ds9-parsed-01/2df50e3cbe07e9e804447dbcccd49bae34b8a68fc40936d16d364562b3041477.md new file mode 100644 index 0000000000000000000000000000000000000000..3d029312a008d7b08f2cbd3c59eedb6c02fb746d --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2df50e3cbe07e9e804447dbcccd49bae34b8a68fc40936d16d364562b3041477.md @@ -0,0 +1,74 @@ +--Start of Tableau TD2 Log entry- +<<< CAUTION: THE OPERATION RECORDED IN THIS LOG DID NOT COMPLETE NORMALLY >>> +Task: Disk to File +Status: Cancelled +Created: 2019-08-11 16:43 +Closed : 2019-08-11 18:14 +User: TD2 CRYSTAL CITY +2 +Case ID: +Epstein case # pending +Case Notes: +Seagate Z6E8M349 from 0214207268 +Duplicator serial num: 11d2003b +Duplicator firmware timestamp: May 02 2013 21:35:47 +Duplicator firmware revision: 4.01 +Duplicator 1og ID num: 107 +-Disk-to-File Results- +# of sectors: 976,773,168 +(500.1 GB) +File size in sectors: 4,194,304 (2.1 +GB) +Files expected: 233 +Files written: 87 +First filename of image: TD2_IMG/Property # 0214 207268 HDD/Z6E8M349.E01 +Errors recorded: 0 +SHA1: 465c7bf5f62aebb6c98ecfc60534110f56274c25 +MD5: 13e7ad6132719bae78d8493fb914cc2 +Verification hash: +SHAl: < +MD5 : < +-Source Disk +Model: ST500DM002-1BD142 +S/N: Z6E8M349 +Firmware Revision: HP74 +Capacity in sectors reported Pwr-ON: 976,773,168 (500.1 GB) +Capacity in sectors reported by HPA: +976,773,168 +(500.1 +GB) +Capacity in sectors reported by DCO: 976,773,168 (500.1 +GB) +HPA in use: No +DCO in use: No +ATA Security in use: No +Cable/Interface type: SATA +ATA PIO mode: PIO 4 +ATA DMA mode: UDMA 5 +-Destination Disks- +Destination disks used: 1 +Destination disks recorded: 1 +---Dest-1 Disk #1-. +Model: WDC WD20EURS-63S48Y0 +S/N: WD-WMAZA7125334 +Firmware Revision: 51.0AB51 +Capacity in sectors +reported Pwr-ON: +Capacity in sectors reported by HPA: +3,907,029,168 (2.0 TB) +3,907,029,168 +(2.0 TB) + + +Capacity in sectors reported by DCO: 3,907, 029,168 (2.0 TB) +HPA in use: No +DCO in use: No +ATA Security in use: No +Cable/Interface type: SATA +ATA PIO mode: PIO 4 +ATA DMA mode: UDMA 6 +Blank check status: Appears to be blank (quick check) +Format status: Disk formatted by duplicator +File system: exFAT +Format type: MBR +-End of Tableau TD2 Log entry-- diff --git a/vision-fixhub/ds9-parsed-01/2df50e3cbe07e9e804447dbcccd49bae34b8a68fc40936d16d364562b3041477.receipt.json b/vision-fixhub/ds9-parsed-01/2df50e3cbe07e9e804447dbcccd49bae34b8a68fc40936d16d364562b3041477.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..999c1a55ed3b7a46ae587b0b005f62a6329b329b --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2df50e3cbe07e9e804447dbcccd49bae34b8a68fc40936d16d364562b3041477.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "2df50e3cbe07e9e804447dbcccd49bae34b8a68fc40936d16d364562b3041477", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "b9e9a622f9e01094718fddec270eee87297230b06a664f670a9ed2e9e3ed8683", + "output_sha256": "41771dbbeda370ab7446b2b6e201451841914f77f8d8d211420c6dc81b23fbc6", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2df86ed89ea4fdf17222a2f7ac4217a1f5177054393de0b7bc498bd882a840f6.md b/vision-fixhub/ds9-parsed-01/2df86ed89ea4fdf17222a2f7ac4217a1f5177054393de0b7bc498bd882a840f6.md new file mode 100644 index 0000000000000000000000000000000000000000..350a40b4dd7434365ce7ea4ae9205dbbd379e83e --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2df86ed89ea4fdf17222a2f7ac4217a1f5177054393de0b7bc498bd882a840f6.md @@ -0,0 +1,17 @@ +From: " +To: " +Subject: bank records +Date: Mon, 01 Jun 2020 15:12:12 +0000 +Hi +For the Epstein case, are you able to assist with getting a copy of some recent bank subpoena returns to our case agent, +?? We were hoping to leave a copy for her downstairs at 1 Saint Andrews sometime this week. I'm not sure +who might be in the office to handle this, but if you could possibly coordinate that, it would be extremely helpful. +Thanks! +The returns are saved here: +//Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\# 2018 SDNY investigation\Subpoena +Returns\FirstBank Puerto Rico +Much appreciated- +Assistant United States Attorney +Southern District of New York +One Saint Andrew's Plaza +New York, NY 10007 diff --git a/vision-fixhub/ds9-parsed-01/2df86ed89ea4fdf17222a2f7ac4217a1f5177054393de0b7bc498bd882a840f6.receipt.json b/vision-fixhub/ds9-parsed-01/2df86ed89ea4fdf17222a2f7ac4217a1f5177054393de0b7bc498bd882a840f6.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..1efbefcc52e8bd98e0023f070e60cf6ef609dc35 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2df86ed89ea4fdf17222a2f7ac4217a1f5177054393de0b7bc498bd882a840f6.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "2df86ed89ea4fdf17222a2f7ac4217a1f5177054393de0b7bc498bd882a840f6", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "3f15065000e8ff95464ff61f8becec436a331aecc2da3c53a496bbf5125b6677", + "output_sha256": "7bca304e8335e32229246f7a57b5f1a4d268cfe037b8eec5508ff603c104125b", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2e0074f242e2dace2b342b04fe5b232573d5b284585d9b5aac03cc0bdfd6b146.md b/vision-fixhub/ds9-parsed-01/2e0074f242e2dace2b342b04fe5b232573d5b284585d9b5aac03cc0bdfd6b146.md new file mode 100644 index 0000000000000000000000000000000000000000..f506971ce7e23609634f185aa89ae3c551035474 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2e0074f242e2dace2b342b04fe5b232573d5b284585d9b5aac03cc0bdfd6b146.md @@ -0,0 +1,210 @@ +PuSkinner +Brad Edwards +Stan Pottinger +(nutes) +2/29/16 +BE- rep- +SP - rep. +Long histry, if litigation +E +Caro now lives in +other victims. Mother complined t, nose is. +PD turned case aver to FBI. + USAD. must of +Evad 5 penas Ep in lan canada, +Entered into a non pros ul quitty plea to stute ct. to +2001-2007 +- proceny merer +Jery Letcart, Jay Letkowitz, Ken Stam, Roy Black, Epstess +MaAn Weinber +• Cary seal never ten shored? +Alex Feasts US Aity. +- Limited to FL in puns. + + +Stil +represen +2 +pay eat to that pa 150. +At Least 12 +Nanned +- adult recaster +- recuted as minor, becane reente += neverter +Leslie Groff -asst. in at-recuters +Ghislaine maxwell - daughter of Robert Marwellhead reciter +Endence = 2000C +- her case chan +@times, +- NO END. +• Oreof Epstein's bfi, Jean Luc Banel, has helpol get +He is want. was seed he dep Jury. +han not to go to depostins. (te says auger parol +by Epstein duped him into milly dep. +Bunel hired Jue Titang in Miami he lawsuit. Titane +Contacted Bad Edwards + two of them mat. Band car, +Stan to Time, Titane says his client has photographe +entence. Deesnt know ages ot garls +and that Banel took +Barel wanks Epstein prosecited twand sn + + +- Bunel doesnt want to implicate himself. +- recently denied photos no Stan o Boin Schilar ottie-Epsteins were. +Band told friend Alas UNO that he has shotes - +made yes ago. +lives in Paires +Time said Bune has friend named Michele Kadorh +in MIami -friend t rabbi - said to Time Band tild +me he has photos. +- Kadesh spoke of alte in Pars fo Buned who adied him. +that it he has +phates he shald destroy them @ ace +-Band mt stan t Boiss togethe few days later t +offered to show compter. Then he cancelat +weat back to Paris + then to Asia an business +- teeto go to Paris + have compter conged lay pat +Brned is afraid of being prosecuted. +0- Vetmred summer ano crage la +1 - abut +to turn 17 +- taken to My fr trang by maxwell Epstein -how t +sence men +- in Cin Case, got recards com. her an hit plane +- She ques to povate island Little st. James - UsUI +- few niles off st. cm. +- 2000-2 aid that in ashlant are hope +othes. +- Prised edic. is marger. ther + + +- @18 told by Epsters too old +- Of 9 went to haula litt get were ++ Fled to Austalia +- filed cunt lusut in 2015-detamatn sut. +- against Maxwell +- She tent pa at deland in e +against USAD b/s they didnt intenica +maved to join those suits +- in 2011 a Bastish reputer Endher t interied her +abut Prince Andrew. Also said met Bill Chikn +- Said was Epstein ser slave +302. FBI Fl want to pursue inu. +Agents +- was lug. w parcub +dad warked & Maralag +dad draped her of o +Epstein's house +tandy; unot tell her to lave. +i 2000 Epstein was appr. 40s.-50s +Dad abrid ++ Unt her at to dads bfs. Two men +- may have sold her +swapped daughter @ +age 7. Ended after a +few yeas, +sent to tamily membo Cant in CA @13 +She ran away to SP +- lid al Parents tran away again: + + +- long series of event on street in mismo +- sugar daddy boyfriends as nun away +OW B+lle, piled ep in 1958 blon +Nice (ASt enteral home, +amasted her, he weat sit f +Outta +- Nithy since 2007 cher than FBI As. +- 2010 - civil depos. of Epsten Armen hatter +UP? +in recarded mts. 13t agent +- Notravez died i ail. +- Agent filed attadaut in abstucn care. +- Epstein's lawyers sacd his property +1997-2005 flight logs + manifess. +UP +- Have ban told Epster had phets in hase, in PBT MYs +USVI +- One photo is a phete of +W/antur gol-naked ++ in sexual pose - on has wall artistic - msible +genitals + + +USM +Photos of haked gals on morell's comp. +*SW executed un PB hase. Collage of phores inchided +wise gils nd. cliens. Epsten tipped off. All Compter +says cameras all over Me house. She believes +They were used tor exam or bin by Epstein. When lat +cut to other men had to repat back. +Videas recad +Maruell + Bunes +tok sexaly explicit phoen her +- Phets hig in are of the homes +Saved as campters. +investinatins +- Subp. issued tr. Compters +Registered as sex offende in PL +level 3 +Legend a Kal +by priate jet +Sax acts an planes = +Manhattan + + +Haghly. +saddle liters - Holly wad adress +- abisa 4y Epstem since +ages. In FL ta planes. +- anyonet - says she whets +to be not is public abat-part.. +wants prosecation. Now has Children tRels oblign to do +mm 2074/2015. +As it turns out, it was summe ot +shebelieved it was mme 1999. +She wants settlement Ng. into non, noft to helps girt +in same sitation +and awa +Did FBI search his planes? Did thy fred hidden +cameras? +Cancern actave pedoplile. +Rich to other prosectors? nu +bar deal? not naw +- 20/20 intenew last sprine > ABC killed it - lawyers pulled it +Bill Caton two women not under age Sh. +bat they still +Have pusins of diang + + +- Scotland tard investatas - all abat tance +ares smatm - vill sud me coutet int +ACTIVE Try audio-recarded intenter. +- They will send me citants - departin +- Mand part. sie r shape +same mo il une other uztim - lyr. dd-emads u/her +-As yong as 12 but yanger the biter. +emailed Epstein +Thaland on chars ++ handunten note w/ naneol +gale - unten by Mae well. + + +1°1 +Brad Edwards +Trial Attorney +Farmer, Jaffe, Weissing, +Edwards, Fistos & Lehrman, P.L. +425 N. Andrews Avenue, Suite 2 +Fort Lauderdale, FL 33301 +0: 9 +Mass Torts +Class Action +Personal Injury +Wrongful Death +Whistleblower Cases +WWW.PATHTOJUSTICE.COM +STAN POTTINGER +J. STANLEY POTTINGER PLLC +575 LEXINGTON AVENUE +SEVENTH FLOOR - BSF +NEW YORK, NY 10022 USA diff --git a/vision-fixhub/ds9-parsed-01/2e0074f242e2dace2b342b04fe5b232573d5b284585d9b5aac03cc0bdfd6b146.receipt.json b/vision-fixhub/ds9-parsed-01/2e0074f242e2dace2b342b04fe5b232573d5b284585d9b5aac03cc0bdfd6b146.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..540903b34cc432e71b42120b071bef056d43f8e1 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2e0074f242e2dace2b342b04fe5b232573d5b284585d9b5aac03cc0bdfd6b146.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -110, + "dataset": "marble-joined", + "doc_id": "2e0074f242e2dace2b342b04fe5b232573d5b284585d9b5aac03cc0bdfd6b146", + "engine": "marble-apple-vision", + "event_count": 10, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "c77fcc14602d63fa4471063bcd821eb8c55c438bf66578363fcd452faf8d8bf6", + "output_sha256": "ac3fa4593cff83962bad1b9c9c0fe5bfc5c122b8be1f245b10d78ed1a491eb13", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2e1fda5a7d0b176766057b420b6d657877d2d6567d40842eaca523ffb8a0b123.md b/vision-fixhub/ds9-parsed-01/2e1fda5a7d0b176766057b420b6d657877d2d6567d40842eaca523ffb8a0b123.md new file mode 100644 index 0000000000000000000000000000000000000000..da06b78e8ed6db9fb3e24d1b12114554a9d1cdf5 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2e1fda5a7d0b176766057b420b6d657877d2d6567d40842eaca523ffb8a0b123.md @@ -0,0 +1,276 @@ +From: White Collar Law360 +To: +Subject: Epstein Accuser Says Dershowitz Is Using Fees To Bully Her +Date: Wed, 31 Jul 2019 09:28:11 +0000 +Law360 White +Collar +WHITE COLLAR +Wednesday, July 31, 2019 +TOP NEWS +Epstein Accuser Says Dershowitz Is Using Fees To Bully Her +An alleged Jeffrey Epstein victim has said that right-wing personality Michael +Cerovich's request to compel her to pay costs in a Second Circuit appeal is +an attempt by Cernovich and Harvard Law School professor Alan Dershowitz +to intimidate her, prompting Cernovich to apologize and distance himself from +the professor. +Motion attached | Read full article » +Rakoff Gives 5 Months To Jeweler Tipped By Ex-S&P Analyst +A French jeweler who traded on an inside tip from former Standard & Poor's +analyst Sebastian Pinto-Thomaz was sentenced to five months in prison +Tuesday by Manhattan U.S. District Judge Jed S. Rakoff, who rejected his +bid for no prison in part because he later took a second tip. +Read full article » +Binary Options Boss Defends Lying To Clients In $145M Fraud +An Israeli binary options executive on trial for her alleged role in a $145 +million investment scam took the stand Tuesday to tell a Maryland federal +jury that she may have lied to clients about her name and her experience in +financial markets, but she never misled investors about the financial product. +Read full article » +5th Circ. Vacates 19½-Year Sentence Over 'Plain' Mistake +The Fifth Circuit vacated Monday the 19½-year sentence of a Mexican +businessman who participated in a $14 million Ponzi scheme, finding a lower +court's "plain" mistake raised his offense level by one point and skewed the +sentencing guidelines. +Opinion attached | Read full article » +British Art Broker Gets 4 To 12 Years In Prison For $10M Theft +A confessed high-dollar art swindler was sentenced in New York state court +on Tuesday to at least four years in state prison for stealing at least $10 +million from his clients in a scheme involving paintings by Pablo Picasso and +Marc Chagall. +SECURITIES +Dewey Impersonator Accused Of Hiding Cushy IT Job +•Follow Law360 +FLaw360 Pro Say Podcast +Listen to our new podcast here +LAW FIRMS +Arent Fox +Baker Botts +Baker Donelson +Baker McKenzie +Blackstone Chambers +Boies Schiller +Cotsirilos Tighe +Dechert +Dentons +Desai Law Firm PC +Dewey & LeBoeuf +Erskine Chambers +Fisher Phillips +Fountain Court Chambers +Greenberg Traurig +Hogan Lovells +Jones Day +Kaufman Dolowich +Latham & Watkins +Linklaters +Loeb & Loeb +Ogletree Deakins +Paul Hastings + + +A convicted New Jersey fraudster who served prison time for impersonating +representatives of the defunct Dewey & LeBoeuf LLP and a bank violated his +probation by concealing his high-paid executive job at a Massachusetts +information technology firm, according to a federal court filing Monday. +Petition attached | Read full article » +Engine Maker's Ex-CEO Pleads Not Guilty In $25M Fraud Case +The former CEO of an Illinois-based alternative-energy engine maker pled +not guilty Tuesday to charges that he and two other company executives +engaged in an accounting fraud scheme that inflated company revenues by +$25 million. +Read full article » +No New Trial For Convicted Life Time Fitness Trader +An Illinois federal judge on Tuesday rejected a California trader's bid for an +acquittal or a new trial after a jury had convicted him of participating in a +conspiracy to trade Life Time Fitness Inc. stock before the gym chain +announced an impending take-private acquisition, ruling that the government +had sufficiently proved the charge. +Order attached | Read full article » +Ex-IT Firm CEO To Pay $2.9M SEC Judgment In Fraud Case +The former CEO of bankrupt IT company Quadrant 4 System Corp. has +agreed to pay $2.9 million to resolve the U.S. Securities and Exchange +Commission's suit alleging he embezzled millions out of the company and +filed false financial statements to cover it up. +2 documents attached | Read full article » +Dubai Watchdog Fines Abraaj $315M For Deceiving Clients +The Dubai Financial Services Authority slapped a $315 million fine on two +Abraaj Group companies Tuesday — the largest penalty it's ever imposed — +saying the defunct private equity firm misused investors' money and then +tried to cover it up. +Read full article » +FCPA +Micronesian Transportation Official Gets 1½ Years For Bribery +A Micronesian government official was sentenced to a year and a half in +prison for his role in a bribery and money laundering scheme to secure +engineering project contracts for a U.S. firm with the Pacific island nation, the +U.S. Department of Justice announced Tuesday. +Read full article » +PUBLIC INTEGRITY +Chicago Area Ex-Teamsters Head Admits Extortion Scheme +A former Teamsters regional leader admitted Tuesday in Illinois federal court +that he extorted a business for at least $325,000 through threats of work +stoppages and filing false labor and tax documents. +1 document attached | Read full article » +CYBERSECURITY +Analysis +Hacker Arrest Provides Rare Insight Into Capital One Breach +Court filings accusing a Seattle software engineer of stealing the personal +data of 106 million Capital One consumers — one of the largest bank data +breaches ever — reveal a rare amount of detail about the historic hack into +the credit-card issuer's rented cloud computing server. +Post & Schell +Randazza Legal Group +Redgrave LLP +Robbins Russell +Sanford Heisler +Vogel Law Firm +White & Case +White and Williams +Zhong Lun Law Firm +COMPANIES +ABB Asea Brown Boveri Ltd. +Amazon.com Inc. +American Express Co. +Capital One Financial Corp. +Equifax Inc. +Ethics & Compliance Initiative +GitHub Inc. +Hitachi Ltd. +International Brotherhood of +Teamsters +KPMG International +LVMH Group +Life Time Fitness Inc. +London Stock Exchange Group +PLC +Power Solutions International Inc. +S&P Global Inc. +Shire PLC +Sotheby's +The Abraaj Group +The Valspar Corporation +Trelleborg AB +Trimble Inc. +Twitter Inc. +USG Corp. +GOVERNMENT AGENCIES +Arizona Supreme Court +Federal Bureau of Investigation +Federal Election Commission +New York Attorney General's Office +Securities and Exchange +Commission +Serious Fraud Office +Solicitors Regulation Authority +U.S. Attorney's Office +U.S. Court of Appeals for the Fifth +Circuit +U.S. Court of Appeals for the +Second Circuit +U.S. Department of Justice + + +Read full article » +LEGAL ETHICS +SFO Defends Talks With ENRC Lawyer In E70M Suit +A former lawyer for Eurasia Natural Resources Corp. had been given +permission to tell the Serious Fraud Office that senior managers had +allegedly paid bribes and were suspected of corruption, the agency said as it +hit back at the mining company's lawsuit challenging the investigation. +Read full article » +INTELLECTUAL PROPERTY +Texas Man Guilty Of Conspiracy In China Trade Secrets Case +A Houston man accused of helping a Chinese manufacturer steal trade +secrets from a U.S. drilling company was convicted Monday of one count of +conspiracy and acquitted of two other counts. +Read full article » +EXPERT ANALYSIS +Effective Compliance Programs Look Beyond DOJ Guidance +Emphasis on adherence to the recently issued U.S. Department of Justice +guidance on corporate ethics and compliance programs is well-intended but +might be diverting focus away from developing the programs and protocols +necessary to yield lasting change, says Patricia Harned of the Ethics & +Read full article » +LEGAL INDUSTRY +Global 20: Baker McKenzie +Baker McKenzie LLP has spent the past year helping clients navigate +multibillion-dollar transactions that span continents, including Japanese giant +Hitachi's $11 billion purchase of a Swiss power grid business, landing the firm +on Law360's Global 20 list for the ninth year in a row. +Read full article » +Senate OKs Greenberg Vet In Race To Confirm 19 Judges +The U.S. Senate confirmed three new judges — including a Greenberg +Traurig attorney — for Arizona, Texas and North Dakota district courts +Tuesday in the first round of a wave of President Donald Trump's judicial +picks Republicans want to clear before leaving for recess at week's end. +Read full article » +Ex-Trump Adviser Returns To Baker Donelson Via Alliance +A recently departed policy adviser to President Donald Trump has returned to +Baker Donelson, inking a strategic alliance to work for the law firm in +Washington, D.C., a Tuesday announcement said. +Read full article » +Ex-Ogletree Lawyers Abandon Push To Take Over Bias Suit +Two female attorneys who sought to take the helm of a suit accusing +employment law giant Ogletree Deakins Nash Smoak & Stewart PC of +systemic sex discrimination after the original plaintiff was forced into +arbitration have dropped their claims, according to a California federal court +filing. +Read full article » +Baker McKenzie Accused Of Mishandling Sex Assault Claim +U.S. District Court for the Central +District of California +U.S. District Court for the District of +Hawaii +U.S. District Court for the District of +Maryland +U.S. District Court for the District of +New Jersey +U.S. District Court for the Eastern +District of Pennsylvania +U.S. District Court for the Northern +District of Illinois +U.S. District Court for the Northern +District of Texas +U.S. District Court for the Southern +District of New York +U.S. District Court for the Western +District of Washington +U.S. Senate + + +Attorney regulatory authorities in the U.K. have referred Baker McKenzie LLP +to the country's disciplinary tribunal over allegations the firm allowed a thenpartner in London to sully a 2012 internal sexual assault investigation, +documents made public Tuesday show. +Read full article » +White & Williams Slams 'Small-Bore' Claims In Atty Bias Suit +White and Williams LLP fired back Tuesday against a May lawsuit from one +of its attorneys alleging a culture of rampant racial and gender bias in the +workplace, writing off the claims as a "catalogue of small-bore grievances" +that failed to show any actual discrimination. +Read full article » +Jones Day Pro Bono Work 'Was A Fiasco,' Ex-Clients Claim +Two Orange County mobile home owners say Jones Day provided pro bono +legal services that were "a fiasco" and ultimately left them homeless, +according to a suit filed in California state court. +Read full article » +Dentons To Combine With Heavyweight New Zealand Firm +Dentons and leading New Zealand law firm Kensington Swan intend to +combine, they said Tuesday, allowing both to expand their presence in the +Australasian region and connect clients to a greater range of legal experts. +Read full article » +JOBS +Search full listings or advertise your job opening +Mid-sized White Plains firm seeks +municipal government associate +KLR Davis +White Plains, New York +elite lit boutique // mid level assoc +Schoen Legal Search +New York, New York +Not sure if your firm subscribes? 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For customer support inquiries, please call +1-646-783-7100 or visit our Contact Us page. +Privacy Policy +Law360 | Portfolio Media, Inc, 111 West 19th Street, 5th Floor, New York, NY 10011 diff --git a/vision-fixhub/ds9-parsed-01/2e1fda5a7d0b176766057b420b6d657877d2d6567d40842eaca523ffb8a0b123.receipt.json b/vision-fixhub/ds9-parsed-01/2e1fda5a7d0b176766057b420b6d657877d2d6567d40842eaca523ffb8a0b123.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..8f4fcf70a92c46b89b4775eda0e926bba0b5b5c7 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2e1fda5a7d0b176766057b420b6d657877d2d6567d40842eaca523ffb8a0b123.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -50, + "dataset": "marble-joined", + "doc_id": "2e1fda5a7d0b176766057b420b6d657877d2d6567d40842eaca523ffb8a0b123", + "engine": "marble-apple-vision", + "event_count": 5, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "72914cb7f65300aac10dd5f29aab95a5817c55034f1b5eff2f99d83bc3b24de1", + "output_sha256": "5c018cf0d7c48e85474d7b79b03059402793c583d4b2fdad807c3a61e50aaa90", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2e23f3208bb126d520561226a2026b58c6c24b5931f9daec19a4a472884a7ba7.md b/vision-fixhub/ds9-parsed-01/2e23f3208bb126d520561226a2026b58c6c24b5931f9daec19a4a472884a7ba7.md new file mode 100644 index 0000000000000000000000000000000000000000..86a355f17a4352c163a9b876a9ba4a0c28f660fb --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2e23f3208bb126d520561226a2026b58c6c24b5931f9daec19a4a472884a7ba7.md @@ -0,0 +1,156 @@ +From: +To: " +(USANYS)" ‹ +Subject: RE: Question re Epstein Relativity +Date: Wed, 17 Mar 2021 13:39:46 +0000 +Inline-Images: image001.png; image002.png; image003.png +Hello, +The screenshots are referencing a different case but the process is the same. +Here are the steps to create your tags: +1. Open up any document +At the right of the screen click on edit +Under the field you want to add the tag (for this case all tags are under issue designation) find manage and click +Manage +on it. +4. The following window will appear: + + +DocumentIssue Designation +Save +Save and Close +Close +See All Choices +Manage Choices (26) 0 +Filter +Ê= | Add Choice +© Add Many Choices +Hot Document +• • +Click to add a choice +5. You can click on add choice to add a single choice (tag) or add many choice to add multiple choices (tags) at one +time. When you click on add many choices you will see the following: + + +Document:Issue Designation +Save Save and Close +Close +See All ( +Manage Choices (26) O +Filter ++ Add Choice +: * Add Many Choices +Complaints +Potential Leads +Civil Case +Copy and paste choices. Place each choice on a separate line. +Apply Cancel +Add all of your choices and then click apply. +6. Once you have added your choice or many choices click Save and Close and you will see your choice appear in the +field. +Please let me know if there are any questions. +Thank you. +From: | +| (USANYS) ‹ +Sent: Wednesday, March 17, 2021 9:34 AM +To: +Cc: +Subject: Re: Question re Epstein Relativity +Can you please send us instructions on how to add tags ourselves? + + +On Mar 17, 2021, at 9:32 AM, +(USANYS) [Contractor] < +• wrote: +The below tag has been added to the database. Please note that you do the ability to add your own tags to the +database so please feel free to do so if necessary. +Thank you. +From: +To: +| (USANYS) < +Sent: Tuesday, March 16, 2021 7:08 PM +P: +| (USANYS) [Contractor] +Subject: RE: Question re Epstein Relativity +Can you please create another issue designation tag - "CVRA Litigation"? +Thanks, +From: | +Sent: Monday, March 15, 2021 2:19 PM +To: +Ccil +I (USANYS) < +Subject: RE: Question re Epstein Relativity +Let's make this an Issue designation tag, please. That's where all of our other tags review tags are currently located. +Thanks, +From: +Sent: Monday, March 15, 2021 2:13 PM +To: +I (USANYS) < +Subject: RE: Question re Epstein Relativity +Do you want to create a new field that says "Not Epstein Related" or do you want to add this to an existing field (ex. +Issue designation). Please note that if you want to add this to an existing field that such as issue designation you should +see something that says manage and you can add this tag to that field as well. +Thank you. +From: +To: +Sent: Monday, March 15, 2021 2:08 PM +Cc: +(USANYS) < +Subject: RE: Question re Epstein Relativity + + +Hi +Thanks for your help with this review project. For this batch only, could you please add a tag that says "Not Epstein +Related"? Thanks. +From: | +Sent: Monday, March 15, 2021 10:14 AM +To: | +I (USANYS) C +Subject: RE: Question re Epstein Relativity +Great, thank you! That's the correct STR. +From: +Sent: Monday, March 15, 2021 10:13 AM +To: L +Cc: +I (USANYS) < +Subject: RE: Question re Epstein Relativity +Here is the STR. Please let me know if this is the STR you need. +Thank you. +From: | +Sent: Monday, March 15, 2021 10:09 AM +To: +Cc:| +| (USANYS) ‹ +Subject: RE: Question re Epstein Relativity +Thanks +I think you forgot to attach the STR hits. Mind resending that attachment, please? +From: +Sent: Monday, March 15, 2021 10:08 AM +To: l +Cc:| +(USANYS) < +Subject: RE: Question re Epstein Relativity +Hello +The following is regarding the batches: +BATCH003 - USAO-SDFL is all of the data from the following folder: + +BATCH004 - OPR Materials is from the following folder and attached STR Hits: + +Please let me know if the batches need to be adjusted. + + +Thank you. +From: +To: +Cc: | +Sent: Friday, March 12, 2021 5:56 PM +(USANYS) < +Subject: Question re Epstein Relativity +Hi +We're hoping you can clarify for us the contents of two separate batches on the USvEpstein Relativity database. Batch +003 - USAO-SDFL appears to reference the documents we've been talking with • +and +about. Batch 004- +OPR Materials appears to reference the D +Lemails that we received from OPR and that you ran the attached search +terms through. Is that correct? +Thanks very much, diff --git a/vision-fixhub/ds9-parsed-01/2e23f3208bb126d520561226a2026b58c6c24b5931f9daec19a4a472884a7ba7.receipt.json b/vision-fixhub/ds9-parsed-01/2e23f3208bb126d520561226a2026b58c6c24b5931f9daec19a4a472884a7ba7.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..85976f9e2954d2ff396e81f380e2848177050cbc --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2e23f3208bb126d520561226a2026b58c6c24b5931f9daec19a4a472884a7ba7.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -72, + "dataset": "marble-joined", + "doc_id": "2e23f3208bb126d520561226a2026b58c6c24b5931f9daec19a4a472884a7ba7", + "engine": "marble-apple-vision", + "event_count": 6, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "41bcf332854b5df09bb3be5fd69e344aa9f0b16fc8c6407bd0db3537e479c65c", + "output_sha256": "b0a15b2ca1775e6e7d0e3c9e58d81169407e9e7290a312747e7ff066008daf6d", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2e4d76b29d2e6f89401ff1627f6ee223548ffc17a696103bc7fb01cad6ebc4fb.md b/vision-fixhub/ds9-parsed-01/2e4d76b29d2e6f89401ff1627f6ee223548ffc17a696103bc7fb01cad6ebc4fb.md new file mode 100644 index 0000000000000000000000000000000000000000..29fb2e0611042a345e7a39beb5974053d190694f --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2e4d76b29d2e6f89401ff1627f6ee223548ffc17a696103bc7fb01cad6ebc4fb.md @@ -0,0 +1,1251 @@ +PAGE 001 +A +Y +* +BUREAU OF PRISONS COUNT SHEET +NEW YORK MCC +QRG EQ **** +OCTG EQ **** +OUTCOUNT +F +H +F +N +E +F +N +Y +S +M +S +SECTION +R +TR +N +D +P +НИНН +08-04-2019 +20:01:46 +UO +TU +N +T +COUNT +AREA +B-A +C-A +E-N +E-S +G-N +G-S +H-A +I-N +K-N +K-S +R-A +Z-A +Z-B +TOTAL +COUNT +VERIFY +CENSUS +26 +10 +87 +78 +78 +82 +1 +87 +89 +142 +77 +5 +762 +1 +VERIFY +COUNT +COUNT COUNT AREA +26 B-A +10 C-A +87 E-N +77 E-S +78 G-N +82 G-S +H-A +87 +I-N +89 +K-N +142 +K-S +R-A +77 +Z-A +5 +Z-B +761 +OFFICIAL PREPARING COUNT: +OFFICIAL TAKING COUNT: +COUNT CLEARED TIME: +10:37pM +Matuannlik +Metropolitan Correntinntinnal Contan +UnitGN +78 V +Metropolitan Correctional Center +Official Count Slip +Date +8. 4•19 +50 +Time: +10pm +Count: +Marrago +Print Name: +Signature: +Print Name: +Signature +10:33pm + + +Unit GN +Count: +78 +Metropolitan Correctional Center +Official Count Slip +Date. +8. 4.19 +00 +Time: +10pm +Print Name: +Signature: +Print Name: +Signature. +Unit: +Count: +Metropolitan Correctional Center +(Ste +Official Count Slip +CA +10 - +_Date +8/4/19 +Time: 1000Pm +Print Name: +Signature: +Print Name: +Signature +Unit: +Count: +Print Name: +Metropolitan Correctional Center +Official Count Slip +2BV +Date: +3/4/17, +• Time: +10рm +Signature: +Print Name: +Signature: +Unit: +Count: +Metropolitan Correctional Center +Official Count Slip +GS +82 +Date: +8, 4/2019 +Time: 10:00pm +Print Name: — +Signature: +Print Name: — +Signature: +Unit: +Count: +Print Name: +Metropolitan Correctional Center +Official Count Slip +BA +261 +Date: 8.4.19 +Time L p +Signature: +Print Name: +Signature: _ +Metropolitan Correctional Center +Official Count Slip +Unit: +Count: — +142 a Dato 08/04/2010 +_ Time: 10sm +Print Name: +Signature: +Print Name: +Signature- +Unit: +Count: +Metropolitan Correctional Center +Official Count Slip +Hosp +Date: 8.4-19 +- +time: 10çm +Print Name: +Signature: +Print Name: +Signature: +Unit: +Count: +Metropolitan Correctional Center +Official Count Slip +ES. +77 +Dуt. +08/04/2019° +Time: +10:00 PM +Print Name: +Signature: +Print Name: +Signature +Unit: +# +Count: +Print Name: +Signature: +Print Name: +Signature: +Metropolitan Correctional Center +Official Count Slip +Unit:_ +IN +87 +Date +8/4/19 +Count: +Time: 10 Р. н. +Print Name: +Signature: +es +Print Name: +Signature. +Metropolitan Correctional Center +Official Count Slip +Date: 8. 4•19 +/ +Time: L +K +RAMAROSOL +Unit: +EN +Count: +Metropolitan Correctional Center +Official Count Slip +Date +8/4/19. +87 1 +Time: +10: +Print Name: +Signature: +Print Name: +Signature +Unit: ZA +Count: - +Metropolitan Correctional Center +Official Count Slip +Date 8/4/19 +77 +Time. +10:00 +Print Name: +Signature: +Print Name: +Signature A +Unit: +Count: +KN +89 +Metropolitan Correctior +Official Count SI +_Date 08/2 +Time: +Print Name: +Signature: +Print Name: +Signature + + +PAGE 001 +H H +BUREAU OF PRISONS COUNT SHEET +NEW YORK MCC +QTRG +EQ **** +OCTG EQ **** +OUTCOUNT +F +F +H +M +S +SECTION +TR +N +S +8 A +S +< Z H +V +08-04-2019 +20:01:46 +V +UO +TU +N +T +COUNT +AREA +B-A +C-A +E-N +E-S +G-N +G-S +H-A +I-N +K-N +K-S +R-A +Z-A +Z-B +TOTAL +COUNT +VERIFY +CENSUS +26 +10 +87 +78 +78 +82 +1 +87 +89 +142 +0 +77 +5 +762 +1 +VERIFY +COUNT +COUNT COUNT AREA +XXXXXXXX +26 B-A +10 C-A +87 +E-N +77 E-S +78 G-N +1 +87 +I-N +89 +K-N +142 +K-S +R-A +77 +Z-A +5 +Z-B +761 +OFFICIAL PREPARING COUNT: +OFFICIAL TAKING COUNT: +COUNT CLEARED TIME: +10:37pm +G.V +10:33pn + + +08/04/2019 +COUNT TIME: +DATE: +FROM: +LOCATION: +10:00PM +HOSP +(Staff Member Preparing Out Count) +APPROVED: +(Operations Lieutenant) +REG # +NAME +UNIT +1. 89673-053 MERSEY ES +REG # +NAME +UNIT +2. +3. +4. +5. +6. +7. +8. +9. +10. +11. +12. +B-A +I-N +C-A +K-N +E-N +K-S +OUT-COUNT BY UNIT +E-S +1 G-N +R-A +Z-A +1 +G-S +Z-B +H-A +Total Out-Counted: +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected count. +Prepare this form in ink. Group the inmates according to their respective housing units. This form is to be used only as an +Out-Count. No other form will be accepted in lieu of the Out-Count Form. + + +NYMDL 530*05 * + +INMATE ROSTER +08-04-2019 +20:01:22 +OPER +CATEGORY: OCT +ASSIGNMENT: HOSP +CATG ASSIGNMENT +OPER +CATG ASSIGNMENT +GROUP CODE: +FACILITY: NYM +OPER CATG ASSIGNMENT +NUM ASSIGNMENT REG NO +NAME +0001 HOSP +89673-053 MERSEY +OCT DATE +QTR +08-04-2019 E12-592U +WRK +FS PM +SUICIDE OR +G0000 + + +NYMDL 530.03 +PAGE 0O1 +* +BUREAU OF +PRISONS COUNT SHEET +NEW YORK MCC +QTRG EQ **** +OCTG EQ **** +OUTCOUNT +F +F +H +S +SECT +I O N +M +S +J +S +E +OKZH +08-04-2019 +15:57:59 +OC +UO +TU +N +T +COUNT +AREA +B-A +C-A +E-N +E-S +G-N +G-S +H-A +I-N +K-N +K-S +R-A +Z-A +Z-B +TOTAL +COUNT +VERIFY +CENSUS +26 +10 +87 +78 +78 +82 +1 +87 +89 +142 +77 +5 +762 +1 +2 +11 +13 +1 +3 +17 +VERIFY +COUNT +COUNT COUNT AREA +26 B-A +10 C-A +87 E-N +78 E-S +78 G-N +82 +G-S +1 +H-A +84 +I-N +89 +K-N +129 +K-S +R-A +76 +Z-A +5 +Z-B +745 +OFFICIAL PREPARING COUNT: +OFFICIAL TAKING COUNT: +COUNT CLEARED TIME: +Metropolitan - +conal Center +Affinial Count Slip +Mot +Metropolitan Correctional Center +New York, New York +Official Count Slip +Unit: FIS +Date: 8/4/19 +Count: +1. Print Name: +Time: 4:00qm +1. Signature: +2. Print Name: +2. Signature: +457 pm +444pm + + +Metropolitan Correctional Center +New York, New York +Official Count Slip +Unit: +S +Date: 8|4/19 +Count: +3 +1. Print Name: +Time: 4:00kM +1. Signature: +2. Print Name: +2. Signature: +Unit: +Count: +ES +78 +Metropolitan Correctional Center +Official Count Slip +Date +08, +04/2019 +Time: +4:00Pm +Print Name: +Signature: +Print Name: +Signature +Unit: +ZA +Count: +Metropolitan Correctional Center +Official Count Slip +Date 8/4/19. +76 +Time: 4:00 +Print Name: +NoeL +Signature: +Print Name: +Signature +Unit: +Metropolitan Correctional Center +Official Count Slip +Date: 8-4-19 +5 +• Time: 400pm +Metropolitan Correctional Center +Official Count Slip +_ Date +8/4/19 +84 +Unit: +Count: +Print Name: +Signature: +Print Name: +Signature. +Metropolitan Correctional Center +Official Count Slip +G-N +78 +Date 8-4-2019. +- Time: 4:00PM +Count: +Print Name: +Signature: +Print Name: +Signature: +Unit: +GS +Count: +82 +Print Name: +Signature: +Metropolitan Correctional Center +Official Count Slip +Date: +3/ 4/2019 +Time: +1:00PM +Print Name: +Signature: +Unit: HA +Count: +Print Name: _ +Signature: +Print Name: +Metropolitan Correctional Center +Official Count Slip +_Date +08/04 +12019 +Time: +4:00pm +Signature +Unit: HOsP +Count: +Print Name: +Metropolitan Correctional Center +Official Count Slip +_ Date. +08/04/299 +Time: +4:00рm +Signature: +Print Name: +Signature, +Unit: I N +Count: +Print Name: +Signature: +Print Name: • +Signature_ +Metropolitan Correctional Center +Official Count Slip +Date: +Unit: +Count: +Print Name: +EN +87 +Time: +8/4/19 +40pм +Signature: +Print Name: +Signature: +Unit: +Count: +Print Name: +BA +26 +Metropolitan —tonal Center +Official Count Slip +Date +08/04/2019 +Time: +4:00pm +Signature: +Print Name: +Signature +Unit: _ +Count: +Print Name: +Metropolitan Correctional Center +Official Count Slip +_ Date +8-41-19 +10 +Tinie: +Signature: +Print Name: +nature +Unit: +Ks +Count: /129 +Print Name: - +Signature: +Metropolitan Correctional Center +Official Count Slip +_ Date. +5-4-19 +Time: +4: E +Print Name: +Signature +Unit: KN +Count: _ +Print Name: +Signature: +Print Name: +Signature +89 +Metropolitan Correctional Center +Offeial Count Slip +Date 08/04/2619 +4:00 + + +* +PAGE P01 +BUREAU OF PRISONS COUNT SHEET +NEW YORK MCC +QTRG EQ **** +OCTG EQ **** +Y +OUTCOUNT SEC +F +N +R +N +Y +S +P +T +I +O N +TR +I +08-04-2019 +15:57:59 +V +OC +UO +TU +T +COUNT +AREA CENSUS +B-A +C-A +E-N +E-S +G-N +G-S +H-A +I-N +K-N +K-S +R-A +Z-A +Z- B +26 +10 +87 +78 +78 +82 +87 +89 +142 +0 +77 +5 +TOTAL +762 +COUNT +VERIFY +2 +11 +13 +1 +13 +17 +VERIFY +COUNT +COUNT COUNT AREA +26 B-A +10 C-A +87 +E-N +78 +E-S +78 +G-N +82 G-S +H-A +84 +I-N +89 +K-N +129 +K-S +0 +R-A +76 +Z-A +Z-B +745 +OFFICIAL PREPARING COUNT +OFFICIAL TAKING COUNT: +COUNT CLEARED TIME: +457pm +GU 444pm + + +8-4-19 +COUNT TIME: +DATE: +FROM: +APPROVED: +LOCATION: +урн +Hosp +(Staff Member Preparing Out Count) +(Operations Lieutenant) +REG # +NAME +UNIT +1.85377-054 Webber KS +2. +3. +4. +5. +6. +7. +8. +9. +10. +11. +12. +REG # +NAME +UNIT +13. +14. +15. +16. +17. +18. +19. +20. +21. +22. +23. +24. +B-A +I-N +C-A +K-N +E-N +K-S +OUT-COUNT BY UNIT +E-S +R-A +G-N +Z-A +G-S +Z-B +H-A +Total Out-Counted: +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected count. +Prepare this form in ink. Group the inmates according to their respective housing units. This form is to be used only as an +Out-Count. No other form will be accepted in lieu of the Out-Count Form. + + + +INMATE ROSTER +08-04-2019 +15:34:49 +CATEGORY: OCT +ASSIGNMENT: HOSP +OPER CATG ASSIGNMENT +OPER CATG ASSIGNMENT +GROUP CODE: +FACILITY: NYM +OPER CATG ASSIGNMENT +NUM ASSIGNMENT REG NO +0001 HOSP +NAME +85377-054 WEBER +OCT DATE +QTR +08-04-2019 K12-078L +WRK +SUICIDE OR +UNASSG +G0000 + + +NEW YORK NY +DATE:_ +8/04/2019 +OFFICIAL OUT-COUNT FORM +TIME:_4:00PM +FROM: +Staff Supervising Out-Count +Number +Name +1 +79965-054 +THOMAS +2 +77863-112 +BANG +76161-054 +GRANADOS +4 +86764-054 +DUNCAN +51702-069 +ESTRADA +6 +86026-054 +MERCHANT +86022-054 +REINGOLD +85976-054 +MARTINEZ +9 +86535-054 +KAMARA +10 +85927-054 +ROMERO +11 +79652-054 +THOMAS +12 +79339-054 +MEDINA +13 +78841-054 +ROMERO +14 +15 +16 +17 +18 +19 +20 +LOCATION:_F/S +Unit +Name +KS +KS +KS +KS +KS +KS +KS +KS +KS +KS +KS +IN +IN +OUT-COUNTS +BY UNIT: +B-A +C-A +E-N +E-S +TOTAL ON OUT COUNT: +G-N +_13 +Number +21 +22 +23 +40 +K-N +Z-A +Z-B +R-A +H-A +Approving Operations Lieutenant +Out-counts will be submitted at a minimum of two (2) hours prior to the count. Out-counts WILL be submitted in ink, and legible. Out-counts +should list inmates alphabetically by unit with the inmate's name, register number, and quarters assignment. Please verify all information. +Unit + + +NYMBQ +NO PAGE 001 OF 001 +INMATE ROSTER +08-04-2019 +13:55:01 +OPER +CATEGORY: OCT +ASSIGNMENT: FS +CATG ASSIGNMENT +OPER CATG ASSIGNMENT +GROUP CODE: +FACILITY: NYM +OPER CATG ASSIGNMENT +NUM +0001 FS +0002 +0003 +0004 +0005 +0006 +0007 +0008 +0009 +0010 +0011 +0012 +0013 +ASSIGNMENT REG NO +NAME +77863-112 BANG +86764-054 DUNCAN +51702-069 ESTRADA-RODRIGUEZ +76161-054 GRANADOS-CORONA +86535-054 KAMARA +85976-054 MARTINEZ +79339-054 MEDINA +86026-054 MERCHANT +86022-054 REINGOUD +78841-054 ROMERO +85927-054 ROMERO-GRANADOS +79652-054 THOMAS +79965-054 THOMAS +OCT DATE +OTR +08-04-2019 K12-062U +08-04-2019 K12-065U +08-04-2019 K09-025U +08-04-2019 K07-007L +08-04-2019 K11-053U +08-04-2019 K09-027U +08-04-2019 I03-924L +08-04-2019 K12-061L +08-04-2019 K12-078U +08-04-2019 I03-923U +08-04-2019 K10-045U +08-04-2019 K08-074U +08-04-2019 K10-044L +WRK +FS PM +SUICIDE OR +FS PM +SUICIDE +OR +FS PM +FS +PM +FS +PM +FS +PM +UNIT 9NFS +FS PM +FS PM +UNIT 9NFS +FS PM +FS PM +FS PM +GO000 + + +DATE: +8/4/19 +COUNT TIME: +FROM: +APPROVED: +LOCATION: +(Staff Member Preparing Out Count) +4:00pm +Atty conf +REG # +NAME +UNIT ++ 76318-054 Epstein zA +2.76156os4 Diaz-MoRl kS +3. 91/26-053 ARANJO IN +4. +5. +6. +7. +8. +9. +10. +11. +12. +REG # +NAME +UNIT +13. +14. +15. +16. +17. +18. +19. +20. +21. +22. +23. +24. +B-A +I-N +- +C-A +K-N +E-N +K-S +Total Out-Counted: +- +OUT-COUNT BY UNIT +E-S +R-A +G-N +Z-A +G-S +Z-B +H-A +3 +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected count. +Prepare this form in ink. Group the inmates according to their respective housing units. This form is to be used only as an +Out-Count. No other form will be accepted in lieu of the Out-Count Form. + + +PAGE +,001 OF 001 +CATEGORY: OCT +ASSIGNMENT: ATTY +OPER CATG ASSIGNMENT +OPER +INMATE ROSTER +08-04-2019 +15:57:34 +CATG ASSIGNMENT +GROUP CODE: +FACILITY: NYM +OPER CATG ASSIGNMENT +NUM ASSIGNMENT +REG NO +NAME +0001 ATTY +91126-053 ARAUJO +0002 +76156-054 DIAZ-MORALEZ +0003 +76318-054 EPSTEIN +OCT DATE +QTR +WRK +08-04-2019 I04-930U +UNASSG +08-04-2019 K09-030U +UNASSG +08-04-2019 Z04-206LAD +UNASSG +GO000 + + +NUMBER +Pre +Check +DATE: SUNDAY, AUGUST 4, 2019. +METROPOLITAN CORRECTONAL CENTER +RUNNING BOARD +TIME: 6:00 AM D/W WATCH OPS. LT +/ ACT. +Page: 1 +STAMP: DJBE (LEFT HAND) +NYPD: #2275 +NAME +FROM +TO +TIME +BA +26 +CA +10 +EN +87 +ES +78 +GN +78 +GS +82 +HA +IN +87 +KN +89 +STARTING COUNT: 762 +KS +142 +RA +VISITING: N/A +ZA +77 +ZB +TOTAL +762 + +Pre Check +Post +Check +762 +MDC BROOKLYN: 718-840-4200 +2 3 5N 55 +7N +75 +HOSP +NATIONAL LOCATOR CENTER: 202-307-3126 +11N +115 +R&D +SHU +10S +TOMBS: 212-225-7311 \ No newline at end of file diff --git a/vision-fixhub/ds9-parsed-01/2e4d76b29d2e6f89401ff1627f6ee223548ffc17a696103bc7fb01cad6ebc4fb.receipt.json b/vision-fixhub/ds9-parsed-01/2e4d76b29d2e6f89401ff1627f6ee223548ffc17a696103bc7fb01cad6ebc4fb.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..1d52389a96cce6ced28948f44bcd4336ffb25859 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2e4d76b29d2e6f89401ff1627f6ee223548ffc17a696103bc7fb01cad6ebc4fb.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -655, + "dataset": "marble-joined", + "doc_id": "2e4d76b29d2e6f89401ff1627f6ee223548ffc17a696103bc7fb01cad6ebc4fb", + "engine": "marble-apple-vision", + "event_count": 19, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "9f2057ff4583699fd650e38bc1f63a9967fdc65b14089c2ed94a25d5dfb36389", + "output_sha256": "fcedcc3c13e67e80151950a19b09d0c23e04b660bb37e754b9c76821f37891aa", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2e6b5eabd7456427d75b7fd5f520b6eb38c8a8e4762f2b1e7b0e8021cc628529.md b/vision-fixhub/ds9-parsed-01/2e6b5eabd7456427d75b7fd5f520b6eb38c8a8e4762f2b1e7b0e8021cc628529.md new file mode 100644 index 0000000000000000000000000000000000000000..b4764fb5fde9efd7b8209febf5b46ffd94169f09 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2e6b5eabd7456427d75b7fd5f520b6eb38c8a8e4762f2b1e7b0e8021cc628529.md @@ -0,0 +1 @@ +No Images Produced diff --git a/vision-fixhub/ds9-parsed-01/2e6b5eabd7456427d75b7fd5f520b6eb38c8a8e4762f2b1e7b0e8021cc628529.receipt.json b/vision-fixhub/ds9-parsed-01/2e6b5eabd7456427d75b7fd5f520b6eb38c8a8e4762f2b1e7b0e8021cc628529.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..c4d5c0137a7616f594f15af3e608c3696bbdcd21 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2e6b5eabd7456427d75b7fd5f520b6eb38c8a8e4762f2b1e7b0e8021cc628529.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "2e6b5eabd7456427d75b7fd5f520b6eb38c8a8e4762f2b1e7b0e8021cc628529", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "ff8653104aad2570696c0d10c19ab33d8730d7d35f9ecafe3670f8803624cbdf", + "output_sha256": "3874328764c818fba06683a6d5ddc2edc2d7850aaf4ba18646f81d3f8420a729", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2e925f2f8c7ae71950d05bb633cf1094fbebb43dd5b9309995e3342200dca8b3.md b/vision-fixhub/ds9-parsed-01/2e925f2f8c7ae71950d05bb633cf1094fbebb43dd5b9309995e3342200dca8b3.md new file mode 100644 index 0000000000000000000000000000000000000000..3d556b735e63c3e63923696943cf6b1a7e484a1a --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2e925f2f8c7ae71950d05bb633cf1094fbebb43dd5b9309995e3342200dca8b3.md @@ -0,0 +1,37 @@ +From: " +To: " +(USANYS)" < +(USANYS)" - +Subject: RE:| +Date: Wed, 28 Aug 2019 22:09:22 +0000 +Call me when you can re: +From: +(USANYS) Y +Sent: Wednesday, August 28, 2019 6:08 PM +To: L +I (USANYS) < +Subject: FW: | +LOLZ +From: / +To: +Cc: +Subject: Re: +| (USANYS) < +Sent: Wednesday, August 28, 2019 6:07 PM +(USANYS) < +(USANYS) < +Yes, that would be +Stephen King book to give you the low down on +Best, +One for the ages. Are you around now? I can tear myself away from my +Sent from my iPhone +On Aug 28, 2019, at 6:04 PM, +Hi +(USANYS) < +> wrote: +said you had a cooperator who was the +give either of us a call when convenient, thanks! +with "urgent" information about Epstein. Feel free to +Assistant United States Attorney +Southern District of New York +Tel: diff --git a/vision-fixhub/ds9-parsed-01/2e925f2f8c7ae71950d05bb633cf1094fbebb43dd5b9309995e3342200dca8b3.receipt.json b/vision-fixhub/ds9-parsed-01/2e925f2f8c7ae71950d05bb633cf1094fbebb43dd5b9309995e3342200dca8b3.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..97b43dec63fa41b7e0f4f55682ce099e85b3f3fe --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2e925f2f8c7ae71950d05bb633cf1094fbebb43dd5b9309995e3342200dca8b3.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "2e925f2f8c7ae71950d05bb633cf1094fbebb43dd5b9309995e3342200dca8b3", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "b615d7e53b5ce234eb1bfbe9522b49b440f3f9d3e0f887f56793aa374fbdc2d5", + "output_sha256": "fab22d02ad6557beeb45615d52ca8c3e44cb54eba33c8e9f00df45df31435283", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2e9336d8e4127b10618845378e559d2554cc5895e017f3cdd38df866959dec59.md b/vision-fixhub/ds9-parsed-01/2e9336d8e4127b10618845378e559d2554cc5895e017f3cdd38df866959dec59.md new file mode 100644 index 0000000000000000000000000000000000000000..e385c52b37309ccc31913b3011cf02901865d11b --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2e9336d8e4127b10618845378e559d2554cc5895e017f3cdd38df866959dec59.md @@ -0,0 +1,108 @@ +From: +To: " +(USANYS)" < +(USANYS)" < +Ce:l +Subject: Law360 +(USANYS) [Contractor]" < +Date: Thu, 11 Feb 2021 12:27:36 +0000 +(USANYS)" +3 Names To Watch As Biden Mulls Next SDNY Top Prosecutor +By Pete Brush +Sent from my iPhone +Share us on: +Law360, New York (February 10, 2021, 5:41 +PM EST) -- President Joe Biden is ramping +up the process of choosing new top federal +prosecutors across the country, and while he +may not rush to replace Manhattan U.S. +Attorney Audrey Strauss, lawyers have their +eye on a handful of her potential successors. +The application process to helm the U.S. +Attorney's Office for the Southern District of +New York, a process that court-watchers say +is active and includes a large pool of +candidates, comes as the Biden +administration begins the work of replacing +U.S. attorneys appointed by former President +Donald Trump, who have all been asked to +step down. +But the president may not hurry to replace +Strauss, who in December was formally +appointed as U.S. attorney by federal judges +amid the chaos of the outgoing Trump +administration. +Strauss, who of late has brought high-profile +cases including sex-abuse charges against + + +Jeffrey Epstein associate Ghislaine +Maxwelland ex-fashion executive Peter +Nygard, is well-regarded, and her presence +leaves the White House the luxury of taking +its time on SDNY if it wishes to prioritize +dozens of other districts across the country. +"She has a stellar reputation inside and +outside the office," Pace Law School +professor Bennett L. Gershman said of +Strauss. +Nevertheless the application process is +underway in the Southern District, sources +said, with Senate Majority Leader Chuck +Schumer, D-N.Y., holding powerful sway over +the process. Asked to handicap top possible +successors, lawyers named three people: +Damian Williams +Damian Williams is a veteran SDNY +prosecutor who heads the district's Securities +and Commodities Fraud Task Force. He +prosecuted former politicians Sheldon Silver +and Chris Collins in recent years, and is +widely regarded as a steadying presence +inside the halls at 1 St. Andrew's Plaza. +Williams, who would be the first Black person +to head the office, is a former law clerk for +D.C. Circuit Judge Merrick B. Garland, +Biden's nominee for attorney general who is +slated for a Feb. 22 confirmation hearing in +the Senate. +The Garland clerk chain, dozens strong, +could be fertile ground for possible picks, + + +lawyers said, on the theory that a pre-existing +relationship with the man who likely will lead +Biden's Department of Justice could be +valuable. +Katherine Goldstein +A white collar partner at Akin Gump Strauss +Hauer & Feld LLP, Katherine Goldstein is a +former SDNY Securities and Commodities +Fraud Task Force chief with a sharp legal +mindwho has worked on modernizing and +improving insider trading enforcement. She +has handled a number of high-profile white +collar fraud cases. +After Strauss and Mary Jo White, who held +the post from 1993 until 2002, Goldstein +would be the third woman to take the job in its +more-than 200 year history, if confirmed. +Anjan Sahni +Like Williams and Goldstein, Anjan Sahni, a +WilmerHale white collar partner, is a former +SDNY Securities and Commodities Fraud +Task Force chief. +Sahni, who is of South Asian descent, also is +noted for his work on a defense team +that won acquittal for Citigroup trader Rohan +Ramchandani in a closely-watched forexrigging criminal trial. +Williams, Goldstein and Sahni are all said to +be friendly with, and have professional ties to, +former Manhattan U.S. Attorney Preet +Bharara, who was fired by the Trump + + +administration in 2017. Sources said Bharara +has a direct line to Schumer as the +application process unfolds. +-Editing by Jill Coffey. diff --git a/vision-fixhub/ds9-parsed-01/2e9336d8e4127b10618845378e559d2554cc5895e017f3cdd38df866959dec59.receipt.json b/vision-fixhub/ds9-parsed-01/2e9336d8e4127b10618845378e559d2554cc5895e017f3cdd38df866959dec59.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..0eb548edb85d34bebd3bd41daf951f1db105da59 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2e9336d8e4127b10618845378e559d2554cc5895e017f3cdd38df866959dec59.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -50, + "dataset": "marble-joined", + "doc_id": "2e9336d8e4127b10618845378e559d2554cc5895e017f3cdd38df866959dec59", + "engine": "marble-apple-vision", + "event_count": 5, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "345cf080f29360d300126e4fed29a10b609a3a67e94947124836798a31f70f02", + "output_sha256": "6c8f2d2da7f40bfd9b0eac8989139c63ff04d2faadd155af94a945dcdeeac15a", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2eafc0edf76b11772947370218c011d74df42f05618620b76ea7528bed465b07.md b/vision-fixhub/ds9-parsed-01/2eafc0edf76b11772947370218c011d74df42f05618620b76ea7528bed465b07.md new file mode 100644 index 0000000000000000000000000000000000000000..10906c95b2d8d9521be34455e62c607e6e6fa207 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2eafc0edf76b11772947370218c011d74df42f05618620b76ea7528bed465b07.md @@ -0,0 +1,3 @@ +8|04|2| +B. Board +160 SW 2,80- 08/10/2019 06:00:42 diff --git a/vision-fixhub/ds9-parsed-01/2eafc0edf76b11772947370218c011d74df42f05618620b76ea7528bed465b07.receipt.json b/vision-fixhub/ds9-parsed-01/2eafc0edf76b11772947370218c011d74df42f05618620b76ea7528bed465b07.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..4e8f7679813e02d5d492b282b33168ed8ab905fb --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2eafc0edf76b11772947370218c011d74df42f05618620b76ea7528bed465b07.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "2eafc0edf76b11772947370218c011d74df42f05618620b76ea7528bed465b07", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "d25872f39c2a6b9837faebe9eeb26ca34b0dba4f8bde6ebb71efcd1c84f49ff1", + "output_sha256": "6f8c438e86a5fcafb4f3121497824a4acc193369bcfe4ca63b112eeeb89ec6c1", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2eb9e24d367d6ad9b851e8053be22bcbd90a26be44262c920157f325f5d0c27f.md b/vision-fixhub/ds9-parsed-01/2eb9e24d367d6ad9b851e8053be22bcbd90a26be44262c920157f325f5d0c27f.md new file mode 100644 index 0000000000000000000000000000000000000000..0330833463f5ace6b09f5682fbf67d0b673606da --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2eb9e24d367d6ad9b851e8053be22bcbd90a26be44262c920157f325f5d0c27f.md @@ -0,0 +1,154 @@ +From: +To: " +Ce: " +(USANYS)" < +(ODAG)" < +(USANYS)" < +Subject: RE: Epstein/Maxwell +Date: Tue, 18 Aug 2020 16:25:42 +0000 +Great. Let's do 10. lIl circulate an invite with a dial in. Thanks! +From: +• (ODAG) < +Sent: Tuesday, August 18, 2020 12:25 PM +To: +(USANYS) < +Cc: +| (USANYS) < +Subject: RE: Epstein/Maxwell +Tomorrow at 10 or 11 is perfect. +From: +To: +Cc: +(USANYS) < +Sent: Tuesday, August 18, 2020 12:22 PM +• (ODAG) < +| (USANYS) < +Subject: RE: Epstein/Maxwell +Sure. Would tomorrow morning work for you? Perhaps around 10 or 11? Could do the same times Friday if that's better. +Thanks, +From: +To: +Cc: +- (ODAG) < +Sent: Tuesday, August 18, 2020 12:06 PM +(USANYS) < +(USANYS) < +Subject: RE: Epstein/Maxwell +Hi +I was typing you an email as your email came in. I will call down to the SDFL and find the best contact for +you. +Do you have time this week for a quick phone call re: the victims? Please let me know your availability. +Thanks, +From: +(USANYS) < +Sent: Tuesday, August 18, 2020 12:03 PM +To: +1. (ODAG) < +Cc: +(USANYS) < +Subject: RE: Epstein/Maxwell +- Thanks again for your help on this a few weeks ago. We've since had a number of productive conversations with +the folks at OPR you pointed us to, and we think it would be helpful to also make contact with someone at SDFL purely for + + +the purpose of ascertaining what hard-copy materials they still have related to the case down there and how we could +best arrange to obtain and review copies. We have had very limited contact with | +, an AUSA in the SDFL civil +division who we understand was the primary point of contact on issues related to the CVRA litigation. Do you know, does +he remain the best point of contact for the issues we hope to discuss, or is there someone else in that office we should +reach out to? +Thanks so much, +From: +- (ODAG) < +Sent: Wednesday, July 22, 2020 2:33 PM +To: +| (USANYS) < +(ODAG) +Cc: +(USANYS) < +Subject: RE: Epstein/Maxwell +Thursday at noon is perfect. Should I give you a call? +From: +To: +(USANYS) < +Sent: Wednesday, July 22, 2020 1:39 PM +• (ODAG) < +(ODAG) +Cc: +(USANYS) < +Subject: RE: Epstein/Maxwell +Thanks, +. Would 12pm tomorrow (Thursday) work for you? If not, we also have availability Friday morning, from +10-12:30 if anything in there works for you. Best, +From: +To: +(ODAG) < +Sent: Wednesday, July 22, 2020 1:03 PM +(ODAG) < +(USANYS) +Cc: +(USANYS) < +Subject: RE: Epstein/Maxwell +Hi +I'm happy to assist you. I'm available Thursday or Friday to discuss what documents you are trying to +locate. Please let me know if you have availability on either of those days. +Thanks, +From: +To: +Cc: +(ODAG) < +Sent: Wednesday, July 22, 2020 12:49 PM +(USANYS) < +| (USANYS) < +Subject: RE: Epstein/Maxwell +Thanks. OPR and +(ODAG) < +may have a better sense on document custodians than do l. + + +From: +To: +Cc: +(USANYS) < +Sent: Wednesday, July 22, 2020 12:41 PM +(ODAG) < +(USANYS) < +Subject: RE: Epstein/Maxwell +(ODAG) < +Thanks, Among our questions was who, whether at ODAG, SDFL, or NDGA we should be in touch with at this point +regarding documents. I also know OPR did a significant document collection last year. +We will reach back to OPR, but if there is a particular point of contact at SDFL or NDGA on issues related to document +collection, in particular, please let us know. And if a call on those issues would be helpful, happy to set one up. +Thanks very much, +From: +To: +Cc: +(ODAG) < +Sent: Wednesday, July 22, 2020 10:56 AM +(USANYS) < +(USANYS) < +Subject: RE: Epstein/Maxwell +- (ODAG) < +Happy to talk, but my only real role related to recusal issues and consequences. Now that the CVRA litigation is over, you +probably are best going directly to SDFL, as I don't have any of their documents. Thanks, +Office: +Cell: +From: +To: +Cc: +(USANYS) < +Sent: Tuesday, July 21, 2020 6:23 PM +(ODAG) < +(USANYS) < +Subject: Epstein/Maxwell +I - Hope all is well. We had spoken last summer, after the Epstein case was charged, about some potential +document/discovery requests related to the SDFL investigation and the NPA, in particular. Those conversations were +largely at mooted at the time by Epstein's death, but as I'm sure you know, we've recently charged Ghislaine Maxwell and, +anticipating potentially similar issues, we were hoping to revisit those conversations. Do you have time later this week +for a quick call? If so, please let us know what might work for you. +Thanks very much, +U.S. Attorney's Office for the +Southern District of New York +Tel. + + diff --git a/vision-fixhub/ds9-parsed-01/2eb9e24d367d6ad9b851e8053be22bcbd90a26be44262c920157f325f5d0c27f.receipt.json b/vision-fixhub/ds9-parsed-01/2eb9e24d367d6ad9b851e8053be22bcbd90a26be44262c920157f325f5d0c27f.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..16598189f42f85b194df1cafe27b4eeebfe0d811 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2eb9e24d367d6ad9b851e8053be22bcbd90a26be44262c920157f325f5d0c27f.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -48, + "dataset": "marble-joined", + "doc_id": "2eb9e24d367d6ad9b851e8053be22bcbd90a26be44262c920157f325f5d0c27f", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "e06d91a5fb149ecc4be09cd691178d1b219f529536371b09ef4439f5c357ba6c", + "output_sha256": "a48e2426a7a59073d6abf01cf917fb46ec1f43409946c5ae722979e955b5bd3f", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2ebff248b817acb25e5684f26975526f65133e4aac1b80a273e6ea1691f14199.md b/vision-fixhub/ds9-parsed-01/2ebff248b817acb25e5684f26975526f65133e4aac1b80a273e6ea1691f14199.md new file mode 100644 index 0000000000000000000000000000000000000000..2cb090429650a614696cdd981d4d5e303b635678 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2ebff248b817acb25e5684f26975526f65133e4aac1b80a273e6ea1691f14199.md @@ -0,0 +1,76 @@ +From: " +To: " +(USANYS)" < +(USANYS)" ≤ +P. +(USANYS) +(USANYS) +Subject: FW: Why the Feds Cannot Forfeit Jeffrey Epstein's Mansion +Date: Tue, 17 Sep 2019 18:18:24 +0000 +(USANYS)" +"," +FYI. +From: Fried Frank Publications +Sent: Tuesday, September 17, 2019 2:13 PM +(USANYS) < +Subject: Why the Feds Cannot Forfeit Jeffrey Epstein's Mansion +Fried Frank +White Collar Defense, Regulatory +Enforcement & Investigations +We are pleased to share recent developments from Fried Frank's White Collar +Defense, Regulatory Enforcement & Investigations Practice. For more +information, please visit friedfrank.com. +Why the Feds Cannot Forfeit Jeffrey Epstein's Mansion +September 9, 2019 +New York Law Journal published an article by litigation partner Evan T. Barr, +which discusses the Southern District of New York's potential filing of a civil +forfeiture action against Jeffrey Epstein's Manhattan townhouse to recover +assets for eventual distribution to his alleged victims. +The full article can be accessed here. +Contacts: +Steven M. Witzel +Head of White Collar Defense, +Regulatory Enforcement & +Investigations Practice +Recent Articles: +Handicapping the "Varsity Blues' +Sentencing +September 5, 2019 +Compelled Use of Biometric +Identifiers to Unlock Devices +June 25, 2019 +James E. Anklam +Partner +vcard +Lawrence Gerschwer +Partner +Evan T. Barr +Partner +vcard +Stephen M. Juris +Partner +Una A. Dean +Partner + + +vcard +Michael C. Keats +Partner +vcard +James Kitching +Partner +vcard +Joshua D. Roth +Partner +vcard +vcard +vcard +James D. Wareham +Partner +vcard +Follow us: +This email was sent by Fried, Frank, Harris, Shriver & Jacobson LLP on behalf of ourselves and our affiliates. Information regarding our LLP +and affiliates can be found at friedfrank.com +Privacy Disclaimer | Manage Subscriptions | Unsubscribe +Attorney Advertising. Prior results do not guarantee a similar outcome. +View as a web page. diff --git a/vision-fixhub/ds9-parsed-01/2ebff248b817acb25e5684f26975526f65133e4aac1b80a273e6ea1691f14199.receipt.json b/vision-fixhub/ds9-parsed-01/2ebff248b817acb25e5684f26975526f65133e4aac1b80a273e6ea1691f14199.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..61154795e0aa0aaf9c207cfb671376e0ba6cae77 --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2ebff248b817acb25e5684f26975526f65133e4aac1b80a273e6ea1691f14199.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "2ebff248b817acb25e5684f26975526f65133e4aac1b80a273e6ea1691f14199", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "5af8195f06c1a059c0b7fa0a4e56e648db4baa670f5632c155e4ce4c67ec5f55", + "output_sha256": "9c63666dc17e5885043f498e0c4b3ae82848e1b76fd76a10e2ae5d1c7f3821fb", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2ee589ba7459c22578001cefcf9874fc3490562d7b1222bb72aa6bf9848e5ac0.md b/vision-fixhub/ds9-parsed-01/2ee589ba7459c22578001cefcf9874fc3490562d7b1222bb72aa6bf9848e5ac0.md new file mode 100644 index 0000000000000000000000000000000000000000..742dd6e3abffe16538df222f98a0034b9dbcb9ff --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2ee589ba7459c22578001cefcf9874fc3490562d7b1222bb72aa6bf9848e5ac0.md @@ -0,0 +1,27 @@ +From: " +To: " +Subject: RE: Ghislaine Maxwell maximum sentence --a doubt +Date: Mon, 06 Jul 2020 15:36:45 +0000 +-----Original Message----. +From: +Sent: Monday, July 06, 2020 11:35 +To: +Subject: Re: Ghislaine Maxwell maximum sentence --a doubt +> On Jul 6, 2020, at 11:22 AM, +• wrote: +> +V +1... +> ----Original Message----- +> From: +> Sent: Monday, July 06, 2020 11:20 +> To: / +> Subject: Re: Ghislaine Maxwell maximum sentence --a doubt +> +> Sent from my iPhone +> +>> On Jul 6, 2020, at 11:02 AM, +> wrote: +>> +>> the maximum sentences for these offenses were different back in 1994-97, which is the time period of our +charges, and the maximum sentences were less at that time than they are now. diff --git a/vision-fixhub/ds9-parsed-01/2ee589ba7459c22578001cefcf9874fc3490562d7b1222bb72aa6bf9848e5ac0.receipt.json b/vision-fixhub/ds9-parsed-01/2ee589ba7459c22578001cefcf9874fc3490562d7b1222bb72aa6bf9848e5ac0.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..acd5425f2111018327a07f2af61da5f516fabf8b --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2ee589ba7459c22578001cefcf9874fc3490562d7b1222bb72aa6bf9848e5ac0.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "2ee589ba7459c22578001cefcf9874fc3490562d7b1222bb72aa6bf9848e5ac0", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "7c93e4d1979996f229b20ff751cc6ae394440919cf65cb22f42d3c75f62f4245", + "output_sha256": "74e7d09ac82442b1004f9948db404cba2a18be4e32e009a0bf03fab75edd2970", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/ds9-parsed-01/2ef28d344cbb71ffdf4ed9d4ff8d92ee99de1ce7e03458fb5ae6e70cabcb65ae.md b/vision-fixhub/ds9-parsed-01/2ef28d344cbb71ffdf4ed9d4ff8d92ee99de1ce7e03458fb5ae6e70cabcb65ae.md new file mode 100644 index 0000000000000000000000000000000000000000..9a6dd1a36dd56b24aa32a7de8cf54c1a56abb20d --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2ef28d344cbb71ffdf4ed9d4ff8d92ee99de1ce7e03458fb5ae6e70cabcb65ae.md @@ -0,0 +1,39 @@ +From: Elkan Abramowitz / Jonathan Sack { +To: +Subject: Limiting Victims' Rights: The Eleventh Circuit Reads the CVRA Narrowly +Date: Thu, 28 May 2020 17:32:52 +0000 + + +May 28, 2020 +New York Law Journal +by Elkan Abramowitz, Jonathan S. Sack +Limiting Victims' Rights: The Eleventh Circuit Reads the +CVRA Narrowly +Dear Friends and Colleagues, +The life, and death, of Jeffrey Epstein has captured the attention of +the legal community and broader public. The latest legal twist in the +story is a decision by the Eleventh Circuit in In re Wild, 955 F.3d +1196 (11th Cir. 2020), which held that federal prosecutors did not +have an obligation to inform, and consult with, Epstein's victims +regarding their decision not to prosecute Epstein for sex trafficking. +In our latest New York Law Journal article, "Limiting Victims' Rights: +The Eleventh Circuit Reads the CVRA Narrowly," we summarize the +federal Crime Victims' Rights Act and discuss the majority, +concurring and dissenting opinions of the divided Eleventh Circuit. +We hope you are all staying healthy and safe. +Best Regards, +Elkan Abramowitz and Jonathan Sack +A VIEW FULL ARTICLE +Elkan Abramowitz +Morvillo Abramowitz Grand Iason & Anello PC +565 Fifth Avenue +New York, New York 10017 +Jonathan S. Sack +Morvillo Abramowitz Grand Iason & Anello PC +565 Fifth Avenue +New York, New York 10017 +For more articles, please visit maglaw.com/publications +A CONTACT US +Copyright © 2020 All Rights Reserved. This communication may contain attorney +advertising. Prior results do not guarantee a similar outcome. +Privacy Policy | Unsubscribe diff --git a/vision-fixhub/ds9-parsed-01/2ef28d344cbb71ffdf4ed9d4ff8d92ee99de1ce7e03458fb5ae6e70cabcb65ae.receipt.json b/vision-fixhub/ds9-parsed-01/2ef28d344cbb71ffdf4ed9d4ff8d92ee99de1ce7e03458fb5ae6e70cabcb65ae.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..30e3b41578b291da70f63ab37c4dab3948c9a21a --- /dev/null +++ b/vision-fixhub/ds9-parsed-01/2ef28d344cbb71ffdf4ed9d4ff8d92ee99de1ce7e03458fb5ae6e70cabcb65ae.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "2ef28d344cbb71ffdf4ed9d4ff8d92ee99de1ce7e03458fb5ae6e70cabcb65ae", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "01ba1e48dec781a699bafd66aecf3e26b20cdffa332ed9faaa5f9ecf788cf38f", + "output_sha256": "6e24d92b8882bb8d937f78f60f4d91f99f659221427f5ae9aa936e64382a7247", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +}